CCPA/CPRA Privacy Notice

Notice of Collection for California Employees and Applicants

[Last Updated December 13, 2022]

This Notice provides information required under the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 (collectively, the “CCPA”). The Notice provides information about [Company’s] (“we,” “us,” “our”) practices regarding the collection, use, and disclosure of Personal Information.

A. Definitions

•Personal Information: As used in this Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household. Personal Information includes Sensitive Personal Information.
•Sensitive Personal Information: As used in this Policy, “Sensitive Personal Information” includes Personal Information that reveals, among other things, social security number, driver’s license number, state identification card number, passport number, racial or ethnic origin, union membership, or the contents of a Consumer’s mail, email, and text messages, unless Blur Studio is the intended recipient of the communication. Sensitive Personal Information also includes information concerning the Applicant or Employee’s health, sex life, or sexual orientation.
•“Service Providers” and “Third Party” have the meanings afforded to it in the CCPA.
•To the extent other terms used in this Notice are defined terms under the CCPA, they shall have the meanings afforded to them in those statutes, whether or not capitalized herein.

B. Collection & Processing of Personal Information

We [and our Third Parties/Service Providers] may have collected and processed the following categories of Personal Information about you in the preceding 12 months:

characteristics, trends, abilities, and aptitudes; and
•Sensitive Personal Information, including:
a. Personal Information that reveals:
i. Social security, driver’s license, state identification card, or passport number;
ii. Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials for allowing access to an account;
iii. Precise geolocation;
iv. Racial or ethnic origin, religious or philosophical beliefs, or union membership;
v. Contents of a Consumer’s email and text messages, unless the business is the intended recipient thereof; or
b. Personal Information Collected and analyzed concerning a Consumer’s health; and
c. Personal Information Collected and analyzed concerning a Consumer’s sex life or sexual orientation.

C. Categories of Personal Information We Disclose to Our Service Providers/Third Parties

We may disclose the following categories of Personal Information to our Service Providers/Third Parties:

•Identifiers, such as name, email address, accounts number, Social Security number (“SSN”), driver’s license number, passport number or similar identifier;
•Financial information, medical information, health insurance information;
•Characteristics of protected classifications under state or federal law, such as age, gender, race, physical or mental health conditions, and marital status;
•Commercial information, such as transaction information and purchase history;
•Internet or other electronic network activity information, such as browsing history and interactions with our websites;
•Geolocation data, such as device location;
•Audio, electronic, visual and similar information, such as call and video recordings;
•Professional or employment-related information, such as work history and prior employer;
•Education information, as defined in the federal Family Educational Rights and Privacy Act, such as student records and directory information;
•Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences, characteristics, trends, abilities, and aptitudes; and
•Sensitive Personal Information, including:
a. Personal Information that reveals:
i. Social security, driver’s license, state identification card, or passport number;
ii. Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials for allowing access to an account;
iii. Precise geolocation;
iv. Racial or ethnic origin, religious or philosophical beliefs, or union membership;
v. Contents of a Consumer’s email and text messages, unless the business is the intended recipient thereof; or
b. Personal Information Collected and analyzed concerning a Consumer’s health; and
c. Personal Information Collected and analyzed concerning a Consumer’s sex life or sexual orientation.

D. Sources From Which We Collect Applicant and Employee Personal Information

We collect Personal Information from:

•Applicants and Employees when they complete recruiting and employment forms;
•Service Providers and Third Parties that help us screen and onboard individuals for hiring purposes, and when they share the information with us; and
•Joint marketing partners, public databases, providers of demographic data, publications, professional organizations, educational institutions, social media platforms.

E. Purposes for Processing Personal Information

We [and our Service Providers and Third Parties] collect[s] Personal Information to use or disclose as appropriate to:

•Comply with all applicable laws and regulations.
•Recruit and evaluate job applicants and candidates for employment.
•Conduct background checks.
•Manage your employment relationship with us, including for:
o onboarding processes;
o timekeeping, payroll, and expense report administration;
o employee benefits administration;
o employee training and development requirements;
o the creation, maintenance, and security of your online employee accounts;
o reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill;
o workers' compensation claims management;
o employee job performance, including goals and performance reviews, promotions, discipline, and termination;
o other human resources purposes[./; and]
o [OTHER PURPOSE.]
•Manage and monitor employee access to company facilities, equipment, and systems.
•Conduct internal audits and workplace investigations.
•Investigate and enforce compliance with and potential breaches of Company policies and procedures.
•Engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers and acquisitions of the Company.
•Maintain commercial insurance policies and coverages, including for workers' compensation and other liability insurance.
•Perform workforce analytics, data analytics, and benchmarking.
•Administer and maintain the Company's operations, including for safety purposes.
•For client marketing purposes.
•Exercise or defend the legal rights of the Company and its employees[,/ and] [affiliates,] customers[, contractors, and agents].
•Operate, manage, and maintain our business.
•Perform accounting, audit, and other internal functions, such as internal investigations.
•Exercise and defend legal claims.
•Otherwise accomplish our business purposes and objectives.

In addition to the purposes identified above, Blur Studio may use and disclose any and all Employee Personal Information that we Collect as necessary or appropriate to:

•Comply with laws and regulations, including (without limitation) applicable tax, health and safety, anti-discrimination, immigration, labor and employment, and social welfare laws;
•Monitor, investigate, and enforce compliance with and potential breaches of Blur Studio policies and procedures and legal and regulatory requirements;
•Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons; and
•Exercise or defend the legal rights of Blur Studio and its employees, affiliates, customers, contractors, and agents.

Service Providers. We may disclose your Personal Information to our Service Providers for the purposes described in Section E of this Notice, to provide:

Applicant selection and related hiring services, benefits and wellness services, website services, as well as other products and services, such as web hosting, data analysis, customer service, infrastructure services, technology services, email delivery services, legal services, and other similar services.

We grant our Service Providers access to Personal Information only to the extent needed for them to perform their functions, and require them to protect the confidentiality and security of such information.

Third Parties. We may disclose your Personal Information to our Third Parties for the purposes described in Section E of this Notice:

•At Your Direction. We may disclose your Personal Information to any Third Party with your consent or at your direction.
•Business Purpose. We may disclose your Personal Information to a Third party for a business purpose.
•Legal and Regulatory. We may disclose your Personal Information to government authorities, including regulatory agencies and courts, as reasonably necessary for our business operational purposes, to assert and defend legal claims, and otherwise as permitted or required by law.

G. Your Rights as a California Resident Applicant or Employee

As an Applicant or Employee, you have the following rights regarding our Collection and use of your Personal Information, subject to certain exceptions:

•Right to Receive Information on Privacy Practices. We have provided such information in this Policy, and you may request further information about our privacy practices by contacting us as at the contact information provided below.
•Right to Deletion: You may request that we delete any Personal Information about you we that we collected from you.
•Right to Correction: You may request that we correct any inaccurate Personal Information we maintain about you.
•Right to Know: You may request that we provide you with the information about how we have handled your Personal Information in the 12 months preceding your request.
•Right to Receive Information About Onward Disclosures: You may request that we disclose to you the categories of Personal Information that we have Sold or Shared about you and the categories of Third Parties to whom the Personal Information was Sold or Shared.
•Right to Opt-Out of the Sale and Sharing of Your Personal Information and to Limit the Use of Your Sensitive Personal Information: You have the right to opt-out of the Sale and Sharing of your Personal Information. You also have the right to limit the use of your Sensitive Personal Information to the purposes authorized by the CCPA.
o We do not Sell or Share Personal Information. Further, we do not use Sensitive Personal Information for purposes beyond those authorized by the CCPA. Relatedly, we do not have actual knowledge that we Sell or Share Personal Information of California Consumers under 16 years of age. For purposes of the CCPA, a “Sale” is the disclosure of Personal Information to a Third Party for monetary or other valuable consideration, and a “Share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

•Right to Non-Discrimination: You have the right not to be discriminated against for exercising your data subject rights. We will not discriminate against you for exercising your data subject rights.

H. Other Disclosures

•Retention of Personal Information: We retain each of the above-listed categories of Personal Information for the duration of your Applicant and/or Employee relationship with us, as applicable, and longer as may be required by applicable laws or necessary for our legitimate business purposes.
•Changes to our Notice. We reserve the right to amend this Notice at our discretion and at any time. When we make material changes to this Notice, we will notify you by notice through ADP.
•Contacting Us. If you have any questions, comments, requests, or concerns related to this Notice, Blur Studio’s information practices, or how to access this policy in another format, please contact us at Blur Studio, 3960 Ince Blvd, Culver City, CA 90232 or at [info@blur.com] for assistance.