Business Associate Agreement

This Notice to California residents, pursuant to the California Privacy Rights Act of 2020 (“CPRA”), supplements the information contained in our CPRA Policy on the website and applies solely to employees, job applicants, candidates, clients, visitors, and other natural persons who reside in the State of California (“Consumers,” “You,” or “Your”). This Notice has been adopted to comply with the CPRA (effective January 1, 2023) and other California privacy laws.

Personal Information We Collect

Innova Solutions, HireGenics, Volt, and their subsidiaries (the “Company”) collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or device (“Personal Information”). The information we collect varies for each type of Consumer but may include the following categories of Personal Information as defined under the CPRA:

Category	Examples	Collected
Identifiers	A real name, IP address, e-mail address, or other similar identifiers.	YES
Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code §1798.80(e))	A name, signature, Social Security Number, address, telephone number, passport number, driver’s license number, insurance policy number, education, employment history, bank account number, credit card number, financial information, medical information, or health insurance information.	YES
Protected classification characteristics under California or Federal law	Age, race, ancestry, national origin, citizenship, religion, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, pregnancy, childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information.	YES
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
Biometric Information	Facial images, fingerprint data, and voice recordings.	YES
Internet or similar network activity	Search history, browsing history, login information, and IP addresses on the Company's information systems and networks.	YES
Professional or employment-related information	Educational and professional backgrounds, such as Your work history, academic and professional qualifications, educational records, references, and interview notes.Employment details, such as Your job title, position, hire dates, compensation, performance, disciplinary records, and vacation and sick leave records.	YES
Non-public educationinformation (per theFamily Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	YES
Precise geolocation data	Data that is derived from a device and that is used or intended to be used to locate a Consumer within a geographic area, such as time and physical location related to the use of the internet on the Company network or physical access to a Company office location.	YES
Contents of a Consumer’s mail, e-mail, and text messages unless the business is the intended recipient of the communication.	E-mails, Microsoft Teams messages, text messages, letters, videos, memos, notes, proposals, contracts, and employee reports.	YES
Audio, electronic, visual, thermal, or similar information.	COVID-19-related temperature checks, call monitoring, and video surveillance.	YES

 

Use of Personal Information

Job Applicant, Candidate, and Employee Information – The Company collects Personal Information to use or disclose as appropriate to:

• Comply with all applicable laws and regulations
• Recruit and evaluate job applicants and candidates for employment
• Conduct background checks
• Manage Your employment relationship with us, including for:
  • Onboarding processes
  • Timekeeping, payroll, and expense report administration
  • Employee benefits administration
  • Employee training and development requirements
  • The creation, maintenance, and security of Your online employee accounts
  • Reaching Your emergency contacts when needed, such as when you are not reachable or are injured or ill
  • Workers’ compensation claims management
  • employee job performance, including goals and performance reviews, promotions, discipline, and termination
  • Other human resources purposes
• Manage and monitor employee access to Company facilities, equipment, and systems
• Conduct internal audits and workplace investigations
• Investigate and enforce compliance with and potential breaches of Company policies and procedures
• Engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers and acquisitions of the Company
• Maintain commercial insurance policies and coverages, including workers’ compensation and other liability insurance
• Perform workforce analytics, data analytics, and benchmarking
• Administer and maintain the Company’s operations, including for safety purposes
• Market to clients
• Exercise or defend the legal rights of the Company, its employees, and others

Client, Service Provider, and Contractor Information – The Company may use the Personal Information about its clients, service providers, and contractors to:

• Store (and update when necessary) their details on our databases so that we can contact them in relation to our agreements
• Offer services to them or obtain support and services from them
• Perform certain legal obligations
• Help us to establish, exercise, or defend legal claims

The Company retains Your Personal Information according to its business requirements, government regulations, judicial or administrative actions, private or governmental contracts, pending litigation, audits, and records retention policy. 

In the preceding twelve (12) months, the Company has not sold or shared any Personal Information as defined by the CPRA.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you with this Notice. 

Our CPRA Policy can be found on the website. 

If you have any questions about this Notice or need to access this Notice in an alternative format due to having a disability, please contact privacy@innovasolutions.com.