Veros Real Estate Solutions
California Employee Privacy Policy
Effective Date August 20, 2024
We provide these disclosures and privacy policy for individuals that reside in California (“California Employee Privacy Policy”). If you are not a resident of California, you can disregard this document.
Here is a summary of what you will learn from these disclosures and privacy policy:
- Personal Information We Collect
- How We Obtain Your Personal Information
- How Long We Keep Your Personal Information
- How We Use Your Personal Information
- How We Disclose Your Personal Information
- Your Rights Under the CCPA
- Right to Know
- Right to Delete
- Right to Correct
- Right to Limit Use of Sensitive Personal Information
- Right to Opt-Out
- Right to Non-Discrimination
- Submitting a Request
- How to Submit a Request Yourself
- Authorized Agents
- Response Timing and Delivery Methods
- Changes to this California Employee Privacy Policy
- How to Contact Us
Below is the legal information we are required to share:
This California Employee Privacy Policy supplements the Employee Handbook and governs the personal information collected, used and shared by Veros Real Estate Solutions, LLC (“VRES,” “we,” “us,” or “our”) and applies to job applicants, employees, owners, directors, officers, and contractors of VRES who are acting in such a capacity (“employment position”) and who reside in the State of California (“consumers” or “you”). This policy also applies to your emergency contacts and beneficiaries. We provide these disclosures and privacy policy to comply with the California Consumer Privacy Act (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this policy.
- PERSONAL INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular consumer (“personal information”). Amongst other things, Personal Information does not include publicly available, de-identified, and aggregated information. Information regulated by the Fair Credit Reporting Act is also excluded.
We collected the following categories of personal information:
- “Sensitive Personal Information” such as Social Security Numbers, Driver’s license, financial account or card numbers, precise geolocation, racial and ethnic characteristics, religious and philosophical beliefs, union membership, contents of mail, email and text messages, genetic and biometric data;
- “Identifiers” such as name, alias, address, unique identifier, internet protocol address, email address, account number, Social Security Number, or government identification number;
- “Other Personal Information” such as name, signature, Social Security Number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, salary information, or any other financial information, or medical information. Some personal information included in this category may overlap with other categories;
- “Protected Characteristics” under California or federal law for classifications such as age (40 years or older), race, color, ancestry, national origin, citizenship, 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, or veteran or military status;
- “Commercial Information” such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
- “Internet or Network Activity” such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement;
- “Geolocation Data” such as physical location or movements;
- “Sensory Data” such as audio, electronic, or visual information;
- “Professional or Employment Related Information” such as current or past job history or performance evaluations;
- “Biometric Information” such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, or gait; and
- “Inferences” drawn from other personal information such as profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- HOW WE OBTAIN YOUR PERSONAL INFORMATION
| Directly from you |
You enter or provide us with information in person, online, by email, by phone, or by document upload For example, when you apply for a job or update your information on file |
| Directly and indirectly from you based on activity on our website or network | For example, from internet browsing or network usage details collected automatically |
| From vendors that interact with us in connection with your employment position | For example, credit reporting agencies from which we check your credit in connection with a submitted employment application, vendors that provide background search results, or vendors that assist in protecting you and us from fraud and identity theft |
- HOW LONG WE KEEP YOUR PERSONAL INFORMATION
- HOW WE USE YOUR PERSONAL INFORMATION
- Performing services on our behalf, including but not limited to:
- To fulfill or meet the reason for which the information is provided.
- To provide you with a decision on an employment application.
- To provide you with employment benefits and process payroll.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- To maintain insurance policies and coverages, including for workers’ compensation and other liability insurance.
- To manage workers’ compensation claims.
- To manage performance of job duties of employees, including compliance with Veros policies and procedures.
- To communicate with personnel regarding employment-related matters such as upcoming benefits enrollment deadlines, action items, availability of W-2 forms, and other alerts and notifications.
- To assist personnel with the coordination of travel
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- To implement, monitor, and manage electronic security measures on devices of Veros personnel that are used to access Veros networks and systems.
- Auditing related to a current interaction with you.
- Undertaking activities to verify or maintain the quality of a service or device controlled by us, and to improve, upgrade, or enhance our services.
- For short-term, transient uses.
- To reduce the risk of spreading COVID-19 or other diseases in the workplace, including contract tracing as needed or required by law.
- To comply with state and federal laws and regulations requiring employers to maintain certain records (such as immigration compliance records, personnel files, wage and hour records, payroll records, accident or safety records, and tax records).
- To conduct workplace investigations (such as investigations of workplace accidents or injuries, harassment claims, or other alleged misconduct).
- To provide benefits, services and perquisites to you.
- HOW WE DISCLOSE YOUR PERSONAL INFORMATION
- With background search and employment eligibility companies we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Professional and Employment Information, Inferences;
- With word processing applications, signing vendors, and communication platforms we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Professional and Employment Information;
- With advisors such as attorneys, banks, credit card companies, accountants, financial advisors, consultants, and insurance providers, we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Geolocation Data, Sensory Data, Professional or Employment Related Information, Biometric Information, and Inferences;
- With insurance and benefits providers we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics;
- With lifestyle benefit providers we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Biometric Data;
- With network monitoring, analytics, and incident response vendors we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Geolocation Data, Sensory Data, Professional or Employment Related Information, Biometric Information, and Inferences; and
- With regulatory and governmental agencies and government sponsored entities we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Geolocation Data, Sensory Data, Professional or Employment Related Information, Biometric Information, and Inferences, and when such sharing involves health information, we maintain an employee’s anonymity whenever possible.
- YOUR RIGHTS UNDER THE CCPA
6.1. Right to Know
You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your personal information (“Right to Know”). Once we receive and verify your request, unless an exemption applies, we will disclose to you:
- Categories of Personal Information
- The categories of personal information we collected about you
- The sources for the personal information we collected about you
- Our business or commercial purpose for collecting that personal information
- The categories of third parties to whom we disclose that personal information
- If we disclosed your personal information, the categories of personal information disclosed with each category of third-party recipients; or
- Specific Information
- The specific pieces of personal information we collected about you.
6.2. Right to Delete
You have the right to request that we delete any of your personal information that we collected and retained (“Right to Delete”). Once we receive and verify your request, we will delete, de-identify, or aggregate your personal information, unless an exemption or exception applies.
We may deny your Request to Delete if retaining the personal information is necessary for us to:
- Complete the transaction for which the personal information was collected, as reasonably anticipated within the context of our ongoing relationship, or otherwise perform a contract between the us and the consumer.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
- To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
- Comply with a legal obligation.
6.3. Right to Correct
You have the right to request that we correct your personal information if it is inaccurate (“Right to Correct”). Once we verify your identity and confirm that your personal information is inaccurate, we will correct your personal information.
6.4. Right to Limit the Use of Sensitive Personal Information
You have the right to direct us to limit the use of your sensitive personal information to uses which are necessary to perform the services or provide the goods reasonably expected. However, we only use Sensitive Personal Information in an employment context and as reasonably expected by a consumer.
6.5. Right to Opt-Out
Consumers have the right to opt-out of 1) the sale of their personal information, 2) the “sharing” of their personal information for cross-context behavior advertising, and 2) for use in automated decision making.
- We do not sell your personal information. Further, we do not sell the personal information of minors under 16 years of age.
- We do not share your personal information. Further, we do not share the personal information of minors under 16 years of age. (“Sharing” means the disclosure of personal information for cross-contextual behavioral advertising.)
- We do not process your personal information with automated decision-making.
6.6. Right to Non-Discrimination
You have the right to not be discriminated against for exercising your rights under the CCPA. Unless permitted by the CCPA, we will not:
- deny you goods or services (including employment opportunities);
- charge you higher prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- provide you a lower level or quality of goods or services (including employment compensation); or
- suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- SUBMITTING A REQUEST TO KNOW OR REQUEST TO DELETE
7.1. How to Submit a Request Yourself
To make a Request to Know, Request to Delete, or Request to Correct, please contact us by either:
- Calling us at 866.458.3767, select option 6
- Contact us at Veros Online Web Form
A Request to Know, Request to Delete, or Request to Correct must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- If you are submitting a Request to Know specific pieces of personal information (rather than categories), you will also need to submit a declaration under the penalty of perjury confirming that you are only requesting information about yourself.
- If you are submitting a Request to Correct specific pieces of personal information, you will need to submit a declaration under the penalty of perjury confirming you are only correcting information about yourself.
Only (1) you or (2) a person authorized by you to act on your behalf, may make a Request related to your personal information.
7.2. Authorized Agents
Before we can respond to a Request to Know, Request to Delete, or Request to Correct submitted by an authorized agent, we need to verify not only that person or entity’s authority to act on your behalf but also verify the identity of the authorized agent.
If you are authorized to submit a request on behalf of a California resident, please email us at privacy@veros.com and provide the following information:
- To verify your authorization to request on behalf of a California resident, please attach a copy of one or more of the following to your request email:
- signed permission from the California resident, or
- a valid power of attorney
- To verify your identity, please attach copies of the following to your request email:
- valid Government Issued ID (not expired) AND
- a Utility Bill, Bank Statement, or similar documentation to verify your name and address.
- To verify the identity of the consumer for whom you are submitting the request, please submit the required information by calling us at (866) 458-3767, select option 6; or by emailing us at privacy@veros.com.
7.3. Response Timing and Delivery Method:
We will acknowledge receipt of a Request to Know, Request to Delete, or Request to Correct within 10 business days of its receipt. We will respond to a request within 45 days of its receipt. If we require more time (up to 45 additional days for a total of 90 days from receipt of the request), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
- CHANGES TO THESE CALIFORNIA DISCLOSURES AND PRIVACY POLICY
We reserve the right to amend this California Employee Privacy Policy at our discretion and at any time. If we make changes to this California Employee Privacy Policy, we will notify you by email or through a notice on our HR SharePoint.
- HOW TO CONTACT US
If you have any questions or comments about this California Employee Privacy Policy, the ways in which we collect and use your personal information, or your rights regarding such use, please do not hesitate to contact us at:
| Privacy Support E-Mail: | privacy@veros.com |
| Toll-Free Number: | 866-458-3767 (option 6) |
| Postal Address: |
Veros Real Estate Solutions
Attn: Privacy 2333 N. Broadway, Suite 350 Santa Ana, CA 92706 |
