The state of California requires that we provide privacy information for individuals that reside in California. If you do not reside in California, you can skip this document.
- 1. Personal Information We Collect
- 1.1. What personal information does not include
- 1.2. How we obtain your personal information
- 1.3. Categories of personal information we may collect
- 1.4. How we may use your personal information
- 1.5. How we may share your personal information
- 1.6. Sale of personal information
- 2. Do Not Track Signals
- 4. Social Media
- 5. How to contact us
Below is the legal information we are required to share:
These CALIFORNIA EMPLOYEE CCPA DISCLOSURES supplement the Employee Handbook and govern the personal information collected, used and shared by Elevate Credit, Inc. (“Elevate,” “we,” “us,” or “our”) and apply to job applicants, employees, owners, directors, officers, and contractors of Elevate who are acting in such a capacity (“employment position”) and who reside in the State of California (“consumers” or “you”). We adopt this policy 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 policy.
1. PERSONAL INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual consumer or device (“personal information”).
1.1. Personal information does not include:
- Publicly available information from government records
- De-identified or aggregated consumer information
- Information excluded from the CCPA, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
1.2. How We Obtain Your Personal Information:
Directly from you.
You enter or provide us with information, whether online or by email, phone, or document upload. For example, your contact information that you provide in an employment application, or documents you provide to verify your identity.
Directly and indirectly from you based on activity on our website or network.
For example, from internet browsing or network usage details collected automatically.
From service providers and third-parties that interact with us in connection with your employment position.
For example, credit reporting agencies from which we check your credit in connection with a submitted employment application, or other service providers that provide background search results.
1.3. Categories of Personal Information We Collect
In the last 12 months, we collected the following categories of personal information:
- “Identifiers” such as name, alias, address, unique identifier, internet protocol address, email address, account number, Social Security Number, or government identification number;
- “Other Personal Information” such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
- “Protected Characteristics” such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information;
- “Commercial Information” such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
- “Internet or Network Activity” such as browsing history, search history, information on a consumer's interaction with a website, application, or advertisement;
- “Geolocation Data” such as physical location or movements;
- “Sensory Data” such as audio, electronic, visual, thermal, olfactory, or similar information; and
- “Professional and Employment Related Information” such as current or past job history or performance evaluations.
1.4. How We Use Your Personal Information:
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided, including but not limited to:
- To fulfill or meet the reason for which the information is provided.
- To provide you with a decision on an employment application.
- To provide you with employment benefits.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- Undertaking internal research for technological development and demonstration.
- Debugging to identify and repair errors that impair existing intended functionality.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Auditing related to a current interaction with you.
- Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction.
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or of a device that is owned, manufactured, manufactured for, or controlled by us.
- To reduce the risk of spreading COVID-19 or other diseases in the workplace, including contract tracing as needed or required by law.
1.5. Who We Share Your Personal Information with for a Business or Commercial Purpose:
We may disclose your personal information to a service provider or third party for a business or commercial purpose. When we disclose personal information to a service provider, we enter a contract that describes the purpose and requires the service provider to both keep that personal information confidential and not use it for any purpose except performing the contract or as otherwise permitted under the CCPA. Examples of who we share with include:
- Service providers, including but not limited to payroll processors, companies that provide security services, software companies, expense and travel management systems, organizational consultants, employment assessment, relocation services.
- Third parties, including those to whom you authorize us to disclose your personal information in connection with your employment position, including:
- Benefits administrators,
- Attorneys such as those who assist with immigration requirements,
- Staffing agencies,
- Insurance providers, and
- Governmental and regulatory agencies. When such sharing involves health information, we maintain an employee’s anonymity whenever possible.
- With our benefits administrators and staffing agencies we share Identifiers, Other Personal Information, Protected Characteristics, Biometric Information Internet or Network Activity, Geolocation Data, Sensory Data, Professional and Employment Related Information, Education Information;
- With our advisors such as lawyers, banks, and insurers we share Identifiers, Other Personal Information, Protected Characteristics, Biometric Information, Internet or Network Activity, Sensory Data, Professional and Employment Related Information, Education Information;
- With governmental and regulatory agencies we share Identifiers, Other Personal Information, Protected Characteristics, Biometric Information, Sensory Data, Internet or Network Activity, Professional and Employment Related Information, Education Information; and
- With our data analytics and web hosting providers we share Identifiers, Other Personal Information, Protected Characteristics, Internet or Network Activity, Geolocation Data.
1.6. Sale of Personal Information:
We do not sell your personal information. We do not sell the Personal Information of minors under 16 years of age without affirmative authorization.
2. DO NOT TRACK SIGNALS
Do Not Track is a web browser setting that requests websites and applications to disable their tracking of an individual user. Our site honors Do Not Track settings in your browser.
3. CHANGES TO OUR CALIFORNIA EMPLOYEE CCPA DISCLOSURES
We reserve the right to amend the CALIFORNIA EMPLOYEE CCPA DISCLOSURES at our discretion and at any time. When we make material changes to the CALIFORNIA EMPLOYEE CCPA DISCLOSURES, we will notify you.
4. SOCIAL MEDIA
If you interact with us on social media and to understand your choices, please review the privacy options and settings on those platforms.
5. HOW TO CONTACT US
If you have any questions or comments about this policy, the ways in which we collect and use your personal information, your rights regarding such use, please contact our Chief Privacy Officer, Kate Vanderkolk at:
Privacy Support Phone:
Privacy Support E-Mail:
4150 International Plaza, Suite 300
Fort Worth, Texas 76109
Version 2.0 – Effective Date 1/1/2021