Diversis Capital Management, L.P.

Privacy Notice for California Residents

Effective Date:June 2023

This notice is only relevant to you if you are a resident of California as determined in accordance with the California Consumer Privacy Act of 2018, as amended (the “CCPA”). This notice serves to notify you of our collection and use of your personal information in connection with your employment. In this notice, we describe the types of personal information we collect, how we may use this personal information. Please read this notice carefully.

Categories of Personal Information We Collect: We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

We may collect some or all of the following categories of personal information in accordance with applicable law:

Category Examples Collected
A. Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
B. Additional data subject to Cal. Civ. Code § 1798.80 Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets). YES
C. Protected classification characteristics under California or federal law Date of birth, citizenship and birthplace. YES
D. Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES
E. Biometric information Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. NO
F. Internet or other similar network activity Browsing history, search history, information on your interaction with our computer systems, websites, or applications. YES
G. Geolocation data Physical location or movements. YES
H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information Current or past job history or performance evaluations. YES, but not prior salary information.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. YES
K. Inferences drawn from other personal information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO
L. Sensitive Personal Information Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. YES, as to the following types of information: social security, driver’s license, state identification care, or passport numbers, account log-in, financial account in combination with any required security or access code password, or credentials allowing access to an account only.

Purposes for Collecting Personal Information: We may collect or disclose the personal information we collect about you for one or more of the following business or commercial purposes in accordance with applicable law:

  • Manage your employment relationship with us, including for:
    • onboarding processes;
    • timekeeping, payroll, and expense report administration;
    • employee benefits administration;
    • employee training and development requirements;
    • the creation, maintenance, and security of your online employee accounts;
    • reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill;
    • workers’ compensation claims management;
    • employee job performance, including goals and performance reviews, promotions, discipline, and termination; and
    • other human resources purposes.
  • Manage and monitor employee access to our facilities, equipment, and systems.
  • Conduct internal audits and workplace investigations.
  • Investigate and enforce compliance with and potential breaches of our policies and procedures.
  • Engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers and acquisitions.
  • Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance.
  • Perform workforce analytics, data analytics, and benchmarking.
  • Track, monitor, and report outcomes related to human capital management, including diversity, equity, and inclusion metrics.
  • Administer and maintain our operations, including for safety purposes.
  • In connection with informing current or future customers or clients of our services, products, and culture.
  • Exercise or defend the legal rights of us and our employees.
  • Complying with U.S., state, local and non-U.S. laws, rules and regulations.

Retention of Personal Information: We retain the categories of personal information set forth above only as long as is reasonably necessary for those purposes set forth above, except as may be required under applicable law, court order or government regulations.

Disclosure of Personal Information: We do not share (i.e., disclose to a third party for the purposes of cross context behavioral advertising) or sell any of the personal information we collect about you to third parties.

We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Within the last twelve (12) months, we have shared the categories of personal information collected with affiliates and service providers, where permitted by applicable law. We may also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares to the extent permitted by applicable law.

At times we may permit third parties to collect personal information about you on our behalf. The business practices of such third parties will be limited to providing us services necessary to fulfil the purposes described above. Each such third party will be subject to contractual obligations required by the CCPA that will limit their use of such personal information.

Your rights under the CCPA

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you. Such information includes:

  • the categories of personal information we collected about you;
  • the categories of sources from which the personal information is collected;
  • our business or commercial purpose for collecting such personal information;
  • the categories of third parties with whom we disclose the personal information;
  • the specific pieces of personal information we have collected about you; and
  • whether we disclosed your personal information to a third party, and, if so, the categories of personal information that each recipient obtained.

Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations.

No Discrimination: We are an equal opportunity employer and are committed to complying with all federal, state, and local equal employment opportunity laws. We will not discriminate against you for exercising your rights as an employee under the CCPA.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.

Contact us

For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.

Email us at the following email address: dataprivacy@diversis.com.

If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number by email at the email address above, and we will call you between 9 a.m. and 6 p.m. Pacific Time.

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.

Our goal is to respond to any verifiable request within forty-five (45) days of our receipt of such request, but in certain cases, additional time might be required. Please contact dataprivacy@diversis.com with any questions about this California Consumer Privacy Act Employee Notice.