Privacy Policy

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of iTech Solutions, Inc. and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to vendors, users, and others who reside in the State of California (“consumer” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (CPRA), and other California Privacy Laws.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular candidate or household (“personal information”). In particular, we have collected the following categories of personal information from candidates within the last twelve (12) months:

• Publicly available information from government records, provided that the data is used for a purpose that is compatible with the purpose for which the data is maintained and made available in the records. Publicly available information also includes information that we have a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media.
• De-identified or aggregated consumer information. De-identified information means information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer, provided that we have implemented technical safeguards and business processes to prevent re-identification.
• Information excluded from the CCPA and CPRA’s scope, such as:

• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.
• Personal information covered by specific privacy laws, including:
• The Fair Credit Reporting Act (FRCA).
• The Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA).
• The Driver’s Privacy Protection Act of 1994.
• The Family Educational Rights and Privacy Act (FERPA)

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

• Directly from you. For example, through forms you complete during the application or onboarding process, or information you provide during interviews and communications.
• Indirectly from you. For example, information we collect from in the course of providing services to you, such as through your use our systems and networks.
• From our clients or their agents. For example, through information we receive from our clients related to the services for which they engage us.
• From third-party service providers. For example background check agencies, or employment verification services that interact with us in connection with the onboarding requirements we perform.
• From public sources. For example, information from public social media profiles or professional networking sites, if applicable.
• From government agencies or regulatory bodies. For example when we verify eligibility for employment or compliance with legal obligations.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information to submit your resume for employment, we will use that information to prepare and submit it to corresponding client job requisition, and designated background vendors for onboarding screening requirements.
• To provide you with information, or services that you request from us.
• To communicate with you about your recruitment and onboarding process, including sending email C texting alerts, and other notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for employment purposes.
• To operate, evaluate, and improve our business, including developing new services, managing communications, performing data analytics, and enhancing our Applicant Tracking System (ATS) portal and HRIS/Payroll system.
• For auditing, security, and fraud prevention purposes.
• For data analysis, reporting, and service development, to enhance our services and performance.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To comply with legal obligations, respond to law enforcement requests, and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA as amended by the CPRA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal information held by us is among the assets transferred.

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

Retention of Personal Information

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, as outlined above, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you.
• Whether there is a legal obligation to which we are subject.
• Whether retention is advisable considering our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

Right to Limit Use of SPI:

We collect and use Sensitive Personal Information (SPI) only as necessary to perform the services or provide the goods reasonably expected by an average consumer, or for other purposes authorized by the CPRA. We do not use or disclose SPI for purposes other than those specified in the CPRA. You have the right to limit the use and disclosure of your SPI to those purposes authorized by the CPRA. To exercise this right, please contact us using the information provided in the “Contact Information” section below.

Sale or Sharing of Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract and will require at all times that you sign a consent C release of authorization before continuing further.

In the preceding twelve (12) months, we have disclosed the following categories of personal information 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 D: Sensitive Personal Information (SPI)
Category I: Professional or employment-related information.

When we disclose personal information for a business purpose we enter into a contract that:

• Describes the purpose of the disclosure;
• Requires that the recipient to keep the personal information confidential;
• Prohibits the recipient from using the information for any purpose other than those specified in the contract
• Requires recipient to comply with all applicable privacy laws.

We do not sell personal information for monetary consideration. We also do not share personal information for cross- context behavioral advertising purposes as defined under the CPRA.

Your Rights and Choices

The CCPA, as amended by the CPRA, provides California residents with specific rights regarding their personal information. This section describes your rights and explains how to exercise them.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or employment purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed your personal information for business purposes, we must disclose the categories identifying the personal information

Right to Correct

You have the right to request that we correct any inaccurate personal information we maintain about you

Right to Deletion

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.

We may deny your deletion request if retaining the information is necessary for us, our clients or service providers to:

1. Complete the transaction for which the personal information was collected.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity.
3. Debug to identify and repair errors.
4. Exercise free speech or ensure the right of another consumer to exercise their free speech rights.
5. Comply with the California Electronic Communications Privacy Act.
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest.
7. Enable solely internal uses that are reasonably aligned with consumer expectations.
8. Comply with a legal obligation.
9. Otherwise use the personal information internally in a lawful manner compatible with the context in which you provided it.

Right to Non-Discrimination

We will not retaliate against you for exercising any of your rights under the CCPA, as amended by the CPRA, we will not:

• Deny you employment.
• Charge you with different rates for services, whether through denying benefits, or imposing penalties.
• Provide you a different level or quality of services.
• Threaten you with any of the above.

Exercising Your Rights

To exercise your rights to access, data portability, deletion, correction or to limit the use of your sensitive personal information, please submit a verifiable consumer request to us by either:

• Calling iTech at 860-674-1636
• Emailing at hr@itechsolutions.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. 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.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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. 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.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. On receiving an access request, we will provide the necessary information in a portable and easily accessible format by mail or electronically, any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

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

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on the company’s ADP Intranet homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: www.itechsolutions.com
Email: hr@itechsolutions.com
Postal Address:
iTech Solutions, Inc.
Attn: Andrea L Bonello, HR Manager
20 Stanford Drive
2^nd Floor
Farmington, CT 06032
Phone: 860-979-0917