If you are a Consumer, as defined under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), or a Workforce Member (including employees, applicants, independent contractors, and other personnel), we are required to provide you with additional information about how RemoFirst processes your Personal Data and the rights available to you under California law.

Categories of Personal Data

The categories of Personal Data that RemoFirst may collect are described in the section titled “Types of Personal Data We Collect” of this Privacy Policy. For purposes of California law, these categories may include:

a. Identifiers, such as name, postal address, email address, telephone number, online identifiers, account identifiers, IP address, passport number, tax identification number, Social Security number, driver’s license number, or other similar identifiers;

b. Personal information described in California Civil Code Section 1798.80(e), such as name, signature, physical characteristics or description, address, telephone number, passport number, insurance policy number, education, employment history, bank account number, payment card number, or other financial information;

c. Protected classification characteristics under California or federal law, such as age, gender, marital status, citizenship, nationality, disability status, veteran status, or other legally protected characteristics;

d. Commercial information, such as records relating to Services purchased, obtained, or considered, or other transaction-related information;

e. Internet or other electronic network activity information, such as browsing history, search history, device data, log data, and information regarding an individual’s interaction with the Website, Platform, Services, emails, or advertisements;

f. Geolocation data, including approximate location derived from IP address and, where relevant, more precise location data where permitted by law and necessary for the Services;

g. Audio, electronic, visual, or similar information, such as recordings of customer support interactions, webinar recordings, or other communications where permitted by law;

h. Professional or employment-related information, such as employer, job title, work location, compensation-related data, work authorization information, employment history, and other workforce administration information;

i. Education information, where relevant to recruitment or workforce onboarding;

j. Sensitive Personal Data / Sensitive Personal Information, where necessary and permitted by applicable law, as further described below; and

k. Inferences drawn from any of the information identified above to create a profile reflecting preferences, characteristics, behavior, or similar information, where relevant for service delivery, fraud prevention, compliance, support, or business operations.

Categories of Sensitive Personal Data

Under California law, certain categories of Personal Data are considered Sensitive Personal Information. Depending on the nature of your relationship with RemoFirst and the Services provided, RemoFirst may collect and process the following categories of sensitive information where necessary and permitted by law:

a. government-issued identifiers, including Social Security number, driver’s license number, state identification card number, passport number, visa information, or similar identifiers;

b. account log-in credentials, financial account information, debit or credit card numbers, and any security or access code, password, or credentials required to access such accounts;

c. precise geolocation data, where collected;

d. racial or ethnic origin, religious or philosophical beliefs, or trade union membership, where required for employment, payroll, benefits, or legal compliance purposes;

e. the contents of mail, email, or text messages where RemoFirst is the intended recipient of the communication or where access is otherwise permitted by law;

f. biometric information, where collected and used in accordance with applicable law;

g. health-related information, where necessary for benefits administration, accommodations, employment compliance, or similar lawful purposes; and

h. information concerning sex life or sexual orientation, only where such processing is strictly necessary, legally required, or otherwise permitted by applicable law.

RemoFirst does not use or disclose Sensitive Personal Information for purposes other than those permitted by applicable law, including as reasonably necessary to provide the Services, comply with legal obligations, manage workforce or customer relationships, maintain security, prevent fraud, and carry out other permitted business purposes.

Sources of Personal Data

RemoFirst may collect Personal Data directly from you, automatically through your use of the Website, Platform, or Services, and from other sources, including:

a. our clients and prospective clients;
b. employers, local partners, payroll partners, and other service partners involved in the delivery of the Services;
c. suppliers, vendors, and service providers;
d. recruiters, referral sources, and publicly available sources;
e. event organizers, marketing partners, and analytics providers; and
f. government authorities, regulators, advisors, and other third parties where legally permitted or required.

In the context of onboarding and workforce administration, certain information such as name, contact details, role information, and work-related information may be provided to us by our clients, local partners, or other entities involved in the Services, after which we may request additional information directly from you to complete onboarding, employment administration, payroll, compliance, verification, or related processes.

How We Use Personal Data

For information about the purposes for which RemoFirst collects and uses Personal Data, please refer to the section titled “How We Use Your Personal Data” in this Privacy Policy.

Sale or Sharing of Personal Data

Under the CCPA, the terms “sell,” “sale,” “share,” and “sharing” are broadly defined and may include certain disclosures of Personal Data to third parties for monetary or other valuable consideration or for cross-context behavioral advertising.

RemoFirst does not sell Personal Data in the ordinary meaning of that term. RemoFirst also does not sell the Personal Data of known minors under 16 years of age.

Where a disclosure of Personal Data could be deemed a “sale” or “sharing” under California law, RemoFirst will provide the rights and choices required by law, including the right to opt out where applicable.

RemoFirst may disclose limited categories of Personal Data to service providers, contractors, partners, or other third parties for business purposes, including to operate the Website, Platform, and Services, provide payroll and workforce administration services, manage onboarding, support customers, perform analytics, deliver communications, maintain security, comply with law, and support business operations.

Where RemoFirst engages in co-hosted events, joint marketing activities, or similar initiatives with third parties, and your information is shared with such third parties based on your participation, registration, request, or consent, such disclosure may in some cases be considered a “sale” or “sharing” under California law.

Your California Privacy Rights

Subject to applicable law and any relevant exemptions or limitations, California residents may have the following rights:

a. Right to Know: the right to request information about the categories of Personal Data we have collected about you, the categories of sources from which the Personal Data was collected, the business or commercial purposes for collecting, selling, or sharing Personal Data, the categories of third parties to whom we disclose Personal Data, and the specific pieces of Personal Data we have collected about you;

b. Right to Delete: the right to request deletion of Personal Data collected from you, subject to certain exceptions under applicable law;

c. Right to Correct: the right to request correction of inaccurate Personal Data maintained about you;

d. Right to Opt Out of Sale or Sharing: the right to opt out of the sale or sharing of your Personal Data, where applicable;

e. Right to Limit Use and Disclosure of Sensitive Personal Information: the right to limit the use and disclosure of Sensitive Personal Information in certain circumstances, where applicable;

f. Right to Non-Discrimination: the right not to receive discriminatory treatment for exercising any of your California privacy rights; and

g. Right to Data Portability: the right to receive certain Personal Data in a portable and, to the extent technically feasible, readily usable format.

Where required by law, the disclosures described above will cover the preceding 12-month period.

Exercising Your California Privacy Rights

To exercise your California privacy rights, please contact RemoFirst using the contact details provided in the “Contact Us” section of this Privacy Policy.

We may need to verify your identity before processing your request. Where permitted by law, we may deny a request if we cannot verify your identity or authority to make the request, or if an exemption applies.

You may designate an authorized agent to make a request on your behalf, subject to proof of authorization and identity verification requirements.

We will respond to verifiable requests within the time period required by applicable law. Where permitted, we may extend the response period and will inform you accordingly.

We will not discriminate against you for exercising any rights available to you under California law.

Disclosure for Business Purposes

RemoFirst may disclose Personal Data to service providers, contractors, affiliates, local partners, payroll providers, professional advisors, regulators, authorities, and other third parties for business purposes, including to:

a. provide, operate, maintain, and improve the Website, Platform, and Services;
b. deliver international payroll, employer of record, workforce management, onboarding, offboarding, benefits, and related services;
c. provide customer support and manage relationships with clients, workers, suppliers, and partners;
d. process payments and administer financial transactions;
e. monitor, secure, and protect our systems, Platform, Website, and Services;
f. conduct analytics, audits, reporting, and business operations;
g. send service-related communications and, where permitted, marketing communications; and
h. comply with legal, regulatory, tax, employment, immigration, and contractual obligations.

For more information regarding how RemoFirst uses and discloses Personal Data, please refer to the sections titled “How We Use Your Personal Data” and “Personal Data Disclosure” of this Privacy Policy.

Children

The Website, Platform, and Services are not directed to children under the age of 16, and RemoFirst does not knowingly sell or share the Personal Data of individuals under the age of 16 without the consent required by applicable law.

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