10. California Consumer Privacy Act
This Privacy Notice is for California Residents of the clients of Resource Management, Inc. (“RMI”) and applies solely to those residents who are visitors, users, and others who reside in the State of California (“consumers” or “you”) when you visit the RMI website and provide information defined below or RMI performs its human resources-related services (collectively, RMI’s “Services”). RMI adopts this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
Information RMI Collects
RMI collects 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”). In particular, RMI has collected the following categories of personal information from consumers within the last twelve (12) months:
Category A – Identifiers
Examples: Name, postal address, Internet Protocol address, email address, Social Security number, driver’s license number, passport number, or other similar identifiers.
Category B – Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) Examples: Name, signature, Social Security number, address, telephone number, fax number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, bank account number, credit card number, debit card number, or any other financial information, physical illness, mental illness or disabilities.
Category C – Protected classification characteristics under California or federal law Examples: Age, ethnicity, citizenship, religion or creed, marital status, physical illness, mental illness or disabilities, gender, veteran status.
Category D – Commercial information Examples: Records of personal property.
Category F – Internet or other similar network activity Examples: Access history and information on your interaction with RMI’s application.
Category I – Professional or employment-related information Examples: Occupation, employer information.
Category J – Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) Examples: Education level, school attended.
RMI obtains the categories of personal information listed above from the following categories of sources:
- Directly from RMI’s clients or their agents. For example, from information RMI’s clients provide to RMI related to the Services for which they engage RMI.
- Directly from you. For example, through information RMI asks from you when RMI’s clients or their agents engage RMI’s Services.
- Directly and indirectly from you when using RMI’s Services or visiting RMI’s website. For example, usage details collected automatically in the course of your interaction with RMI’s platform or website.
Use of Personal Information
RMI may use or disclose the personal information it collects for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, to submit this information to or for RMI’s clients or their agents in the form of insurance application forms or request for information.
- To provide you with email alerts and other notices concerning RMI’s Services, or updates to your insurance application process or your employment situation.
- To improve RMI’s Services to you.
- For testing, research, analysis, and product development.
- As necessary or appropriate to protect the rights, property, or safety of RMI, its clients, or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of RMI’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by RMI is among the assets transferred.
RMI will not collect additional categories of personal information or use the personal information it collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
RMI may disclose your personal information to a third party for a business purpose. When RMI discloses personal information for a business purpose, it enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, RMI has disclosed the following categories of personal information for a business purpose:
- Category A: Identifiers.
- Category B: California Customer Records personal information categories.
- Category C: Protected classification characteristics under California or federal law.
- Category D: Commercial information.
- Category I: Professional or employment-related information.
- Category J: Non-public education information.
RMI discloses your personal information for a business purpose to the following categories of third parties:
- Its clients or their agents for which you have engaged in an employment relationship.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with RMI’s Services.
In the preceding twelve (12) months, RMI has not sold any personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that RMI disclose certain information to you about its collection and use of your personal information over the past 12 months. Once RMI receives and confirms your verifiable consumer request, it will disclose to you:
- The categories of personal information that RMI collected about you.
- RMI’s business or commercial purpose for collecting that personal information.
- The categories of third parties with whom RMI shares that personal information.
- The specific pieces of personal information that RMI collected about you (also called a data portability request).
Deletion Request Rights
You have the right to request that RMI delete any of your personal information that RMI collected from you and retained, subject to certain exceptions. Once RMI receives and confirms your verifiable consumer request, RMI will delete (and direct its service providers to delete) your personal information from its records, unless an exception applies.
RMI may deny your deletion request if retaining the information is necessary for it or its service providers to:
- Complete the transaction for which RMI collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of RMI’s ongoing relationship with you, or otherwise perform its Services for you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with RMI.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to RMI by email at email@example.com.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows RMI to reasonably verify you are the person about whom RMI collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows RMI to properly understand, evaluate, and respond to it.
RMI cannot respond to your request or provide you with personal information if it cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a verifiable consumer request does not require you to create an account with RMI. RMI will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
RMI will try to respond to a verifiable consumer request within 45 days of its receipt. If RMI requires more time (up to 90 days), it will inform you of the reason and extension period in writing. If you are a co-employee of RMI, then RMI will deliver its written response to the email that you provided in the RMI Center or to your work-site employer. If you are not an RMI co-employee, then RMI will deliver its written response by mail or electronically, at your option. Any disclosures that RMI provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response that RMI provides will also explain the reasons that it cannot comply with a request, if applicable. For data portability requests, RMI will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
RMI does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If RMI determines that the request warrants a fee, RMI will inform you why it made that decision and provide you with a cost estimate before completing your request.
RMI will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, RMI will not:
- Deny you use of its Services.
- Provide you a different level or quality of Services.
Changes to RMI’s Privacy Notice
RMI reserves the right to amend this Privacy Notice at its discretion and at any time. The date that this Privacy Notice was last updated is identified at the bottom of this page. You are responsible for periodically visiting the RMI website and this Privacy Notice to check for any changes.