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PRIVACY POLICY FOR INDEPENDENT CONTRACTORS

Privacy Policy
for California Independent Contractors

Last Updated: January 1, 2023

This Privacy Policy (“Privacy Policy”) describes how the ClearChoice Dental Implant Center that employs you and its affiliates, including ClearChoice Management Services, LLC (collectively, “Company”, “we”, “us,” and “our”) may collect, use, retain, and disclose personal information about our independent contractors who are California residents, and their rights with respect to their personal information.

For purposes of this Privacy Policy, “personal information” has the meaning given in the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”) but excludes information exempted from the CCPA’s scope.

This Privacy Policy does not create or form part of any contract nor is it intended to create an employment relationship between the Company and you.

If you have questions about this Privacy Policy or to exercise your privacy rights under the CCPA, please follow the instructions at https://www.clearchoice.com/legal/privacy-policy/ or contact CCMS.Legal@clearchoice.com.


1. Personal Information We Collect About Independent Contractor

Categories of Personal Information

The categories of personal information we may collect, or may have collected in the 12 months preceding the “Last Updated” date of this Privacy Policy, and process before, during and after your engagement with the Company include:

  • Identifiers, such as:

    • Contact information, such as your work and home address, telephone number, and email address.

    • Identification information, such as your name, social security number, government-issued identification information (e.g., driver’s license, passport), or other similar identifiers.

  • Protected classifications, such as:

    • Immigration status, such as your citizenship and and other information that would allow us to verify your authorization to work.

    • Information needed to evaluate accommodation requests regarding potential disabilities or other health conditions.

  • Professional or employment related information, such as:

    • Role/function information, such as a description of current role/function and services, branch/unit/department, location, terms of engagement as an independent contractor or through a staffing agency or other third party that employs you, contract start and termination date(s) and reason.

    • Biographical information, such as gender, date of birth, professional history, references, language proficiencies, professional qualifications, information in your company biography, social media profiles and activity, and your photo.

    • Evaluation information, such as your resume/CV or other information, including materials provided by staffing agencies or other third parties, to evaluate your skills and qualifications (e.g., education history, professional qualifications, language, skills, certifications), and information necessary to complete background checks and other screens permitted by law.

    • Payment information, such as your fee and payment information, banking details, hours worked, and reimbursable expenses.

    • Credentials, access and system information, such as your Company email address, usernames, passwords, and badge number.

    • Other information you provide to us during the course of your engagement with us.

  • Education information, such as education records directly related to you and maintained by an educational institution, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

  • Internet or network activity, such as information about your use of, as well as content and communications you send and receive through, devices, Company communications, IT systems and applications (e.g., time of use, files accessed, search history, web pages viewed, IP address, device ID, device location).

  • Audio, electronic, visual, or similar information, such as information about your access to offices and facilities (e.g., badge scans and security camera footage).

In certain cases we may ask you for additional information for purposes of complying with applicable laws. We may also inquire about criminal records. We will do so only where permitted by applicable law.

To the extent we collect sensitive personal information (as defined under the CCPA), we only use or disclose it for purposes permitted under the CCPA (e.g., to provide payment, monitor for security incidents, and for compliance and safety purposes). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California independent contractors.


Sources of Personal Information

We collect personal information from you when we are exploring an engagement with you as well as during and after the course of the engagement.

We may also collect your personal information from various other sources and combine it with the personal information you provide to us. For example, we may collect your personal information from:

  • your employers, including staffing agencies or other third parties that refer you to us;

  • professional references;

  • providers of background check, credit check, or other screening services (where permitted by law);

  • your public social media profiles or other publicly available sources;
    employment agencies or recruiters;

  • Company communications and IT systems/applications that automatically collect information about, and transmitted by, users; and

  • other Company personnel.


2. Purposes of the Collection and Use of Personal Information

We may use the categories of personal information above for the following business purposes or as otherwise described at the point of collection:

  • Workforce management. Managing work activities and personnel generally, such as:

    • paying fees in respect of your services and managing authorized expense reimbursements;

    • performing background, reference, or credit checks;

    • accommodating disabilities or health conditions;

    • providing information technology resources and support;

    • maintaining internal personnel directories;

    • communicating with you; and

    • otherwise administering our engagement with you.

  • Business operations. Operating and managing our business, including managing communications and IT systems; research, development and operation of our products and/or services; managing and allocating Company assets and personnel; strategic planning and project management; business continuity; maintenance of business and audit records; budgeting, financial management and reporting; internal communications; promoting our business; physical and information security; and evaluating and undergoing mergers, acquisitions, sales, re-organizations or disposals, and integration with purchasers.

  • Compliance, safety, and fraud prevention. Complying with legal and other requirements, such as tax, audit, recordkeeping, reporting, verifying identity; complying with lawful requests and legal process, such as responding to subpoenas or requests from government authorities; protecting our, your or others’ rights, safety and property; investigating and deterring against fraudulent, harmful, unauthorized, unethical or illegal activity, or conduct in violation of our policies or procedures; pursuing legal rights and remedies, including investigating, making and defending complaints or legal claims; administering and enforcing internal policies and procedures; and sharing information with government authorities, law enforcement, courts, or private parties for the foregoing purposes.

  • Monitoring. Monitoring offices and facilities, IT and communications systems, devices, equipment and applications through manual review and automated tools such as security software, website and spam filtering, and monitoring our physical premises (e.g., by using security cameras and keycard scans) to protect our, your or others’ rights, safety and property; operate, maintain and protect the security of our network systems and devices; protect our proprietary and confidential information and intellectual property; for recordkeeping and archiving; for personnel training (where applicable); for the compliance, safety and fraud prevention purposes described above; to investigate and respond to security and other incidents; and for business continuity (such as monitoring business-related emails following an independent contractor’s departure).

  • Research and Development. Creating anonymous, aggregated or de-identified data that we use and share to analyze our workforce and business and for other lawful business purposes.

  • With Your Consent. We will use and disclose your personal information in accordance with your prior direction or, in some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.


3. Disclosure of Personal Information

We may disclose, and during the 12 months preceding the “Last Updated” date of this Privacy Policy may have disclosed, each of the categories of personal information described in Section 1 with other parties as necessary for the business purposes described above or as described at the time of collection, including the following persons or entities:

  • Affiliates. Our corporate parent, subsidiaries, and other affiliates under the control of our corporate parent, for purposes consistent with this Privacy Policy or to operate shared infrastructure, systems and technology.

  • Company service providers. Providers of services to the Company, such as training (where applicable), IT systems and support, information and physical security, and background checks and other screenings.

  • Business contacts. Current and prospective customers and other business contacts with whom you interact with in the ordinary course of your engagement.

  • Government authorities, law enforcement and others. Government authorities, law enforcement, courts, and others as described in the compliance, safety, and fraud prevention section above.

  • Business transfer participants. Parties to transactions and potential transactions whereby we sell, transfer or otherwise share some or all of our business or assets, including your personal information, such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

  • Professional advisors. Accountants, auditors, lawyers, insurers, bankers, and other outside professional advisors who require your information in the course of providing their services.

  • Customers and business partners. Customers, other companies and individuals with whom the Company does business or is exploring a business relationship.

We do not and, during the 12 months preceding the “Last Updated” date of this Privacy Policy, have not “sold” or “shared” personal information about employees. Further, we do not knowingly “sell” or “share” the personal information of California residents under 16 years of age.


4. Retention of Personal Information

We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.


5. Your California Privacy Rights

California independent contractors may exercise the rights listed below by contacting us as described at the beginning of this Privacy Policy. However, these rights are not absolute, and in certain cases we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.

  • Know/Access. You can request the following information about how we have collected and used your personal information:

    • the categories of personal information that we have collected.

    • the categories of sources from which we collected personal information.

    • the business or commercial purpose for collecting, selling, or sharing (if applicable) personal information.

    • the categories of third parties with whom we disclose personal information.

    • a copy of the personal information that we have collected about you.

  • Delete. You can ask us to delete the personal information that we have collected from you.

  • Correct. You can ask us to correct inaccurate personal information that we maintain about you.

  • Nondiscrimination. You are entitled to exercise the rights described above free from discrimination.

To submit a request, please contact us using the contact information at the top of this Privacy Policy.

We may need to confirm your identity to process your requests to know/access, delete, or correct. In addition, consistent with California law, you may designate an authorized agent to make a request on your behalf. If you do so, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.


6. Third Party Services

This Privacy Policy does not address, and we are not responsible for, the practices of any third parties, which have their own rules for how they collect and use your personal information. Our links to third party websites or services are not endorsements.


7. Changes to this Privacy Policy

We reserve the right to change this Privacy Policy at any time. The “Last Updated” date at the top of this Privacy Policy indicates when it was last revised. Any changes will become effective when we post the revised Privacy Policy where we make it available to you.


8. Your Obligations

It is your responsibility to ensure that information you submit does not violate any third party’s rights.

You should keep your personal information on file with the Company up to date and inform us of any significant changes to it.