California Employee Privacy Notice​

The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act, imposes specific obligations on businesses processing personal information of California residents. Pursuant to the CCPA, Grasshopper House, LLC d.b.a. Passages Malibu, Passages Silver Strand, LLC d.b.a. Passages Ventura, and their affiliated entities (together, “Passages”, “we” or “us”) are required to provide its employees and applicants who are California residents (“California Persons”) a notice, used at or before the point of collection of such personal information, that identifies the categories of personal information that may be collected and why Passages collects such information.

This California Employee Privacy Notice (“Notice”) is intended to provide California Persons with the CCPA required notice.

Definitions

“Personal information” has the meaning as defined in the CCPA, and includes information that is collected by Passages about you in the course of employment and application for employment, for employment related purposes, and encompasses any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

“Process”, “processed” or “processing” means any operation or set of operations which is performed on personal information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal information.

“Employees”, “employee” or “you” means an identified or identifiable natural person who is a California resident and who is acting as a Passages job applicant, employee, or contractor. In this context “job applicant” refers to any person who has submitted his or her candidacy with Passages; “employee” refers to any person who is employed at Passages as a full-or part-time employee or temporary worker, and “contractor” means a natural person who provides any service to a business pursuant to a written contract.

Personal Information We Collect About You and Other Individuals

Listed below are the categories of personal information that Passages may process about employees:

Identifiers, including real name, nickname or alias, postal address, unique personal identifiers, email, account name, social security number, driver’s license number, passport number or other similar identifiers. In this context, a “unique personal identifier” means a persistent identifier that can be used to recognize an employee, or a device that is linked to an employee, over time and across different services, including, but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, or similar technology; unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers.

Characteristics of Protected Classifications Under California or Federal Law, including the following: race, skin color, national origin, ethnicity, religion (includes religious dress and grooming practices), sex/gender (includes pregnancy, childbirth, breastfeeding and/ or related medical conditions), gender identity, gender expression, sexual orientation, marital status, medical condition (such as genetic characteristics, cancer or a record or history of cancer), disability (such as mental and physical including HIV/AIDS, or cancer), military or veteran status, request for family care leave, request for leave for an employee’s own serious health condition, request for pregnancy disability leave, and age.

Internet or Other Electronic Network Activity Information, including browsing history, search history, application access location and information regarding an employee’s interaction with an internet website, application or advertisement, time and geolocation data related to use of an internet website, application or physical access to a Passages office location.

Professional or Employment-related Information, including job related data, maintained as part of the employment relationship that is present in: a job application, resume, or writing sample; an employment contract; a contractor agreement; a performance review; a disciplinary record; photos; biometric data, including imagery of your face and voice recordings; information from employee expenses; browsing and search history; payroll and benefits related data; internal and external contact information; or information captured from video, audio, systems, or other forms of monitoring or surveillance.

Education Information, including information about an employee’s educational background, such as education records, report cards, and transcripts that is not publicly available.

Inferences, including any information drawn from any of the personal information categories referenced above to create a profile about an employee reflecting the employee’s characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Information provided about other individuals, if you provide us with Personal Information of a reference or any other individual as part of your application or in connection with your employment, it is your responsibility to inform them of this Notice and obtain consent from that individual prior to providing the information to Passages.

Purposes for Collecting Your Personal Information

Passages collects the personal information identified in Section 3 above for the reasons listed below.

To Recruit Employees, including to conduct employment related background screening and checks.

To Administer Benefits, such as medical, dental, optical, commuter, and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, insurance and accident management and provision of online total reward information and statements.

To Pay and Reimburse for Expenses, including salary administration, payroll management, payment of expenses, to administer other compensation related payments, including assigning amounts of bonus payments to individuals, administration of departmental bonus pools and administration of stock option payments.

To Conduct Performance-Related Reviews, including performance appraisals, career planning, skills monitoring, job moves, promotions and staff re-structuring.

To Monitor Work-Related Licenses and Credentials, including provisioning software licenses for use in the course of an employee’s work-related responsibilities, ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies.

To Provide Our Employees with Human Resources Management Services, including providing employee data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of employee claims, and travel administration.

To Maintain Your Contact Information, including altering your details across relevant entities within the Passages group of companies (for example personal, other employment and transferring roles).

To Assist You in Case of Emergency, including maintenance of contact details for you, and your dependents in case of personal or business emergency.

To Monitor Eligibility to Work in the U.S., which means monitoring and ensuring compliance of employees’ ability to work in the U.S.

To Conduct Healthcare-Related Services, including conducting pre-employment and employment-related medical screenings for return to work processes and medical case management needs; determining medical suitability for particular tasks; identifying health needs of employees to plan and provide appropriate services, including operation of sickness policies and procedures; and providing guidance on fitness for travel and fitness for expatriation.

To Facilitate Better Working Environment, which includes conducting staff surveys, providing senior management information about other employees, and conducting training.

To Ensure a Safe and Efficient Working Environment, which includes Passages actions relating to disciplinary actions, and code of conduct processes and investigations.

To Maintain Security on Passages Websites and Internet Connected Assets, which includes hosting and maintenance of computer systems and infrastructure; management of Passages’ software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; and monitoring email and Internet access.

To Comply with Applicable Law or Regulatory Requirements, such as legal (state and federal) and internal company reporting obligations, including headcount, management information, demographic and Health, Safety, Security and Environmental reporting.

To Manage Litigation and Other Legal Disputes and inquiries involving Passages, and to meet legal and regulatory requirements.

In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of Passages or any of its affiliated entities.

To manage licenses, permits, and authorizations applicable to Passages' business operations.

Sources of Your Personal Information

During the application process and employment, Passages may collect Personal Information about you from the following sources:

• You, for example, in your job application, forms you fill out for us, assessments you complete, surveys you complete, and any information you provide to us during the course of your application and interview process.
• Vendors and service providers, for example, recruiters
• Third parties, for example, job references, affiliated companies, professional employer organizations or staffing agencies.
• Public internet sources, for example, social media, job boards, public profiles, and other public online sources.
• Public records, for example, court records, and credentialing and licensing organizations.
• Automated technologies on Passages' electronic resources, for example, to track logins and activity on Passages' careers page.
• Surveillance / recording technologies installed by Passages, for example, video surveillance in common areas of Passages facilities, voicemail technologies, webcams, and audio/video recording technologies with consent to the extent required by law.
• Government or administrative agencies, for example, law enforcement or public health authorities.
• Acquired company, if Passages acquired your employer, Passages might collect personal information from that employer.

How We May Disclose Your Information

From time to time, Passages may have legitimate business needs to disclose your personal information for one of the business purposes listed above. Passages may disclose your personal information to the following:

Service providers and contractors, to assist us in our recruiting efforts and in meeting our business needs and legal obligations.

Government or administrative agencies, for example, the Equal Employment Opportunity Commission as required for reporting, the California Department of Fair Employment and Housing as required to respond to employment claims and charges, and law enforcement in the event of criminal investigation.

Required Disclosures, such as in a court proceeding, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.

Legal Compliance and Protections, when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Passages, our users, or others.

Passages has not sold or shared Personal Information as defined or contemplated by the CCPA or its amendments.

Retention Period

Passages will retain Personal Information for the period necessary to fulfill the purposes outlined in this Notice and in accordance with our records retention schedule, unless a longer retention period is required or permitted by law. Please note, the information collected about you during the job application process may become part of your personnel file and may be used to administer the employment relationship and for related reporting and recordkeeping purposes should you be hired by Passages.

Updates

This Notice will be reviewed and revised annually to reflect changes in our business, legal or regulatory obligations. Updates to this notice will be posted on Passages' job applicant site. as well as www.passagesmalibu.com/employeeprivacy. Passages will not collect additional categories of your personal information or use your personal information already collected for additional purposes without providing you with a notice of our intent to do so. Any changes to this Notice will be effective from the date they are communicated to you.

Further Information

If you have any questions about this statement, please contact the Passages Data Protection Officer at privacy@passagesmalibu.com or Human Resources at hr@passagesmalibu.com.

Last revised April 8, 2024