Creative Circle, LLC (“the Company”, “we”, “our” or “us”) is committed to protecting the privacy and security of your personal information.  This Privacy Notice describes how the Company collects, uses, discloses, and safeguards personal information about you before, during, and after your working relationship with us.  This Privacy Notice also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions.

This Privacy Notice applies to all job applicants, permanent and temporary employees, workers, contractors and any other individuals who are working for the company but are not directly employed, located in California (“staff member” or “you”). Please note that because this Privacy Notice is comprehensive, it may refer to types of information that we collect and share about people other than yourself.

Information We Collect About You

For the purposes of this Privacy Policy, “personal information” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, regardless of whether it is held in paper, electronic or any other format.

We collect, maintain, and use different types of personal information in the context of our relationship or potential relationship with you. The following provides examples of the type of information that we collect from you, and have collected in the preceding 12 months, and how we use the information.

Context

Categories of Information

Primary Purpose of Collection and Use of Information

Benefits 

Wage and benefit information, including but not limited to salary, bonus, additional pay, variable compensation, annual leave, retirement savings plans and related compensation history and benefits information.

To provide employee benefits, including health insurance, expense reimbursements, etc. Our interest in maintaining accurate business accounts.

Closed Circuit TV and Facilities Access

CCTV footage and other information obtained through electronic means such as key fob/swipe card records and geolocation.

To protect the Company’s property, and to maintain the security of information held by the Company and the security of its facilities.

Certifications and Qualifications

We collect information from individuals who have access to our facilities and equipment including licensing and certification, and when applicable, nationality and citizenship.

To secure our facilities and equipment, and track those individuals with access to either for security and maintenance purposes.  In some jurisdictions, we are also required by law to validate and record information about the individuals that access our facilities and equipment.  We have an interest in complying with all legal requirements to collect information in the countries in which we operate.

Contact Details

Personal contact details such as name, title, addresses, telephone numbers, including your mobile number, and work and personal email address.

To communicate with you, including regarding your application process, reminders, and documentation we may need to collect. In some jurisdictions, we are also required to collect this information to comply with law.

Electronic Communications

Information about your use of our information and communications systems.

To monitor your use of our information and communication systems and provide for security of the IT system to ensure compliance with our IT policies.

Government Identification

Social security numbers, taxpayer identification numbers, passport

To comply with applicable laws.

Health Related

Information about your health, including any medical condition, health and sickness records, details of any absences from work (other than holidays), including time on statutory parental leave and sick leave.

To ascertain your fitness to work, manage sickness absence. To comply with legal obligations related to health and safety. To provide health benefits such as insurance.

Identification

Name, date of birth, and driver’s license.

To identify you personally.

Interviews and Meetings

Audio and video

Engaging with applicants and employees who are applying from or working in a remote location.

Investigations

Details of any disciplinary investigations and proceedings, or of investigations following an alert.

To gather evidence for possible grievance or disciplinary hearings, or to make arrangements for the termination of our working relationship if warranted. To determine whether you, or another employee, has complied with our policies, procedures, and protocols.

Other Special Categories of Sensitive Information

Information about your gender, race, ethnicity, sexual orientation, religious beliefs, and health and disability data (where permitted and in accordance with applicable law and in certain instances only where you voluntarily provide such information).

To comply with government regulations and our interest in promoting and monitoring equal opportunities and diversity (if permissible under local applicable law).

Payroll, Retirement Savings Plans, and Taxes

Payroll information, including but not limited to social security number or equivalent, tax status information (i.e., marital status, dependents, etc.), payroll records, bank account details, direct deposit/credit arrangements, and information about retirement savings plans.

To calculate and pay your salary, tax, social security, and retirement savings plan contributions. In some jurisdictions, to comply with legal obligations.

Photographs

Photographs

Our interest in maintaining external and internal directories and/or a security badge (if applicable). We may additionally use photographs for marketing purposes.

Recruitment

Recruitment information, including copies of right to work documentation such as citizenship, work permit or visa; references and other information included in a CV, resume, or cover letter or as part of the application process; criminal background; references and interview notes; letters of offer and acceptance of employment, and employment agreements.

Our interest in making a decision about your recruitment or employment. In some jurisdictions, to comply with legal requirements to verify you are legally entitled to work in the country in which you are applying.

Surveys

If you participate in a survey, we will collect information that you provide through the survey.

We have an interest in understanding your opinions, and in collecting information relevant to our Company.

Terms of Employment

Employment records including job titles/duties, job location, working arrangements, seniority data, employee identification number, performance ratings, hire/re-hire date, termination date, job history, training records, professional memberships, and business travel arrangements.

Our interest in business management and planning, including accounting and auditing; conducting performance reviews, managing performance and determining performance requirements; making decisions about salary reviews and compensation; assessing qualifications for a particular job or task, including decisions about promotions; making decisions about your continued employment or engagement. To provide salary and benefits to certain employees.

Training

We collect information from individuals concerning the training that they receive from us, or from third parties.

Our interest in understanding and recording the qualifications and training of the individuals that work with us. We may also be required by law, or by contract, to share the training or qualification of certain staff with third parties such as regulators or clients. We may also choose to share the training or qualification of certain staff with third parties as part of our effort to develop business. We have an interest in complying with any statutory, regulatory, or contractual obligation to disclose the training of our staff, and we have an interest in using the qualifications of our staff to help development business.

How We Collect Your Personal Information

In addition to the information that we collect from you directly through your activities and interactions during the course of your employment and employment application process, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.  For example, through the application and recruitment process, we collect personal information about staff members either directly from candidates or sometimes from an online job site or background check provider where background checks are permitted. In addition, we may sometimes collect additional information from third parties including former employers, personal and professional references, credit reference agencies or other background check agencies, or government agencies (where permitted). By providing a mobile phone number, you agree to receive text messages from the Company. Text messages will be sent to notify you of a position or keep you updated on activities relevant to your application process, which may include reminders.

We will also collect additional personal information in the course of job-related activities throughout the period of you working for us. This may include monitoring communications and use of company IT equipment and systems, or from other staff members or supervisors.

Monitoring Use of Company IT Equipment and Systems

In the course of conducting our business, we may – under conditions permitted by applicable law- monitor employee activities and our premises and property. For example, some of our locations are equipped with surveillance cameras. Where in use, surveillance cameras are for the protection of employees and third parties, and to protect against theft, vandalism and damage to the Company’s property. They do not aim at controlling the working activity of the individual employee. Recorded images are typically destroyed and not shared with third parties unless there is suspicion of a crime or wrongdoing, in which case they may be turned over to the police, or other appropriate government agency or other appropriate third parties.

Additionally, where permitted by law, we have the ability to monitor all business communications, including, without limitation, phone, internet browsing, email, instant messaging, and VoIP. For the purposes of your own personal privacy, you need to be aware that such monitoring might reveal sensitive personal data about you if you include such information in a business communication. By carrying out such activities using the Company’s facilities you acknowledge that sensitive personal data about you may be revealed to the Company by such monitoring.

How We Use Your Personal Information

In addition to the purposes and uses described above, we use your personal information for the following business purposes associated with the administration of your employment with us and our general business operations:

  • Administering your relationship with us, including fulfilling any obligation that we have to provide you with compensation, applicable benefits, or other work related allowances;
  • Complying with corporate financial responsibilities, including audit requirements (both internal and external), accounting, and cost/budgeting analysis and control;
  • Conducting security, background, and health screenings, to the extent permitted and in accordance with applicable law;
  • Insurance claim investigation and resolution;
  • Complying with applicable laws or regulations including employment-related requirements (including certain diversity and inclusion reporting and making workplace accommodations);
  • Complying with our contractual obligations;
  • Conducting analytics;
  • Detecting and preventing fraud or crime, and investigating potential misconduct;
  • Managing corporate information technology (e.g., computers, phones, company systems and applications) and information security, including the helpdesk, corporate directory, IT support, fraud prevention, and information security;
  • Managing mergers and acquisitions, and other business reorganizations and job eliminations, business transfers, and potential divestments;
  • Monitoring and ensuring compliance with applicable laws, regulatory requirements, and applicable Company procedures, including the Company Code of Business Conduct and Ethics and Acceptable Use Policy;
  • Protecting the rights, safety, and property of the Company, our employees, and/or others; and
  • Responding to and complying with requests and legal demands from regulators or other authorities, and enforcing, exercising, or defending legal claims.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. Our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our general interest in conducting our business. Note that this Privacy Notice may be updated to notify you of additional purposes for which we process your personal information.

Disclosures of Your Personal Information

In addition to the specific situations discussed elsewhere in this policy, we share your personal information in the following situations:

We may disclose information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control) in the course of our normal business operations.

  • Business Transactions. If another company acquires, or plans to acquire, any part of our company, business, or our assets, or similar corporate restructuring activities, we may disclose information to that company, including at the negotiation stage.
  • Legal or Regulatory Requests and Investigations. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process or administrative proceeding, or to comply with relevant laws or regulations. We may also need to disclose your personal information to tax authorities, courts, regulators, the police and other governmental authorities where we are required or permitted to do so by law.
  • Prospective Job Placements. We may disclose information such as your name, training and qualification records, certifications, and other information relevant to your candidacy to our clients, in order to facilitate your temporary or permanent job placement.
  • Other Third-Parties. We may disclose certain information such as name, work contact details (including your workplace ID photo), training and qualification records, certifications, and other information about your work arrangements to other third parties, such as professional advisers (including lawyers, auditors and accountants), professional bodies, and regulatory authorities in the normal course of business.
  • Other Disclosures with Your Consent. We may ask to disclose your information to other unaffiliated third parties who are not described elsewhere in this Privacy Notice.
  • Protection of the Company or Others. We may disclose your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.
  • Third-Party Service Providers. We may disclose your information to service providers. For example, we may disclose your personal information to payroll administrators, IT service providers, training providers, benefits providers, security providers, and marketing/events providers. In addition to the specific situations discussed elsewhere in this Notice, we disclose your personal information in the following situations and for the purposes identified above:

Data Security

We maintain reasonable physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to help protect your personal information against loss, unauthorized access or disclosure, modification, or destruction.  While we use reasonable efforts to protect your personal information, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any privacy or security event relating to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our internal programs require you to create an account.  When you do you will be prompted to create a password.  You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you.  You should notify us of any unauthorized use of your password or account.

Retention Period

We retain information about you and your relationship with us for as long as is needed to fulfil our legitimate business purposes outlined in this Policy. The specific periods for which we keep information about you vary depending on the nature of the information, why we need it, and whether the personal information is de-identified. We also consider the minimum necessary retention period prescribed by applicable laws, recommended by industry standards, and stated in contracts and other legal obligations.

Your Rights in Relation to Your Personal Information

You have certain rights regarding your personal information as detailed below:

  • Request access to your personal information. You have the right to request access to personal information we hold about you. Specifically, you have the right to request access to information about the categories of personal information concerned and categories of recipients to whom the personal information has been or will be disclosed, and the sources from which we receive that personal information among other information. You generally have the right to receive this personal information, in a structured, commonly used, and machine-readable format so you can transmit this personal information to another entity.
  • Request Deletion of Your Personal Information. You may request that we delete your personal information. There may be instances where applicable law or regulatory requirements allow or require us to refuse a deletion request. For example, we may keep your personal information as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements.
  • Opt-out of the Sale or Sharing of Personal Information. We do not currently, nor have we in the preceding 12 months, sold or shared (in this context, share means use of your personal information for cross-contextual behavioral advertising) your personal information in the applicant/employment context. We do not knowingly sell or share the Personal Information of individuals under the age of 16.
  • Automated Processing: We do not use any technology that makes a significant decision based solely on automated processing (i.e., without human intervention). In the event we begin to use such technology, you have the right to object to that automated processing unless that decision is required or authorized by law.
  • Non-discrimination: We do not discriminate against employees who exercise any of their rights described in this Privacy Notice, nor do we retaliate against employees who exercise these rights. However, we may require the use of your Personal Information to administer your employment relationship with us. Therefore, in some instances, we may not be able to process your request.
  • Restrict Use of Your Sensitive Personal Information (in certain instances and if permissible under applicable law). You have the right to request the restriction of processing of your sensitive personal information. At the current time, however, we do not use or disclose sensitive personal information for purposes other than those described in this Notice and these uses cannot be limited under applicable law.
  • Notification of Employment Opportunities. You may choose to provide us with your email address for the purpose of allowing us to send you employment opportunities. You can stop receiving these emails by following the unsubscribe instructions in e-mails that you receive.  If you decide not to receive these emails, we may still send you service-related communications.
  • Promotional Text Messages. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”

If you choose to assert any of these rights under applicable law, we will respond within the time period prescribed by such law. Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on the circumstances of the request.

A person authorized to act on your behalf may make a verifiable request related to your personal information. If you designate an authorized person to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf.

Your verifiable request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

To exercise your rights, call us at 800-536-1390; or submit your request online here.

Other Important Information

The following additional information relates to our privacy practices:

  • Changes To This Privacy Notice. We may change our privacy Notice and practices over time.  To the extent that our Notice changes in a material way, the Notice that was in place at the time that you submitted personal information to us will generally govern that information.
  • Contact Information. If you have any questions about this Privacy Notice, please contact MyPrivacy@CreativeCircle.com

Last Revised: December 22, 2022

California Information Sharing Disclosure

California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether the following categories of personal information are collected, transferred for “valuable consideration,” or transferred for an organization’s “business purpose” (as those terms are defined under California law).  We do not “sell” your personal information. The table below indicates the categories of personal information we collect and transfer in a variety of contexts.  Please note that because this list is comprehensive, it may refer to types of information that we collect and share about people other than yourself.  For example, while we collect the bank account information of our current employees, we do not collect the bank account information of applicants that have not yet been hired.

Categories of Personal Information We Collect

To Whom We Disclose Personal Information for a Business Purpose

Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, social security number, driver’s license number, passport number or other similar identifiers.

  • Affiliates or subsidiaries
  • Business partners and clients
  • Data analytics providers
  • Internet service providers
  • Operating systems and platforms
  • Payment processors and financial institutions
  • Professional services organizations, this may include auditors and law firms
  • Other Service Providers

Government entities, as may be required to comply with law or prevent illegal activity

Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, and other financial information, medical information, and health insurance information.

  • Affiliates or subsidiaries
  • Operating systems and platforms
  • Payment processors and financial institutions
  • Professional services organizations, this may include auditors and law firms
  • Other Service Providers

Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical or mental handicap, etc.

  • Affiliates or subsidiaries
  • Operating systems and platforms
  • Professional services organizations, this may include auditors and law firms
  • Other Service Providers

Biometric information

  • Affiliates or subsidiaries
  • Operating systems and platforms
  • IT Service Providers
  • Government entities, as may be required to comply with law or prevent illegal activity

Internet or other electronic network activity information – this may include browsing history, search history, geolocation data, and information regarding an individual’s interaction with an internet website, application, or advertisement.

  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Internet service providers
  • Operating systems and platforms
  • Professional services organizations, this may include auditors and law firms
  • Social networks
  • Other Service Providers

Government entities, as may be required to comply with law or prevent illegal activity

Audio, electronic, visual, or similar information

  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Internet service providers
  • Operating systems and platforms
  • Professional services organizations, this may include auditors and law firms
  • Other Service Providers

Professional or employment-related information

  • Affiliates or subsidiaries
  • Business partners and clients
  • Data analytics providers
  • Internet service providers
  • Operating systems and platforms
  • Professional services organizations, this may include auditors and law firms
  • Other Service Providers

Non-public education information (as defined in the Family Educational Rights and Privacy Act)

  • Affiliates or subsidiaries
  • Business partners and clients
  • Data analytics providers
  • Internet service providers
  • Operating systems and platforms
  • Professional services organizations, this may include auditors and law firms
  • Other Service Providers
  • Government entities, as may be required to comply with law or prevent illegal activity

Inferences drawn from any of the information listed above

  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Internet service providers
  • Joint marketing partners
  • Operating systems and platforms
  • Professional services organizations, this may include auditors and law firms
  • Other Service Providers
  • Government entities, as may be required to comply with law or prevent illegal activity