California Privacy Policy

Effective Date: 1/1/2023

This California Privacy Policy supplements the information contained in our Privacy Policy and is adopted to comply with the California Consumer Privacy Act (CCPA) 2018, Cal. Civil Code Section 1798.100 et. seq., as amended, and related regulations, as may be further amended from time to time (“CCPA Policy”). This CCPA Policy applies solely to visitors, users, clients, client’s employees, Registered Users, and/or others who reside in the State of California (“consumers”) (collectively “you”). Any terms defined in the CCPA have the same meaning when used in this CCPA Policy. All other capitalized terms shall have the same meaning as those designated in the NannyChex Privacy Policy. This CCPA Policy explains how NannyChex, a SurePayroll company, and our subsidiaries and affiliates, (“NannyChex” “we,” “us,” or “our”) collect, use, disclose and retain Personal Information, otherwise known as our Information Practices, and how consumers may exercise their rights under CCPA.

NannyChex as a Service Provider

This CCPA Policy governs Personal Information collected, processed, or disclosed by NannyChex as a Service Provider for our clients and for our own purposes. NannyChex will collect and process Personal Information as instructed or permitted by you or in accordance with this CCPA Policy.

What Information is Collected

The CCPA defines Personal Information as “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household” but does not include certain exempt information, publicly available information, or deidentified or aggregated information.  NannyChex’ Information Practices include the collection and use of Personal Information as described in the Privacy Policy and as set forth below. This CCPA Policy applies to our Information Practices both online and offline. NannyChex retains this information as set forth in the Privacy Policy. (See, Data Retention).

Our Purposes for the Collection and Use of Personal Information

We may collect Personal Information directly from you, affiliates, business partners, agents, and vendors. Our collection of Personal Information is limited to the business and commercial purposes as described below:

  1. To facilitate current, prospective, or former employer requested Services, transactions, investments, distributions and/or benefits
  2. Administer and improve our Site
  3. Facilitate billing and collections
  4. Contact Clients and consumers with information on Services, new Services or products, or upcoming events, including via SMS or MMS text messaging if mobile phone number is provided for that purpose
  5. Market our Services to Clients and consumers or for auditing our interactions
  6. Detect fraud or theft or for other security purposes
  7. Comply with legal, reporting, and regulatory requirements
  8. Maintain, manage, or service accounts
  9. Provide customer service or support
  10. Verify consumer identity as well as eligibility to receive Services, information, and products
  11. Research and develop technological improvements
  12. Send transactional communications as part of our Services
  13. Improve, upgrade, or enhance our Services
  14. Administer quality and safety maintenance for our Site or Services
  15. For other purposes that are compatible with this Privacy Policy or where permitted by applicable law
  16. In any other way we may describe when you provide the information, or for which you provide authorization

Sources of Collection of Personal Information

We collect Personal Information from the following sources:

  • When a client provides it to NannyChex to facilitate the processing of the Services
  • From you when you utilize the Site or Services
  • From applications, forms, webinars, surveys, and other information you provide us
  • If you provide us with comments or suggestions, request information about our Services, or contact our customer service or support departments via phone, email, chat or other forms of communication
  • From consumer and business reporting agencies regarding your creditworthiness or credit history
  • Between NannyChex and third party vendors

Categories of Third Parties with Whom We Disclose Personal Information

We may use, disclose, or transmit Personal Information we collect to other service providers or other third parties for business purposes, to provide our Services, or for other purposes as provided by the CCPA as described below:

  1. Our affiliates, partners, or subsidiary organizations
  1. Government agencies to fulfill legal, reporting and regulatory requirements
  2. Attorneys, accountants and auditors
  3. Our employees, affiliated companies, subsidiaries, contractors, agents and third-party vendors to perform Services related to your account, to offer additional Services, perform analysis to determine qualification to receive future services, collect amounts due, or for our business operations
  4. Third-party providers for services that you may sign-up for via our Site or Services
  5. Banking and brokerage firms to process payroll-related and/or securities transactions
  6. To a buyer or successor in the event of 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 is among the assets transferred
  7. Credit bureaus and similar organizations, law enforcement or government officials. We reserve the right to release information if we are required to do so by law or if, in our business judgment, such disclosure is reasonably necessary to comply with any court order, law, or legal process, in a fraud investigation, an audit or examination
  8.  Health and welfare providers in support of benefit Services
  9.  Cloud providers, customer management platforms, security providers, and similar Services in connection with providing products, Services and in the support of daily operations
  10. Any other entity disclosed by NannyChex when you provide the information, or for which you provide authorization

The chart below describes the categories of Personal Information collected in the previous twelve months, the business or commercial purposes for such collection, and the categories of third parties with whom we have disclosed Personal Information in the previous twelve months.

Category of Personal Information that We May Collect and Transmit

 

Examples

 

Collected During the Past 12 Months Business or Commercial Purpose(s) Categories of Third Parties with Whom We Disclosed Personal Information During Past 12 Months
Personal Information  Full name, address, telephone number, social security number, date of birth, driver’s license number, passport numbers, financial, bank account, geolocation data, medical and beneficiary information, signatures, vaccination related information, and similar identifiers Yes 1-16 A-K
Sensitive Personal Information ·         Social security number, driver’s license, state ID card, passport number, a consumer account login, financial account, debit card or credit card number in combination with any: required security code, password, credentials allowing access to an account, a consumer’s precise geolocation, racial or ethnic origin, religious or philosophical beliefs, union membership, contents of: a consumer’s mail, email and text messages (unless the business is the intended recipient), consumer’s genetic data, processing of biometric information for the purpose of uniquely identifying a consumer, Information collected and analyzed concerning a consumers health, sex life and sexual orientation

 

Yes 1-3,5-10,12-16 A-K
Protected Personal Characteristics Age (40 years or older), race, color, ancestry, sex, gender identity, sexual orientation, national origin, marital status, veteran or military status, medical information (including medial conditions, disabilities), and similar identifiers Yes 1-3,5,7,8-10,12,13,15,16 A-E,G-K
Profession and Employment Related Information (job applicants) Employment history, job title(s), work descriptions, locations, dates worked, performance evaluations, and similar information Yes 1-5,7-10,13,16 A-E,G-H,J-K
Education Information (non-public) Institution name, degree, GPA, years attended, professional certifications, visa sponsorship and similar information No
Internet and Other Electronic Identifiers Unique user ID, browsing history, cookie data, IP address, unique device information, session logs, analytics logs, geolocation data, and similar identifiers Yes 1-2,4-11,14-16 A,C-E,G-K
Inference Information Profile reflecting preferences, characteristics or predispositions, product and service interests, order histories, search histories and similar information Yes 1,2,4,5,12,13,15,16 A,D-E,G,J-K
Biometric Information Iris, finger, facial scan, or voice used in the creation of identification templates for time products and voice assistance services No
Geolocation Data Physical location, Device coordinates/location, or movements Yes 1,8-10,13-16 A-D,G,H,K
Sensory Information Images, visual, thermal, olfactory information, audio or video recordings related to the services Yes 1,2,5-11,13-16 A-D,G,H,K

Categories of Personal Information Sold or Shared to Third Parties

NannyChex does not sell or share Personal Information with Third Parties. We only make business purpose disclosures as detailed above and pursuant to written contracts that describe the purposes of use, require the recipient to keep Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract.

Consumer Rights under CCPA

The CCPA provides consumers with specific rights regarding their Personal Information. This section explains how those rights may be exercised. NannyChex is receiving requests directly from consumers on behalf of its clients.  As a Service Provider to our clients, we may not be able to execute all requests. Consumers may wish to reach out to their employer or former employer when making such requests.

  1. Consumers have the right to request to certain information about our collection and use of Personal Information (the “Right to Know”) or access to specific pieces of personal information (“Specific Request to Know”). Consumers may only submit two requests per a twelve-month period.
  2. Consumers have the right to request correction of Personal Information (“Right to Correct”). We have processes in place to allow consumers to correct Personal Information. Please see this information in our Privacy Policy (See, Changing, Correcting or Removing Information and Closing Account). As of January 1, 2023, you may call us at 877-626-6924 if you have additional questions regarding the ability to correct information.
  3. Consumers have the right to request deletion of Personal Information, subject to certain exceptions (the “Right to Delete”). Once we receive a request and confirm the consumer’s identity we will review the request to determine if an exception allowing us to retain the information applies. We may deny a deletion request if retaining the Personal Information is necessary for us to:
  • Complete the transaction(s) for which we collected the Personal Information including to provide Services to our clients, provide a good or service that was requested, take actions reasonably anticipated within the context of our ongoing business relationship with our Registered Users, or otherwise to fulfill our contractual obligations; and/or
  • As otherwise allowed by the CCPA.
  1. We will not discriminate against consumers for exercising CCPA rights including refusing Services or offering different pricing models.

How To Exercise Rights Under CCPA

As January 1, 2023 California consumers or authorized agents may submit a request in one of the following ways:

  1. By using our CCPA Request Form
  2. By calling us at 877-626-6924

If you’re making a request as an Authorized Agent, we will email you a CCPA Authorized Agent Form after you submit the request. The CA consumer must fill out and sign the Form, and you or the consumer will need to send us a copy of the completed form in order for us to fulfill your request.  If the request is submitted by someone with a power of attorney (POA), the POA may be submitted instead of the Authorized Agent Form.

When submitting a request under CCPA, we are required to reasonably validate the requestor to appropriately secure Personal Information. If we cannot validate the requestor based on the information provided, we will notify the requestor that we are unable to fulfill the request. We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make it. We will confirm receipt of a request within ten (10) business days. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period. We do not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will detail why we made that decision and provide a cost estimate before completing the request.

Updates to this CCPA Policy

Please refer to this CCPA Policy regularly as it may be revised due to legislative changes, changes in technology or our privacy practices or new uses of customer information not previously disclosed in this CCPA Policy. Revisions are effective upon posting. If you have any comments, concerns or questions about this CCPA Policy, please contact us at 877-626-6924.

This CCPA Policy does not apply to current or former employees or independent contractors of NannyChex.

 

Last Updated January 4, 2023