The privacy of our website (https://www.adaptivewfs.com) visitors is important to us. The purpose
of this Privacy Notice is to provide such visitors 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 of our website visitors
and is intended to comply with applicable 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 this 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

YES

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).

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

YES

elicit this sort of preferential information.

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.
 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.adaptivewfs.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 provide.
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 the 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 requested from us.
 To follow-up with you after correspondence (e.g., via live chat, email, text, 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 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 with 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”)
In accordance with CalOPPA, we agree to the following:
 Users can visit our site anonymously.
 Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on our
home page.

You will be notified of any Privacy Policy changes:
 On our Privacy Policy Page
You 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.
We collect your email address in order to:
 Send information, respond to inquiries, and/or other requests or questions.
 Process orders and 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.

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.
Non-Discrimination
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 service.

Changes to Our Privacy Notice
Your use of our website is subject to the current version of this Notice and any Privacy Policy
posted.  We reserve the right to amend this Notice at our discretion and at any time. When we
make changes to this Notice, any changes will become effective when we post the revised Notice
on our website, as indicated by the Date of Notice found after the end of this Notice at the bottom
of this webpage.
Data Security
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.

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 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?”
Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive
through your Web browser (if you allow) that enables the site’s or service provider’s systems to
recognize your browser and capture and remember certain information. For instance, we use
cookies to help us remember and process the items in your shopping cart. They are also used to
help us understand your preferences based on previous or current site activity, which enables us
to provide you with improved services. We also use cookies to help us compile aggregate data
about site traffic and site interaction so that we can offer better site experiences and tools in the
future.
We use cookies to:
 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 browsers are 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
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.
Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART
cookie enables it to serve ads to our users based on previous visits to our site and other sites on
the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and
Content Network privacy policy.
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.
Opting out
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.
Third-Party Links
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.
Contact Information

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:
Phone: 480-536-6588
Website: www.adaptivewfs.com
Email: Legal@abstaffing.com
Address: Adaptive Workforce Solutions LLC
Attn: Legal Department
111 E. Rivulon, Ste. 107
Gilbert, Arizona 85297
Date of Notice/Last Updated:  April 2, 2024