PRIVACY NOTICE TO CALIFORNIA EMPLOYEES AND CONTRACTORS
REGARDING THE COLLECTION OF PERSONAL INFORMATION
Effective Date: July 1, 2020
LongTail Ad Solutions, Inc. dba JW Player, and its operating groups, subsidiaries and affiliates, including its subsidiaries JW Player UK LTD, JW Player Netherlands BV, and JW Player Singapore PTE. LTD. (the "Company" or "we") is committed to protecting the privacy and security of personal information of our current and former employees ("Employees") and contractors (together with Employees, "Personnel") and their emergency contacts and beneficiaries. The Company does not sell or otherwise disclose this personal information for monetary or other consideration to any third parties.
The Company is committed to complying with the California Consumer Privacy Act ("CCPA") effective January 1, 2020, and all data privacy laws in the jurisdictions in which the Company collects personal information of Personnel.
What Categories of Personnel Information Do We Collect and How Do We Use This Information?
We collect the following categories of personal information for the purposes described below:
|Category of Personal Data||Personal Information Collected||Purpose|
- Real name
- Preferred name
- Postal address
- Email address
- Unique personal or online identifier
- Internet Protocol address
- Social Security number
- Passport number, driver's license or state identification card number
- Age or date of birth
- Other similar identifiers
|The Company collects personal identifiers to onboard Personnel; enroll and administer benefits; enter into contracts; and use for general human resource purposes.|
|Records identified by state law (including the California Customer Records statute (Cal. Civ. Code § 1798.80(e)))||Examples:
- Social Security number
- Telephone number
- Passport number, driver's license or state identification card number
- Insurance policy number
- Employment history
- Bank account number
- Credit card information or any other financial information
- Medical information or health insurance information
|The Company collects this information to process job applications; onboard Personnel; enroll and administer benefits; enter into contracts; and use for general human resource purposes.
The Company collects pay information – such as pay rate, payroll deduction information banking information for direct deposit, and credit card information for expense reimbursement – to pay its Personnel and comply with applicable laws.
|Protected classification characteristics under state or federal law||Examples:
- Religious creed
- National origin
- Physical or mental disability
- Medical condition
- Marital status
- Sex, gender, gender identity, or gender expression
- Sexual orientation
- Military and veteran status
|The Company collects equality and diversity information, such as minority, veteran and disability status, through voluntary self-disclosure and other means to implement the Company's diversity programs and to comply with applicable laws.
The Company collects health and safety information to maintain a safe workplace; assess your working capacity; administer health and Workers' Compensation insurance programs; and comply with applicable laws.
The Company also collects information necessary for benefits enrollment and administration purposes.
- Records of personal property, products or services purchased, obtained, or considered
- Other purchasing or consuming histories or tendencies
|If you are a contractor, we may collect commercial information from or about you in connection with obtaining services from you.|
|Internet or other similar network activity information||Examples:
- Email, computer, internet, telephone, and mobile device usage
- IP address, log-in information, and location information
- Browsing history, search history, or information regarding your interaction with a website, application or advertisement
|The Company collects this information to protect Company, customer, and Personnel property, equipment and confidential information; monitor Personnel performance; and enforce the Company's electronic communications acceptable use policies.|
|Sensory data||- Audio and visual information||The Company may collect audio and visual information of Personnel through photographs used for identification purposes and to promote the Company. The Company collects audio and video recordings of training sessions.|
|Professional or employment-related information||- Performance management information, such as employment status (full-time or part-time, regular or temporary), work schedule, job assignments, hours worked, accomplishments and awards
- Training and development information
- Performance evaluation information
- Discipline and counselling information
- Employment termination information
|The Company collects professional and employment-related information to manage its relationship with Personnel.|
|Education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))||Examples:
- Education records such as grades, transcripts, and class lists
|The Company collects education information in connection with the job promotion process; to evaluate Employees for promotions; and to feature Employees in marketing materials and on the Company's website.|
|Inferences drawn from other personal information||Examples:
- Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes
|The Company may collect inferences drawn from other personal information to manage our relationship with Personnel.|
|Personal Data about children under the age of 16||Personal information about Employees' dependents under the age of 16.||The Company collects information about Employees' dependents under the age of 16 if Employees voluntarily provide such information in connection with the enrollment and administration of benefits and other human resource purposes that involve such dependents.|
|Legal and Contractual Information||Information necessary to: respond to law enforcement and governmental agency requests; comply with legal and contractual obligations; exercise legal and contractual rights; and initiate or respond to legal claims||The Company collects this information to comply with legal and contractual requirements and to establish, exercise and defend legal and contractual rights and claims.|
|Emergency Contact Information||- Name and contact information
- Relationship to Employee
|The Company collects this information to contact the Employee's designated emergency contact persons in the event of an emergency.|
|Beneficiary Information||- Name and contact information
- Relationship to the Employee
- Birth date
- Social Security Number
- Information necessary to process benefits claims
|The Company collects this information to enroll and administer benefits programs for beneficiaries of Employees.|
Sources of Personal Information
We collect personal information directly from you. We may also combine personal information collected from other sources with the personal information you provide to us. For example, we may collect information from:
- Prior employers (e.g., for references)
- Professional references you provide to us
- Educational institutions
- Pre-employment screening services
- Credentialing and licensing organizations
- Publicly available sources such as your social media profile (e.g., LinkedIn, Twitter and Facebook)
- Third parties as necessary for providing you with benefits and ancillary services
- Other sources as directed by you
Disclosure of Personal Information
We may share your personal information as necessary for the purposes described in this Privacy Notice. For example, we share your personal information with the following parties:
- Affiliates: We may share your personal information with our corporate affiliates.
- Service Providers: We use service providers to operate, host and facilitate our operations and business (including human resources operations). These include hosting, technology and communication providers; security and fraud prevention consultants; analytics providers; background and reference check screening services; and hiring process and benefits management and administration tools.
- Government authorities and law enforcement: In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- Business transfers: Your personal information may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
- Professional advisors: We may share your personal information with our professional advisors.
- Other: We may also share your personal information with third parties for purposes of fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, us or another party; enforcing any agreements with you; responding to claims; and resolving disputes.
Contact for Questions
If you have any questions or concerns regarding this Privacy Notice or the collection of your personal information, please contact: firstname.lastname@example.org or email@example.com. Personnel with disabilities may access this notice in an alternative format by contacting to firstname.lastname@example.org or (212) 422-0140.