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NOTICE TO CALIFORNIA EMPLOYEES AND APPLICANTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT

The purpose of this notice is to provide you with information on the categories of personal information that are collected by Curology and David Lortscher MD, P.C. (“Curology,” “we” or “us”) regarding the Personal Information that we collect and use about California residents in the context of their current, former or potential role as our employees, job applicants, contractors, owners, directors, medical staff members for affiliate organizations, or officers. We supply this information consistent with the California Consumer Privacy Act of 2018 (“CCPA”), which has limited applicability in this context but provides for a privacy notice describing the categories of Personal Information collected and used regarding employees, job applicants, contractors, owners, directors, medical staff members for affiliate organizations, and officers.

Definition

Personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular employee or applicant. Personal information does not include publicly available information.

Categories of Personal Information

Curology collects and stores different types of personal information about employees and applicants such as:

  • Pre-recruitment data, e.g. personal data contained in a job application form, resume, references, interview notes, etc.
  • Where permitted by law and applicable, we may collect the results of credit and criminal background checks, and the results of drug and alcohol testing and screening
  • Name, gender, home address and telephone number, date of birth, marital status, employee identification number and emergency contacts
  • Residency and work permit status, nationality, and passport information
  • Information related to gender, race, or ethnic origin for purposes of complying with anti-discrimination laws
  • Social security or other taxpayer/government identification number
  • Payroll data, e.g. tax forms, bank account information, etc.
  • Information related to benefit entitlements and plans, e.g. details of participation, contributions made, beneficiary information, etc.
  • Employee equity information
  • Employment details such as job title/position, office location, hire/transfer/promotion dates, offer letters/employment agreements, compensation data, performance data, disciplinary and complaint/grievance documentation, training records, travel and expense records
  • Medical and other relevant information/documentation for purposes of disability accommodation, leaves of absence, verification of need for time off, etc.
  • Time and attendance records
  • Height, weight and clothing sizes, photograph, videos, physical limitations and special needs
  • Date of resignation or termination, reason for resignation or termination, information relating to administering termination of employment
  • Data collected through monitoring processes (e.g. building access control records collected via wall terminals, records of automatic monitoring operations of Curology IT and Communications equipment, as carried out by software operating automatically)
  • Images captured/recorded by Curology’s security camera system
  • Voicemails, e-mails, correspondence, documents, and other work product and communications created, stored or transmitted using our networks, applications, devices, computers or communications equipment
  • Data relating to accidents or dangerous occurrences in the workplace
  • Information required for Curology to comply with laws, the requests and directions of law enforcement authorities or court orders (e.g., child support and debt payment information)
  • Acknowledgments regarding our policies
  • Any other information that you provide directly to us

Purposes For Which The Categories Of Personal Information Will Be Used

Curology may use your personal information for the following purposes:

  • Managing all aspects of an employee’s employment relationship, including, but not limited to: determining eligibility for initial employment, including the verification of references and qualifications; pay and benefit administration; the issuance and management of stock options and phantom equity units; corporate travel and other reimbursable expenses; development and training; absence monitoring; project management; auditing, compliance, and risk management activities; conflict of interest reporting; employee communications; performance evaluation; disciplinary actions; internal investigation activities; career management, including the assessment of qualifications for a particular job or task; processing employee work-related claims (e.g., worker compensation, insurance claims); succession planning; relocation assistance; obtaining and maintaining insurance; the provision of employee related services; and other general operations, administrative, financial, and human resources related purposes.
  • Assisting you with obtaining an immigration visa or work permit where required
  • Video conferencing
  • Maintaining directories of employees
  • Employee engagement programs, including surveys
  • Administering our occupational safety and health programs
  • Protecting the safety and security of our workforce, guests, property, and assets (including controlling and facilitating access to and monitoring activity on and in our premises and activity using our computers, devices, networks, communications and other assets and resources)
  • Investigating and responding to claims against Curology
  • Maintaining emergency contact and beneficiary details
  • Complying with applicable laws (e.g. health and safety, employment laws, office of foreign asset controls regulations, tax laws), including judicial or administrative orders regarding individual employees (e.g., garnishments, child support payments)
  • Carrying out any additional purposes that we advise you of (if applicable law requires your express consent for such additional use or disclosure we will obtain it from you)
  • Carrying out other purposes as part of our business activities when reasonably required by us

Questions

Any questions or concerns about this notice should be referred to in the first instance to the People Operations Team at hr@curology.com.