California employees & job applicants

Woman with her child using ECOS dish soap

Privacy Notice to California Employees & Job Applicants

Under the California Consumer Privacy Act (“CCPA”), Venus Laboratories, Inc., dba Earth Friendly Products (“Company” hereinafter, “we”, “our”, or “us”) may collect personal information and use it for certain business purposes as described below in this Job Applicant and Employee Privacy Notice. We are required to disclose the following information to California “consumers” regarding our collection of their personal information. Under the CCPA, “consumers” means California residents, including job applicants, employees or contractors of a business.

We are committed to properly handling the personal information collected or processed in connection with your employment relationship with us.

We will not sell the personal information, including any sensitive personal information, we collect about our employees or applicants for employment or share it with third parties for cross-context behavioral advertising.

To view our full privacy policy, please visit http://cth.nakedcityradio.com/privacy-policy.

We may collect the personal information categories listed in the table below. We collect information from our employees and job applicants that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, Company may have collected the following categories of personal information from its employees or job applicants within the last twelve (12) months:

Personal Information Category	Business Purpose
Identifiers, such as your full name, contact information, gender, date of birth, signature, Social Security number, driver’s license or state identification numbers, and similar information for your dependents and beneficiaries.	Recruit and process employment applications, including verifying eligibility for employment and conducting background and related checks Conduct employee onboarding Maintain and administer payroll and employee benefit plans, including enrollment and claims handling Maintain personnel records and complying with record retention requirements Provide employees with human resources management services and employee data maintenance and support services Communicate with employees and their emergency contacts and plan beneficiaries Comply with applicable state and federal labor, employment, tax benefits, workers’ compensation, disability, equal employment opportunity, workplace safety, and related laws Prevent unauthorized access to or use of the Company property, including information systems, electronic devices, network, and data Ensure employee productivity and adherence to Company policies Conduct internal audits and investigate complaints, grievances, and suspected violations of Firm policy Respond to law enforcement requests and as required by applicable law or court order Exercise or defend the legal rights of the Company and its employees, and affiliates, customers, contractors, and agents
California Customer Records employment and personal information, such as your name, signature, Social Security number, physical characteristics or description, photograph, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, current employment, employment history, membership in professional organizations, licenses and certifications, bank account number, credit card number, debit card number, or any other financial, medical or health insurance information.	Same purposes as for identifiers category
Protected classification characteristics under California or federal law, such as 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, reproductive health decision making, military and veteran status, or genetic information (including familial genetic information).	Comply with federal and state equal employment opportunity laws Design, implement, and promote the Company’s diversity and inclusion programs Perform workforce analytics, data analytics, and benchmarking Conduct internal audits, grievances, and suspected violations of Company policy Exercise or defend the legal rights of the Company and its employees, and affiliates, customers, contractors, and agents
Commercial information, such as transaction information, purchase history, and financial details.	Respond to law enforcement requests and as required by applicable law or court order
Biometric information, such as facial recognition, fingerprints, iris or retina scans, keystroke, or other physical patterns, and certain wellness metrics.	Fingerprinting for a criminal background check after an initial offer of employment is made. Criminal background checks protect the company, mitigate risk, and avoid potential negligent hiring lawsuits Administer and design health wellness programs Exercise or defend the legal rights of the Company and its employees, and affiliates, customers, contractors, and agents
Internet or other similar network activity information, including all activity on the Company’s information systems (such as internet browsing history, search history, intranet activity, email communications, social media postings, stored documents and emails, usernames, and passwords) and all activity on communications systems (such as phone calls, call logs, voicemails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications, and other information regarding an employee’s use of company-issued devices).	Facilitate the efficient and secure use of Company information systems Ensure compliance with Company information systems policies and procedures. Comply with applicable state and federal laws Prevent unauthorized access to, use, or disclosure or removal of the Company’s property, records, data, and information Enhance employee productivity Conduct internal audits and investigate complaints, grievances, and suspected violations of Firm policy Exercise or defend the legal rights of the Company and its employees, and affiliates, customers, contractors, and agents
Geolocation data, such as the time and physical location related to use of an internet website, application.	Improve safety of employees, customers, and the public regarding use of the Company property and equipment Prevent unauthorized access, use, or loss of the Company property Improve efficiency, logistics, and supply chain management Ensure employee productivity and adherence to the Company’s policies Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company’s policy
Sensory and surveillance data, such as COVID-19 related temperature checks and call monitoring and video surveillance.	Comply with applicable state and federal laws, including on workplace health and safety Prevent unauthorized access, use, or loss of the Company property Improve customer service Exercise or defend the legal rights of the Company and its employees, and affiliates, customers, contractors, and agents
Professional or employment-related information, such as employment application information (work history, academic and professional qualifications, educational records, references, and interview notes, background check, drug testing results, work authorization, performance and disciplinary records, salary, bonus, commission, and other similar compensation data, benefit plan enrollment, participation, and claims information, leave of absence information including religious, military and family obligations, health data concerning employee and their family members.	Recruit and process employment applications, including verifying eligibility for employment, background checks, and onboarding Design and administer employee benefit plans and programs, including for leaves of absence. Maintain personnel records and comply with record retention requirements Communicate with employees and their emergency contacts and plan beneficiaries. Comply with applicable state and federal labor, employment, tax, benefits, workers’ compensation, disability, equal employment opportunity, workplace safety, and related laws. Prevent unauthorized access to or use of the Company’s property, including its information systems, electronic devices, network, and data. Ensure employee productivity and adherence to the Company policies. Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company policy. Evaluate and provide useful feedback about job performance, facilitate better working relationships, and for employee professional development Exercise or defend the legal rights of the Company and its employees, and affiliates, customers, contractors, and agents.
Non-public education information, such as education records, degrees and vocational certifications obtained, report cards, and transcripts.	Evaluate an individual’s appropriateness for hire, or promotion or transfer to a new position at the Company
Inferences drawn from other personal information to create a profile or summary, for example, an individual’s preferences, abilities, aptitudes, and characteristics.	Engage in human capital analytics, including to identify correlations about individuals and job success, analyze data to improve retention and productivity, and analyze employee preferences to inform human resources policies and procedures Conduct applicant reference checks to assist in hiring decisions

Sensitive personal information is a subtype of personal information consisting of specific information categories. We may collect or use information that falls with the sensitive personal information categories listed in the table below.

Sensitive Personal Information Category	Business Purpose
Government identifiers, such as your Social Security number, driver’s license, state identification card, and passport and visa information, and immigration status and documentation.	Recruit and process employment applications, including verify eligibility for employment and conducting background and related checks Process and administer payroll and employee benefit plans, including enrollment and claims handling Maintain personnel records and comply with record retention requirements Provide employees with human resources management services and employee data maintenance and support services Communicate with employees and their emergency contacts and plan beneficiaries Comply with applicable state and federal labor, employment, tax benefits, workers’ compensation, disability, equal employment opportunity, workplace safety, and related laws Prevent unauthorized access to or use of the Company property, including information systems, electronic devices, network, and data Respond to law enforcement requests and as required by applicable law or court order
Complete account access credentials, such as user names, account numbers, or card numbers combined with required access/security code or password.	Recruit and process employment applications, including verify eligibility for employment and conducting background and related checks. Provide employees with human resources management services and employee data maintenance and support services Prevent unauthorized access to or use of the Company information systems, electronic devices, network, and data
Precise geolocation, such as physical access to a Company office location, or the location of a delivery, sales, or other employee in the field.	Improve safety of employees, customers, and the public regarding use of the Company property and equipment Prevent unauthorized access, use, or loss of the Company property Improve efficiency, logistics, and supply chain management Ensure employee productivity and adherence to the Company’s policies Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company’s policy Exercise or defend the legal rights of the Company and its employees, and affiliates, customers, contractors, and agents
Racial or ethnic origin.	Comply with federal and state equal employment opportunity laws Design, implement, and promote the Company’s diversity and inclusion programs Perform workforce analytics, data analytics, and benchmarking Conduct internal audits and investigate complaints, grievances, and suspected violations of Company policy
Religious or philosophical beliefs.	Review and process religious reasonable accommodation requests Exercise or defend the legal rights of the Company and its employees, and affiliates, customers, contractors, and agents
Mail, email, or text messages contents not directed to the Company.	Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company policy Exercise or defend the legal rights of the Company and its employees, and affiliates, customers, contractors, and agents
Genetic data.	Investigate and process workers’ compensation claims Process health insurance claims Conduct and process employment testing
Unique identifying biometric information.	Fingerprinting for a criminal background check after an initial offer of employment is made. Criminal background checks protect the company, mitigate risk, and avoid potential negligent hiring lawsuits. Exercise or defend the legal rights of the Company and its employees, and affiliates, customers, contractors, and agents
Health information, including job restrictions and workplace illness and injury information.	Investigate and process workers’ compensation claims Process health insurance claims Conduct and process employment testing Ensure equal access to retirement programs and fertility planning by same-sex spouses Ensure equal family leave policies and insurance for transgender surgeries
Sex life or sexual orientation information.	Process health insurance claims Ensure equal access to retirement programs and fertility planning by same-sex spouses Ensure equal family leave policies and insurance for transgender surgeries

Sales of Personal Information or Sensitive Personal Information

The Company does not sell or otherwise disclose this information for monetary or other consideration to any third parties.

Retention of Personal Information or Sensitive Personal Information

We will not retain your Personal Information or Sensitive Personal Information for longer than is reasonably necessary to carry out the purposes we disclose in this policy.

Your Consumer Rights and Choices

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of Personal Information we collect, use, disclose, and to access your information, (2) request deletion of your Personal Information, (3) request correction of your Personal Information, (4) not be discriminated against for exercising these rights, and (5) limit processing of Sensitive Personal Information.

Access Request Rights

You have the right to request that Company disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will disclose to you:

The categories of Personal Information we collected about you.
The categories of sources for the Personal Information we collected about you.
Our business or commercial purpose for collecting that Personal Information.
The categories of third parties with whom we disclose that Personal Information.
The specific pieces of Personal Information we collected about you.
If we disclosed your Personal Information for a business purpose, a list identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Company delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will delete your Personal Information from our records, unless an exception applies.

We may deny your deletion request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.

Right to Correction

You have the right to correct inaccurate Personal Information maintained by us. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will correct (and direct our service providers to correct) your inaccurate Personal Information from our records, unless an exception applies.

Right to Limit Processing of Sensitive Personal Information

You have the right to limit our processing of Sensitive Personal Information to that use which is necessary to perform services reasonably expected by an average consumer who requests such services, including processing applications for employment purposes and administering the employment relationship with you. When we collect your Sensitive Personal Information, we collect and use that information in order to perform the services for which that information is necessary and as reasonably expected by you.

Exercising Your Rights

To exercise the access, data portability, correction, and deletion rights described above, as well as to request that we limit our processing of your sensitive personal information, please submit a verifiable consumer request to us by either:

Calling us at 800-335-ECOS
Emailing us at info@nakedcityradio.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Changes To Our Job Applicant and Employee Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and employee handbook. If you have any questions or would like to access this policy in an alternative format, please contact Human Resources.

Feel free to contact us if you have more questions.

If you have any questions about this Notice or want to access, delete, or correct your information, please email us at info@nakedcityradio.com to submit your question or request.

You can also write to us at:
Venus Laboratories, Inc., dba Earth Friendly Products
Legal Department
11150 Hope St.
Cypress, CA 90630

EFFECTIVE: January 1, 2023