The privacy of our visitors to our website (https://www.adaptivewfs.com) is important to us. The purpose of this Privacy Notice is to provide visitors of our website with information concerning the types of information Adaptive Workforce Solutions collects, how it is used, and other, related information concerning the security of information. This Privacy Notice applies to all visitors of our website and is intended to comply with privacy laws including the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this notice. Please read our Privacy Notice carefully to get a clear understanding of how we collect, use, protect, or otherwise handle such information.
Information Adaptive Workforce Solutions (“we,” “our,” or “us”) Collects
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 consumer or device (“Personal Information”). In particular, Adaptive Workforce Solutions has collected the following categories of Personal Information from consumers, both online and “offline,” within the last twelve (12) months:
|Category||Examples of Such Personal Information||Collected|
|A. 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. Some Personal Information included in this category may overlap with other categories.||YES|
|B. 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.||YES|
|C. 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).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||YES|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||NO|
|G. Geolocation data.||Physical location or movements. Internet Protocol addresses, for example, may provide information about where a consumer is located when they visit our website.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history including job titles, departments, job roles, and performance evaluations. Information you might provide about others you would like us to contact (for example, referrals or references) or emergency contact information. Information about employment and education history, such as language proficiencies, security clearance information, and other work-related skills, awards, and honors, membership in organizations, personal interests and activities, and information regarding your career interests and other qualifications for or desires regarding future employment opportunities, including information regarding desired compensation and benefits. Information concerning your citizenship and work authorization status. New hire/onboarding paperwork, including resumes, employee applications, background check results, IRS Form W-4 (withholding), payroll information (including employee bank account numbers for direct deposit), credit card information provided in connection with expense reports, drug testing paperwork and results, documentation related to various types of leave (e.g., sick leave, vacation, Family and Medical Leave Act, etc.), employee benefit plans (to the extent they are not exempt from the CCPA).||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||YES|
|K. Inferences drawn from other Personal Information.||A profile of a person reflecting their preferences or desires to work in a particular geographic location, to perform a certain type of work, and to earn a certain amount of compensation. This information may be inferred from a person’s professional history and/or may be collected directly from a person during conversations intended to elicit this sort of preferential information.||YES|
Personal Information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’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 certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from prospective workers, applicants, and current or former employees who provide such Personal Information to us to determine their fit for a particular assignment or employment opportunity and/or for future assignments or employment opportunities. Collection of this information may come from both online and offline sources (e.g., social media platforms, by email, telephone, at trade shows, or other events).
- Indirectly from third-party sources, which may include current or former workers or employees providing a referral of a friend or colleague or other third-party sources such as Indeed.com, Monster.com, or LinkedIn.com. Collection of this information may come from both online and offline sources (e.g., social media platforms, by telephone, at trade shows, or other events).
- Indirectly from third-party sources such as background check providers or the National Practitioner Data Bank.
- Indirectly from sources who make such information publicly available, such as job boards or professional social media websites where Personal Information is made available by individuals and can be viewed by recruiters.
- Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us. Collection of this information may come from both online and offline sources (e.g., social media platforms, by telephone, at trade shows, or other events).
- Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
- Directly and indirectly from activity on our website (www.abstaffing.com). For example, from submissions through our website portal or website usage details collected automatically.
- From third-parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.
Purposes for Collection/Use of Personal Information
The Personal Information we collect will be used only as described in this Notice and/or in the way we may specify at the time of collection. Our primary purpose for collection of Personal Information and any subsequent use of such Personal Information is to effectively provide and improve the services that Adaptive Workforce Solutions offers.
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 Adaptive Workforce Solutions with Personal Information to find a temporary assignment or temporary employment, we may use that information to evaluate potential opportunities and submit that information to organizations to determine your candidacy. Put simply, we may use Personal Information to match job seekers with job positions, or to match job positions with job seekers.
- To take steps to enter into any contract or carry out our obligations arising from any contract entered into between you and us.
- To keep records of individual activity, such as geographic locations where an individual works and the compensation they have earned. This information can help us personalize your experience by determining if other employment or working opportunities might be of interest to you.
- To provide you with information that you request from us.
- To follow-up with you after correspondence (e.g., via live chat, email, or by telephone).
- To provide you with alerts, information, or other notices concerning assignment or employment opportunities that may be of interest to you.
- To notify you about changes in the services we provide.
- To engage in or maintain an employment relationship with you or for any other employment-related permissible purposes, including administration of benefits and recruiting efforts.
- To carry out Adaptive Workforce Solutions’ obligations and enforce our rights arising from any contracts entered into between you and us and/or between third parties (i.e., clients) and us, including for billing and collections.
- For data security purposes.
- To improve our website and present its contents to you.
- To administer a contest, promotion, survey, or other, similar site feature.
- To quickly process your transactions.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To 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.
- To evaluate or conduct 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.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without first providing you notice.
Adaptive Workforce Solutions Does Not Sell Personal Information
In the preceding twelve (12) months, we have not sold any Personal Information. Adaptive Workforce Solutions will never sell, rent, or lease your Personal Information to any external company unless you have granted us permission to do so.
No Services for Minors/Child Online Privacy Protection Act
We do not knowingly collect information from minors. To use this site, you must be the age of legal majority in your place of residence. By using this site, you hereby represent that you are at least the age of legal majority in your place of residence. We do not use an application or other mechanism to determine the age of users of our website. All information provided to us will be treated as if it was provided by an adult. We will use commercially reasonable efforts to delete information associated with a minor as soon as practicable if we learn that a minor has submitted information about themselves to us.
If you are a parent or guardian and you are aware that your child or children have provided us with Personal Information, please contact us.
California Online Privacy Protection Act (“CalOPPA”)
According to CalOPPA, we agree to the following:
- Users can visit our site anonymously
Can change your personal information:
- By emailing us
- By logging in to your account
- By chatting with us or by sending us a support ticket
How does our site handle Do Not Track signals?
We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Does our site allow third-party behavioral tracking?
It’s also important to note that we allow third-party behavioral tracking
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or question
- Process orders and to send information and updates pertaining to orders
- Send you additional information related to your product and/or service
- Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CANSPAM, we agree to the following:
- Not use false or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Include the physical address of our business or site headquarters.
- Monitor third-party email marketing services for compliance, if one is used.
- Honor opt-out/unsubscribe requests quickly.
- Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, please follow the instructions at the bottom of any one of our emails and we will promptly remove you from all correspondence.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you services.
- Provide you with a different level or quality of services.
- Suggest that you receive a different level or quality of services.
Changes to Our Privacy Notice
With respect to the Personal Information we collect, we have implemented reasonable technical and physical security protocols (1) to ensure the security and preserve the confidentiality of the information, (2) to protect against any anticipated threats or hazards to the security or the integrity of the information, (3) to protect against unauthorized access to or use of the information, and (4) to ensure proper disposal of the information. For example, our Jobs at Adaptive Workforce Solutions website located at https://www.adaptivewfs.com is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. We also regularly complete Malware Scans.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user places an order to maintain the safety of your personal information.
All transactions are processed through a gateway provider and are not stored or processed on our servers.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of information transmitted to the Site. Accordingly, any transmission of information is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorized access.
Do we use “cookies?”
- Help remember and process the items in the shopping cart.
• Understand and save user’s preferences for future visits.
• Keep track of advertisements.
• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.
If you turn cookies off, some of the features that make your site experience more efficient may not function properly.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
We use Google AdSense Advertising on our website.
We have implemented the following:
- Remarketing with Google AdSense
• Google Display Network Impression Reporting
• Demographics and Interests Reporting
• DoubleClick Platform Integration
We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.
Occasionally, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We are not responsible or liable for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback you may have about these sites.
If you have any questions or comments about this Notice, the ways in which we collect and use your Personal Information, or your choices and rights regarding such use, contact us at:
Date of Notice/Last Updated: January 2020