Privacy Policy for California Residents
Information We Collect
Verstela and its operating groups, parents, subsidiaries and affiliates (collectively referred to as, “Verstela”, “We” or Us”)
collects information that identifies, relates to, describes, references, is reasonably capable of being associated with,
or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”).
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, 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), clinical trial data, or
other qualifying research 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.
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996
In particular, we have collected the following categories of personal information from consumers within the last twelve
(12) months:
Category | Examples | Collected |
A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. |
YES |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, signature, Social Security number, physical characteristics or description, address, umber, passport number, driver’s license or state identification card number, insurance policy number, Some personal information included in this category may overlap with other categories. |
YES |
C. Protected classification characteristics under California or federal law. | 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). |
YES |
D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
NO |
E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
NO |
F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. |
NO |
G. Geolocation data. | Physical location or movements. | NO |
H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
I. Professional or employment-related information. | Current or past job history or performance evaluations. | YES |
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)). |
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
NO |
K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
NO |
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
Use of Personal Information
We may use, or disclose the personal information we collect for one or more of the following purposes:
- Comply with applicable laws and regulations.
- Recruit and evaluate job applicants and candidates for employment.
- Conduct background checks.
- Manage your employment relationship with us, including for: onboarding processes; timekeeping, payroll, and
expense report administration; employee benefits administration; employee training and development requirements. - The creation, maintenance, and security of your online employee accounts.
- Reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill.
- Workers’ compensation claims management.
- Employee job performance, including goals and performance reviews, promotions, discipline, and termination.
- Other human resources purposes.
- Manage and monitor employee access to company facilities, equipment, and systems.
- Conduct internal audits and workplace investigations.
- Investigate and enforce compliance with and potential breaches of Company policies and procedures.
- Engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers
and acquisitions of the Company. - Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability
insurance. - Perform workforce analytics, data analytics, and benchmarking.
- Administer and maintain the Company’s operations, including for safety purposes.
- For client marketing purposes.
- Exercise or defend the legal rights of the Company and its employees and affiliates, customers, contractors, and
agents. - To fulfill or meet the reason you provided the information. For example, if you share your name and contact
information to ask a question about our products or services, we will use that personal information to respond
to your inquiry. If you provide your personal information to purchase a product or service, we will use that
information to process your payment and facilitate delivery. We may also save your information to facilitate new
product orders or process returns. - 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 our assets, whether as a going concern or as part of bankruptcy, liquidation, or
similar proceeding, in which personal information held by us about our Website users is among the assets
transferred.
We will not collect additional categories of personal information or use the personal information we collected for
materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may share your personal information by disclosing it to a third party for a business purpose. We only make these
business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the
personal information confidential, and prohibit using the disclosed information for any purpose except performing the
contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the
categories of third parties indicated in the chart below.
Personal Information Category | Category of Third-Party Recipients | |
Business Purpose Disclosures | Sales | |
A: Identifiers. | Service providers, Internet Cookie Data Recipients, Clients, and Affiliates | None |
B: California Customer Records personal information categories. | Service providers, Clients, and Affiliates | None |
C: Protected classification characteristics under California or federal law. | None | None |
D: Commercial information. | None | None |
E: Biometric information. | None | None |
F: Internet or other similar network activity. | None | None |
G: Geolocation data. | None | None |
H: Sensory data. | None | None |
I: Professional or employment-related information. | Service Providers, Clients, and Affiliates | None |
J: Non-public education information. | None | None |
K: Inferences drawn from other personal information. | None | None |
Exclusion
SMS consent and phone number will not be shared with any third-party or affiliate companies for marketing purposes.
Your Rights and Choices
Under applicable laws, certain consumers (e.g., California residents) have specific rights regarding their personal
information. This section describes such rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal
information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see
Exercising Your Rights to Know or Delete), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information. - The categories of third parties with whom we share that personal information.
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient
obtained.
- The specific pieces of personal information we collected about you (also called a data portability request).
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained,
subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see
Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the
information applies. We may deny your deletion request if retaining the information is necessary for us or our service
provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested,
take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms
of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with
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 us.
- 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.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will
direct our service providers to take similar action.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request either
Calling us at 833-837-7247
Emailing us at Privacy@Verstela.com
Visiting http://localhost:10008/privacy-policy/
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your
personal information. To designate an authorized agent, contact HR@Verstela.com.
You may also make a request to know or delete on behalf of your child by contacting HR@Verstela.com.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must provide
sufficient information that allows us to reasonably verify you are the person about whom we collected personal
information or an authorized and describe your request with sufficient detail that allows us to properly understand,
evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or
authority to make the request and confirm the personal information relates to you.
You do not need to create an account with us to submit a request to know or delete. We will only use personal
information provided in the request to verify the requestor’s identity or authority to make it.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the
10-day timeframe, please contact HR Manager @ HR@Verstala.com.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we
require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with
us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we
provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we
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, specifically PDF.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or
manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and
provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or
imposing penalties. - Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or
services.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California
residents to request certain information regarding our disclosure of personal information to third parties for their
direct marketing purposes. To make such a request, please send an email to Privacy@Verstela.com or write us
at: Verstela
Attn: Human Resources
1000 SE Everett Mall Way
Suite 301
Everett, WA 98208
Changes to Our Privacy Policy
We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this
privacy policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued
use of our website following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which Verstela collects and uses your
information described here, your choices and rights regarding such use, or wish to exercise your rights under California
law, please do not hesitate to contact us at:
Phone: 833-837-7247
Website: Verstela.com
Email: Privacy@Verstela.com
Postal Address:
Verstela
Attn: Human Resources
1000 SE Everett Mall Way
Suite 301
Everett, WA 98208
If you need to access this Policy in an alternative format due to having a disability, please contact
Privacy@Verstela.com or 833-837-7247.