PRIVACY NOTICE

(Version 3.0 | Rev 01/01/2023)

This Privacy Notice describes the information SPECTRAFORCE TECHNOLOGIES, INC. and its subsidiaries (“SPECTRAFORCE”, “we”, “our”, or “us”) collects, how we use this information, with whom we share it, and the choices you have in connection with these activities. This Privacy Notice applies to the SPECTRAFORCE website, https://spectraforce.com/ and any sub-domains, (collectively, the “Website”) and any other products or services listed below (collectively, our “Services”):

Effective 1st January, 2023, we have updated our Privacy Notice. This Privacy Notice has been changed in the following ways:

  • We added the ways in which we collect your personal information;
  • We added the ways in which your personal information is sold or shared in the future;
  • We included consumer rights you may be entitled to under the California Privacy Rights Act;
  • We added additional ways in which you can exercise your consumer rights; and
  • We added the period for which your personal information will be retained.

PERSONAL INFORMATION WE COLLECT, HOW WE USE IT, HOW LONG WE KEEP IT

Through your use of our Services, we collect personal information, which is information that identifies you or relates to you as an identifiable individual. We will retain this information for seven (7) years, unless otherwise disclosed below. Through your use of our Website and Services, we collect personal information as described below.

A. Information We Collect Directly From Your Interaction with the Services

  • Apply for employment. When you apply for employment with SPECTRAFORCE, we collect from you your personal identifiers (name, email address, physical address, telephone number, location) and your professional or employment information (resume, cover letter, employment history, and educational history/information, credentials, license). We use this personal information to assess and manage your application, determine suitability for the role, and as necessary to comply with applicable laws. We may also collect sensitive personal information (last four digits of your social security number or date of birth), health information (vaccination status), and protected categories (race, gender, ethnicity, disability status, military or veteran status/spouse status, age range.) We use this information as necessary to comply with applicable laws and provide services to our clients.   For additional information on our applicant privacy practices, please see our CA applicant notice.
  • Communicate with us via email. When you communicate with us via email, we collect your personal identifiers (name, email address, telephone number, and company name) and any other information you choose to include in your correspondence. We use this personal information to respond to your questions or inquiries, troubleshoot as necessary, and address any issues you have with our Services. We also use this personal information to send you marketing communications.
  • Utilize the search function. When you use the search function in our homepage, we collect the keywords of your search. We use this information to search for content that matches your search.
  • Call us. When you call us on a recorded telephone line, we will collect auditory information, i.e., a recording of your voice during the call. We use this information for legal compliance, training, and quality assurance.
  • Use the search function within our job board. When you use the search function within our job board, we collect the keywords of your search (type of role, and location). We use this information to search our database of jobs to match the jobs that match your search. Alternatively, if you decide to apply though Indeed, Indeed will collect the information described above and as described in Indeed’s privacy policy.

We also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION.

B. Information We Collect From Current and Prospective Clients, Service Providers, and Vendors

If you are a current or prospective client, service provider or third party vendor of SPECTRAFORCE, we will collect from you or third party sources (public websites, government agencies, client or third party referrals) your personal identifiers (name, business name, physical address, telephone number, tax identification number, and email address), and if any of our calls are recorded, your auditory, electronic, visual information (recorded voice or video), and if you are a current client financial account information (bank details, routing and account number. If you are a prospective client, we will use this information to communicate with you about providing our services. If you are a current client, we use this personal information to communicate with you and to fulfill and manage the services we provide to you. If you are a prospective service provider or third-party vendor, we use this information to inquire about the services you provide to SPECTAFORCE. If you are a current service provider or third-party vendor, we will use this information to facilitate the business relationship we have with you and communicate with you.

In our processing of your personal information, we may also use your personal information to defend our rights and the rights of others, to efficiently maintain our business, to comply with the law, and for other limited circumstances as described in HOW WE SHARE YOUR INFORMATION.

C. Information Collected From Third-Party Sources

SPECTRAFORCE receives personal information from the following third party sources to provide the services to you or our client.

  • Identity verification provider. We receive inferences from our identity verification provider (results of the identity verification process). We use this information to confirm your identity, determine work authorization status, and the accuracy of the information you provided to us.
  • Background check provider. We receive your background check results which may include criminal, credit, drug testing results, education, employment, motor vehicle, employment licenses/credentials, references, and inferences (results of your background check). We will use this information to provide to fulfil our agreement with our client, assess your suitability for the position in which you applied, and verify the information you provided to us.
  • Law enforcement agencies. We receive your criminal record from law enforcement agencies. We collect this information to comply with applicable law, assess your application for employment, and provide our services to our clients.
  • Referral sources and former employers. We receive inferences about your job performance (referral source or former employer’s opinion on your job performance). We will use this information to assess your application and provide our services to our clients.
  • Health or Vaccination Providers. If requested by the client or managed service provider that has engaged us to conduct the applicant search, we receive the conclusions drawn from your health examination, eye exam, and vaccination status (i.e., whether you passed the examination or have the requisite vaccinations, and not your health information) from the health examination/vaccination provider. We use this information to fulfil the requirements of our agreement with our client or managed service provider and determine whether you fulfil the health examination or vaccination requirements of the client or managed service provider. The inferences drawn from your health examination and vaccination check will be shared with the employer with which you applied.

We may also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION.

D. Information We Collect Automatically via Cookies and Other Trackers

In addition to the personal information you provide or we collect from third parties, we collect information, including internet or other electronic network activity information, automatically via cookies and similar technologies. Please review our Cookie Policy to learn about how your personal information is collected via cookies and other tracking technology.

HOW WE SHARE YOUR PERSONAL INFORMATION

A. General Sharing

SPECTRAFORCE shares personal information in the following instances:

  • Within SPECTRAFORCE. We share your personal information among our affiliated/subsidiary entities for the legitimate business purposes of efficiently and effectively providing the Services. Access to your personal information is limited to those on a need-to-know basis.
  • With service providers. We share personal information with service providers that assist us in providing the Services. These service providers are described more specifically in the Information Collected From Third-Party Sources section of this Notice, and includes email service provider, data hosting, analytics, network service provider, IT service provider, recruitment service provider, payroll providers, credit reporting agencies, branding and marketing service provider, legal and compliance service provider, admin and procurement service provider, finance and audit service provider.
  • With Clients and Managed Service Providers. When we are hired to find applicants or provide staffing services, we provide your identifiers (name, telephone number, address), and employment or professional information. We provide this information to provide the recruiting or staffing services to our client and managed service provider.
  • With Leoforce, LLC. Unless you object, we will share your personal information with our recruitment service provider, Leoforce LLC, to assist with the application review process.
  • In the event of a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We would also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
  • For legal purposes. We will share your personal information where we are legally required to do so, such as in response to court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights, as required to enforce our terms of service or other contracts; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; or to comply with the requirements of any applicable law.

B. Disclosure of your Personal Information for a Business Purpose

In the preceding 12 months, SPECTRAFORCE has disclosed the following personal information for a business purpose with the following categories of third parties:

  • We have disclosed your internet or other electronic network information collected by cookies to our marketing/IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair website and platform errors.
  • We have disclosed your internet or other electronic network information collected by cookies to our marketing/IT support to update, improve, and maintain the website and platform.
  • We have disclosed your identifiers, education information, employment information, sensitive personal information (last four digits of your social security number or date of birth) to our background check services providers to conduct a background check on you to assess your fit with the requirements of the position or staffing requirements, and as required by applicable law.
  • We have disclosed your identifiers to law enforcement agencies to obtain your criminal record to conduct a criminal background check on you to assess your fit with the requirements of the position or staffing requirements, and as required by applicable law.
  • We disclose your identifiers to your referral sources and previous employers to assess your fit with the requirements of the position or staffing requirements, and as required by applicable law.
  • On your behalf, we have disclosed all information received during the application process to our client or managed service provider to facilitate your application with the client or managed service provider.

C. Sale or Sharing of Personal Information

In the preceding 12 months, SPECTRAFORCE has shared your internet or other electronic network activity information collected via cookies and other tracking technologies with our data analytics providers as described in “Information We Collect Automatically via Cookies and Other Trackers”. Such sharing may be deemed a sale under the CCPA or a share under CPRA. To opt-out of this sale/sharing, please visit Do Not Sell or Share My Personal Information.

GENERAL INFORMATION CHOICES

You have the following choices with respect to your personal information:

  • Correct or view your personal information. If you have accepted a conditional offer, you may access or correct your onboarding documents through Spectranet or by contacting your assigned SPECTRAFORCE representative.
  • Opt Out of Other Cookies. To set your cookie preferences please see our cookie preference center. All session cookies are temporary and expire after you close your web browser. Persistent cookies can be removed by following your web browser’s directions. To find out how to see what cookies have been set on your computer or device, and how to reject and delete the cookies, please visit: https://www.aboutcookies.org/. Please note that each web browser is different. To find information relating to your browser, visit the browser developer’s Website and mobile application. If you reset your web browser to refuse all cookies or to indicate when a cookie is being sent, some features of our website may not function properly. If you choose to opt out, we will place an “opt-out cookie” on your device. The “opt-out cookie” is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences. By clicking on the “Opt-Out” links below, you will be directed to the respective third-party website where your computer will be scanned to determine who maintains cookies on you. At that time, you can either choose to opt out of all targeted advertising or you can choose to opt out of targeted advertising by selecting individual companies who maintain a cookie on your machine.

RIGHTS OF CALIFORNIA RESIDENTS

The California Privacy Rights Act, (CPRA) entitles California residents to certain rights. To the extent the CPRA applies to our processing of your personal information, you are entitled to the following rights:

  • Right to Access/Know. You have the right to request what personal information we have collected, used, disclosed, and sold about you, unless doing so proves impossible or would involve disproportionate effort.
  • Right to Deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions. Once we receive your request to delete and confirm your identity, we will delete (and notify any service providers or third parties, who we have shared or sold your personal information to, to delete) your personal information, unless an exception applies under applicable law.
  • Right to Opt-Out of Sale/Sharing. You have the right to opt-out of the sale or sharing of your personal information to third parties. SPECTRAFORCE does not have actual knowledge that it sells or shares personal information of minors under the age of sixteen (16) years. To exercise your right to opt-out of the sale or sharing of your personal information visit Do Not Sell or Share My Personal Information.
  • Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, opt-out, correct, or limit use of sensitive personal information under the CPRA.
  • Right to correct. You have the right to correct inaccurate personal information that we collect or maintain.

To exercise your right to access/know, correct, or delete your personal information, you may submit a request toll-free at 1-800-762-6318 or via email data.privacy@spectraforce.com . You can also exercise your rights by visiting our California Privacy Rights Act page. For requests submitted via telephone or email, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information.

To opt out of the sale or sharing of your personal information, visit Do Not Sell or Share My Personal Information, or, effective January 1, 2023, utilize the opt out preference signal to instruct us to not sell or share any of your personal information collected online. The opt out preference signal will apply to the device and browser in which you utilize it. You can utilize the opt out preference signal by activating the opt out preference signal in your browser, device, or other platform.

Using an Authorized agent

Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. If a consumer is using an authorized agent to submit a CCPA/CPRA privacy request to know (disclosure report) or delete their personal information, the following is required.

  • Using an authorized agent without power of attorney to submit a request to know or delete
    • Signed permission from the consumer authorizing the agent to submit the CCPA privacy request(s) on their behalf. Describe the type of privacy request(s) being requesting (know/disclosure report and/or deletion).
    • The consumer must verify their own identity directly with the us by submitting information or documentation that provides sufficient proof of identification, such as a copy of a driver’s license, an identification card issued by the motor vehicle administration, or any other government issued identification.
  • Using an authorized agent with power of attorney to submit a request to know or delete: If you have provided the authorized agent with power of attorney pursuant to California Probate Code sections 4000 to 4465, provide only the following: the valid power of attorney executed lawfully under California Probate Code sections 4121 to 4130.
  • Using an authorized agent to submit an opt-out request: Please provide written permission, signed by the consumer, authorizing the agent to submit the opt-out request.

RIGHTS OF NEVADA RESIDENTS

If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your personal information. We do not currently sell any of your personal information under Nevada law, nor do we plan to do so in the future. However, you can submit a request to opt-out of future sales by contacting us at data.privacy@spectraforce.com. Please include “Opt-Out Request Under Nevada Law” in the subject line of your message.

DO NOT TRACK

We do not process Do Not Track (DNT) signals. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

SECURITY OF YOUR PERSONAL INFORMATION

We implement and maintain reasonable security measures to protect the personal information we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. These security measures include access controls, multi-factor authentication, and encryption. However, no security measure or modality of data transmission over the Internet is 100% secure and we are unable to guarantee the absolute security of the personal information we have collected from you.

AGE RESTRICTION

The Services are not intended for individuals under the age of sixteen (16). If we learn that we have collected or received personal information from a child under the age of sixteen (16), we will delete that information. If you believe we might have information from or about a child under the age of sixteen (16), please contact us at data.privacy@spectraforce.com.

CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy in our sole discretion at any time. If we do, we will post the changes to this page, and will indicate the date the changes go into effect. We encourage you to review our Privacy Policy to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on the Website and/or via email and obtain your consent, if required.

CONTACT US

If you have any questions regarding this Privacy Policy, please contact us at: data.privacy@spectraforce.com