Privacy Notice for California Residents

Last Modified: May 18, 2023

This Privacy Notice for California Residents (this "Notice") supplements the information contained in the YearOne Privacy Policy and applies solely to visitors, users, employees, applicants, and others who reside in the State of California ("consumers" or "you"). PocketMentor, Inc. ("we" or "PocketMentor") adopt this Notice to comply with the California Consumer Privacy Act of 2018 (the "CCPA"), as amended by the California Privacy Rights Act of 2020 (the "CPRA") (together, the "California Privacy Laws") and any terms defined in the California Privacy Laws have the same meaning when used in this Notice.

Information We Collect

We collect 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:

In particular, we have collected the following categories of personal information within the last 12 months:

Personal Information Category Retention Period Business Purpose(s) Collection and/or Disclosure Details

Identifiers, such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

As required by law or as long as necessary for a business purpose, whichever is longer.

To process your requests, purchases, transactions, and payments and prevent transactional fraud.

To create, maintain, customize, and secure your account with us.

To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

To evaluate an individual's appropriateness for hire.

To fulfill or meet the reason you provided the information.

To comply with record retention requirements.

To help maintain the safety, security, and integrity of YearOne, our products and services, databases and other technology assets, and business.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

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 consumers is among the assets transferred.

As described to you when collecting your personal information or as otherwise set forth in the California Privacy Laws.

We collect this information and may share it with our third-party service providers, affiliates, and business partners for a business purpose.

For example, we share financial information with our third-party transaction processor to process your purchase with us.

California Customer Records personal information, which includes a name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

As required by law or as long as necessary for a business purpose, whichever is longer.

Same as the identifiers category directly above.

We collect this information and may share it with our third-party service providers, affiliates, and business partners for a business purpose.

For example, we share your financial information with our third-party transaction processor to process your purchase with us.

Protected classification characteristics under California or federal law, 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, reproductive health decision-making, military and veteran status.

As required by law or as long as necessary for a business purpose, whichever is longer.

To personalize your experience with our websites, YearOne, and other products and services.

To promote your resume and status as an employment candidate.

To fulfill or meet the reason you provided the information.

We only collect this information if voluntarily provided (for example, through a resume you upload to YearOne).

For example, we share your uploaded resume with business that are hiring, pursuant to your explicit consent.

Commercial information, such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

As required by law or as long as necessary for a business purpose, whichever is longer.

To personalize your experience with our websites, YearOne, and other products and services.

To comply with record retention requirements.

For testing, research, analysis, and product development, including to develop and improve YearOne and our products and services.

To provide, support, personalize, and develop our YearOne and out products and services.

To fulfill or meet the reason you provided the information.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

We collect this information and may share it with our third-party service providers, affiliates, and business partners for a business purpose.

For example, we provide this type of information to our third-party analytics service providers to better personalize your experience with our products and services.

Internet or other similar network activity, such as browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

As required by law or as long as necessary for a business purpose, whichever is longer.

To engage in human capital analytics, including to identify correlations about individuals and job success, analyze data to improve retention and productivity, and analyze employee preferences to inform human resources policies and procedures.

To personalize your experience with YearOne and our products and services.

To provide, support, personalize, and develop YearOne and our products and services.

To perform workforce analytics, data analytics, and benchmarking.

To engage in human capital analytics, including to identify correlations about individuals and job success, analyze data to improve retention and productivity, and analyze employee preferences to inform human resources policies and procedures.

To help maintain the safety, security, and integrity of YearOne, our products and services, our databases and other technology assets, and business.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

We collect this information and may share it with our third-party service providers, affiliates, and business partners for a business purpose.

For example, we provide this type of information to our third-party analytics service providers to better personalize your experience with our products and services.

Geolocation data, such as physical location or movements.

As required by law or as long as necessary for a business purpose, whichever is longer.

To provide, support, personalize, and develop YearOne, our products, and services.

To conduct internal audits and investigate complaints, grievances, and suspected violations of our policies.

To exercise or defend our legal rights and the rights of our employees, customers, contractors, and agents.

We collect this information and may share it with our third-party service providers, affiliates, and business partners for a business purpose

For example, our analytics service providers collect your IP address’s general location when providing us with analytical services.

Professional or employment-related information, such as current or past job history or performance evaluations.

As required by law or as long as necessary for a business purpose, whichever is longer.

To personalize your experience with YearOne and our products and services.

To promote your resume and status as an employment candidate.

To evaluate an individual's appropriateness for hire.

To fulfill or meet the reason you provided the information.

We only collect this information if voluntarily provided (for example, through a resume you upload to YearOne).

For example, we share your uploaded resume with business that are hiring, pursuant to your explicit consent.

Non-public education information, which may include 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.

As required by law or as long as necessary for a business purpose, whichever is longer.

To fulfill or meet the reason you provided the information.

We only collect this information if voluntarily provided (for example, through a resume you upload to YearOne).

For example, we share your uploaded resume with business that are hiring pursuant to your explicit consent.

Inferences drawn from other personal information, such as a profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

As required by law or as long as necessary for a business purpose, whichever is longer.

To provide, support, personalize, and develop YearOne, our products, and services.

To engage in human capital analytics, including to identify correlations about individuals and job success, analyze data to improve retention and productivity, and analyze employee preferences to inform human resources policies and procedures.

We only collect this information to better our services.

Sensitive Personal Information

Sensitive personal information ("SPI") is a subtype of personal information consisting of specific information categories. In particular, we have collected the below categories of SPI from employees and applicants within the last 12 months. While we collect information that falls within the SPI categories listed in the table below, California Privacy Laws do not treat this information as sensitive because we do not collect or use it to infer characteristics about a person.

Sensitive Personal Information Category Retention Period Business Purpose(s) Collection and/or Disclosure Details

Racial or ethnic origin.

As required by law or as long as necessary for a business purpose, whichever is longer.

To fulfill or meet the reason you provided the information.

To comply with federal and state equal employment opportunity laws.

To conduct internal audits and investigate complaints, grievances, and suspected violations of our policies.

We only collect this information if voluntarily provided (for example, through a resume you upload to YearOne).

For example, we share your uploaded resume with business that are hiring pursuant to your explicit consent.

Religious or philosophical beliefs.

As required by law or as long as necessary for a business purpose, whichever is longer.

To fulfill or meet the reason you provided the information.

To conduct internal audits and investigate complaints, grievances, and suspected violations of our policies.

We only collect this information if voluntarily provided (for example, through a resume you upload to YearOne).

For example, we share your uploaded resume with business that are hiring pursuant to your explicit consent.

Union membership.

As required by law or as long as necessary for a business purpose, whichever is longer.

To fulfill or meet the reason you provided the information.

We only collect this information if voluntarily provided (for example, through a resume you upload to YearOne).

For example, we share your uploaded resume with business that are hiring pursuant to your explicit consent.

Mail, email, or text messages contents not directed to us.

N/A

N/A

N/A

Health information.

As required by law or as long as necessary for a business purpose, whichever is longer.

To comply with federal and state equal employment opportunity laws.

To conduct internal audits and investigate complaints, grievances, and suspected violations of our policies.

To fulfill or meet the reason you provided the information.

We only collect this information if voluntarily provided (for example, through a resume you upload to YearOne).

For example, we share your uploaded resume with business that are hiring pursuant to your explicit consent.

Sex life, or sexual orientation information.

As required by law or as long as necessary for a business purpose, whichever is longer.

To comply with federal and state equal employment opportunity laws.

To conduct internal audits and investigate complaints, grievances, and suspected violations of our policies.

To fulfill or meet the reason you provided the information.

We only collect this information if voluntarily provided (for example, through a resume you upload to YearOne).

For example, we share your uploaded resume with business that are hiring pursuant to your explicit consent.

We obtain the categories of personal information listed above from the following categories of sources:

Use of Personal and Sensitive Personal Information

We will not sell the personal information or sensitive personal information we collect. We may share your personal information by disclosing it to a third party for a business purpose. 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. For more information on how we may use or disclose the personal information we collect, please see our Privacy Policy.

Your Rights and Choices

California Privacy Laws provide California residents with specific rights regarding their personal information. This section describes your 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:

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:

  1. 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.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. 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.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. 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 by either:

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

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 10 business days.

We endeavor to substantively respond to a verifiable consumer request within 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.

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.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

We will not discriminate against you for exercising any of your California Privacy Law rights.