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Privacy Notice For Applicants, Employees, And Contractors

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Effective Date: January 1, 2020

kaleo, Inc. (“Company,” “we,” or “us”) provides this Privacy Notice to job applicants, employees, and contractors to inform you about our privacy practices and to comply with applicable law. This Privacy Notice describes the types of personal information we collect, how we may use the information, and with whom we may share it. In addition, California privacy law now gives job applicants, employees, and contractors the right to know about the information companies collect about them.Click on one of the links below to jump to the listed section:

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Information We Collect or Obtain

Personal Information
“Personal information” is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device. We collect or obtain the following categories of personal data about you when you apply for a position with us or accept a position with us as an employee or contractor. Please see “How We Use Personal Information” for more information about why we collect the categories of information below.


Examples of Information We Collect


Name, address, phone number, email address (collectively, “Contact Information”); account name, NPI number, or other identifier; IP address; Social Security number, driver’s license number or state ID card number, passport number, or other similar identifiers.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Signature, phone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, health insurance information.

Protected classification characteristics under California or federal law.

Age, marital status, sex, pregnancy or childbirth. You may optionally disclose certain additional protected characteristics, such as race, national origin, or veteran/military status, to us during the hiring process or your employment with us.

Commercial information.

Information about products or services purchased, such as when you use your Kazoo points.

Internet or other similar network activity.

Information about how employees or contractors use websites or apps when performing their duties, use a Company network, or use a Company device. Search history and browsing history is recorded and logged.

Geolocation data.

Location information, including physical location of Company devices.

Sensory data.

Video and audio recordings, such as from security surveillance of physical premises. Visual information, such as employee headshots.

Professional or employment-related information.

Current and past job history.

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

Educational records, such as grades or transcripts.

Inferences drawn from other personal information.

We may develop a profile reflecting characteristics, abilities, or preferences, such as to optimize compatibility or help identify strengths.

Company does not collect biometric information. You may choose to use device features, such as FaceID or fingerprint-to-unlock technology, to secure your device. Such features are stored locally and are not accessible by us.

The “personal information” categories disclosed in this Privacy Notice do not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information. We may use or disclose de-identified or aggregated information (that is no longer personally identifiable) to any party for any purpose. For example, we may share this aggregated data with our affiliates, agents, advertisers, manufacturers and business partners. We also may disclose aggregated user statistics in order to describe our services to current and prospective business partners and to other third parties for other lawful purposes.
  • Information covered by sector-specific privacy laws, such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA); the Fair Credit Reporting Act (FCRA); the Gramm-Leach-Bliley Act (GLBA); the California Financial Information Privacy Act (FIPA); or the Driver’s Privacy Protection Act of 1994 (DPPA).

Sources of Personal Information

  • We may obtain the categories of personal information listed above from the following categories of sources:
  • Directly from you. For example, you provide us with information when you apply for a position with us.
  • Indirectly from you. For example, we log browsing history for security purposes.
  • From third-party service providers. For example, our benefits providers may provide us with some non-claims related information about you.
  • From public databases or government entities. For example, we perform background checks before hiring employees.

How We Use Personal Information

We may obtain the categories of personal information listed above from the following categories of sources:

  • To fulfill the reason you provided the information. For example, to evaluate your application for employment with us.
  • To create, maintain, and secure your Company account or credentials.
  • To compensate you or otherwise fulfill our obligations to you.
  • To provide you with customized support and training, including to monitor, investigate, and respond to your inquiries and concerns.
  • For testing, research, analysis, and product development, including to develop and improve our benefits programs or products.
  • To conduct our business or to help maintain the safety, security, and integrity of our products and services, databases and other technology assets, and business.
  • To perform data analyses and other processing (including scientific, market and consumer research, trend analysis, financial analysis, anonymization, encryption or tokenization of personal information).
  • To protect against, identify, and prevent fraud and other criminal activity, or to defend against or enforce legal claims and other liabilities.
  • To evaluate, enforce, defend, or fulfill our own or others’ legal rights or obligations.
  • To respond to law enforcement requests; as required by applicable law, court order, or governmental regulations; or to monitor our compliance with those obligations.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, acquisition, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred or otherwise impacted by or relevant to the transaction or proceeding.
  • With your consent, as described to you when collecting your personal information.

How We Share Personal Information

We do not sell or otherwise share personal information about you, except as described in this Privacy Notice.

We share your personal information with the following categories of third parties:

  • Service providers. We share your personal information with third parties that provide services for us. These third parties are not authorized by us to use or disclose the information except as necessary to perform services for us or to comply with legal requirements.
  • Benefits providers. We share your personal information in order to provide you with benefits.
  • Government entities. We disclose information about you (i) if we are required to do so by law, regulation or legal process (such as a court order or subpoena), (ii) in response to requests by government agencies, such as law enforcement authorities, (iii) for the purpose of, or in connection with, legal proceedings, or otherwise for the purpose of establishing, exercising or defending our legal rights, (iv) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.

Please note that we share the names and titles of certain high-level employees, including VPs and officers, on our public website(s). We may share employees’ business contact information with customers or the public in the course of conducting our business.

We may transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution, liquidation or other corporate restructuring).

We do not disclose personal information of our users to third parties for their direct marketing purposes.

Sales of Personal Information

In the preceding twelve (12) months, we have not sold personal information. Our policy is that we do not and will not sell your personal information, unless you give us your consent or direct us to do so.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following categories of personal information for the business purposes described above (in How We Use Personal Information):

  • Identifiers.
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
  • Protected classification characteristics under California or federal law.
  • Commercial information.
  • Internet or other similar network activity.
  • Geolocation data.
  • Sensory data.
  • Professional or employment-related information.
  • Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)
  • Inferences drawn from other personal information.

How to Submit A Request Regarding Your Personal Information

Please contact us using the information below (in Contact Us) if you have a question about your personal information or if you would like to make a request to correct, access, or delete your information. We strive to keep your personal information accurate. Please note that we may not be able to delete your information; for example, we may not be able to delete information about you that we retain in order to act as your employer, protect against fraud or illegal activity, or enforce our legal obligations.

We will not be able to respond to your request or provide you with personal information, if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Updates to This Privacy Notice

This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will notify you before materially changing the way we use your personal information. If this Privacy Notice is revised, we will update the date at the top of this Privacy Notice and post the updated version on our intranet or otherwise provide it to you.

Contact Us

If you have any questions or concerns about this Privacy Notice or about our privacy practices, or if you would like to make a request regarding your information, please contact us at PrivacyPolicy@kaleo.com.