Bright Sky CPRA Employee / Applicant / Independent Contractor Notice

Effective date: 4/29/23

I. Personal Information Collected, Used, Disclosed, Sold or Shared

Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 and its implementing regulations (“CPRA”), we are required to notify you that we collect certain personal information in connection with your employment, application for employment or independent contractor relationship. In particular, we collect, use and disclose the following categories of “personal information” regarding job applicants, employees and their emergency contacts and beneficiaries, and independent contractors:

Categories of Personal Information Collected	Disclosed for a Business Purpose?	Categories of Third Parties to whom the Personal Information is Disclosed
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	Third-party service providers including, but not limited to, payroll processors, benefits administration providers and data storage or hosting providers as well as credit card vendors, travel agents and similar service providers who support the performance of your employment responsibilities Other members of our group of companies Government agencies or law enforcement to comply with legal obligations or valid legal processes such as search warrants, subpoenas or court orders and to protect our rights and property or protect the rights, property or safety of others Buyers/acquirors in the event of a corporate transaction, including but not limited to a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy
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	Yes
Characteristics of protected classifications under California or federal law (race, color, national origin, religion, gender (including pregnancy), disability, age (at least 40 years old), citizenship status, sexual orientation, gender identity and gender expression)	Yes
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding interaction with an internet web site, application, or advertisement	Yes
Audio, electronic, visual, thermal, olfactory, or similar information	Yes
Professional or employment-related information	Yes
Education information	Yes

We collect, use and disclose the following categories of sensitive personal information regarding applicants, employees and their emergency contacts and beneficiaries, and independent contractors:

Categories of Sensitive Personal Information Collected	Disclosed for a Business Purpose?	Categories of Third Parties to whom the Sensitive Personal Information is Disclosed
Personal information that reveals social security, driver’s license, state identification card, or passport number	Yes	Third-party service providers including, but not limited to, payroll processors, benefits administration providers and data storage or hosting providers as well as credit card vendors, travel agents and similar service providers who support the performance of your employment responsibilities Other members of our group of companies Government agencies or law enforcement to comply with legal obligations or valid legal processes such as search warrants, subpoenas or court orders and to protect our rights and property or protect the rights, property or safety of others Buyers/acquirors in the event of a corporate transaction, including but not limited to a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy
Personal information that reveals account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account	Yes
Personal information that reveals racial or ethnic origin, religious or philosophical beliefs or union membership	Yes
Personal information collected and analyzed concerning an individual’s health	Yes
Personal information collected and analyzed concerning an individual’s sex life or sexual orientation	Yes

Bright Sky does not use or disclose the above sensitive personal information for any purpose other than those permitted under the CPRA.

Bright Sky does not have actual knowledge that it collects, sells or shares such information of minors under 18 years of age.

The personal information, including the sensitive personal information, described above are collected directly from you when you apply for employment and during your employment or from other sources such as benefit providers, third parties for reference checks (e.g., past employers), recruitment agencies, background check agencies, timekeeping software, internal or third-party tracking of usage of Bright Sky email and telephone systems and computer networks, public agencies (e.g., tax authorities, the California Department of Fair Employment and Housing, the California Labor Commissioner, the California Occupational Safety Administration, and if applicable to the position, the California Department of Motor Vehicles), workers’ compensation carriers, law enforcement agencies and litigation.

We use the personal information, including the sensitive personal information, described above only for business purposes related to your employment, application for employment, or independent contractor relationship. Those purposes may include:

To evaluate an applicant’s qualifications and suitability for employment
To administer pre-employment and post-employment tests and training activity
To complete the onboarding process
To conduct criminal and other background checks on applicants and employees
To manage the terms and conditions of employment, such as payment of wages/salary, direct deposit authorization, the provision and administration of benefits and leaves of absence and maintenance of emergency contact information
To process work related claims (e.g., insurance claims)
To prepare and maintain legally required records, such as I-9 forms, EEO-1 forms and affirmative action plans
To provide a safe work environment
To manage employee timekeeping
To maintain information regarding training, disciplinary action, injuries and other employment history
To ensure compliance with company policies and regulatory and legal requirements
To meet tax obligations
To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity
To achieve other operational purposes for which the personal information was collected that are compatible with the context in which the personal information was collected and our employment or independent contractor relationship

II. Security and Retention

We employ physical, technical and organizational security measures designed to protect your personal information against accidental loss and unauthorized access, use, alteration or disclosure. In addition, we limit access to personal information to those employees, agents, contractors and other third parties that have a legitimate business need for such access.

Please note, however, that the security of any information transmitted through the Internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the Internet or for changes to or losses of data. You are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our websites, including our employee or job opportunity pages and Intranet. In order to protect us, you and your personal information, we may suspend your use of our websites, without notice, if any breach of security is suspected. Access to and use of password protected and/or secure areas of our website(s) are restricted to authorized users only. Unauthorized access to such areas is prohibited.

We will retain the personal information, including sensitive personal information, described above as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.

III. CPRA Rights

As a California resident, you have the following rights under the CPRA:

Right to Know: You have the right to request that we disclose certain information to you about our collection and use of certain personal information, including sensitive personal information, about you as described below:

The specific pieces of personal information collected;
The categories of personal information collected;
The categories of sources from whom the personal information is collected;
The purpose for collecting, selling or sharing the personal information;
The categories of third parties with whom we have disclosed the personal information;
The categories of personal information that we have sold or shared, and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each third party to whom the personal information was sold or shared;
The categories of personal information that we disclosed for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

Right to Delete: You have the right to request that we delete your personal information, subject to certain exceptions.

Right to Correct Inaccurate Personal Information: You have the right to request that we correct inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

Right to Opt-Out of Sale or Sharing: As stated above, we do not receive any form of monetary consideration for the transmission of your personal information. However, we do use third-party cookies for targeted advertising purposes. The collection of data through certain third-party cookies for our targeted advertising purposes may be considered a “sale” and is considered “sharing” under the CPRA. To opt-out of having your information sold and shared with third-party website analytics and digital advertising service providers for this purpose, visit Do Not Sell or Share My Personal Information.

Right to Limit the Use and Disclosure of Sensitive Personal Information for Certain Purposes: As stated above, we do not use or disclose your sensitive personal information for any purpose other than those permitted under the CPRA.

Freedom from Discrimination: You have the right not to receive discriminatory treatment for exercising your rights above, including not to be retaliated against for exercising such rights.

IV. How to Exercise Your Rights

To exercise the rights above, you must submit a verifiable request to us via email at info@brightskyinc.com, by visiting brightskyinc.com/contact-us/ or calling us at (630) 595-6396.

To submit a verifiable request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the personal data that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors.

You may designate an authorized agent to make a request on your behalf by providing the agent with signed written permission to do so.

V. Contact

If you have any questions regarding the information contained in this notice, please contact us through any of the following:

Email Address: info@brightskyinc.com
Mailing Address: Bright Sky Inc., 1001 Fairway Drive, Bensenville, IL 60106

VI. Changes to Our Notice

Any changes to this notice will be posted to this page so users are always aware of the information we collect and how we use it. Accordingly, please refer back to this page frequently as it may change.