TO CALIFORNIA EMPLOYEES, OFFICERS, DIRECTORS, CONTRACTORS, AND APPLICANTS REGARDING THE COLLECTION OF PERSONAL INFORMATION
Effective Date: 04/28/2023
Origence, and its operating groups, subsidiaries and affiliates, (the “Company” or “we”) are committed to protecting the privacy and security of personal information of our current and former employees, Officers, (“Employees”), contractors (together with Employees, “Personnel”), their emergency contacts and beneficiaries, directors and job applicants who reside in the State of California. The Company does not sell or otherwise disclose this personal information, including sensitive personal information, for monetary or other consideration to any third parties.
The Company is committed to complying with the California Consumer Privacy Act (“CCPA”), and all data privacy laws in the jurisdictions in which the Company collects personal information, including sensitive personal information, of personnel, directors, and job applicants.
To learn more about how we protect your personal information, please refer to our Privacy Policy.
We collect the following categories of personal information for the purposes described below:
| Category of Personal Data | Personal Information Collected | Purpose |
| Personal identifiers | Examples:
| The Company collects personal information to process job and board of director applications; send correspondence and invitations to board of directors and spouses; onboard Personnel; enroll and administer benefits; enter contracts; and use for general human resource purposes. The Company uses some personal identifiers for cybersecurity monitoring purposes and are key in security incident event monitoring response. |
| Records identified by state law (including the California Customer Records statute (Cal. Civ. Code § 1798.80(e))) | Examples:
| The Company collects this information to process job and board of director applications; onboard Personnel; send correspondence and invitations to board of directors and spouses; enroll and administer benefits; enter into contracts; and use for general human resource purposes. The Company may collect pay information – such as payroll deduction information, banking information for direct deposit, for expense reimbursement, to pay its Personnel and comply with applicable laws. |
| Category of Personal Data | Personal Information Collected | Purpose |
| Protected classification characteristics under state or federal law | Examples:
|
The Company may collect equality and diversity information, such as minority, veteran and disability status, through voluntary self-disclosure and other means to implement the Company’s diversity programs and to comply with applicable laws. The Company may collect health and safety information to maintain a safe workplace; assess your working capacity; administer health and Workers’ Compensation insurance programs; and comply with applicable laws. The Company may also collect information necessary for benefits enrollment and administration purposes. |
| Commercial information | Examples:
|
If you are a contractor, we may collect commercial information from or about you in connection with obtaining services from you. |
|
Category of Personal Data |
Personal Information Collected |
Purpose |
|
Internet or other similar network activity information |
Examples:
|
The Company may collect this information to protect Company, customer, and Personnel property, equipment and confidential information; monitor Personnel performance; and enforce the Company’s electronic communications acceptable use policies. Information may also be used for cybersecurity monitoring purposes which are key in security incident event monitoring response. |
|
Geolocation data |
Examples:
|
The Company may collect geolocation data for general human resource purposes and for cybersecurity monitoring purposes which are key in security incident event monitoring response. |
|
Professional or employment-related information |
|
The Company may collect professional and employment- related information to manage its relationship with Personnel. |
|
Personal Data about children under the age of 16 |
Personal information about Employees’ dependents under the age of 16. |
The Company may collect information about Employees’ dependents under the age of 16 if Employees voluntarily provide such information in connection with the enrollment and administration of benefits and other human resource purposes that involve such dependents. |
|
Category of Personal Data |
Personal Information Collected |
Purpose |
|
Legal and Contractual Information |
Information necessary to: respond to law enforcement and governmental agency requests; comply with legal obligations; exercise legal rights; and initiate or respond to legal claims |
The Company may collect this information to comply with legal requirements and to establish, exercise, and defend legal rights and claims. |
|
Emergency Contact Information |
|
The Company may collect this information to contact the Employee’s designated emergency contact persons in the event of an emergency. |
|
Beneficiary Information |
|
The Company may collect this information to enroll and administer benefits programs for beneficiaries of Employees. |
The Company does not engage in the selling or sharing of consumers’ personal information, as defined under the CCPA.
The length of time the Company will retain each category of personal information will depend on a number of criteria including the length of time we are required to maintain the personal information in order to comply with applicable regulatory requirements and the length of time the information is needed to accomplish the business or commercial purposes for which the information is collected, used, or disclosed.
CONTACT FOR QUESTIONS
If you have any questions or concerns regarding this Notice or the collection of your personal information, please contact the Compliance department at [email protected].
Individuals with disabilities may access this notice in an alternative format by contacting the Compliance department at [email protected].
Rev. 2/10/2023
For 25 years CU Direct has helped deliver a better digital lending experience, increase efficiencies, and fuel growth. With a vision to create the ultimate origination experience, we introduced a new brand for financial institution technology and solutions—Origence. Our new Origence website is where the journey begins…
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