Last Updated: December 12, 2022
Generate Capital, PBC and its affiliates (“Company,” “we,” or “us”) value the trust of our job applicants and employees and endeavor to protect the privacy of their personal information. The purpose of this privacy policy (this “Policy”) is to notify California residents (“you”) of the processing of information that can reasonably be linked with them and that we collect, use, and disclose in the context of their current or former role as our employees or job applicants (“Personal Information”).
This Policy also applies to the beneficiaries of your employment benefits, such as the individuals who are on your health plan and the beneficiaries of your retirement accounts, as well as your emergency contacts. It is your responsibility to inform any such individuals about this Policy and ensure that you have the right to provide their Personal Information to us.
We collect Personal Information in a number of ways, for example:
The following chart details which categories of Personal Information we collect and process, as well as which categories we disclose to third parties for our operational business and employment purposes, including within the 12 months preceding the date this Policy was last updated.
| Categories of Personal Information | Disclosed to Which Categories of Third Parties for Operational Business Purposes |
|---|---|
| Identifiers, such as name, alias, postal address, unique personal identifiers, IP address that can reasonably be linked or associated with a particular individual, email address, account name, online identifiers, photos, beneficiary designations, and government-issued identifiers (e.g., Social Security number, driver’s license) | Our affiliates; investors; capital providers; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement |
| Personal information as defined in the California customer records law, such as name, contact information, signature, passport number; medical, insurance, financial, education and employment information | Our affiliates; investors; capital providers; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, and other services; professional advisors, such as accountants, auditors , bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement |
| Protected Class Information under California or federal law, such as sex, age, gender, race, religion, national origin, disability, medical conditions, citizenship, military/veteran status, gender identity and expression, primary language, immigration status, marital status, and requests for leave | Our affiliates; investors; capital providers; service providers that provide services such as payroll, benefits, consulting, , medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement |
| Commercial Information, such as transaction information and purchase history, such as travel expenses, including information about corporate credit card purchases, frequent flyer rewards, and other travel-related programs and expenses | Our affiliates; investors; capital providers; service providers that provide services such as payroll, benefits, training, consulting, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement |
| Internet or network activity information, such as access and usage information regarding websites, applications, and systems, information about online communications, including browsing and search history, timestamp information, IP address, and access and activity logs | Our affiliates; service providers that provide services such as IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement |
| Geolocation Data, such as device location, company-owned vehicle location, and approximate location derived from IP address, or GPS, Wi-Fi, or BLE tracking | Our affiliates; service providers that provide services such as payroll, benefits, training, consulting, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement |
| Audio/Video Data. Audio, electronic, visual, and similar information, such as call and video recordings, including voicemail and security camera footage, information about the use of electronic devices and systems, key card usage; photos on websites or in employee directories | Our affiliates; investors; capital providers; service providers that provide services such as payroll, benefits, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners |
| Education Information subject to the federal Family Educational Rights and Privacy Act, s, academic standing, confirmation of graduation and degree received | Our affiliates; investors; capital providers; service providers that provide services such as background checks, payroll, professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement |
| Employment Information. Professional or employment-related information, such as work history and prior employer, information from reference checks, background screening information, employment application, membership in professional organizations, personnel files, personal qualifications and training, eligibility for promotions and other career-related information, work preferences, business expenses, wage and payroll information, benefit information, information on leaves of absence or PTO, performance reviews, information on internal investigations or disciplinary actions | Our affiliates; investors; capital providers; service providers that provide services such as payroll, benefits, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement |
| Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences, characteristics, predispositions, and abilities | Our affiliates; service providers that provide services such as payroll, benefits, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement |
Sensitive Personal Information.
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Our affiliates; investors; capital providers; service providers that provide services such as payroll, benefits, training, consulting, expense management, medical/health, IT, and other services; public and governmental authorities, such as regulatory authorities and law enforcement |
We may also disclose the above categories of Personal Information to a third party in the context of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
We do not sell Personal Information, and we do not share or otherwise process Personal Information for purposes of cross-context behavioral advertising, as defined under California law. We have not engaged in such activities in the 12 months preceding the date this Policy was last updated. Without limiting the foregoing, we do not sell or share the Personal Information of minors under 16 years of age.
We collect and use Personal Information for the purposes of operating, managing, and maintaining our business, managing our workforce and other employment purposes, and accomplishing our business purposes and objectives, including, for example, to:
We may use Sensitive Personal Information for purposes of performing services for our business, providing services as requested by you, and ensuring the security and integrity of our business, infrastructure and the individuals with whom we interact. This includes, without limitation, establishing and maintaining your employment relationship with us, ensuring the diversity of our workforce, complying with legal obligations, managing payroll and corporate credit card use, administering and providing benefits, and securing the access to, and use of, our facilities, equipment, systems, networks, applications, and infrastructure.
We retain Personal Information, including Sensitive Personal Information, for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:
You may, subject to applicable law, make the following requests:
We will not unlawfully retaliate or discriminate against you for making a request under the CCPA.To make a privacy request, please use the privacy request form available at the bottom of our website at www.generatecapital.com or call 1 (833) 723-3264. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as first name, last name, email address and phone number, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information. We will verify and respond to your request consistent with applicable law.
If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted in the section entitled “Individual Requests.” As part of our verification process, we may request that the agent provide proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Individual Requests” or confirm that you provided the agent permission to submit the request.
We may change or update this Policy from time to time. When we do, we will communicate changes and updates to this Policy by posting the updated policy on The Grid.
If you have any questions about this Policy or how we process your Personal Information, you may contact the People Team at [email protected].
