California Personal Information Collection Notice for Employees, Job Applicants, and Independent Contractors This Notice discloses eHarmony, Inc.’s (“eharmony”, “we,” “us,” or “our”) policies and practices relating to the collection, use, and disclosure of the personal information (“PI”) of employees, job applicants, and independent contractors, (collectively, “Affected Individuals,” “you” or “your”), as required under the California Consumer Privacy Act (“CCPA”), amended by the California Privacy Rights Act (“CPRA”).
Below is a list of: (i) the categories of PI, including sensitive PI, we may have collected from you since January 1, 2022, (ii) the categories of sources from which that PI was collected, (iii) the business or commercial purposes for which the PI was collected, (iv) the categories of third parties to whom eharmony disclosed the PI, and (v) how long we retain the PI. Depending on your role, we do not necessarily collect all specific pieces of PI listed.
Categories of PI we may collect: Identifiers such as a real name, alias, postal address, employee ID, online identifier, Internet Protocol address, email address, telephone number, social security number, driver’s license number, passport number, or other similar identifiers.
We may collect such PI from the following sources: Employee, job applicant or independent contractor. Third parties, such as an external recruiter or recruiting platform and publicly available sources, such as social networks.
We may collect such PI for the following business purposes: To perform our duties and obligations as your employer including with respect to the creation of company work accounts and onboarding, administration of employment agreements, human resources, recruiting, processing of payroll payments, administration of company benefits, background checks, administration of independent contractor agreements, ensuring the safety and security of employees and customers, and for uses required by law.
We may disclose such PI to the following categories of third parties: Affiliates and related entities, human resources management software & service provider, payroll processor, benefits administrators and service providers, insurance providers, workers’ compensation administrator, background check processor, external recruiters, tax and accounting service providers, legal service providers, contracts management software, as required by law (e.g., with applicable government agencies), and other third party business entities if we become involved with a business transaction involving the transfer of some or all of our assets.
We retain PI for the following periods: Employee files are retained for 4 years after termination of employment. Job applicant files are retained for 4 years after application date if the applicant did not become an eharmony employee. Payroll information is retained for 10 years after termination of employment. Independent contractor information is retained for as long as required. PI may be retained for valid legal requests or to defend our legal interests for as long as required.
Categories of PI we may collect: Categories of PI described in subdivision (e) of Section 1798.80.
We may collect such PI from the following sources: Employee, job applicant or independent contractor. Third parties, such as an external recruiter or recruiting platform.
We may collect such PI for the following business purposes: To perform our duties and obligations as your employer including with respect to the creation of company work accounts and onboarding, administration of employment agreements, human resources, recruiting, processing of payroll payments, administration of company benefits, background checks, ensuring the safety and security of employees and customers, and for uses required by law, such as tax information. Also, medical information may be collected in data sent to eharmony through its COVID-19 related safety protocols, administration of independent contractor agreements, and for uses required by law.
We may disclose such PI to the following categories of third parties: Affiliates and related entities, human resources management software & service provider, payroll processor, benefits administrators and service providers, insurance providers, background check processor, workers’ compensation administrator, external recruiters, tax and accounting service providers, legal service providers contracts management software, as required by law (e.g., with applicable government agencies), and other third party business entities if we become involved with a business transaction involving the transfer of some or all of our assets.
We retain PI for the following periods: Employee files are retained for 4 years after termination of employment. Job applicant files are retained for 4 years after application date if the applicant did not become an eharmony employee. Payroll information is retained for 10 years after termination of employment. Independent contractor information is retained for as long as required.PI may be retained for valid legal requests or to defend our legal interests for as long as required.
Categories of PI we may collect: Characteristics of protected classifications under California or federal law (e.g., age, sex/gender, race, ethnic origin, marital status, military or veteran status, disability, national origin, medical leave information).
We may collect such PI from the following sources: Employee or job applicant. Third parties, such as an external recruiter or recruiting platform.
We may collect such PI for the following business purposes: To perform our duties and obligations as your employer including with respect to human resources, recruiting, background checks, reporting to government agencies, and for uses required by law.
We may disclose such PI to the following categories of third parties: Affiliates and related entities, human resources management software & service provider, payroll processor, benefits administrators and service providers, insurance providers, background check processor, workers’ compensation administrator, external recruiters, tax and accounting service providers, legal service providers, as required by law (e.g., with applicable government agencies, and other third party business entities if we become involved with a business transaction involving the transfer of some or all of our assets.
We retain PI for the following periods: Employee files are retained for 4 years after termination of employment. Job applicant files are retained for 4 years after application date if the applicant did not become an eharmony employee. Payroll information is retained for 10 years after termination of employment. PI may be retained for valid legal requests or to defend our legal interests for as long as required.
Categories of PI we may collect: Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
We may collect such PI from the following sources: Background checks service provider.
We may collect such PI for the following business purposes: To perform our duties and obligations as your employer including to perform background checks.
We may disclose such PI to the following categories of third parties: Affiliates and related entities, human resources management software & service provider background check processor, workers’ compensation administrator, legal service providers, as required by law (e.g., with applicable government agencies, and other third party business entities if we become involved with a business transaction involving the transfer of some or all of our assets.
We retain PI for the following periods: Employee files are retained for 4 years after termination of employment. Job applicant files are retained for 4 years after application date if the applicant did not become an eharmony employee. Payroll information is retained for 10 years after termination of employment. PI may be retained for valid legal requests or to defend our legal interests for as long as required.
Categories of PI we may collect: Internet or other electronic network activity information, including, but not limited to your use of eharmony’s technology, systems, and equipment such as emails sent and received, browsing history, search history, and information regarding an employee’s interaction with an Internet Web site, application, or advertisement.
We may collect such PI from the following sources: Operating systems and platforms and third parties, such as an IT service provider/software.
We may collect such PI for the following business purposes: To perform our duties and obligations as your employer including with respect to security, compliance and legal requirements, to ensure the proper use of work computers and equipment, protect our assets, and for information technology purposes.
We may disclose such PI to the following categories of third parties: Affiliates and related entities, legal service providers (if applicable), as required by applicable law (e.g., with applicable Government entities), and other third party business entities if we become involved with a business transaction involving the transfer of some or all of our assets.
We retain PI for the following periods: Employee files are retained for 4 years after termination of employment. PI may be retained for valid legal requests or to defend our legal interests for as long as required.
Categories of PI we may collect: Geolocation data.
We may collect such PI from the following sources: Employee, job applicant or independent contractor. External recruiter or recruiting platform. Operating systems and platforms and third parties, such as an IT service provider/software.
We may collect such PI for the following business purposes: To perform our duties and obligations as your employer. For example: addresses are collected for the creation of company work accounts and onboarding, administration of employment agreements, human resources, recruiting, processing of payroll payments, administration of company benefits, background checks, administration of independent contractor agreements, and for uses required by law,
For security, compliance and legal reasons, to ensure the proper use of work computers and equipment, and for information technology purposes.
We may disclose such PI to the following categories of third parties: Affiliates and related entities, human resources management software & service provider, payroll processor, benefits administrators and service providers, insurance providers, background check processor, workers’ compensation administrator, external recruiters, tax and accounting service providers, legal service providers, contracts management software, IT service providers, as required by law (e.g., with applicable government agencies), and other third party business entities if we become involved with a business transaction involving the transfer of some or all of our assets.
We retain PI for the following periods: Employee files are retained for 4 years after termination of employment. Job applicant files are retained for 4 years after application date if the applicant did not become an eharmony employee. Payroll information is retained for 10 years after termination of employment. PI may be retained for valid legal requests or to defend our legal interests for as long as required.
Categories of PI we may collect: Audio, electronic, visual, or similar information (e.g., photos, videos, voice-overs).
We may collect such PI from the following sources: Employee or job applicant. Third parties, such as an external recruiter or recruiting platform, security vendor/platform, video chat platform.
We may collect such PI for the following business purposes: To perform our duties and obligations as your employer including with respect to creation of employee company profile, applicant information, human resources, recordings/photos of employee at work related events and meetings, security surveillance.
We may disclose such PI to the following categories of third parties: Affiliates and related entities, human resources management software & service provider. Legal service providers (if applicable). As required by applicable law (e.g., with applicable government entities), and other third party business entities if we become involved with a business transaction involving the transfer of some or all of our assets.
We retain PI for the following periods: Employee files are retained for 4 years after termination of employment. PI may be retained for valid legal requests or to defend our legal interests for as long as required.
Categories of PI we may collect: Professional or employment- related information.
We may collect such PI from the following sources: Employee or job applicant. Third parties, such as an external recruiter or recruiting platform.
We may collect such PI for the following business purposes: To perform our duties and obligations as your employer including with respect to human resources and recruiting.
We may disclose such PI to the following categories of third parties: Affiliates and related entities, human resources management software & service provider, external recruiters, and legal service providers (if applicable), as required by applicable law (e.g., with applicable government entities), and other third-party business entities if we become involved with a business transaction involving the transfer of some or all of our assets.
We retain PI for the following periods: Employee files are retained for 4 years after termination of employment. Job applicant files are retained for 4 years after application date if the applicant did not become an eharmony employee. PI may be retained for valid legal requests or to defend our legal interests for as long as required.
Categories of PI we may collect: Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99) (e.g., whether you went to college).
We may collect such PI from the following sources: Employee or job applicant. Third parties, such as an external recruiter or recruiting platform.
We may collect such PI for the following business purposes: To perform our duties and obligations as your employer including with respect to human resources and recruiting.
We may disclose such PI to the following categories of third parties: Affiliates and related entities, human resources management software & service provider, external recruiters, and legal service providers (if applicable), as required by applicable law (e.g., with applicable government entities), and other third party business entities if we become involved with a business transaction involving the transfer of some or all of our assets.
We retain PI for the following periods: Employee files are retained for 4 years after termination of employment. Job applicant files are retained for 3 years after application date if the applicant did not become an eharmony employee. PI may be retained for valid legal requests or to defend our legal interests for as long as required.
Categories of PI we may collect: Inferences drawn from any of the information identified in this chart including to create an employment, applicant file, or independent contractor file.
We may collect such PI for the following business purposes: To perform our duties and obligations as your employer including with respect to human resources, recruiting, and administration of independent contractor agreement.
We may disclose such PI to the following categories of third parties: Affiliates and related entities, human resources management software & service provider, external recruiters, contract management software, and legal service providers (if applicable), as required by applicable law (e.g., with applicable government entities), and other third party business entities if we become involved with a business transaction involving the transfer of some or all of our assets.
We retain PI for the following periods: Employee files are retained for 4 years after termination of employment. Job applicant files are retained for 4 years after application date if the applicant did not become an eharmony employee. Payroll information is retained for 10 years after termination of employment. Independent contractor information is retained for as long as required. PI may be retained for valid legal requests or to defend our legal interests for as long as required.
Important information related to our handling of your PI:
1) eharmony does not sell or share (for cross context behavioral advertising) your PI.
2) eharmony does not knowingly collect, share, or sell the PI of minors under 16 years of age.
3) California residents have the right to limit the use and disclosure of their sensitive PI (if it is used to draw inferences about the individual). eharmony only uses sensitive PI for purposes permitted under the CCPA. Thus, no relevant option to limit the use of sensitive PI is available to you.
Your rights under the CPRA:
You may have the right to request access to your PI in accordance with applicable law,, including:
- The categories of PI we have collected about you, the categories of sources from which we have collected this PI, the business or commercial purpose for which we collected the PI, the categories of third parties with whom we disclosed the PI.
You may also have the right to:
- request deletion of your PI; and
- request correction/update of your PI.
Some important details related to exercising your CPRA rights:
1) We must verify your identity prior to processing your request. If we are unable to verify your identity, we may not be able to proceed with your request.
2) You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise your rights and choices on your behalf please sign a written declaration, certified by a notary public, that you authorize the agent to act on your behalf; mail your written declaration to this address: eHarmony, Inc, 10900 Wilshire Blvd., Suite 17, Los Angeles, CA 90024, Attn: Human Resources with an emailed copy to HR@eharmony.com; and provide any additional information requested. Alternatively, if you provide an authorized agent with power of attorney we will respond to any request from such authorized agent.]
3) We will not discriminate against you for exercising your rights and choices.
4) Please note that we may not be able to process your request(s) for legal or other (e.g., accounting, unable to confirm accuracy of updated information) reasons.
To submit a request to access, delete and/or correct/update your PI:
Please email HR@eharmony.com with the Subject Line “CPRA Request” and include your specific request in the body of the email. Please contact HR with any questions or concerns.
Security
We have in place commercially reasonable technological and procedural security measures in an attempt to protect and safeguard the security of PI. Despite these efforts, please understand that no system is perfect or can guarantee that unauthorized access or theft of data might not occur.
Changes to This Privacy Policy
We may amend this Privacy Statement at any time, so please review it frequently. If we make a material change to this Privacy Policy, we will update the Effective Date on this notice.
This Notice is effective as of January 1, 2023.
