C2 Fusion LLC and its affiliates ("C2 Fusion LLC," "we," "our," and/or "us") highly prioritize the privacy of individuals engaging with our websites, app, and associated content and/or services (collectively referred to as our "Services"). This Privacy Notice serves to elucidate the processes of information collection, usage, and sharing concerning users of our Services ("Users" or "you"). Through the utilization of our Services, you explicitly consent to the collection, usage, disclosure, and processing of your information in accordance with the guidelines outlined in this Privacy Notice.

It is crucial to note that in addition to this Privacy Notice, your utilization of our Services is also governed by our Terms of Use (https://www.c2fusion.com/veteran-services/terms-of-use) and any supplementary agreements that may be entered into with us. These collectively establish the framework within which your engagement with our Services is conducted.

Information We Collect Automatically When You Use Our Services

We retain the capacity to gather diverse information about you and/or your devices from multiple sources, as outlined below.

Information You Provide to Us

Registration Information
In the event that you opt to create an account, register for the utilization of our Services, or subscribe to emails or other updates, we may request fundamental contact details, such as your name, email address, phone number, or mailing address. Additionally, during the registration process for our Services, we may solicit specific demographic details, encompassing age, gender, income, or marital status. Furthermore, the collection extends to personal health information (PHI) and identification particulars, such as the social security number. It is noteworthy that the preponderance of the information we gather is directly provided by you, encapsulating all the particulars enumerated herein.

Communications
In instances where you engage with us directly, there exists the possibility of collecting supplementary information from you. Specifically, when you initiate contact with our veteran support team, we may solicit details such as your name, email address, mailing address, phone number, or additional contact information to facilitate identity verification and communication. Additionally, the contents of any message or attachments transmitted to us, along with information submitted through our forms or questionnaires, may be stored for reference.

Job Applications
In the event of a job application with us, pertinent information may be collected, including but not limited to your name, phone number, email address, position sought, job history, education history, references, a cover letter, and analogous details.

Information We Collect Automatically When You Use Our Services

Device Information
We retain the authority to collect information pertaining to the devices and software employed in accessing our Services. This encompasses details such as your IP address, web browser type, device identifiers, operating system version, and other similar information.

Usage Information

In order to comprehend your utilization patterns of our Services and to enhance their functionality, we may gather data regarding your interactions with the Services. This incorporates details such as crash reports, session durations and timestamps, the specific pages or other content you peruse, and any searches you initiate.

Cookies and Similar Technologies
Both we and our third-party collaborators retain the ability to collect information through the utilization of cookies, pixel tags, or analogous technologies. Cookies, in this context, refer to small text files comprising a string of alphanumeric characters. It is pertinent to note that we may deploy both session cookies, which vanish upon browser closure, and persistent cookies, which persist after the browser is closed and may be utilized by your browser during subsequent visits to our Services.

Information We Receive from Other Sources

We may receive information about you from other sources, including third parties that help us update, expand, and analyze our records, identify new customers, or detect or prevent fraud. We may also receive information about you from social media platforms, for example when you interact with us on those platforms or access our social media content. What information we receive from third parties is governed by the privacy settings, policies, and/or procedures of the relevant organizations, and we encourage you to review them.

De-Identified Data

The utilization of de-identified personal data may be employed in fulfilling the contracted services requested by our clients. This denotes information that has undergone a process making it unlinkable to a specific individual or household. C2 Fusion LLC steadfastly upholds a commitment to retaining such data in its de-identified state as deemed necessary to safeguard client privacy. Clear instructions are provided to employees, explicitly prohibiting attempts to associate or infer characteristics about a particular individual using de-identified data. Additionally, any processors handling de-identified data are mandated to adhere to these stipulations. 

How We Use the Information We Collect

We may use the information we collect:

• To furnish, uphold, refine, and enrich our Services;

•  To comprehend and scrutinize your utilization patterns of our Services, facilitating the development of new products, services, features, and functionality;

• To assess and process applications submitted for employment opportunities with us;

• To engage in communication with you, delivering updates, relevant information about our Services, responding to inquiries, and furnishing user support;

• For marketing and advertising endeavors, encompassing the creation and provision of promotional and advertising materials tailored to your potential interest;

• To identify and mitigate instances of fraud, and address matters related to trust and safety;

• For compliance imperatives, involving the enforcement of our Terms of Service and other legal rights, or as mandated by applicable laws and regulations, or pursuant to requests from any judicial process or governmental agency; and

• For other explicitly stated purposes, offering specific notice at the time the information is collected.

Storage

Personal Data, encompassing details like your name, email address, Social Security number, PHI, street address, and telephone number, is securely stored and safeguarded behind a firewall within a system compliant with Health Insurance Portability and Accountability Act regulations (HIPAA).

Payment

The administration of our payment processing solution is entrusted to Stripe. Within Stripe's platform, users have the capability to execute one-time payments or opt for recurring payments until the balance is settled in full. The Payment Card Industry Data Security Standard (PCI-DSS) serves as a protective measure for your payment card information during processing by Stripe. It is crucial to emphasize that the payment process is exclusively monitored by Stripe, and C2 Fusion LLC does not retain or store any of your payment card information.

How We Share the Information We Collect

Service Providers

Any information collected may be shared with service providers engaged in facilitating the provision of our Services. These service providers are strictly authorized to utilize the information solely for the purpose of assisting us in delivering our Services and are expressly prohibited from using it for their own purposes.

Data collected through the short code text (SMS) program will not be shared with any third parties for marketing purposes. 

These Service Providers include:

SuiteDash, a business management cloud solution company. SuiteDash’s Privacy Policy can be found here: https://suitedash.com/privacy-policy/

Our Affiliates

We may share your information with our affiliates, subsidiaries, and representatives as needed to provide our Services.

Our Partners

The utilization of analytics services is employed for the collection and processing of specific analytics data. These services may extend their data collection to encompass information about your interactions with other websites, apps, and online resources. Additionally, collaborations may exist with third-party advertising partners, potentially including:

Google
Google's services may be utilized for the collection and processing of analytics data, as well as for placing ads that we believe may be of interest to our users and potential users. Google Privacy and Terms

Facebook
Facebook's services may be engaged for the placement of ads that we believe may be of interest to our users and potential users. Meta [Facebook] Data Policy – Facebook Advertising

LinkedIn
The services provided by LinkedIn may be utilized for the placement of ads that we believe may be of interest to our users and potential users. Additionally, these services may be employed to advertise job openings to potential employees. LinkedIn Privacy Policy – LinkedIn Cookie Policy

Kindly be aware that updates may be communicated to you periodically to furnish you with the latest information. For more details about your options concerning how these partners utilize your information, please refer to the 'Your Choices' section below.

As Required by Law and Similar Disclosures

We reserve the right to access, retain, and disclose your information if we deem such actions necessary or appropriate under the following circumstances: (a) to comply with law enforcement requests and legal processes, including but not limited to court orders or subpoenas; (b) to respond to your requests; or (c) to safeguard your, our, or others' rights, property, or safety. Specifically, relevant information may be disclosed to the appropriate third parties if you post any content on or through the Services that is deemed illegal, threatening, or objectionable.

Merger, Sale, or Other Asset Transfers

Your information may be transferred to service providers, advisors, potential transactional partners, or other third parties in association with the evaluation, negotiation, or finalization of a corporate transaction. This could include scenarios where we are acquired by or merged with another company, or where we sell, liquidate, or transfer all or a portion of our assets. The subsequent use of your information following any such events will be regulated by the provisions outlined in this Privacy Policy as effective at the time the relevant information was initially collected.

Consent

Furthermore, your information may be disclosed with your explicit permission. For instance, when you engage in direct payment, authenticate your payment card, or access specific features on our website, there may be a request for your private information. By participating in such actions, it is inferred that you consent to the collection of this information, with its utilization specifically directed towards the purposes outlined in this Privacy Policy and no other. Should there arise a need to employ your information for a different purpose at any time, express consent will be sought. 

Informed Consent to be Contacted by Telephone

By registering on the Site, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing (where you supply your telephone number to us) in accordance with the Rule and applicable state do-not-call regulations. In addition, where you provide “prior express written consent” within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”), you consent to receive telephone calls, including artificial voice and pre-recorded messages and/or calls delivered via automated technology, to the telephone number(s) that you provided. You understand and agree that this consent applies even if your telephone number is a wireless number. You further acknowledge and agree that you are not required to consent to the above-stated terms to gain access to the C2 Fusion LLC’s Services.

Your Choices

Our Communications

At intermittent intervals, you may receive marketing or other informational email messages from us. Should you wish to discontinue receiving our promotional and informational emails, you can opt-out by utilizing the provided link in the emails. It is important to note that users may still receive administrative messages deemed necessary for servicing user accounts even after opting out of promotional messages.

Cookies

The majority of web browsers afford you the ability to regulate cookies through the browser settings. It is essential to be aware that opting out and refusing the use of specific cookies may result in a diminished experience on our Services, and certain features may not function as intended, depending on the type of cookie. To acquire further insights into cookies, you may visit www.aboutcookies.org or www.allaboutcookies.org.  

Our Partners
For a comprehensive understanding of Google's privacy practices and options regarding the utilization of your information, you can refer to Google's website. Additionally, you have the option to install the Google Analytics Opt-out Browser Add-on. Meta, the parent company of Facebook, provides insights into how it utilizes information collected through our Services in its Data Policy. Specific details about Facebook's advertising practices can be found on its website.

Several of our advertising partners are affiliated with either the Network Advertising Initiative or the Digital Advertising Alliance. You can explore these organizations' websites to understand how you may opt out of receiving personalized web-based ads from their member companies. Furthermore, accessing settings provided by your mobile operating system allows you to limit ad tracking. If you have inquiries about your choices regarding our business partners in general, feel free to contact us at compliance@c2fusion.com.

Third-Party Content
Our Services may feature links to other websites, products, or services that are not owned or operated by us. It is important to note that we are not responsible for the content or privacy practices of these third parties. This Privacy Policy does not extend to your activities on these third-party services or any information you disclose to them. We strongly recommend reviewing their privacy policies before sharing any information with them.

Security
We diligently employ reasonable measures to safeguard your information, utilizing administrative, technological, and physical safeguards crafted to enhance the security of the information we uphold. These measures are intended to prevent accidental loss, unauthorized access or use, and any other inappropriate or unlawful processing of your information. Nonetheless, it's important to acknowledge that, as no information system can be entirely immune, we cannot provide an absolute guarantee of the security of your information.

Children’s Privacy
We do not knowingly collect, retain, or utilize personal information from children under 18 years of age, and none of our Services are directed toward children. If you become aware that a child has furnished us with personal information in contravention of this Privacy Policy, please notify us promptly at compliance@c2fusion.com.

International Visitors

Our Services are hosted in the United States and are intended for visitors located within the United States. If you opt to utilize the Services from the European Union or other regions of the world with laws governing data collection and use that may diverge from U.S. law, please be aware that your personal information is being transferred outside of those regions to the United States for storage and processing. Additionally, we may transfer your data from the U.S. to other countries or regions in connection with data storage and processing, fulfilling your requests, and operating the Services. By engaging with our Services, you express your consent to the transfer, storage, and processing of your information in accordance with the terms outlined in this Privacy Policy.

Changes to this Privacy Policy

Any modifications to the Privacy Policy will be posted on this page, with the revised version becoming effective upon posting. In the event of material changes, we may notify you through a notice posted on our website or through other means. We strongly encourage you to periodically review this Privacy Policy to stay informed about our privacy practices.

Last updated: 1/27/2024

C2 Fusion LLC collects Personal Data from US residents and comply with the consumer privacy laws of California, Colorado, Connecticut, Utah, and Virginia (“US Privacy Laws”). This Detailed US Privacy Notice applies to US residents (“users,” “you,” or “your”). 

For the purposes of this Detailed US Privacy Notice, “Personal Data” means information that is linked or reasonably linkable to a particular individual or household. However, the following categories of information are not Personal Data: 

• Publicly available information; 

• Deidentified or aggregated data; or 

• Information otherwise excluded from the scope of US Privacy Laws. 

This Privacy Notice provides the following information to US residents: 

• Categories of Personal Data we collect; 

• Purposes for which we use Personal Data; 

• Categories of Personal Data we disclose to third parties; 

• Categories of third parties to which we disclose Personal Data; and 

• How US residents can exercise their rights under US Privacy Laws: 

• The right to access, correct, or delete Personal Data; 

• The right to obtain a portable copy of Personal Data; 

• The right to limit the use of sensitive Personal Data in certain circumstances; 

• The right to opt out of targeted advertising, sales of Personal Data, or profiling; and 

• The right to appeal our decisions about your requests. 

Categories of Non-Sensitive Personal Data 

Below are the categories of Personal Data C2 Fusion LLC collects about US residents and whether and how they are disclosed to third parties. 

We collect Non-Sensitive Personal Data from the following sources:  

• Directly from our users 

Category of Non-Sensitive Personal Data: Identifiers

Examples 

Identifiers may contain the following: name, address, social security number, driver’s license number, email address, telephone number, date of birth 

Purpose(s) for Collection 

Providing VA disability claim evidence consulting services and conducting internal research and development to improve these services. 

Targeted Advertising 

We do not engage in targeted advertising or disclose this information for targeted advertising purposes 

Sale 

This information is not sold to third parties 

Other Disclosures 

This information is not otherwise disclosed to third parties 

Retention Period 

We typically retain client data for a period of six years to protect our clients’ interests and to comply with federal regulations such as HIPAA or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services. 

Category of Non-Sensitive Personal Data: Personal Characteristics

Examples 

Personal Characteristics may contain the following: age, gender, height, weight 

Purpose(s) for Collection 

Providing VA disability claim evidence consulting services and conducting internal research and development to improve these services. 

Targeted Advertising 

We do not engage in targeted advertising or disclose this information for targeted advertising purposes 

Sale 

This information is not sold to third parties 

Other Disclosures 

This information is not otherwise disclosed to third parties 

Retention Period 

We typically retain client data for a period of six years to protect our clients’ interests and to comply with federal regulations such as HIPAA or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services. 

Category of Non-Sensitive Personal Data: Commercial Data

Examples 

Commercial Data may contain the following: statements from clients regarding ownership of assets and income.

Purpose(s) for Collection 

Providing VA disability claim evidence consulting services and conducting internal research and development to improve these services. 

Targeted Advertising 

We do not engage in targeted advertising or disclose this information for targeted advertising purposes.

Sale 

This information is not sold to third parties.

Other Disclosures 

This information is not otherwise disclosed to third parties.

Retention Period 

We typically retain client data for a period of six years to protect our clients’ interests and to comply with federal regulations such as HIPAA or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services. 

Category of Non-Sensitive Personal Data: Internet/Electronic Activity

Examples 

Internet/Electronic Activity may contain the following: cookie ID, device ID.

Purpose(s) for Collection 

To optimize marketing and client experience.

Targeted Advertising 

We do not engage in targeted advertising or disclose this information for targeted advertising purposes.

Sale 

This information is not sold to third parties.

Other Disclosures 

This information is not otherwise disclosed to third parties.

Retention Period 

We typically retain client data for a period of six years to protect our clients’ interests and to comply with federal regulations such as HIPAA or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services. 

Category of Non-Sensitive Personal Data: Imprecise Geolocational Data

Examples 

Imprecise Geolocational Data may contain the following: IP address. 

Purpose(s) for Collection 

To optimize marketing, client experience, and to comply with relevant state laws. 

Targeted Advertising 

We do not engage in targeted advertising or disclose this information for targeted advertising purposes. 

Sale 

This information is not sold to third parties. 

Other Disclosures 

This information is not otherwise disclosed to third parties. 

Retention Period 

We typically retain client data for a period of six years to protect our clients’ interests and to comply with federal regulations such as HIPAA or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services. 

Category of Non-Sensitive Personal Data: Professional Data

Examples 

Professional Data may contain the following: statements from clients as to employment history, statements as to income.

Purpose(s) for Collection 

Providing VA disability claim evidence consulting services and conducting internal research and development to improve these services.

Targeted Advertising 

We do not engage in targeted advertising or disclose this information for targeted advertising purposes.

Sale 

This information is not sold to third parties.

Other Disclosures 

This information is not otherwise disclosed to third parties.

Retention Period 

We typically retain client data for a period of six years to protect our clients’ interests and to comply with federal regulations such as HIPAA or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services. 

Category of Non-Sensitive Personal Data: Educational Data

Examples 

Educational Data may contain the following: client statements as to educational history. 

Purpose(s) for Collection 

Providing VA disability claim evidence consulting services and conducting internal research and development to improve these services. 

Targeted Advertising 

We do not engage in targeted advertising or disclose this information for targeted advertising purposes. 

Sale 

This information is not sold to third parties.

Other Disclosures 

This information is not otherwise disclosed to third parties.

Retention Period 

We typically retain client data for a period of six years to protect our clients’ interests and to comply with federal regulations such as HIPAA or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services. 

Categories of Sensitive Personal Data 

The table below outlines the categories of Sensitive Personal Data C2 Fusion LLC collects about US residents and whether they are disclosed to third parties. C2 Fusion LLC obtains affirmative consent from US residents to process Sensitive Personal Data to the extent required by US Privacy Laws.  

We collect Sensitive Personal Data from the following sources:  

• Directly from our users.

Category of Sensitive Personal Data: Government ID Data

Examples 

Government ID Data may contain the following: Social Security number, driver’s license number.

Purpose(s) for Collection 

Providing VA disability claim evidence consulting services and conducting internal research and development to improve these services.

Targeted Advertising 

We do not engage in targeted advertising or disclose this information for targeted advertising purposes.

Sale 

This information is not sold to third parties.

Other Disclosures 

This information is not otherwise disclosed to third parties.

Retention Period 

We typically retain client data for a period of six years to protect our clients’ interests and to comply with federal regulations such as HIPAA or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services. 

Category of Sensitive Personal Data: Sensitive Category Data

Examples 

Sensitive Category Data may contain the following: race and health data.

Purpose(s) for Collection 

Providing VA disability claim evidence consulting services and conducting internal research and development to improve these services.

Targeted Advertising 

We do not engage in targeted advertising or disclose this information for targeted advertising purposes.

Sale 

This information is not sold to third parties.

Other Disclosures 

This information is not otherwise disclosed to third parties.

Retention Period 

We typically retain client data for a period of six years to protect our clients’ interests and to comply with federal regulations such as HIPAA or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services. 

Use of Personal Data

We use Personal Data for the purposes described above. Personal Data may also be used or disclosed as otherwise permitted or required by applicable law. 

Disclosing Personal Data

We share Personal Data with the following categories of third parties: 

• Processors: We use processors to securely handle Personal Data on our behalf and only on our instructions. These companies may not use your Personal Data for their own purposes. 

See above for more details about how different categories of Personal Data are disclosed. 

We do not sell Personal Data to anyone. 

Exercising Your Personal Data Rights

US residents have the following rights under US Privacy Laws: 

• The rights to access, correct, or delete Personal Data; 

• The right to obtain a portable copy of Personal Data;  

• The right to limit the use of Sensitive Personal Data in certain circumstances; 

• The rights to opt out of targeted advertising, sales of personal data, or profiling;  

• The right not to receive discriminatory treatment for exercising your privacy rights; and 

• The right to appeal our decisions about your requests if you disagree with them. 

If you are a US resident, you can submit a request to exercise your personal data rights under US Privacy Laws by sending an email to compliance@c2fusion.com with the subject line “Privacy Rights Request”. 

To safeguard your privacy, the authentication of your identity may be necessary before responding to your privacy rights request. As part of this process, additional information, including the last four digits of your social security number, may be requested. Failure to complete the verification process may result in an inability to process your request. Any information provided for authentication purposes will be exclusively utilized for processing your privacy rights request and not for any other purpose. Please note that privacy rights requests submitted through alternative means are not accepted or processed.

Our commitment is to respond to your privacy rights request within 45 days. However, in specific instances, we may notify you if an additional 45 days is required to address your request. Should there be suspicion of fraudulent or malicious activity associated with your account, we may postpone taking action on your request until proper verification of your identity and the authenticity of the request can be conducted. Additionally, it is essential to acknowledge that certain exceptions apply to each of the enumerated rights.

We retain the right to refuse the processing of requests from U.S. residents that are evidently unfounded, excessive, or repetitive. In such cases, we may also exercise the option to impose a reasonable fee.

Notice of Right to Limit the Use of Sensitive Personal Information

You possess the right to restrict certain uses of Sensitive Personal Data. Specifically, you can instruct companies not to utilize Sensitive Personal Data unless it is necessary to provide the goods or services you have requested or for other exempt purposes. 

It's important to note that we exclusively employ Sensitive Personal Data for purposes that fall under exemptions from this right. These purposes include providing you with requested goods or services, detecting and preventing security incidents, and verifying the quality of our goods and services. The comprehensive list of these exempt purposes is outlined in California Code of Regulations, Title 11, Section 7027(m).

Children's Data

We do not knowingly collect or use the Personal Information of children under 18. If you believe that we have collected the Personal Information of a child under 18, please contact us at compliance@C2fusion.com. 

Authorized Agent Requests

You have the option to appoint an authorized agent to make a rights request on your behalf. The authorized agent can submit the request using the same method outlined in the section titled "Exercising Your Personal Data Rights." It is possible that we may necessitate verification of your authorized agent's authority, in addition to the information required for verifying your identity.

Last updated: 1/27/2024

C2 Fusion LLC collects Personal Information from current and past employees (‘Employees’), Contractors, and Applicants in compliance with the California Consumer Privacy Act and related laws and regulations (“California privacy laws”). This California HR Privacy Notice applies to California Employees, Contractors, and Applicants (“you” or “your”).

“Personal Information” means information that is linked or reasonably linkable to a particular individual or household. However, the following categories of information are not Personal Information:

●Publicly available information;

●Deidentified or aggregated data; or

●Information otherwise excluded from the scope of California privacy laws.

This Privacy Notice provides the following information to California Employees, Contractors, and Applicants:

●Categories of Personal Information we collect;

●Purposes for which we use Personal Information;

●Categories of Personal Information we disclose to third parties;

●Categories of third parties to which we disclose Personal Information; and

●How Employees, Contractors, and Applicants can exercise their rights under California privacy laws:

o   The rights to access, correct, or delete Personal Information;

o   The right to limit the use of sensitive Personal Information in certain circumstances; and

○The rights to opt out of targeted advertising, sales of Personal Information, or profiling.

Categories of Non-Sensitive Personal Information

Below you will find an outline of the categories of Personal Information may C2 Fusion LLC collect about Employees, Contractors, and Applicants, and whether and how they are disclosed to third parties.

We collect Non-Sensitive Personal Information from the following sources:

• Directly from our Employees, Contractors, and Applicants

• From our business partners (“business partners” are companies that we have a pre-existing commercial relationship with)

Category of Personal Information: Identifiers

Examples

Identifiers may contain the following: Names, physical addresses, email addresses, telephone number, birthday, dependents.

Purpose(s) for Collection

To comply with EEO-1 filing requirements, to verify employment eligibility, to conduct statistical analysis, to provide personalized HR services and improvement of employment experience, and to comply with and/or provide accommodation under Title VII of the Civil Rights Act of 1964, the Age Discrimination in Employment Act, the Americans with Disabilities Act, the Family Medical Leave Act and other state and federal laws.

Targeted Advertising

We do not engage in targeted advertising or disclose this information for targeted advertising purposes.

Sale

This information is not sold to third parties.

Other Disclosures

This information may be disclosed to Processors and Affiliates. We disclose Identifiers to enable our processors to provide customer service on our behalf, to debug our products and identify errors that may impair functionality, to conduct research and development to improve our existing services and employment experience.

Retention Period

We retain this information throughout the employment period and for 6 years post-termination or as required by law

Category of Personal Information: Personal Characteristics

Examples

Personal Characteristics may contain the following: age, gender, ethnicity, citizenship, veteran status, disability status, marital status, dependents, emergency contact, medical providers, previous aliases, pronouns, predictive index assessment.

Purpose(s) for Collection

To comply with EEO-1 filing requirements, to verify employment eligibility, to conduct statistical analysis, to provide personalized HR services and improvement of employment experience, and to comply with and/or provide accommodation under Title VII of the Civil Rights Act of 1964, the Age Discrimination in Employment Act, the Americans with Disabilities Act, the Family Medical Leave Act and other state and federal laws.

Targeted Advertising

We do not engage in targeted advertising or disclose this information for targeted advertising purposes.

Sale

This information is not sold to third parties.

Other Disclosures

This information may be disclosed to Processors and Affiliates. We disclose Personal Characteristics to enable our processors to provide customer service on our behalf, to debug our products and identify errors that may impair functionality, to conduct research and development to improve our existing services and employment experience.

Retention Period

We retain this information throughout the employment period and for 6 years post-termination or as required by law.

Category of Personal Information: Imprecise Geolocational

Examples

Imprecise Geolocational may contain the following: IP address.

Purpose(s) for Collection

To improve and test our systems and conduct oversight of computer usage.

Targeted Advertising

We do not engage in targeted advertising or disclose this information for targeted advertising purposes.

Sale

This information is not sold to third parties.

Other Disclosures

This information may be disclosed to Processors and Affiliates. We disclose Imprecise Geolocational to enable our processors to provide customer service on our behalf, to debug our products and identify errors that may impair functionality, to conduct research and development to improve our existing services and employment experience.

Retention Period

We retain this information throughout the employment period and for 6 years post-termination or as required by law.

Category of Personal Information: Sensory Information

Examples

Sensory Information may contain the following: Profile picture, video recordings, voice recordings, computer usage.

Purpose(s) for Collection

Comply with statutory obligations, provide personalized HR services, improve employment experience, improve and test our systems, conduct oversight of computer usage.

Targeted Advertising

We do not engage in targeted advertising or disclose this information for targeted advertising purposes.

Sale

This information is not sold to third parties.

Other Disclosures

This information may be disclosed to Processors and Affiliates. We disclose Sensory Information to enable our processors to provide customer service on our behalf, to debug our products and identify errors that may impair functionality, to conduct research and development to improve our existing services and employment experience.

Retention Period

We retain this information throughout the employment period and for 6 years post-termination or as required by law.

Category of Personal Information: Professional Information

Examples

Professional Information may contain the following: Employment history, salary, any information provided on a resume or application for employment.

Purpose(s) for Collection

To assess qualifications, provide personalized HR services, improve employment experience, conduct statistical analysis.

Targeted Advertising

We do not engage in targeted advertising or disclose this information for targeted advertising purposes.

Sale

This information is not sold to third parties.

Other Disclosures

This information may be disclosed to Processors and Affiliates. We disclose Professional Information to enable our processors to provide customer service on our behalf, to debug our products and identify errors that may impair functionality, to conduct research and development to improve our existing services and employment experience.

Retention Period

We retain this information throughout the employment period and for 6 years post-termination or as required by law.

Category of Personal Information: Educational Information

Examples

Educational Information may contain the following: Degrees and certificates or course work, any information provided on a resume or application for employment.

Purpose(s) for Collection

To assess qualifications, provide personalized HR services, improve employment experience, conduct statistical analysis.

Targeted Advertising

We do not engage in targeted advertising or disclose this information for targeted advertising purposes.

Sale

This information is not sold to third parties.

Other Disclosures

This information may be disclosed to Processors and Affiliates. We disclose Educational Information to enable our processors to provide customer service on our behalf, to debug our products and identify errors that may impair functionality, to conduct research and development to improve our existing services and employment experience.

Retention Period

We retain this information throughout the employment period and for 6 years post-termination or as required by law.

Categories of Sensitive Personal Information

The details below outline the categories of Sensitive Personal Information C2 Fusion LLC collects about Employees, Contractors, and Applicants and whether they are disclosed to third parties.

We collect Sensitive Personal Information from the following sources:

• Directly from our Employees, Contractors, and Applicants.

Category of Sensitive Personal Information: Government ID Information

Examples

Government ID Information may contain the following: Social Security Number, any form of ID listed on I-9 (passport, driver’s license, ID card, birth certificate, etc.).

Purpose(s) for Collection

To comply with EEO-1 filing requirements, to verify employment eligibility, to conduct statistical analysis, and to comply with and/or provide accommodation under Title VII of the Civil Rights Act of 1964, the Age Discrimination in Employment Act, the Americans with Disabilities Act, the Family Medical Leave Act and other state and federal laws.

Targeted Advertising 

We do not engage in targeted advertising or disclose this information for targeted advertising purposes.

Sale 

This information is not sold to third parties.

Other Disclosures 

This information may be disclosed to Processors and Affiliates. We disclose Government ID Information to enable our processors to provide customer service, such as payroll and benefits services, on our behalf.

Retention Period 

We retain this information throughout the employment period and for 6 years post-termination or as required by law.

Category of Sensitive Personal Information: Sensitive Category Information

Examples

Sensitive Category Information may contain the following: If the candidate/employee/contractor provides it, information on race, ethnicity, religious beliefs, mental or physical health diagnosis which may include genetic information, sexual orientation, sex life, or citizenship or immigration status.

Purpose(s) for Collection

To comply with EEO-1 filing requirements, to verify employment eligibility, to conduct statistical analysis, and to comply with and/or provide accommodation under Title VII of the Civil Rights Act of 1964, the Age Discrimination in Employment Act, the Americans with Disabilities Act, the Family Medical Leave Act and other state and federal laws.

Targeted Advertising

We do not engage in targeted advertising or disclose this information for targeted advertising purposes.

Sale

This information is not sold to third parties.

Other Disclosures

This information may be disclosed to Processors and Affiliates. We disclose Sensitive Category Information to enable our processors to provide customer service, such as payroll and benefits services, on our behalf.

Retention Period

We retain this information throughout the employment period and for 6 years post-termination or as required by law.

Category of Sensitive Personal Information: Communication Data

Examples

Communication Data may contain the following: All the content of computer usage on company equipment and systems.

Purpose(s) for Collection

Compliance with statutory obligations, security, performance evaluation, quality assurance and control, and improvement of employment experience, debugging our products and/or services, conducting research and development to improve our products/services.

Targeted Advertising 

We do not engage in targeted advertising or disclose this information for targeted advertising purposes.

Sale

This information is not sold to third parties.

Other Disclosures 

This information may be disclosed to Processors and Affiliates. We disclose Communication Data to enable our processors to provide customer service, to debug our products and/or services, to maintain digital security, and to conduct research and development to improve our products/services and employment experience.

Retention Period

We retain this information throughout the employment period and for 6 years post-termination or as required by law.

Category of Sensitive Personal Information: Financial Information

Examples

Financial Information may contain the following: Bank account information needed for direct deposit payroll processing and 401K contributions.

Purpose(s) for Collection 

To perform payroll functions including direct deposit and 401K contributions.

Targeted Advertising

We do not engage in targeted advertising or disclose this information for targeted advertising purposes.

Sale

This information is not sold to third parties.

Other Disclosures

This information may be disclosed to Processors and Affiliates. We disclose Financial Information to enable our processors to provide customer service, such as payroll and benefits services, on our behalf.

Retention Period 

We retain this information throughout the employment period and for 6 years post-termination or as required by law.

Use of Personal Information

We use Personal Information for the purposes described above. Other examples of how we may use your Personal Information within C2 Fusion LLC include:

• Publishing Employees’ work contact information in an intra-company directory for other Employees to view.

• Disclosing applicants’ submitted Personal Information with our HR department and other employees to process applications.

• Creating profiles of contractors’ performance based on work product.

Personal Information may also be used or disclosed as otherwise permitted or required by applicable law.

Disclosing Personal Information

We disclose Personal Information to the following categories of third parties:

Processors (also referred to as “Service Providers” or “Contractors” in California law): We use processors to securely handle Personal Information on our behalf for our business purposes and only on our instructions. California privacy laws and our contracts with these companies prevent them from using your Personal Information for their own purposes.

Affiliates: We may disclose your information to our affiliates, subsidiaries, and representatives as part of our relationship with you.

Other Employees, Contractors, and Applicants: Content you post on our systems may be displayed to other Employees, Contractors, and Applicants as appropriate.

See above for more details about how different categories of Personal Information are disclosed.

We do not sell Personal Information to anyone. We do not share Personal Information for advertising purposes.

Exercising Your Personal Information Rights

California Employees, Contractors, and Applicants have the following rights under California privacy laws:

The right to know the Personal Information we have collected about them, including the categories of sources from which we collected the Personal Information, the purpose(s) for collecting, selling, or sharing your Personal Information, and the categories of third parties to whom we have disclosed your Personal Information.

• The rights to correct, or delete Personal Information;

• The right to limit the use of Sensitive Personal Information in certain circumstances;

• The rights to opt out of targeted advertising, sales of Personal Information, or profiling; and

• The right not to receive discriminatory treatment for exercising their privacy rights.

If you are a California Employee, Contractor, or Applicant, you can submit a request to exercise your Personal Information rights under California privacy laws by emailing compliance@c2fusion.com with the subject line “California Privacy”.

To protect your privacy, we may need to authenticate your identity before we respond to your rights request. We will verify your identity by sending an email to your email address on file with a link to click. We may ask you for additional information as part of this process, including the last 4 digits of your social security number, if we have that number in our records. If you do not complete the verification process, we may be unable to process your request. Any information you provide to authenticate your identity will only be used to process your rights request and not for any other purpose. Please be aware that we do not accept or process rights requests submitted through other means.

We will respond to your rights request within 45 days, though in certain cases we may inform you that we will need up to another 45 days to act on your request. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic. Also note that each of the rights are subject to certain exceptions.

We reserve the right to decline to process, or charge a reasonable fee for, requests from a Employee, Contractor, or Applicant that are manifestly unfounded, excessive, or repetitive.

Notice of Right to Limit the Use of Sensitive Personal Information

You have the right to limit some uses of Sensitive Personal Information. You may direct companies not to use Sensitive Personal Information except as necessary to provide goods or services you have requested or other exempt purposes.

However, we only use Sensitive Personal Information for purposes that are exempt from this right, such as to provide you with goods or services you have requested, to detect and prevent security incidents, or verifying the quality of our goods and services. The full list of these exempt purposes are specified in California Code of Regulations, Title 11, Section 7027(m).

Children’s Data

We do not knowingly collect or use the Personal Information of children under 18. If you believe that we have collected the Personal Information of a child under 18, please contact us at compliance@c2fusion.com.

Authorized Agent Requests

California privacy law allows you to designate an authorized agent to make a rights request on your behalf. Your authorized agent may submit such a request by following the same method described above. We may require verification of your authorized agent in addition to the information for verification above for Employees, Contractors, and Applicants and households.

Contact Us

If you have any questions or concerns regarding this California HR Privacy Notice, contact us at compliance@c2fusion.com.

Last updated: 1/27/2024