Personnel Policy - Color Health

Scope of Policy

Scope of Policy

This Policy applies to the Personal Information of job applicants (including internal applicants, referrals, and candidates submitted by third-party agencies and recruiters), directors, current and former employees, independent contractors, consultants, and other individuals who currently work or previously have worked for Color (collectively, “Personnel,” “you,” or “your”), as well as any third parties whose information is provided to us in connection with any Personnel’s application for employment, employment, or engagement relationship with Color (e.g., emergency contacts, beneficiaries, and dependents). This Policy also applies to prospective candidates or leads who have expressed an interest in receiving news and details about future Color opportunities or other related communications.

Where we refer to “Personnel,” “employment,” or “engagement” in this Policy, we do so for convenience only, and these terms should not be interpreted as purporting to confer employment status on non-employees such as applicants or independent contractors to whom this Policy also applies. This Policy does not form part of any contract of employment or engagement, does not confer any employment status or contractual right on any Personnel, and does not place any contractual obligation on us.

This Policy does not apply to (a) our collection and processing of Personal Information from consumers and visitors to our website, which is governed by our general Privacy Policy; or (b) Protected Health Information (“PHI”) governed by HIPAA and our Notice of Privacy Practices.

Personal Information We Collect

Personal Information We Collect

We collect Personal Information in order to manage our relationship with you during the course of your application, employment, or engagement with us. The categories of Personal Information we collect include:

Information We Collect Directly From You

Identifiers, such as name, alias, postal address, signature, unique personal identifier, online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, date of birth, citizenship, username and password for our online recruitment system, and other similar identifiers.
Professional and Employment-Related Information, such as information contained in your resume or CV and other documents related to the application or recruitment process (e.g., cover letter, transcripts, certifications), job title, employee number, work-related documentation, performance reviews, disciplinary reports, and any other information you choose to voluntarily submit in connection with your application or employment.
Educational Information, such as educational history, qualifications, certifications, skills, and graduation dates.
Eligibility to Work Information, such as citizenship, work permit, or visa application information.
Financial Information, such as banking and direct deposit forms, salary, tax forms, and expense reimbursement records.
Information Related to Health Insurance and Other Benefits, which relates to application for, changes to, and enrollment in employee health and welfare benefits, life insurance, and retirement accounts, including details on contributions and deferral levels, names and legally required information of beneficiaries, and information about your spouse, partner, dependents, and emergency contacts.
Information About Family and Dependents, such as information collected for relocation, benefits enrollment, and emergency contact purposes.
Debarment and Suspension Information, as it relates to an award for a contract from a U.S. federal agency or relevant licenses.

Information Collected from Other Sources

Internet or Electronic Network Activity Information, including information about your interactions with our websites, applications, and recruitment system (such as pages visited and features used), along with technical data gathered via cookies, web beacons, and similar technologies.
Background Check Data, potentially including criminal records history, employment history, educational history, and/or compensation history, from employment screening agencies, publicly available registers or databases, former employers, and/or educational institutions (as allowed by applicable law).
References and Feedback, including information about your performance or conduct from references, other Color employees, clients or service providers, or current or former employers.
Publicly Available Information, from websites or social media (e.g., LinkedIn), including information you choose to submit in connection with your application.
Interview Feedback, from Color employees who interview you and provide feedback about your candidacy.

Sensitive Personal Information

We may collect sensitive or special category data about you, as permitted or required by applicable law. We consider the following categories as sensitive Personal Information:

Characteristics of Protected Classifications, such as age, gender, sex, marital status, race or ethnicity, sexual orientation, veteran status, disability status, and religious beliefs.

Citizenship or Immigration Information, such as information needed for visa purposes and right-to-work verification.

Health and Disability Information, such as disability status, requests for accommodation in the application or interview process, and health status information.

Social Security Number, Driver’s License, or State Identification Card Number.

Account Log-In Credentials, including required security or access codes, password, or credentials allowing access to an account.

We may also collect any sensitive data that you voluntarily disclose. If we request your explicit consent to collect sensitive data about you, you have the right to withdraw that consent at any time by contacting us at privacy@color.com.

Monitoring

We reserve the right to monitor the use of our premises, equipment, devices, computers, network, applications, software, and similar assets and resources. In the event such monitoring occurs, it may result in the collection of Personal Information about you. Any and all telephone conversations, electronic mail or transmissions, or internet access or usage by Personnel using any electronic device or system, including but not limited to the use of a computer, telephone, or radio may be subject to monitoring at any and all times by any lawful means. This is not meant to suggest that all Personnel will in fact be monitored, but to alert you that, when using Color equipment and resources, you should not have any expectation of privacy with respect to your use of such equipment or resources.

How We Use Your Personal Information

How We Use Your Personal Information

We limit our use of your Personal Information and aim to only collect and use it for specific, necessary reasons. We use your Personal Information for the following purposes:

Recruitment Purposes, such as communicating with you about your interest in a role with Color, job opportunities, and your applications; processing job applications; assessing your suitability for a role; identifying candidates for open roles; creating and managing the recruitment system, applications, and a database of interested individuals and leads; and conducting background checks after extending a conditional offer of employment.

Personnel Management, such as monitoring assignments, evaluating performance, making compensation determinations, training Personnel, communicating with you and responding to your requests, carrying out disciplinary and grievance investigations, and making and recording employment decisions.

Operational Purposes, such as distributing payroll and company benefits, updating Personnel files, conducting audits and training, reimbursing business expenses, providing IT support, facilitating participation in voluntary employee programs, and managing shifts, working hours, and attendance.

Benefits Administration, such as administering group health insurance benefits, wellness programs, retirement plans, life insurance, disability insurance, leave programs, and other Color-offered benefit programs.

Marketing Activities, such as using Personnel photos, videos, social media posts, and other content for internal and external marketing with your consent.

Statistical and Analytical Purposes, to understand and improve worker satisfaction, engagement, and performance.

Security and Debugging, such as ensuring the security and integrity of our systems and data, detecting and responding to fraud or potentially illegal activities, and debugging to identify and repair errors.

Pre-Boarding Communications, such as sending you information about the new hire and employee experience at Color before your first day.

Legal and Compliance Purposes, such as implementing internal policies, detecting and responding to suspected fraud or security incidents, protecting Color’s and others’ rights and property, cooperating with law enforcement investigations, and complying with applicable laws, regulations, legal processes, or governmental requests.

Health and Safety, to protect the health, safety, and vital interests of Personnel or another natural person.

Workplace Accommodations, as necessary and appropriate to provide reasonable workplace accommodations.

De-Identification and Aggregation, to create de-identified and/or aggregated information, such as demographic information or other analyses. De-identified and/or aggregated information is not Personal Information, and we may use and disclose such information for research, analytics, publications, and any other legally permissible purposes. We will not re-identify data we intend to maintain as de-identified.

With Your Consent, for other purposes that are clearly disclosed to you at the time you provide Personal Information or otherwise with your consent.

Contractual Performance, as necessary for the performance of a contract or to take steps at your request prior to entering into a contract (if you do not provide certain information when requested, we may not be able to perform the contract, such as paying you or providing a benefit).

How We Disclose Your Personal Information

How We Disclose Your Personal Information

We may disclose Personal Information to the following categories of recipients:

Within Color: We disclose Personal Information to Personnel and affiliates who need to know the information for the purposes described above, including Human Resources, Payroll, Legal, and Information Technology departments.

Authorized Third Parties and Service Providers: We may disclose your Personal Information to our service providers and vendors that assist us with talent acquisition, administration of payroll, pension, benefits, performance management, training, communication platforms, expense management, hosting, IT support, web analytics, and related services.

Professional Advisors: We may disclose information with our professional advisors, including accountants, auditors, lawyers, insurers, and bankers, as needed.

Law Enforcement, Government Authorities, and Regulators: We may disclose Personal Information to courts, government authorities, independent external advisers, and internal compliance and investigation teams if we believe such disclosure is in accordance with, or is otherwise required by, applicable law, regulation, or legal process.

Corporate Transactions: In connection with, or during negotiations of, any merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be disclosed, sold, or transferred as part of such a transaction, as permitted by law.

Other Third Parties: In certain limited circumstances, we may disclose Personal Information with your consent and at your direction, or to protect the rights and property of Color, our customers, and the public.

We may also disclose aggregated or de-identified information, which cannot reasonably be used to identify you. Color Processes, maintains, and uses this information only in a de-identified fashion and will not attempt to re-identify such information except as permitted by law.

Supplemental CALIFORNIA Privacy Policy

Supplemental CALIFORNIA Privacy Policy

TThis Supplemental California Privacy Policy (“California Addendum”) is provided pursuant to the California Consumer Privacy Act, as amended, and regulations promulgated thereunder (collectively, “the CA Privacy Law”). This California Addendum supplements this Policy for Personnel who are residents of California. In California, the term “Consumer” includes individuals acting in a business-to-business context.This California Addendum applies only to information governed by the CA Privacy Law, which does not include PHI governed by HIPAA.

Categories of Personal Information Collected, Used, and Disclosed

In the preceding 12 months, we have collected the following categories of Personal Information about Personnel: identifiers; characteristics of protected classifications under California or U.S. law; commercial information; internet and electronic network activity; geolocation data; audio, visual, or other sensory information; professional or employment-related information; education information; and sensitive Personal Information. We collect such information directly from you, indirectly from parties such as references and emergency contacts, automatically through surveillance equipment or other devices, and we also develop data during our interactions with you.

We collect, use, and disclose Personal Information for the business purposes described in Sections 4 and 5 of this Policy. We do not use or disclose your sensitive Personal Information for purposes other than those expressly permitted by the CA Privacy Law.

Disclosure of Personal Information for Business Purposes

In the preceding 12 months, we have disclosed the following categories of Personal Information for business purposes to the following categories of recipients:

Category of Personal Information	Categories of Recipients
Identifiers, such as name, mailing address, email address, and Social Security number	Recruitment and personnel management service providers, benefits providers, payroll providers, fraud detection and security service providers
Characteristics of protected classifications under state or federal law, such as gender and race	Recruitment and personnel management service providers, benefits providers
Commercial information, such as bank account and routing number	Recruitment and personnel management service providers, payroll providers
Internet or electronic network activity information	Fraud detection and security service providers
Geolocation data	Fraud detection and security service providers
Professional and employment-related information, such as resume, application, and performance reviews	Recruitment and personnel management service providers, benefits providers, immigration services providers, payroll providers
Sensitive Personal Information, such as race, ethnicity, veteran status, SSN, and account log-in credentials	Recruitment and personnel management service providers, benefits providers, payroll providers, government authorities, regulators, and operational service providers (e.g., data processing, cloud, security)

“Sales” and “Sharing” of Personal Information

Consistent with Color’s general Privacy Policy, we do not “sell” or “share” Personnel Personal Information as those terms are defined under the CA Privacy Law. We do not process sensitive Personal Information in a manner that is deemed a “sale” or “sharing.” We also do not have actual knowledge of any “sales” or “sharing” of the Personal Information of minors under 16 years of age.

California Privacy Rights

Subject to meeting the requirements for verification and limitations permitted by the CA Privacy Law, Color provides Personnel residing in California with the following privacy rights:

Right to Know. You have the right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources, our business or commercial purposes for collecting the information, and the categories of recipients to which we disclose it. You also have the right to request the specific pieces of Personal Information we have collected about you, subject to certain exceptions.

Right to Delete. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions.

Right to Correct. If you believe the Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.

Right to Opt Out. You have the right to opt out of the sale of your Personal Information and to request that we do not share your Personal Information for targeted advertising. As stated above, we do not sell or share Personnel Personal Information.

Right to Limit Use of Sensitive Personal Information. We only Process sensitive Personal Information for purposes of providing services and other limited purposes (e.g., compliance with law and legal process, defending claims) for which you are not entitled to limit our retention and use.

Right to Non-Discrimination. We will not discriminate or retaliate against you for your exercise of your California Privacy Rights.

Automated Decision Making / Profiling. We do not use automated decision-making tools or profiling to make employment decisions about Personnel or candidates. All hiring and employment decisions involve human review.

How to Exercise Your California Privacy Rights

To submit a request to exercise any of these rights, or to submit a request as an authorized agent, please contact us by calling 844-352-6567 or by emailing: privacy@color.com. We do not accept or process requests through other means (e.g., fax, chats, social media). You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed.

Response Timing and Formats

We endeavor to respond to California Privacy Rights requests within the applicable timeframe under the CA Privacy Law. If we require more time, we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded.

Color Health, Inc. Personnel and Candidate Privacy Policy