Human Capital Privacy Policy

Human Capital Privacy Policy

This Privacy Policy is effective as of December 19, 2019.

This Privacy Policy relates to Lytx, Inc., together with its affiliates (collectively, “Lytx”, “Company”, “we”, “us” and/or “our”), and describes our policies and practices with respect to Personal Information, as defined by the California Consumer Privacy Act, obtained from or related to our current and former employees (collectively referred to as “employees”), independent contractors, applicants, and their beneficiaries and emergency contacts, who are California residents.  

What Categories of Employee Information Do We Collect and How Do We Use This Information?

We collect the following categories of Personal Information for the purposes described below:

  • New-Hire Onboarding Information, such as name and contact information; work history, education, skills, and information collected during application process; job title and duties; Social Security Number, driver’s license number, passport and other government identification numbers; age, birth date and place; availability for work; immigration and work authorization status; emergency contact information; signature; withholding tax information; marital status; voluntary self-disclosure information regarding minority, veteran, and disability status; and dependent and beneficiary information.  The Company collects this information to onboard new employees and to comply with applicable laws.
  • Pay Information, such as pay rate, hours or time worked, and bonus amounts or percentages; commission amounts; payroll deduction information; banking information for direct deposit, and credit card information for, and details related to, expense reimbursement.  The Company collects this information to pay its employees and comply with applicable laws.
  • Benefits Enrollment and Administration Information, such as benefit entitlement and selection information; beneficiary information; Social Security Numbers or other government identification numbers; dates of birth; dependents; holidays and leave information, including usage information; travel information; and other information necessary to administer benefits programs and process benefits claims.  The Company collects this information to enroll and administer Company benefits for employees and their beneficiaries.
  • Performance Management Information, such as employment status (full-time or part-time, regular or temporary); work schedule; job assignments; hours worked and attendance information; accomplishments and awards; training and development information; performance evaluation information; policy compliance and internal audit information; discipline, counseling, and appeal information; grievances and complaints; and employment termination information.  The Company collects this information to manage our employment relationship with employees.
  • Equality and Diversity Information, such as minority, veteran and disability status and other characteristics protected by law.  The Company collects this information through voluntary self-disclosure and other means to implement the Company’s diversity programs and to comply with applicable laws.
  • Health and Safety Information, such as health condition, job restrictions, workplace accident and illness information, and health insurance information.  The Company collects this information to maintain a safe workplace, assess your working capacity, administer health and Workers’ Compensation insurance programs, and comply with applicable laws.
  • Electronic Communications and Tracking Information, such as email, text, computer, internet, telephone, and mobile device usage; IP address; log-in information; video surveillance and location information.  The Company collects this information to protect Company, customer, and employee property, equipment and confidential information; monitor employee performance; and enforce the Company’s Use of electronic Communications Policy.
  • Legal and Contractual Information, such as information necessary to respond to law enforcement and governmental agency requests, comply with legal and contractual obligations, exercise legal and contractual rights; and initiate or respond to legal claims.  The Company collects this information to comply with legal and contractual requirements and to establish, exercise and defend legal and contractual rights and claims.

What Categories of Independent Contractor Information Do We Collect and How Do We Use This Information?

We collect the following categories of Personal Information for the purposes described below:

  • Name and contact information;
  • Employer Identification Number and/or other identification information;
  • Qualifications, licenses, and experience;
  • Information regarding services provided;
  • Billing, payment, expenses, and financial information;
  • Equality and diversity information; and
  • Electronic communications information such as emails, IP addresses, and telephone calls and voicemails.

The Company collects this information to retain qualified independent contractors and to comply with applicable laws.

What Categories of Emergency Contact Information Do We Collect and How Do We Use This Information?

We collect the following categories of Personal Information for the purposes described below:

  • Name and contact information; and
  • Relationship to employee.

The Company collects this information to contact the employee’s or independent contractor’s designated emergency contact person in the event of an emergency. If you provide us with Personal Information of an individual other than yourself, including without limitation Personal Information of your emergency contacts, you are responsible for providing such individual(s) prior notice of your submission of their Personal Information to us and a copy of this Privacy Policy.

What Categories of Beneficiary Information Do We Collect and How Do We Use This Information?

We collect the following categories of Personal Information for the purposes described below:

  • Name and contact information;
  • Relationship to the employee;
  • Birth date;
  • Social Security Number; and
  • Information necessary to process benefits claims.

The Company collects this information to enroll and administer benefits programs for beneficiaries of eligible employees.  If you provide us with Personal Information of an individual other than yourself, including without limitation Personal Information of your beneficiaries, you are responsible for providing such individual(s) prior notice of your submission of their Personal Information to us and a copy of this Privacy Policy.

What Categories of Personal Information Do We Collect When You Apply for a Position at Lytx and How Do We Use This Information?

We collect the following categories of Personal Information for the purposes described below:

  • Name, identification numbers and contact information;
  • Education, skills and qualifications;
  • Employment history and experience;
  • Military service;
  • Work availability;
  • Eligibility information, including age and immigration status;
  • Reference and background check information, including relevant criminal history and credit history;
  • Social media information;
  • Pre-employment test results;
  • Voluntary self-disclosure information regarding minority, veteran, and disability status; and
  • Information provided to you and by you during the hiring process.

The Company collects this information to hire the best qualified applicants and to comply with applicable employment laws.

Who Does Lytx Share My Personal Information With?

We may share your Personal Information with the following categories of recipients:

  • Affiliates and service providers, including without limitation
    • payroll processors
    • HRMS platform (i.e. Workday)
    • benefits providers
    • testing providers
    • background check providers
    • education and training services providers
  • In individual cases we may also share Personal Information with professional advisers including lawyers, bankers, auditors and insurers;
  • We may also share your Personal Information with our affiliated entities;
  • If we are involved in a merger or reorganization, sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by another company, we may transfer some or all of your Personal Information to such third party.

Lytx will never sell any Personal Information in any manner inconsistent with this Privacy Policy without such individuals consent. However, Lytx, its partners, agents, officers and employees may provide specific information collected about you, including Personal Information, to third-parties if required to do so by law or in the good faith belief that such action is required to: (i) protect Lytx against legal liability; (ii) protect and defend the rights or property of Lytx, including without limitation, exchanging information with other companies and organizations for fraud protection or investigation; (iii) comply with a legal obligation; or (iv) act in urgent circumstances to protect the personal safety of employees or the public.

Data collected from or about you may be used in an aggregate form, that is, as a statistical measure, and not in a form that would reasonably allow anyone to identify you. Along with using this data in aggregate form ourselves, we may share these statistics with certain strategic relations.

How Will Lytx Update This Privacy Policy?

Lytx reserves the right to update this Privacy Policy at any time. Any updates to this Privacy Policy will be posted to this location. We recommend that you check this Privacy Policy regularly for changes and read any related notices issued by us.

Does This Privacy Policy Apply to Information That I Provide to a Third Party?

This Privacy Policy applies only to Lytx’s collection and use of your Personal Information in connection with prospective, current or former employment.  This Privacy Policy does not apply to third party services to which Lytx does not control nor have access to your information. For example, information you provide directly to a benefits provider, such as your health care provider or financial institution, are not subject to this Privacy Policy.  Such third party services are governed by their own privacy statements and policies, and Lytx is not responsible for their operations, including but not limited to their information practices. You should read the privacy policies of each third party service provider.

What Happens in the Event of a Change in Corporate Structure?

Notwithstanding any of the foregoing, Lytx may sell, share or otherwise transfer some or all of its assets, including information  related to its workforce, in connection with a bankruptcy, merger, acquisition, reorganization or sale of substantially all of its assets or substantially all of the assets of a division or other unit of Lytx. You acknowledge that such transfers may occur and that any acquirer may continue to use your Personal Information as set forth in this Privacy Policy.

What if I Have Additional Questions?

If you have any questions about this Privacy Policy or would like to obtain a copy in a different accessible format, please contact us directly by e-mail at privacy@lytx.com. If you prefer to contact us by mail, please send any communications to:

Lytx, Inc.

 9785 Towne Centre Drive

 San Diego, California 92121

 Attn: Chief Privacy Officer