Notice At Collection

Our Privacy Commitment

CC Wellness (“CC Wellness” “we” “us” or “our”) is committed to respecting the privacy rights and concerns of our employees. We have established and implemented this Privacy Notice to inform you about how we use and protect the information we collect. This Privacy Notice is effective as of the date set forth above and covers our collection, use, and disclosure of information we collect.

This Privacy Notice answers the following questions:

What information do we collect about you and how do we use it?
How do we use the information you give us?
What rights do I have as an employee of CC Wellness?

What information do we collect about you and why?

Why we need your information

As an employee, we need your personal information to perform certain basic functions necessary and typical in the regular scope of employment, such as contacting you, contacting your emergency contact if something happens to you, to calculate work hours, to distribute payments, and to provide benefits to you and your dependents.

Other information that we collect such as internet browsing history you create on CC Wellness-owned devices, video recordings, sound recordings, or any other records may also be used by CC Wellness in order to secure both tangible and intangible property belonging to CC Wellness.

For example, CC Wellness may collect images of employees for the purposes of internal identification. CC Wellness may also elect to use internet history to determine if an employee improperly distributed any intangible property, such as trade secrets, copyright-protected materials or any valuable information typically protected by CC Wellness, as well as general productivity. This information may also be used for other employee evaluation decisions, such as determining productivity.

We may also use some information about you, including your HR file, and evaluations filled out by yourself or your managers.

Furthermore, we need your information to ensure that you can access and operate CC Wellness' systems to the extent necessary for you to perform your job.

What information we collect.

We collect all the information that you provide us in the course of employment. This information is supplied through your job application, and other documents you provided to us when you started work. To help you manage your personal information, we also provide this chart as laid out below, which outlines the categories and examples of the information that we collect from you, how we collect it, and how it is used. To the extent that you have a relationship with CC Wellness outside of your employment contract, we may collect additional information subject to our Privacy Policy located here.

Category	Examples	How We Collect This	How we use this
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.	We collect this information through your résumé and job application documents. In addition, we may collect this information informally, though communication with HR or other CC Wellness employees.	We use this information to know who you are, and to provide important tax information to you as necessary. We may also use information, such as your personal or external email addresses, in order to contact you outside of work if needed.
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.	We collect this information through your résumé and job application documents. Important financial information, such as your bank account number, may also be collected for the purposes of a direct deposit. Medical and health insurance information will also be collected by CC Wellness through (a) our Human Resources team or (b) your requests for accommodations, time off, or worker's compensation, as is necessary. In addition, we may collect this information informally, though communication with our Human Resources team or other CC Wellness employees.	We use this information to know who you are, and to provide important tax information to you as necessary. We may also use certain information, such as your phone number or address to contact you outside of work, if needed. Financial information, such as your bank account number, will only be used to ensure that you receive payment for your work. Medical and health insurance information will be used in a limited fashion, to respond to your requests for accommodations, time off, or worker's compensation, as is necessary. We may also use your signature to memorialize or indicate your consent on agreements between you and CC Wellness.
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).	We collect this information through your job application documents and through informal observation by our Human Resources team or communication between you and our Human Resources team. We may also collect certain information, such as information regarding your pregnancy, marital status, medical condition, religion or other protected information from discussions between you and our Human Resources team, as you deem necessary.	Workforce demographic information is used solely to comply with annual EEO-1 reporting obligations. To the extent that we collect information regarding a medical condition or pregnancy, this information will only be used for the purposes of determining and implementing accommodations, as well as the administration of any benefits, as they may occur. To the extent that we collect information about your religion or creed as part of a request for accommodations, we will only use this information for the purposes of making such accommodations. To the extent that you provide any information sa to your marital status, this information will only be used for (a) the purposes of providing you with tax documents and (b) for the purposes of an emergency contact to be provided by you.
Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	We may receive information regarding your commercial purposes when you apply for a loan and ask for confirmation of employment.	While we may collect this kind of commercial information incidentally; we only use this information in order to respond to requests to confirm your employment.
Biometric information.	Physiological, behavioral, and biological characteristics.	We may collect certain medical information as it pertains to leave of absence administration, drug and alcohol testing, administration of medical insurance, and/or workers’ compensation.	Medical and health information will be used in a limited fashion, for the purposes of drug tests, to respond to your requests for accommodations, time off, or worker's compensation, as is necessary.
Internet or other similar network activity.	Browsing history, search history, information on an employee's interaction with a website, application, or advertisement.	We may collect browsing history, search information, and information about your use of a website through CC Wellness issued devices, or through devices you are permitted to connect onto a network owned or otherwise provided by CC Wellness.	CC Wellness collects this information to (a) measure productivity; and (b) ensure the security and well-being of devices belonging to CC Wellness, or devices connected to its networks. This information may be used to determine a data breach and the source of a data breach.
Geolocation data.	Physical location or movements.	We may collect geolocation data only as it pertains to the use of any mobile devices issued by CC Wellness, such as tablets.	We collect geolocation data only as it pertains to devices owned by CC Wellness, in order to ensure the safety and security of our devices, and the data within them.
Professional or employment related information.	Current or past job history or performance evaluations.	We compile information about your job history and performance evaluations as part of your work with CC Wellness. We may also request that you and your supervisors provide performance evaluations about your work.	We collect this information in in order to determine productivity and make compensation decisions or decisions made towards Human Resources purposes. In addition, performance evaluations may guide our actions by suggesting additional trainings needed.
Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	We may request that you and your supervisors provide performance evaluations about your work. In addition, additional information may be collected by our Human Resources team through discussions with you personally, or by general observation by our Human Resources team or your supervisors.	We collect this information in order to determine productivity and make compensation decisions or decisions made for Human Resources purposes. In addition, performance evaluations may guide our actions by suggesting additional trainings needed.
Family members and Emergency Contacts	Names, addresses and phone numbers of third party individuals with whom you have a relationship, as well as their connection to you.	We request this information through your job application documents, and through additional forms relating to benefits.	We use the information you provide us regarding your family members and emergency contacts to (a) alert them in the event of an emergency or an event where you are in mortal peril; and (b) for the administration of benefits to any named beneficiaries.
Sensitive Personal Information	Social security number or state identification number; precise geolocation; racial or ethnic origin, religious beliefs and personal health information.	We collect this information through your job application documents and through informal observation by our Human Resources team or communication between you and our Human Resources team. We may also collect certain information, such as information regarding your pregnancy, marital status, medical condition, religion or other protected information from discussions between you and our Human Resources team, as you deem necessary. We may also collect this information through informal observations.	Workforce demographic information is used solely to comply with annual EEO-1 reporting obligations. To the extent that we collect information regarding a medical condition or pregnancy, this information will only be used for the purposes of determining and implementing accommodations, as well as the administration of any benefits, as they may occur. To the extent that we collect information about your religion or creed as part of a request for accommodations, we will only use this information for the purposes of making such accommodations. We collect geolocation data only as it pertains to devices owned by CC Wellness, in order to ensure the safety and security of our devices, and the data within them.

We may update this list from time to time in the event that we need to collect new categories of personal information, or need to use your personal information for a reason not specified above.

What information we disclose.

For the most part, your information may be disclosed to third party service providers, such as Paycom or ADP, which help us simplify and streamline our processes related to your paycheck and your interactions with our Human Resources team. However, to give you a better idea of how and with whom your information may be shared, please see the below:

Category	Examples	Who We Share this With	Why do we share it?
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.	We share this information with our service providers, your fellow employees and third parties, such as benefit providers, training vendors, and banks.	We share this information so that these other parties are able to identify you and provide information specific and unique to you in an easily accessible manner. We may also share this information to employees to improve and foster communication inside and outside of the workplace.
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.	We share this information with our service providers, your fellow employees and third parties, such as benefit providers, training vendors, and banks. However, medical information and health insurance information may only be shared with your benefit providers, or, in the event of an emergency, to qualified medical personnel. We do not share any financial information.	We share this information so that these other parties are able to identify you and provide information specific and unique to you in an easily accessible manner. We may also share this information with employees to improve and foster communication inside and outside of the workplace. Medical and health insurance information will be shared in a limited fashion, to respond to issues related to benefits or in the event of an emergency, in order to save your life.
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).	We are required to share this information with the federal government for the purposes of annual EEO-1 reporting obligations. In addition, we may share this information with our service providers, your fellow employees and benefit providers.	Workforce demographic information is shared solely to comply with annual EEO-1 reporting obligations. As part of these obligations, we share this information with the Federal Government. In addition, we may share this kind of information as part of any accommodations that you may request, or the administration of benefits.
Biometric information.	Physiological, behavioral, and biological characteristics.	We may share this information with our service providers, your fellow employees and benefit providers.	We may share your medical and health information as part of any accommodations, time off, worker's compensation, as is necessary, or the administration of benefits. Certain information may only be shared to third party service providers and certain supervisors in connection with the results of any drug tests conducted at the request of CC Wellness.
Internet or other similar network activity.	Browsing history, search history, information on an employee's interaction with a website, application, or advertisement.	We may share your browsing history with our service providers or your fellow employees.	This information will only be shared with individuals on our IT team and other service providers as necessary to determine (a) the nature of a data breach; (b) the source of a data breach, and (c) the severity of a data breach.
Professional or employment related information.	Current or past job history or performance evaluations.	We may share this information with employees, and third parties such as (a) your future employers; or (b) banks and lenders;	If you happen to leave us, we will generally confirm your employment with CC Wellness if asked by a potential future employer or will respond for inquiries by a bank regarding any loans you may want to make.
Family members and Emergency Contacts	Names, addresses and phone numbers of third party individuals with whom you have a relationship to, as well as their connection to you.	We may share this information with employees, and third parties, including medical professionals and hospitals.	We share the information you provide us regarding your family members and emergency contacts to ensure that the third party or hospital can (a) alert your contacts in the event of an emergency or an event where you are in mortal peril; and (b) for the administration of benefits to any named beneficiaries.
Sensitive personal information.	Social security number or state identification number; racial or ethnic origin, religious beliefs and personal health information.	We are required to share this information with the federal government for the purposes of annual EEO-1 reporting obligations. Medical and health information may only be shared with your benefit providers, or, in the event of an emergency, to qualified medical personnel. In addition, we may share this information with our service providers, your fellow employees and benefit providers	We share this information so that these other parties are able to identify you and provide information specific and unique to you in an easily accessible manner. Medical and health information will be shared in a limited fashion, to respond to issues related to benefits or in the event of an emergency, in order to save your life. Workforce demographic information is shared solely to comply with annual EEO-1 reporting obligations. As part of this, we share this information with the Federal Government. In addition, we may share this kind of information as part of any accommodations that you may request, or the administration of benefits.

What rights do I have as an employee of CC Wellness?

California Privacy Rights

If you are a resident of the State of California, you have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended and expanded by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You. You have the right to know:

• The categories of personal information we have collected about you, including sensitive personal information;

• The categories of sources from which the personal information is collected;

• Our business or commercial purpose for collecting, selling, or sharing personal information;

• The categories of third parties with whom we share personal information, if any; and

• The specific pieces of personal information we have collected about you.

Please note that we are not required to:

• Retain any personal information about you if, in the ordinary course of business, that information about you is not retained;

• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or

• Provide the personal information to you more than twice in a 12-month period.

Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose. In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:

• The categories of personal information about you that we have sold or shared and the categories of third parties to whom the personal information was sold or shared; and

• The categories of personal information that we have disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose.

Right to Opt-Out of the Sale or Sharing of Personal Information. You have the right to opt-out of the sale or sharing of your personal information.
Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to opt-out of the use and disclosure of your sensitive personal information for anything other than supplying requested goods or services.
Right to Deletion. Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

• Delete your personal information from our records;

• Direct any service providers to delete your personal information from their records; and

◦ Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort.

Please note that we may not delete your personal information if it is necessary to:

• Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you (for example, in the employee-employer context), or otherwise perform a contract between you and us;

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

• Debug to identify and repair errors that impair existing intended functionality;

• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

• Comply with the California Electronic Communications Privacy Act;

• 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

• Enable solely internal uses that are reasonably aligned with your expectations based on the your relationship with us;

• Comply with an existing legal obligation; or

• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Right to Correction. You have the right to request correction of inaccurate personal information maintained by us about you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Protection Against Discrimination. You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA and CPRA. This means we cannot, among other things:

• Deny goods or services to you;

• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

• Provide a different level or quality of goods or services to you; or

• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate, or provide a different level or quality of [goods and/or services] to you, if that difference is reasonably related to the value provided to us by your personal information.

How to Exercise Your Rights

How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:

Complete a data subject request form available here [link to consumer webform];
Call us, toll-free, at 1- 855-476-4080 or
Email us at privacy@ccwellness.com

Please note that you may only make a data access or data portability disclosure request twice within a 12-month period.

Verifying Your Identity. If you choose to contact directly, you will need to provide us with:

Enough information to identify you (e.g., your full name, address and / or employee number); and
A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access, deletion, correction or data portability disclosure if we cannot verify that the person making the request is the person about whom we have collected information or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

Updates

This privacy notice may be updated from time to time, as new information is collected or information is being used for different purposes. We will post a copy of our Privacy Notice in a publicly accessible location, and may elect to issue a copy to each employee. A summarized and condensed version of this Employee Privacy Notice is also available in our employee handbook.

Notice At Collection

The statements made regarding these products have not been evaluated by the Food and Drug Administration. The efficacy of these products has not been confirmed by FDA-approved research. These products are not intended to diagnose, treat, cure, or prevent any disease. © 2023 JO

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