CCPA Privacy Policy

PRIVACY NOTICE SUPPLEMENT FOR CALIFORNIA RESIDENTS ONLY

Last Updated: January 2020

This Privacy Notice Supplement for California Residents Only (this “Supplement”) supplements the
Privacy Notice (the “General Privacy Notice”) of Infinity Consulting Solutions, Inc. (the “Company”,
“we”, “us” or “our”), and applies solely to individuals who are residents of the State of California (such
individuals,” Consumers” or “you”). This Supplement addresses your rights under the California
Consumer Privacy Act of 2018 (“CCPA”). This Supplement does not apply to individuals who are not
residents of the State of California. Capitalized terms used but not otherwise defined in this Supplement
have the meanings given to them in the General Privacy Notice.

I. Personal Information We Collect and Use

The CCPA defines “personal information” as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The table below states whether or not we have collected the following categories of such “personal information” from consumers within the last twelve months:

Category	Examples	Collected?	If Collected, Business or Commercial Purpose for Collection
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	(A) it is necessary for our legitimate interests; (B) we need to comply with legal or regulatory obligations; and (C) performance of any contract we are about to enter into or have entered into with you.
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, 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. Some personal information included in this category may overlap with other categories.	Yes	(A) it is necessary for our legitimate interests; (B) we need to comply with legal or regulatory obligations; and (C) performance of any contract we are about to enter into or have entered into with you.
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	(A) it is necessary for our legitimate interests; and (B) we need to comply with legal or regulatory obligations.
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.	Yes	(A) it is necessary for our legitimate interests; and (B) we need to comply with legal or regulatory obligations.
G. Geolocation data.	Physical location or movements.	Yes	(A) In connection with company issued devices to ascertain their location.
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	(A) it is necessary for our legitimate interests; and (B) we need to comply with legal or regulatory obligations.
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.	Yes	(A) it is necessary for our legitimate interests

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

• Through our Website.
• Indirectly from you (for example, from observing your actions on our Website).
• HRIS, payroll and onboarding software

II. Collection and Use of Personal Information

We may collect and use the personal information we collect about you for the following purposes:

When you use or register with the Site, we may ask for certain Personal Information. The categories of Personal Information we may request include your name and contact information (email, address and phone number). Depending on the nature of your inquiry or activities on the Site, we may also ask for

your job search criteria and preferences, your employment experience, educational history, your skills, references information, background information, and other information contained in your resume, and any login ID or email address and password created by you. The Site also utilizes cookies to track your online activities within this Site, including, but not limited to, registration, submissions, and information requests. After your successful registration with the Site, you will be able to access, review and change your Personal Information provided by you through the My Profile feature of the Site.

We use Personal Information and other data collected through the Site to register you with the Site, to provide you with information regarding employment opportunities and career-related information, and to otherwise provide you with requested information or services. We may also from time to time use your Personal Information to send you automated email messages or marketing materials regarding our services, including employment information.

In addition to the above, we may collect or use your personal information for other purposes for which either we or our client(s) will provide notice to you at the time of collection, or as otherwise permitted under the CCPA or other applicable law.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated or incompatible purposes without providing you notice.

III. Sharing of Personal Information for a Business Purpose

We share your personal information with third parties when it is necessary for a business purpose.
When we share personal information to third parties for a business purpose, we contractually require that the recipient not

We share your personal information with the following categories of third parties:

• Our service providers; and
• When presenting a candidate to a client for placement

During the preceding twelve months, we have shared the following categories of personal information to third parties for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category I: Professional or employment-related information.
Category J: Non-public education information.
Category K: Inferences drawn from other personal information.

IV. “Selling” Personal Information

During the preceding twelve months, we have not “sold” personal information (as the term “sell” is defined in the CCPA).

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category I: Professional or employment-related information.
Category K: Inferences drawn from other personal information.

We do not sell the personal information of minors under 16 years of age without affirmative authorization.

Your Rights Under the CCPA

The CCPA provides California residents with certain rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

A. Requests to Know

Through a verifiable consumer request, you may request disclosure of:

• The categories of personal information that we have collected about you.
• The categories of sources from which the personal information about you is collected.
• The business or commercial purpose for collecting or selling personal information.
• The categories of third parties with whom we share personal information.
• The specific pieces of personal information that we have collected about you.
• Categories of personal information that we “sold” or disclosed for a business purpose about you.
• Categories of third parties to whom the personal information was sold or disclosed for a business purpose.

You may only submit a request to know twice within a 12-month period.

B. Requests to Delete

Through a verifiable consumer request, you may request that we delete your personal information that we have collected and retained, subject to certain exceptions. Once we receive and confirm such a verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Nevertheless, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete a 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, 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 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 et. seq.).
• Enable 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 it has been provided to us.

C. Right to Opt Out of Our “Selling” of Your Personal Information

If we “sell” your personal information to third parties, you have the right, at any time, to direct us not to sell your personal information. This right may be referred to as the right to opt out. If you so direct us, we will refrain from selling personal information that we collect about you, unless you subsequently provide us express authorization for the sale of your personal information.

The CCPA provides that the following acts do not constitute “selling” personal information, meaning that you will not have the right to opt out of our sharing or disclosing your personal information in the following ways:

• If you direct us to intentionally disclose personal information, or you use us to intentionally interact with a third party (provided that the third party does not also sell the personal information, unless that disclosure would be consistent with the CCPA).
• We use or share an identifier about you after you opt out of the sale of your personal information, for the purposes of alerting third parties that you have opted out of the sale of your personal information.
• We use or share with a service provider personal information that is necessary to perform a business purpose, if both of the following conditions are met:
  • we have provided notice of the information being used or shared; and
  • the service provider does not further collect, sell, or use the personal information exceptas necessary to perform the business purpose.
• We transfer to a third party the personal information of a consumer as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of the business, provided that information is used or shared consistently with relevant provisions of the CCPA.

D. Submitting Your Requests to Know and Requests to Delete and Right to Opt Out

To submit a request to know or a request to delete or a right to opt out to us, you must submit a “verifiable consumer request” (as defined below) to us by writing us at the mailing address below, or sending an email to us at the email address below.

462 Seventh Avenue, 2nd Floor, New York, NY 10018
Email: privacy@infinity-cs.com
Toll Free: 1 (866) 240-9850

 

Under the CCPA, a “verifiable consumer request” means a request that is made by a consumer, by a consumer on behalf of the consumer’s minor child, or by a natural person or a person registered with the Secretary of State, authorized by the consumer to act on the consumer’s behalf, and that we can reasonably verify, to be the consumer about whom we have collected personal information.

The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Specifically, you must provide the information below with your request.
  • Your full legal name
  • Phone number
  • Mailing Address
  • Email Address
  • Recent job history
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

In addition to the list above, we may need additional information from you, if we reasonably determine that additional information is needed to properly verify your identity.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may make a verifiable consumer request on behalf of your minor child. 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. To verify your identity or authority to make the request, we may match data points you provide with your request, with data points that we maintain,

If you choose to use an authorized agent to submit a request to know or a request to delete to us, we will require that you (i) provide us with a copy of the written permission you gave the authorized agent to submit the request to us; and (ii) verify your own identity directly with us. We may deny a request from an agent that does not submit proof that such agent has been authorized by you to act on your behalf.

If you submit a request in a manner that is not one of the designated methods of submission described above, or if your request is deficient in some manner unrelated to the verification process, we will either: (i) treat the request as if it had been submitted in accordance with our designated manner, or (ii) provide you with specific directions on how to submit the request or remedy any deficiencies with the request, if applicable.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

E. Response Timing and Format

Upon receiving a verifiable consumer request, we will confirm receipt of it within 10 days and provide information about whether and how we will process the request.

We will deliver our written response either by mail or electronically. We will endeavor to respond to a verifiable consumer request within forty-five days of its receipt. If we require more time (up to 90 additional days), we will inform you of the reason and extension period in writing.

Any information we deliver in response to your request may be delivered by mail or electronically. If it is provided electronically, we will take reasonable steps to provide that the information will be portable and, to the extent technically feasible, in a readily useable format that would allow you to transmit the information to another entity without hindrance.

Any disclosures we provide will only cover the 12-month period preceding the date we received the verifiable consumer request.

We do not charge a fee to process or respond to your verifiable consumer request unless the verifiable consumer request is excessive, repetitive, or manifestly unfounded. If we determine that the verifiable consumer request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

VI. 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 will receive a different price or rate for goods or services or a different level or quality of goods or services.

The CCPA permits us to charge consumers a different price or rate, and to provide a different level or quality of goods or services to you, if that difference is reasonably related to the value that your data provides to us.

We may also offer financial incentives, including payments to consumers as compensation, for the collection of personal information, the sale of personal information, or the deletion of personal information. We may also offer a different price, rate, level or quality of goods or services to the consumer if that price or difference is directly related to the value provided to the business by your data. We will not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.

If we offer any financial incentives, we shall notify you of those financial incentives. We will enter you into a financial incentive program only if you give us prior opt-in consent, which may be revoked by the consumer at any time.

VII. Changes to This Supplement

We reserve the right to amend this Supplement at our discretion and at any time. When we make changes to this Supplement, we will post the updated notice on the Website and update the Supplement’s effective date. Your continued use of our Services and our Website after the posting of changes constitutes your acceptance of such changes.

VIII. Our Contact Information

If you have any questions or concerns regarding this Supplement, please contact us at:

462 Seventh Avenue, 2nd Floor, New York, NY 10018
Email: privacy@infinity-cs.com
Toll Free: 1 (866) 240-9850