Notice at Collection and Privacy Policy for California HR Contacts

Last Updated: June 10, 2025

This Privacy Policy and Notice at Collection (“Privacy Policy”) explains Wilshire Law Firm’s (“Company” or “Wilshire”) collection, use, and disclosure of your personal information, as well as certain rights you may have relating to your personal information under the California Consumer Privacy Act of 2018 (the “CCPA”).

California Notice at Collection: Company collects the personal information identified in Section 1 for the purposes identified in Section 3 and retains it for the period described in Section 5. We do not sell your personal information or disclose it for cross-context behavioral advertising (“sharing”). We also do not collect or process sensitive personal information to infer characteristics about you. By providing us with any personal information, you agree that you are authorized to provide us with such information. To the extent you provide the Company with personal information about your dependents, spouse, beneficiaries, or emergency contacts, you are responsible for providing this notice to them.

Assistance For The Disabled

Alternative formats of this Privacy Policy are available to individuals with a disability. Please contact HR@wilshirelawfirm.com for assistance.

This Privacy Policy explains:

The categories of personal information we collect about you
The categories of sources from which we collect your personal information
The purposes for which we use your personal information
How we may disclose your personal information
Confidentiality
How long we keep your personal information
Your privacy rights and how to exercise them
Changes to this Privacy Policy

Scope:

This Privacy Policy applies only to the personal information of California residents who are Company (a) employees (“Team Members”), (b) applicants (“Team Member Applicants”), or (c) independent contractors, interns, other individuals who perform work for Company (collectively “Non-Team Member Workers”), or (d) Team Member and Non- Team Member Workers’ dependents, emergency contacts, and beneficiaries (“Related Contacts”), collectively all these groups are considered “HR Individuals”. This Privacy Policy informs HR Individuals about the categories of personal information Company has collected about them in the preceding twelve months as well as the categories of personal information that the Company will collect about them in the future.

Except where the Privacy Policy specifically refers only to a specific category, e.g., employees/team members, this Privacy Policy refers to all categories collectively.

“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular HR Individual.

“Personal information” does not include:

Information publicly available from government records or made publicly available by you or with your permission;
Deidentified or aggregated information;
Information excluded from the CPRA’s scope, such as:
- protected health information covered by the Health Insurance Portability and Accountability Act (“HIPAA”) or the Health Information Technology for Economic and Clinical Health Act (“HITECH”) or medical information covered by California Confidentiality of Medical Information Act (“CMIA”); or
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”), or the California Financial Information Privacy Act (“FIPA”).

THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT ABOUT YOU

We may collect, and may have collected during the 12-month period prior to the effective date of this Privacy Policy), the following categories of personal information. Not all categories may be collected from every individual.

- Identifiers, for example: real name, alias, telephone number, postal address, e-mail address, signature, bank account name and number for direct deposits, Social Security number for example for tax purposes, driver’s license number, and photographs.
- Professional or Employment-Related Information, for example: educational institutions attended, degrees and certifications, licenses, work experience and previous employers, professional memberships and affiliations, union representation, seniority, training, employment start and ending dates, and job title, and in some circumstances, compensation and benefits information such as salary, bonus and commission, equity compensation information, hours and overtime, leave information, bank details (for payroll and reimbursement purposes only), benefits in which you may be enrolled, and identifying information for dependents and beneficiaries.
- Education information, such as student records or other education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99);
- Commercial Information, for example: business travel and expense records.
- Internet or Other Electronic Network Activity Information, for example: Internet browsing and search history while using Company’s network, log in/out and activity on Company's electronic resources, interactions with Company’s Internet web site, application, or advertisement, and publicly available social media activity.
- Geolocation data, such as time and approximate physical location related to use of an internet website, application, device, or physical access to an office location;
- Biometric information, such as facial scans collected and used by our office security system.
- Sensory or Surveillance Data, for example: voicemails, recordings of meetings or videoconferences, and footage from video surveillance cameras, including through the use of artificial intelligence enabled security systems.
- Categories of personal information described in California Civil Code § 1798.80: personal information described under Cal. Civ. Code § 1798.80 to the extent not already included in other categories here, such as benefit information to administer short and long-term benefits as well as other benefit plans.
- Other information you choose to provide, for example, hobbies and leisure activities, membership in voluntary/charitable/public organizations, and preferences regarding work tools, travel, hours, food for company events, etc.
- Inferences and profiles based on other personal information, such as information about your behavior and aptitudes for hiring purposes;
- Demographic data or characteristics of Protected Classifications Under California or Federal Law, for example: race, age, national origin, disability, sex, and veteran status as necessary to comply with legal obligations and to support diversity and inclusion programs; disability, medical condition, and pregnancy, childbirth, breastfeeding, and related medical conditions, as necessary to comply with Federal and California law related to leaves of absence and accommodation; and marital and familial status as necessary to provide benefits to employees and for tax purposes.

We do not collect or process “sensitive personal information” (as defined by the CCPA) for purposes other than those identified in Cal. Code Regs. tit. 11 § 7027(m).

THE CATEGORIES OF SOURCES FROM WHICH WE COLLECT YOUR PERSONAL INFORMATION

We collect personal information from the following categories of sources and, during the 12-month period prior to the effective date of this Privacy Policy, may have collected or received (not all categories apply to every individual):

- You, for example, in your job application, forms you fill out for Company assessments you complete, surveys you submit, and any information you provide during the course of your relationship with Company.
- Affiliated companies, for example, when an employee works on a cross-enterprise team.
- Third parties such as our service providers and business partners, for example, job references, business partners, professional employer organizations or staffing agencies, insurance companies.
- Automated technologies on Company’s electronic resources, for example, to track logins and activity across Company network, including through logging and analytics tools, cookies, pixel tags, and other similar technologies.
- Surveillance/recording technologies installed by Company, for example, video surveillance in common areas of Company facilities, which may be artificial intelligence enabled, global positioning system (“GPS”) technologies, voicemail technologies, webcams, audio recording technologies, and blue-tooth technologies, any of these with consent to the extent required by law.
- Government or administrative agencies, for example, law enforcement, public health authorities, California Department of Industrial Relations, Employment Development Department.

THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION

A. General Purposes

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

Fulfilling the purpose for which you provided the information or at your direction. For example, if you share your name and contact information to apply for a job or become a Team Member, we will use that personal information in connection with your employment or potential employment.
Administering the employment relationship including, but not limited to, human resources administration, payroll processing, benefits administration, leave programs, corporate travel and other business expenses,

timekeeping, managing work supplies, grievance or disciplinary matters, diversity and inclusion, ascertaining your fitness to work, drug and alcohol screening, worker’s compensation administration, occupational health surveillance, direct threat analysis, and facilitating Team Member, communication and collaboration.

Managing and/or analyzing all aspects of Team Member, performance including, but not limited to, talent management, periodic reviews, performance tracking, promotions, retention, discipline, education, training and development, and data analytics.
Administering the relationship with Non- Team Member Workers, including, but not limited to, evaluating the Non- Team Member Worker’s qualifications, negotiating and executing work contracts, orientation and familiarization with Company’s working environment, administering the contractual relationship including payments, facilitating communications, and workforce satisfaction.
Administering the relationship with Related Contacts, including, but not limited to, communications, managing and administering benefits, and managing participation in Company events.
Promoting Company and creating a positive environment in the workplace, including, but not limited to, planning and running Company events, conducting surveys, or running contests.
Ensuring compliance with Company policies and applicable laws and regulations, including, but not limited to, developing and enforcing policies and procedures, authenticating your identity, conducting internal audits and investigations, administering Company’s whistleblower hotline, and preparing reports.
Protecting health and safety of team members, employee applicants, non-employee workers, visitors, customers, and the public, including, but not limited to, identifying and responding to physical security risks, responding to medical emergencies, reducing the risk of exposure to infectious disease and preventing its spread in compliance with applicable laws and regulations, and protecting the safety and security of Company’s facilities.
Managing the security and integrity of our information and electronic resources including, but not limited to, monitoring use of our electronic resources, preventing unauthorized access to our electronic resources, preventing malicious software distribution, debugging, audits, disaster recovery, business continuity, and cyber security.
Running our business, including, but not limited to, customer service, project management, research, data analysis, and development, quality assurance and improvement, managing licenses, permits, and authorizations applicable to Company’s business operations, maintaining records, and efficiently managing and operating administrative, information technology, and communications systems, risk management and insurance functions, budgeting, financial management and reporting, and strategic planning.
Providing, supporting, personalizing, and improving our website and online services relating to your prospective, current, or former employment or engagement.
Protecting the rights or property of Company, including, but not limited to, detecting and prevent fraud or other types of wrongdoing, managing litigation involving Company, and other legal disputes and inquiries, crisis management, dispute resolution, reporting suspected criminal conduct to law enforcement and cooperating in investigations, short-term transient use of personal information, responding to requests or orders from governmental agencies, exercising Company’s rights under applicable law, and supporting any claim, defense, or declaration involving the Company in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel.
In connection with a corporate transaction, transfer, or assignment of assets, merger, divestiture, or other changes of control or our financial status or any of related subsidiaries or affiliates.

Purposes For Using Team Member Health Information:

To the extent necessary to comply with Company’s legal obligations, such as to accommodate disabilities
To conduct a direct threat analysis in accordance with the Americans with Disabilities Act and state law
For workers’ compensation purposes
For occupational health surveillance
For occupational health and safety compliance and record-keeping
To conduct fitness-for-duty examinations
To administer leaves of absence and sick time
To provide a wellness program
To respond to an employee’s medical emergency

Purposes For Using Team Member Protected Categories Of Information:

Company collects information about race, age, national origin, disability, sex, and veteran status as necessary to comply with legal obligations, including the reporting requirements of the federal Equal Employment Opportunity Act, The Office of Federal Contracting Compliance Programs (applicable to government contractors), and California’s Fair Employment and Housing Act. Company also collects information about disability status to the extent an employee may need special assistance during emergencies from Company or from first responders.
In addition, Company uses this personal information for purposes including:

as necessary to comply with Federal and California law related to leaves of absence and accommodation;
as necessary to comply with leave requirements under applicable law and for tax purposes;
as necessary for identity verification;
as necessary for accommodations under applicable law;
the extent this information is contained in documents that you provide in I-9 documentation; and
for Company events and as necessary to provide benefits and for tax purposes.

Note, the Company collects personal information about membership in protected categories on a purely voluntary basis, except where required by law, and uses the information only in compliance with applicable laws and regulations.

HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION

Personal information related to individuals is generally kept confidential by the Company. However, from time to time, Company may have a legitimate business need to disclose personal information. In that event, Company discloses information within the categories of personal information listed in Section 1, above, only to the minimum extent necessary to achieve the purpose of the disclosure and only if the disclosure is permitted by the CCPA and other applicable laws.

Disclosures for Business Purposes

Company may disclose each of the categories of personal information listed in Section 1, above, to the following categories of third parties, and may have done so in the 12-months preceding the date of this Privacy Notice, for business or commercial purposes:

- Service providers: Company may disclose to service providers any of the categories of personal information listed in Section 1, above, for the business purpose of performing services on Company’s behalf; particularly for the specific purposes described in Section 3, above.
- Auditors, lawyers, consultants, and accountants engaged by Company: Company may disclose the categories of personal information listed in Section 1, above, to these services providers or contractors for the business purpose of auditing compliance with policies and applicable laws, in addition to performing the services identified in Section 3 on the Company’s behalf.
- Other third parties: Company may disclose the categories of personal information listed in Section 1 to the following additional categories of third parties for the purposes in Section 3, above, including the following:
- Your direction: We may disclose your personal information to third parties at your direction.
- Business partners: For example, Company might disclose your business contact information to a co-developer of a new product or service with which you will be working.
- Government or administrative agencies: These may include, for example the

Internal Revenue Service to pay taxes or the California Department of Industrial Relations as required to resolve workers’ compensation claims.

- Public: Company may disclose your personal information to the public as part of a press release, for example, to announce promotions or awards.
- Required Disclosures: We may be required to disclose personal information (a) in a court proceeding, (b) in response to a court order, subpoena, civil discovery request, other legal process, or (c) as otherwise required by law.
- Potential Buyers: We may disclose personal information to potential buyers (and their agents and advisors) in connection with any proposed merger, acquisition, or any form of sale or transfer of some or all of our stock or assets (including in the event of a reorganization, dissolution, or liquidation).
- Legal Compliance and Protections: We may disclose personal information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Company, HR Individuals, or others.
- Where disclosure is otherwise required: We may disclose personal information where it is required for an ordinary business purpose in connection with our provision of services.

No Sales or Sharing

Company does not sell or “share” (disclose to a third party for cross-context behavioral advertising) your personal information in connection with the HR relationship. In addition, we have no actual knowledge that we sell or share the personal information of individuals of any age in connection with the HR relationship, including the personal information of children under 16.

CONFIDENTIALITY

Although we endeavor to safeguard your personal information using industry-standard practices and reasonable security controls, no method of electronic transmission or storage can be guaranteed completely secure. To help protect both your information and the integrity of our systems, please refrain from storing or transmitting extraneous personal content, such as personal photographs, financial account numbers, or health information, on Company-owned devices, applications, or networks. Introducing non-business-related personal information into our environment can increase the risk of exposure and impede our ability to maintain secure operations.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

Company keeps your personal information for as long as necessary for the purposes described in Section 3 above, unless Company is required to retain your personal information longer by applicable law or regulation, by administrative needs, by legal process, or to exercise or defend legal claims. In specific circumstances we may also retain your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

YOUR PRIVACY RIGHTS AND HOW TO EXERCISE THEM

Your California Privacy Rights

Subject to applicable law, individuals have the following rights:

- Right to Know: You have the right to submit a verifiable request up to twice in a 12-month period that we disclose the personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purposes for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of your personal information we have collected about you.
- Right to Portability: You have the right of portability, or the right to have use transfer your personal information to other persons or entities upon your request.
- Right to Delete: You have the right to submit a verifiable request for the deletion of personal information that the Company has collected about you.
- Right to Correct: You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by Company, taking into account the nature of the personal information and the purposes of processing the personal information.

How to Exercise Your Rights

Company will respond to requests in accordance with applicable law if the identity of the individual submitting the request can be verified. You can exercise your rights in the following ways:

- Call: (888) 300-3382
- Email: privacy@wilshirelawfirm.com
- Fill out the form on the Wilshire Law Firm website.

How We Will Verify Your Request

We match personal information that you provide Company against personal information Company maintains in its files. The more risk entailed by the request (e.g., a request for specific pieces of personal information), the more items of personal information Company may request to verify your identity. If you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the individual whose personal information is the subject of the request and provide appropriate proof of identity. For requests to know or delete information about a child under the age of 13, we accept requests for information regarding minors under the age of 13 if we can determine that such requests were submitted by a parent of guardian.

If Company cannot verify your identity to a sufficient level of certainty to respond securely to your request, Company will let you know promptly and explain why your identity cannot be verified.

Authorized Agents

You may designate an authorized agent to exercise your rights. If an authorized agent submits a request on your behalf, the authorized agent must submit with the request another document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, Company may ask you or your authorized agent to follow the applicable process described above for verifying your identity. You can obtain the “Authorized Agent Designation” form by contacting HR@wilshirelawfirm.com.

In the alternative, you can provide a power of attorney compliant with the California Probate Code.

Responding to Requests

Within 10 days of receiving an HR Individual’s request, we will confirm receipt of the request and provide information about how we will process the request. Generally, we will respond to an HR Individual’s request within 45 days. If we need more time to respond, we will provide the HR Individual with notice and an explanation of the reason we need more time to respond. We may deny the HR Individual’s request if we cannot verify their identity or are legally permitted to deny the request, such as if doing so proves impossible or would involve disproportionate effort.
If we deny the HR Individual’s request, we will explain the basis for the denial, provide or delete any personal information that is not subject to the denial, and refrain from using the personal information retained for any purpose other than permitted by the denial. We will maintain a record of the HR Individual’s request and our response for 24 months. To the extent permitted by applicable law, we may charge a reasonable fee to comply with an HR Individual’s request if the request is manifestly unfounded, excessive, or repetitive.

Company’s Non-Discrimination and Non-Retaliation Policy

Company will not unlawfully discriminate or retaliate against you for exercising your rights under the California Consumer Privacy Act.

7. CHANGES TO THIS PRIVACY POLICY

If we change this Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date above. When we do so, we will update the Last Updated date, above.

For More Information

For questions or concerns about Company’s privacy policies and practices, please contact HR@wilshirelawfirm.com.

Your Recruitment Partner Wilshire Law Firm will be storing your data in Recruit CRM to manage your information and send your profile to companies to present you for potential job Opportunities.

Recruit CRM is a software system that helps recruitment firms manage their relationship with their clients. You can view Recruit CRMs privacy policy or GDPR commitment on our website.
Recruit CRM may store your data in a Data Centre inside or outside Europe.
You can ask your recruiter at any point to delete your data or simply ask them for an “Update resume link” which you can use to update your profile information/resume or simply delete your data from their system.

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