Effective Date: May 1, 2024
Last Reviewed on: May 1, 2024
1. Introduction
This Notice at Collection for California Personnel (the “California Personnel Notice at Collection”) describes Gravie. Inc.’s (“Gravie,” “we,” “our,” or “us”) collection and use of Personal Information. This California Personnel Notice at Collection applies solely to all job applicants to, and current or former employees of, owners of, directors of, officers of, and contractors of Gravie who reside in the State of California (“Personnel” or “you”). We adopt this notice to comply with the California Privacy Rights Act of 2020 (“CPRA”) and any terms defined in the CPRA have the same meaning when used in this notice.
2. Scope of this California Privacy Notice at Collection
This California Personnel Notice at Collection applies to information that we collect about Gravie Personnel that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your device (“Personal Information”). “Personal Information” includes all “Sensitive Personal Information” as defined below. However, publicly available information that we collect from government records and deidentified or aggregated information (when deidentified or aggregated as required under the CPRA) are not considered Personal Information and this California Privacy Addendum does not apply.
This California Personnel Notice at Collection does not apply to outside of the context of your relationship with Gravie as Gravie Personnel or to certain Personal Information that is excluded from the scope of the CPRA, like: (a) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA); and (b) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), or the California Financial Information Privacy Act (FIPA). Some of these exclusions may apply to Personal Information we collect about you as part of background checks and verification of employment. If you have any questions on whether one of these exceptions apply to your Personal Information, please contact your local Human Resources personnel.
3. Information We Collect About You
We collect the following categories of Personal Information from Gravie Personnel:
| Category | Applicable Pieces of Personal Information Collected |
| A. Identifiers | A real name; alias; postal address; unique personal identifier; online identifier; Internet Protocol address (when you access our network resources); email address; username; Social Security number; and other similar identifiers. If provided by you as proof of eligibility to work or as part of your business travel profile, driver’s license number and passport number. |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name; signature; Social Security number; physical characteristics or description; address; telephone number; insurance policy number; education; employment; employment history; bank account number; credit card number; and health insurance information. If provided by you as proof of eligibility to work or as part of your business travel profile, passport number, driver’s license or state identification card number. NOTE: Some Personal Information included in this category may overlap with other categories. |
| C. Protected classification characteristics under California or federal law. | Required: Age (40 years or older); national origin; or citizenship. Note: We require your age to verify your identity, run background checks, and to provide you with health and retirement benefits. We require your national origin and citizenship to verify your eligibility to work in the United States. You are not required to provide us with this information for any other uses. Optional: Race; color; ancestry; religion or creed; marital status; medical condition; physical or mental disability; sex (including gender; gender identity; gender expression; pregnancy or childbirth and related medical conditions); sexual orientation; and veteran or military status. NOTE: Providing this information is completely optional at your discretion, and we will collect this information only to the extent you choose to provide it in your resume, as part of the equal opportunity forms you fill out when you are hired, or as may be provided by a reference or other third party during reference and background checks. |
| D. Internet or other similar network activity. | Browsing history; search history; file access history; information on your interaction that occurs on our networks (including via VPN) with a website or application. |
| E. Sensory data. | Audio; electronic; visual; or similar information. |
| F. Professional or employment-related information. | Current or past job history or performance evaluations. |
| G. Inferences drawn from other Personal Information | Profile reflecting a person’s preferences; characteristics; psychological trends; predispositions; behavior; attitudes; intelligence; abilities; and aptitudes. |
| H. Sensitive Personal Information (“Sensitive Personal Information”) | • Government identifiers (social security; driver’s license; state identification card; or passport number). This may be provided by you as proof of eligibility to work or as part of your travel profile. • Complete account access credentials (user names; account numbers; or card numbers combined with required access/security code or password); • Racial or ethnic origin (see note below); • Religious or philosophical beliefs (see note below); • Mail, email; or text messages contents not directed to us; • Health; sex life; or sexual orientation information (see note below). Note: Providing information about your racial or ethnic origin, religious or philosophical beliefs, and health, sex life, or sexual orientation is completely optional at your discretion, and we will collect this information only to the extent you choose to provide it in your resume, as part of the equal opportunity forms you fill out when you are hired, or as may be provided by a reference or other third party during reference and background checks. |
4. Purposes for Collecting and Selling/Sharing Of Your Personal Information
Gravie is collecting your Personal Information for the following purposes:
- recruiting, including identifying and evaluating job applicants, including assessing skills, qualifications, and interests for the purposes of determining suitability for the position for which you have applied;
- if you are an employee of Gravie, delivering or administering your salary and benefits, including insurance benefits;
- if you are a contractor of Gravie, providing you with your agreed upon compensation;
- managing our workforce and, if you are an employee of Gravie, your career;
- delivering training programs, and measuring and recording the results of training;
- communicating with you and for you to communicate with other Gravie Personnel and other third parties;
- collecting and maintaining information about your work history and work performance;
- investigating accidents and claims of wrongdoing, including to collect evidence for possible grievance or disciplinary actions or legal disputes;
- to run and manage business operations, including to schedule work, manage the business organization, business assets, travel and expense reimbursement, managing corporate credit cards and card payment history, maintaining corporate contact directories and organizational charts, managing and storing records;
- processing IT infrastructure, including email, internet, social media systems, and file shares;
- maintaining the security and safety of our facilities, personnel, and other assets, including to authenticate personnel to access Gravie’s IT resources and facilities, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- to conduct screening and background and compliance checks before and during the time you are considered Gravie Personnel and maintaining records on such screening and checks;
- if you are an employee, providing employee programs such as on-site health services, stock options, and other similar benefits;
- to comply with legal requirements, including to withhold taxes, and to report accidents, salary, and tax information to regulatory authorities;
- to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Gravie’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Gravie about Gravie Personnel is among the assets transferred;
- in order to publish your name, picture, and contact information in our internal employee directory and, for leadership positions, to publish your online biography and for similar marketing efforts in accordance with Gravie’s policies; and
- as described to you when collecting your Personal Information or as otherwise set forth in applicable law.
We do not “sell” any categories of Personal Information for monetary or other valuable consideration and we do not “share” any categories of Personal Information for cross-context behavioral advertising.
5. Personal Information Retention Periods
For all categories of Personal Information described above, we will retain your Personal Information for any time required by applicable law for the type of document that contains your Personal Information and in accordance with Gravie’s Record Retention Policy. However, we may also retain any or all categories of Personal Information when your information is subject to one of the following exceptions:
- When stored in our backup and disaster recovery systems. Your Personal Information will be deleted when the backup media your Personal Information is stored on expires or when our disaster recovery systems are updated.
- When necessary for us to exercise or defend legal claims.
- When necessary to comply with a legal obligation.
- When necessary to help ensure the security and integrity of our Website and IT systems.
6. Changes to This California Personnel Notice at Collection
Gravie reserves the right to amend this California Personnel Notice at Collection at our discretion and at any time. When we make changes to this California Personnel Notice at Collection, we will provide you an updated notice before collecting any additional personal information and update the addendum’s effective date. Your continued provision of personal information following the posting of changes constitutes your acceptance of such changes.
7. Full California Privacy Addendum & Contact Information
Click here to view our full California Personnel Privacy Addendum.
If you have any questions about this California Personnel Notice at Collection or need to access it in an alternative format due to having a disability, please contact the Human Resources Department.