California Employee, Applicant, and Independent Contractor Privacy Policy and Notice
California Employee, Applicant, and Independent Contractor Privacy Policy
Here at Sanctus LLC, d/b/a Shift Digital (“we,” “us,” “our”), we work hard to build and maintain a relationship of trust with you. This Privacy Policy (the “Privacy Policy”) governs our collection, use, and disclosure of your Personal Information (as defined below) in connection with your potential, present, future, or past employment or independent contractor relationship with us. This Privacy Policy only applies to California residents who are natural persons.
Please carefully read this Privacy Policy. By providing us with your Personal Information in connection with your potential, present, future, or past employment or independent contractor relationship with us, you agree to our use of your information consistent with this Privacy Policy. Our website(s) (“Site”), such as www.shiftdigital.com, have separate privacy policies and terms of use such that any Personal Information we collect, use, or disclose in connection with your use of those websites is not subject to this Privacy Policy.
Some jurisdictions have different or specific legal requirements governing the use of Personal Information including Personal Information of contractors, applicants, employees, and beneficiaries. We will comply with all laws and regulations, including local data protection laws, and will implement additional procedures and policies wherever needed to meet these requirements.
Please also review the California Consumer Privacy Rights section below for additional rights with regard to your Personal Information (as defined below) in connection with your potential, present, future, or past employment or independent contractor relationship with us.
INFORMATION WE COLLECT
Personal Information
We may collect, use, and disclose information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”) for business-related purposes in connection with your present, future, or past employment or independent contractor relationship with us. In the past twelve months, we have collected the following categories of Personal Information:
| Personal Information Category | Examples | Do we collect this information? |
|---|---|---|
| Identifiers | A real name, alias, date of birth, mailing address, billing address, phone number, IP address, email address, account name, device ID, or other similar identifiers. | YES |
| Personal Information listed in Cal. Civ Code 1798.80(e) | Name, signature, address, telephone number, education level, and credit/debit card number, brand, expiration date. Shift Digital does not collect personal information in this category beyond the personal information it collects in other categories identified herein. | YES |
| Protected classification characteristics under California or federal law | Age, gender, marital status. | YES |
| Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming history or tendencies. | NO |
| 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, sleep, health, exercise data, and drug test data. | NO |
| Internet or other electronic network activity | Browsing/search history, browser type, location of browser request, logs and records of use of Shift Digital electronic resources. | YES |
| Geolocation data | Physical location or movements. | NO (provided the company may have the ability to track company equipment in employee’s possession) |
| Audio, electronic, visual, thermal, olfactory, or similar information (“sensory information”) | Call recordings, video or audio surveillance. | YES |
| Professional or employment-related information | Job title, job description, benefits elections, performance evaluations, correspondence and other communications in connection with employment or contractor relationship, professional credentials and/or association memberships, payroll and tax withhold records. | YES |
| Education information meaning 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. | YES |
| Inferences drawn from other personal information | Inferences relating to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES |
Sensitive Personal Information
We collect and use Sensitive Personal Information about you for business-related purposes in connection with your potential, present, future, or past employment or contractor relationship with us. “Sensitive Personal Information” is Personal Information that reveals government identifiers, complete account credentials, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, union membership, biometric information, genetic data, communication contents if we are not the intended recipient, identifying biometric information, and information about a person’s health, sex life, or sexual orientation. In the past twelve months, we have collected the following categories of Sensitive Personal Information:
| Sensitive Personal Information Category | Examples | Do we collect this information? |
|---|---|---|
| Government identifiers | Social security, driver's license, state identification card, and passport number. | YES |
| Complete account access credentials | Usernames, account numbers, or card numbers combined with required access/security code or password. | YES |
| Precise geolocation | Geographic area used to locate an individual that is equal to or less than the area of a circle with a radius of 1,850 feet. | NO |
| Racial or ethnic origin | YES | |
| Religious or philosophical belief | YES | |
| Union membership | NO | |
| Mail, email, or text message content where we are not the intended recipient | NO (provided that the employee does not use company equipment or systems for personal use) | |
| Biometric information | NO | |
| Health information | Diagnosis, disability | YES |
| Sex life information or sexual orientation | YES |
We do not sell or share Sensitive Personal Information of applicants, employees, past employees, beneficiaries, or contractors to third parties.
HOW WE COLLECT PERSONAL INFORMATION
Voluntary Disclosure From You
In most cases, we will collect the Personal Information that we use directly from you.
Third Parties
In some circumstances third parties may provide your Personal Information to us, such as friends, family, former employers, medical professionals, and/or insurers, or in connection with a background, employment, or reference check, subject to your consent where required by law.
Shift Digital-Authorized Equipment & Systems and Communication Recordings
We and our Service Providers (defined below) may collect, use, and disclose Personal Information from our review of your use of (i) Shift Digital systems such as email, project management software, and communication platforms, (ii) Shift Digital-authorized devices such as computers, tablets, telephones, and (iii) Shift Digital-issued equipment and vehicles.
We and our Service Providers may record and retain your usage of, and contents within, Shift Digital-authorized devices such as computers, tablets, telephones. By using such devices, you consent to our and our Service Providers recording and retention of your usage and the contents within. You understand that you have no expectation of privacy when using Shift Digital-authorized devices.
Employee Through Whom a Beneficiary Receives Benefits
If you are not employed by us, but receive benefits through one of our employees, we may collect Personal Information from the employee through whom you receive benefits.
PURPOSE FOR COLLECTING PERSONAL INFORMATION
We may collect, use, or disclose Personal Information for business-related purposes in connection with your potential, present, future, or past employment or independent contractor relationship with us, including for the following purposes:
- Identifying and evaluating job applications, including assessing skills, qualifications, and interests for the purposes of determining suitability for the position for which you have applied.
- Verifying your information and carrying out employment, background, and reference checks, subject to your consent where required by applicable law.
- Communicating with you about the recruitment process and your application.
- Verifying your eligibility for employment or contracting and, if applicable and required, supporting you with obtaining a work permit or visa.
- Keeping records related to our hiring, employment, and contracting processes, for only as long as appropriate under the circumstances.
- If you accept an offer for employment or contracting, onboarding you as a new employee or contractor.
- Improving our recruitment, bidding, and onboarding practices and processes.
- Creating and submitting reports as required by applicable laws or regulations.
- To comply with our legal, regulatory, or other corporate governance requirements.
We may collect, use, and disclose your Personal Information for the purposes of administering our employment or independent contractor relationship with you, including, without limitation, for the following purposes:
- Payroll administration.
- Benefits administration.
- Invoicing and payment administration.
- Business management and planning.
- Processing employee work-related claims (for example, insurance claims).
- Accounting and auditing.
- Conducting performance reviews and determining performance requirements.
- Assessing qualifications for a particular job or task.
- Gathering evidence for disciplinary action or termination.
- Complying with applicable laws, regulations, and corporate governance requirements.
- Education, training, and development requirements.
- Healthcare administration.
- Disability accommodation.
- Complying with health and safety obligations.
We may also collect, use, and disclose your Personal Information for our own legitimate business purposes, including, without limitation, for the following purposes:
- To prevent fraud.
- To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.
- To ensure physical security of our personnel, offices, vehicles, and equipment.
- To evaluate or facilitate business transactions such as a merger, acquisition, or asset sale.
Where we have a legitimate need to process Sensitive Personal Information about you for purposes not identified above, we will only do so in compliance with applicable law.
Profiling
We do not use Personal Information for automated profiling of job applicant, current or former employee, beneficiary, or contractor with legal or similarly significant effects upon the consumer.
Personal Information Disclosures
We disclose your Personal Information to businesses who require such information to assist us with administering services in connection with your potential, present, future, or past employment or contractor relationship with us (“Service Providers”), including Service Providers who provide services to us or to you or others on our behalf. Service Providers may include, but are not limited to, payroll processors, benefits administration providers, background check providers, and data storage or hosting providers. These Service Providers may be located outside of your home jurisdiction. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure.
We do not permit our Service Providers to use or retain your Personal Information for their own purposes. Additionally, we do not permit our Service Providers to sell your Personal Information or to share your Personal Information for cross-context behavioral advertising purposes. We only permit them to use your Personal Information for contractually specified purposes in accordance with our instructions. In the past twelve months, we have disclosed to our Service Providers the following categories of Personal Information: identifiers; personal information listed in Cal. Civ. Code § 1798.80(e); protected classification characteristics under California or federal law; Internet or other electronic network activity; sensory information; professional or employment-related information; education information; Inferences drawn from other Personal Information; Sensitive Personal Information.
We may also disclose your Personal Information to third parties where required by law or to our employees, contractors, designated agents, or representatives.
We may also disclose your Personal Information for the following additional purposes where permitted or required by applicable law:
- To other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Privacy Policy and as necessary to administer the application and recruitment process.
- As necessary to perform our obligations as an employer or, if you are an independent contractor, to fulfill our contract with you.
- To confirm your employment or contractor relationship with us.
- To comply with applicable law, legal obligations, or valid legal processes such as search warrants, subpoenas, or court orders.
- To protect our rights and property and the rights or property of our subsidiaries, affiliates, and parent company.
- During emergency situations or where necessary to protect the safety of persons.
- Where the Personal Information is publicly available.
- If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction.
- For additional purposes with your consent where such consent is required by law.
We do not sell or share for cross-context behavioral advertising purposes the Personal Information of applicants, employees, past employees, beneficiaries, or contractors to third parties, including the Personal Information of persons under 16 years of age.
PERSONAL INFORMATION SECURITY
We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect such Personal Information from unauthorized access, disclosure, and use. In addition, we limit access to Personal Information to those employees, agents, contractors, and other Service Providers that have a legitimate business need for such access.
HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
We keep your Personal Information for as long as needed or permitted considering the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you; (ii) as required by a legal obligation to which we are subject to; and/or (iii) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).
If you are offered and accept employment with us, the Personal Information we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with this Privacy Policy. If you do not become an employee, or, once you are no longer an employee of us, we will retain and securely destroy your Personal Information in accordance with our document retention policy and applicable laws and regulations.
Updating Your Information
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during the application process or during your employment or contractor relationship with us. If you are an employee, you are responsible for updating your Personal Information through the employee management tools made available to you. If you need assistance, please contact Employee Relations. If you are a contractor, you are responsible for updating your Personal Information in accordance with the terms of our contract with you.
CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Act, as amended by the California Privacy Rights Act, require us to provide the following privacy rights to our job applicants, current and former employees, beneficiaries, and contractors who are California residents.
Right to Know
You have the right to request twice per 12-month period that we disclose to you certain information about our collection, use, and disclosure of your Personal Information over the past 12 months, including: (i) the categories or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose(s) for which we collected your Personal Information; (iv) the categories of third parties (excluding Service Providers) with whom we shared your Personal Information, if any; (v) the categories of Personal Information we sold to third parties (excluding Service Providers) and the categories of third parties (excluding Service Providers) to whom we sold your Personal Information, if any; and (vi) the categories of Personal Information that we disclosed for a business purpose and the categories of third parties (excluding Services Providers) to whom we disclosed each category for a business purpose.
We are not permitted to provide access to specific pieces of Personal Information if the Personal Information is sensitive or creates a high risk of potential harm from disclosure to an unauthorized person such as financial information, social security numbers, and driver's license numbers. We will not provide specific pieces of Personal Information unless you expressly request them.
Right to Deletion
You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, or comply with legal obligations.
Right to Correct
You have the right to request that we correct inaccurate Personal Information we maintain about you. After you request to correct inaccurate Personal Information, we will provide instructions for you to provide us with optional documentation to support your request and we will consider any supporting documentation you provide.
We may decline to correct your Personal Information if we determine based on the totality of the circumstances that your Personal Information on file is more likely than not accurate. We may also decline to correct your Personal Information if we determine that your request is fraudulent or abusive. If your request to correct your Personal Information is denied, you may request that we note in our records and notify any Service Providers to whom we disclosed your allegedly inaccurate Personal Information that its accuracy has been disputed.
We may decide to delete your allegedly inaccurate Personal Information instead of correcting it.
Submitting a Rights Request
You may submit your request(s) by: sending an email to employeerelations@shiftdigital.com or completing an online request form. If you email us, please include at least your name, mailing address, email address, and a description of your request.
After you submit your request, we may contact you to obtain additional information necessary to verify your identity. For example, we may require you to verify certain information in our files or submit a signed declaration under penalty of perjury verifying your identity. We will not process Right to Know or Deletion requests without verifying your identity, so please respond promptly. If you do not timely respond to our requests for information, we may deny your request.
We will process verified Right to Know, Correct, and Delete requests within 45 days of receipt, subject to any applicable exemptions and extensions permitted by law up to 90 days. If you request access to specific Personal Information and that information creates a high risk of potential harm from disclosure to an unauthorized person, we will withhold that information and replace it with a category identifier. For example, if we withhold a social security number, we will inform you that we have a social security number on file. If you have an online account with us, we will provide the response to your request via the online account, otherwise, we will give you the option to choose between mail and electronic delivery. We will retain a copy of your request for at least two years as required by law.
Authorized Agent
If you are an authorized agent submitting a request on behalf of another person, you must provide a copy of a lawful power of attorney or a written signed authorization from that person along with proof of your identity. You may provide this documentation via email to privacy@shiftdigital.com and employeerelations@shiftdigital.com after submitting the request. We may contact you and person on whose behalf you claim to act to verify your identity, the identity of the person, and your authorization to act on their behalf.
Non-Discrimination Notice
We will not discriminate or retaliate against any job applicant, current or former employee, beneficiary, or contractor for exercising their privacy rights under law or this Privacy Policy.
Non-Waiver Notice
We will not agree to or contract to limit or waive any consumer’s privacy rights under law or this Privacy Policy.
NOT A CONTRACT OF EMPLOYMENT
This Privacy Policy does not create a contract for employment, compensation, hours of work, or for the provision of benefits. If you are a current employee, you are employed at-will, without any definite term or duration, and your employment with us can be terminated at any time, by either party, for any or no reason. If you are an independent contractor, this Privacy Policy does not amend your contract with us.
PRIVACY POLICY CHANGES
This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. Changes to this Privacy Policy will be posted on our website and will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued present, future, or past employment with us or continuation of your contractor relationship with us. If we determine that a change to this Privacy Policy will result in using your Personal Information acquired before the change in a materially new way, we will provide you notice before using your Personal Information in the new way.
CONTACT US
If you have any questions about this Privacy Policy, please email us at employeerelations@shiftdigital.com, or send us a letter to the following address:
Shift Digital
Attn: Employee Relations Privacy Request
348 E. Maple Rd.
Birmingham, MI 48009
UNITED STATES OF AMERICA
California Employee, Applicant, and Independent Contractor Privacy Notice
Here at Sanctus LLC, d/b/a Shift Digital (“we,” “us,” “our”), we work hard to build and maintain a relationship of trust with you. This Privacy Notice (the “Privacy Notice”) gives California residents information about our collection, use, and disclosure of your Personal Information (as defined below) in connection with their potential, present, future, or past employment or independent contractor relationship with us. Please also review our California employee, applicant, and independent contractor privacy policy (“CA Employee Privacy Policy”) above for additional information.
Please also review the California Consumer Privacy Rights section below for additional rights with regard to your Personal Information (as defined below) in connection with your potential, present, future, or past employment or independent contractor relationship with us.
INFORMATION WE COLLECT
Personal Information
We may collect, use, and disclose information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”) for business-related purposes in connection with your present, future, or past employment or independent contractor relationship with us. In the past twelve months, we have collected the following categories of Personal Information:
| Personal Information Category | Examples | Do we collect this information? |
|---|---|---|
| Identifiers | A real name, alias, date of birth, mailing address, billing address, phone number, IP address, email address, account name, device ID, or other similar identifiers. | YES |
| Personal Information listed in Cal. Civ Code 1798.80(e) | Name, signature, address, telephone number, education level, and credit/debit card number, brand, expiration date. Shift Digital does not collect personal information in this category beyond the personal information it collects in other categories identified herein. | YES |
| Protected classification characteristics under California or federal law | Age, gender, marital status. | YES |
| Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming history or tendencies. | NO |
| 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, sleep, health, exercise data, and drug test data. | NO |
| Internet or other electronic network activity | Browsing/search history, browser type, location of browser request, logs and records of use of Shift Digital electronic resources. | YES |
| Geolocation data | Physical location or movements. | NO (provided the company may have the ability to track company equipment in employee’s possession) |
| Audio, electronic, visual, thermal, olfactory, or similar information (“sensory information”) | Call recordings, video or audio surveillance. | YES |
| Professional or employment-related information | Job title, job description, benefits elections, performance evaluations, correspondence and other communications in connection with employment or contractor relationship, professional credentials and/or association memberships, payroll and tax withhold records. | YES |
| Education information meaning 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. | YES |
| Inferences drawn from other personal information | Inferences relating to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES |
Sensitive Personal Information
We collect and use Sensitive Personal Information about you for business-related purposes in connection with your potential, present, future, or past employment or contractor relationship with us. “Sensitive Personal Information” is Personal Information that reveals government identifiers, complete account credentials, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, union membership, biometric information, genetic data, communication contents if we are not the intended recipient, identifying biometric information, and information about a person’s health, sex life, or sexual orientation. In the past twelve months, we have collected the following categories of Sensitive Personal Information:
| Sensitive Personal Information Category | Examples | Do we collect this information? |
|---|---|---|
| Government identifiers | Social security, driver's license, state identification card, and passport number. | YES |
| Complete account access credentials | Usernames, account numbers, or card numbers combined with required access/security code or password. | YES |
| Precise geolocation | Geographic area used to locate an individual that is equal to or less than the area of a circle with a radius of 1,850 feet. | NO |
| Racial or ethnic origin | YES | |
| Religious or philosophical belief | YES | |
| Union membership | NO | |
| Mail, email, or text message content where we are not the intended recipient | NO (provided that the employee does not use company equipment or systems for personal use) | |
| Biometric information | NO | |
| Health information | Diagnosis, disability | YES |
| Sex life information or sexual orientation | YES |
We do not sell or share Sensitive Personal Information of applicants, employees, past employees, beneficiaries, or contractors to third parties.
HOW WE COLLECT PERSONAL INFORMATION
Voluntary Disclosure From You
In most cases, we will collect the Personal Information that we use directly from you.
Third Parties
In some circumstances third parties may provide your Personal Information to us, such as friends, family, former employers, medical professionals, and/or insurers, or in connection with a background, employment, or reference check, subject to your consent where required by law.
Shift Digital-Authorized Equipment & Systems and Communication Recordings
We and our Service Providers (defined below) may collect, use, and disclose Personal Information from our review of your use of (i) Shift Digital systems such as email, project management software, and communication platforms, (ii) Shift Digital-authorized devices such as computers, tablets, telephones, and (iii) Shift Digital-issued equipment and vehicles.
We and our Service Providers may record and retain your usage of, and contents within, Shift Digital-authorized devices such as computers, tablets, telephones. By using such devices, you consent to our and our Service Providers recording and retention of your usage and the contents within. You understand that you have no expectation of privacy when using Shift Digital-authorized devices.
Employee Through Whom a Beneficiary Receives Benefits
If you are not employed by us, but receive benefits through one of our employees, we may collect Personal Information from the employee through whom you receive benefits.
PURPOSE FOR COLLECTING PERSONAL INFORMATION
We may collect, use, or disclose Personal Information for business-related purposes in connection with your potential, present, future, or past employment or independent contractor relationship with us, including for the following purposes:
- Identifying and evaluating job applications, including assessing skills, qualifications, and interests for the purposes of determining suitability for the position for which you have applied.
- Verifying your information and carrying out employment, background, and reference checks, subject to your consent where required by applicable law.
- Communicating with you about the recruitment process and your application.
- Verifying your eligibility for employment or contracting and, if applicable and required, supporting you with obtaining a work permit or visa.
- Keeping records related to our hiring, employment, and contracting processes, for only as long as appropriate under the circumstances.
- If you accept an offer for employment or contracting, onboarding you as a new employee or contractor.
- Improving our recruitment, bidding, and onboarding practices and processes.
- Creating and submitting reports as required by applicable laws or regulations.
- To comply with our legal, regulatory, or other corporate governance requirements.
We may collect, use, and disclose your Personal Information for the purposes of administering our employment or independent contractor relationship with you, including, without limitation, for the following purposes:
- Payroll administration.
- Benefits administration.
- Invoicing and payment administration.
- Business management and planning.
- Processing employee work-related claims (for example, insurance claims).
- Accounting and auditing.
- Conducting performance reviews and determining performance requirements.
- Assessing qualifications for a particular job or task.
- Gathering evidence for disciplinary action or termination.
- Complying with applicable laws, regulations, and corporate governance requirements.
- Education, training, and development requirements.
- Healthcare administration.
- Disability accommodation.
- Complying with health and safety obligations.
We may also collect, use, and disclose your Personal Information for our own legitimate business purposes, including, without limitation, for the following purposes:
- To prevent fraud.
- To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.
- To ensure physical security of our personnel, offices, vehicles, and equipment.
- To evaluate or facilitate business transactions such as a merger, acquisition, or asset sale.
Where we have a legitimate need to process Sensitive Personal Information about you for purposes not identified above, we will only do so in compliance with applicable law.
PERSONAL INFORMATION SELLING OR SHARING
We do not sell or share for cross-context behavioral advertising purposes the Personal Information of applicants, employees, past employees, beneficiaries, or contractors to third parties, including the Personal Information of persons under 16 years of age. We may disclose Personal Information to our Service Providers or to others as disclosed in our CA Employee Privacy Policy.
HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
We keep your Personal Information for as long as needed or permitted considering the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you; (ii) as required by a legal obligation to which we are subject to; and/or (iii) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).
If you are offered and accept employment with us, the Personal Information we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with this Privacy Notice. If you do not become an employee, or, once you are no longer an employee of us, we will retain and securely destroy your Personal Information in accordance with our document retention policy and applicable laws and regulations.
NOT A CONTRACT OF EMPLOYMENT
This Privacy Notice does not create a contract for employment, compensation, hours of work, or for the provision of benefits. If you are a current employee, you are employed at-will, without any definite term or duration, and your employment with us can be terminated at any time, by either party, for any or no reason. If you are an independent contractor, this Privacy Notice does not amend your contract with us.
PRIVACY NOTICE CHANGES
This Privacy Notice is subject to change. We encourage you to review this Privacy Notice frequently for any revisions or amendments. Changes to this Privacy Notice will be posted on our website at [link] and will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued present, future, or past employment with us or continuation of your contractor relationship with us. If we determine that a change to this Privacy Notice will result in using your Personal Information acquired before the change in a materially new way, we will provide you notice before using your Personal Information in the new way.
CONTACT US
If you have any questions about this Privacy Notice, please email us at privacy@shiftdigital.com, or send us a letter to the following address:
Shift Digital
Attn: Privacy
348 E. Maple Rd.
Birmingham, MI 48009
UNITED STATES OF AMERICA