Privacy - PlanSource

PlanSource Privacy Notices

PlanSource Website Privacy Notice

Last Updated: October 9, 2026

This Privacy Notice describes how PlanSource Holdings Inc. and its subsidiaries (“PlanSource,” “we”, “us,” “our”) collects, uses and discloses information about individuals who use our website (https://plansource.com/) and such other websites upon which this Privacy Notice is posted or other means in which you may interact with us (collectively, the “Site”). For the purposes of this Privacy Notice, “you” and “your” means you as the user of the Site, whether you are a customer, an end user of a customer, website visitor, or representative of a company with whom we do business, or another individual whose information we have collected pursuant to this Privacy Notice.

Please read this Privacy Notice carefully. By using any of the Site, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice. If you do not agree to this Privacy Notice, please do not use or access the Site.

Please also note that this Privacy Notice does not apply to the collection of information pursuant to or otherwise through our services, participant portal, mobile applications, and features therein (collectively, “Services”).

The English language version of this Notice shall control.

1. CHANGES TO THIS PRIVACY NOTICE

We may modify this Privacy Notice from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Notice. If we make material changes to the way in which we use or disclose information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Site, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Site.

2. COLLECTION AND USE OF INFORMATION

When you use or access the Site, we collect certain categories of information about you from a variety of sources.

Information You Provide to Us

Some features of the Site may require you to provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Site includes:

Basic contact details, such as name, address; phone number, and email.
Professional and employment information, such as your professional / employer contact information (e.g., work email or phone number), job title, the organization you represent, your organization’s details and location.
Any other information you choose to include in communications with us, for example, when sending a message through the Site or submitting information to us (e.g., through a contact or request form on the Site).

Information We Collect Automatically

We also automatically collect certain information about your interaction with the Site (“Usage Data”). To do this, we may use cookies, pixels, web beacons/clear gif, and other tracking technologies used by Company (“Tracking Technologies”). Usage Data includes:

Device information, such as device type, operating system, device ID numbers and unique device identifier, media access control (MAC) address, and internet protocol (IP) address.
Location information, such as imprecise geolocation (based on IP address).
Other information regarding your interaction with the Site, such as operating system, browser type, log data, date and time stamps, device screen resolution, the pages you access on the Site, the websites you access before and after visiting the Site, the length of time you spend on the Site, clickstream data, and ad impressions.

For more information on how we use Tracking Technologies and your choices, see the section below, Cookies and Other Tracking Technologies.

Information Collected from Other Sources

We may obtain information about you from outside sources, including information that we collect directly from third parties and information that you choose to share with us. Such information includes:

Analytics Data: Information such as aggregate information about your interactions with the Site that we receive from analytics providers such as Google Analytics.
Conferences and Trade Shows. Information such as your contact information we receive from you in our interactions with you at conferences or trade shows.
Advertising Networks. Information we received from advertising networks or advertising services providers (such as LinkedIn Ads or Meta Pixel).

Any information we receive from outside sources will be treated in accordance with this Privacy Notice. We are not responsible for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below,

Third Party Websites and Links.

Finally, we may deidentify information about you such that it cannot reasonably be used to infer information about you or otherwise be linked to you (or we may collect information that has already been identified), and we may use such deidentified information for any purpose. To the extent we possess or process any deidentified information, we will maintain and use such information in deidentified form and not attempt to re-identify the information, except solely for the purpose of determining whether our deidentification process satisfies legal requirements.

3. USES OF INFORMATION

With respect to the categories of information we collect, we use information about you as described below:

Site Administration and Purpose Collected; Communication with You:

For the purpose for which you disclosed and we collected information about you, for example, to process and communicate with you in connection with your use of the Site, to process your requests for information, to display requested content and/or our business activities, and to provide user support to users of the Site.

Personalization; Advertising; Analytics:

To tailor the content and information that we may send or display to you, suggest personalized help and instructions, and personalize your experience while visiting or using our Site; to share it with our third party service providers to understand how our Site is used and to improve the Site; to share it with our third party service providers to target advertisements for goods and services and to display those advertisements on other websites (for more information, please see the Cookies and Other Tracking Technologies section below).

Marketing Communications:

To send you marketing communications about our business, products, Site, and other programs that may be of interest to you. In order to provide you with a personalized experience, these communications may be tailored to your preferences based on, for example, inferences we make using your visits to the Site or the links you click on in our emails. Please note that pixel tags, cookies and other online trackers may be used within emails to track your interactions with those websites and when emails are opened. You may opt out of receiving marketing communications from us at any time by following the unsubscribe instructions contained in the applicable email. Note that, even if you opt out of receiving promotional communications from us, you may still receive administrative communications from us with respect to your use of the Site.

Evaluation and Improvement:

To analyze, develop, and improve the content, materials, products, and the Site; to inform marketing and communication plans; to understand user demographics and preferences; to analyze the effectiveness of the Site; and to evaluate user experiences (e.g., analyzing which features and portions of the Site are most popular; for troubleshooting, for statistical purposes).

Quality Assurance:

To perform quality assurance, to assist with fraud identification, and to assist our customer relationship representatives (for example, through representatives in our call center), we use tools to monitor and record certain user experience information, including, without limitation, audio of customer service calls and information resulting from such calls.

Lawful Processes; Protection of Company:

In accordance with and in response to regulatory authorities, courts with competent jurisdiction, valid law enforcement requests, governmental agency requests, emergency services, and other necessary third parties for legal, protection, security, and safety purposes (e.g., to protect the safety of our employees, agents, and customers, or any other person); to protect our rights or the rights of others, including to enforce our agreements, policies, and terms; to bring legal action; and to protect our operations and assets.

4. COOKIES AND OTHER TRACKING TECHNOLOGIES

The Site automatically use cookies and Tracking Technologies to track your use of the Site in order to facilitate and enhance the user experience on the Site, to learn and track how you access and use the Site, including when and how users visit the Site and how popular particular Service pages are and aren’t, to provide you with customized advertising, and for other purposes as described herein.

Most browsers accept cookies and other Tracking Technologies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Site, including certain features and general functionality, to work incorrectly. Changing your cookie preferences in one browser will not necessarily carry over to other browsers, so you may need to adjust your preferences each time you get a new device, install a new browser, upgrade an existing browser, or alter or delete a browser’s cookie file. If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

Visit our Cookie Policy for more information about how we use cookies and other Tracking Technologies.

Analytics Tools & Providers

As noted above, the Site uses third-party analytics tools (e.g., Google Analytics) to collect and process data about your use of the Site. Our analytics providers may set and read cookies to collect this data, and your web browser will automatically send data collected by those cookies to our analytics providers. Our analytics providers use this data to provide us with reports that we will use to improve the Site’s structure and content.

For example, we utilize Google Analytics and other analytical tools offered by Google. For more information on how Google uses this data, visit Google’s page on How Google uses data when you use websites or apps that use Google Services. To prevent this data from being used by Google Analytics, follow the instructions to download and install the Google Analytics Opt-out Browser Add-on for each browser you use. Using the Google Analytics Opt-out Browser Add-on will not prevent us from using other analytics tools and will not prevent data from being sent to the Service itself or to Google.

Advertising networks, Personalized Advertising, Remarketing & Retargeting

We may use or participate in advertising networks and related advertising services that are managed and provided by third-party advertising servers, advertising agencies, technology vendors, and research firms, including LinkedIn Ads.

Advertising networks often gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables their computers to deliver advertisements directly targeted to the consumer’s specific interests. This practice is often referred to as “online behavioral advertising.” For example, a third-party advertising network might collect the type of web browser you use, the type of computer operating system you use, the domain name of a website you visit, whether or not you visit specific pages of the Site and other websites, the location of your Internet service provider, the date and time of a visit to a website, and other interactions between you and a website.

Through Google Ads, Google uses your Internet searches, cookies, and similar identifiers (e.g., pixel tags) to collect information about your visits to the Service and your interaction with our products and services to generate targeted advertisements to you on other websites that you visit across the Internet. We may also enable and implement Google Analytics Advertising Features on the Site. To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions.

To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, please visit the National Advertising Initiative Consumer opt-out page. Please remember that changing your settings with individual web browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads from time to time. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.

Do Not Track & Global Privacy Controls

Your browser settings may allow you to transmit a “do not track” signal, “opt-out preference” signal, or other mechanism for exercising your choice regarding the collection of information about you when you visit various websites. Our website recognizes the Global Privacy Control (GPC) signal which enables you to opt out of certain uses or disclosures of information about you. If you notify us of your preference through GPC, we will honor your request only for the browser or device that sends the GPC signal. If you do not have an account or are not logged into your account, your request to opt out through the GPC will not apply to any account information. To learn more about GPC, you can visit https://globalprivacycontro1.urg/.

5. DISCLOSURE OF INFORMATION

We may disclose information about you to third parties for legitimate purposes subject to this Privacy Notice, including the following categories of third parties:

Affiliates: Our affiliates, subsidiaries, or others within our corporate group.
Service Providers: Vendors or other service providers who help us provide the Site, including for system administration, cloud storage, security, website hosting, mailing, customer relationship management, marketing communications, web analytics, payment networks, and payment processing.
Marketing Providers: Third parties for marketing purposes.
At Your Direction: Third parties to whom you request or direct us to disclose information, such as through your use of social media widgets or login integration.
Advisors: Professional advisors, such as auditors, law firms, or accounting firms.
Bankruptcy and Other Business Transactions: Third parties in connection with or anticipation of an asset sale, merger, or other business transaction, including in the context of a bankruptcy.

We may also disclose information about you as needed to comply with applicable law or any obligations thereunder or to cooperate with law enforcement, judicial orders, and regulatory inquiries, to enforce any applicable terms of service, and to ensure the safety and security of our business, employees, and users.

6. SOCIAL FEATURES

Certain features of the Site allow you to initiate interactions between the Site and third party services or platforms, such as social networks (“Social Features”). Social Features include features that allow you to access our pages on third party platforms, and from there “like” or “share” our content. Use of Social Features may allow a third party to collect and/or use information about you. If you use Social Features, information you post or make accessible may be publicly displayed by the third party service. Both we and the third party may have access to information about you and your use of both the Site and the third party service for more information, see the section below, Third Party Websites and Links.

7. THIRD PARTY WEBSITES; LINKS AND EMBEDDED CONTENT

We may provide links to third party websites or platforms. If you follow links to sites or platforms that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies, and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. Information you provide on public or semi-public venues, such as third party social networking platforms, may also be viewable by other users of the Site and/or users of those third party platforms without limitation as to its use. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owner or operators.

The Site may also incorporate features, add-ons, portals, and content including feeds, scripts embedded in the Site’s code, and visible content (e.g., videos), provided by third parties. In some cases, those third parties collect data about how you interact with their content.

8. CHILDREN’S PRIVACY

Children under the age of 13 are not permitted to use the Site, and we do not seek or knowingly collect any personal information about children under 13 years of age for use in association with the Site. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the information below to request that it be deleted.

9. DATA SECURITY AND RETENTION

Despite our reasonable efforts to protect information about you, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Site or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information.

Information you provide to us should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up to date. We retain information about you for as long as it is reasonably necessary for the purposes specified in this Privacy Notice and in accordance with our internal policies and procedures (including, without limitation, backup and archival processes). When determining the length of time to retain information about you, we consider various criteria, including whether we need the information to continue to provide you with the Site, resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security and integrity, or protect ourselves, including our rights, property or product.

10. CALIFORNIA RESIDENTS

This section applies to you only if you are a California resident (“resident” or “residents”). For purposes of this section, references to “personal information” shall include “sensitive personal information,” as these terms are defined under the California Consumer Privacy Act (“CCPA”).

Processing of Personal Information

In the preceding 12 months, we (i) collected the following categories of personal information about residents for the following purposes, and (ii) (where indicated below) disclosed for a business or commercial purpose (as identified below) to third parties the following categories of personal information:

Category	Categories of Purposes (defined in the Use of Information section above)	Categories of Recipients (defined in the Disclosure of Information section above)
Identifiers such as name, telephone number, e-mail address, IP address	Site Administration and Purpose Collected; Communication with You Personalization; Advertising; Analytics Marketing Communications Evaluation and Improvement Quality Assurance Lawful Processes; Protection of Company	Affiliates Service Providers Marketing Providers At Your Direction Advisors Bankruptcy and Other Business Transactions
Commercial information such as records of products or services requested or that your requested information on	Site Administration and Purpose Collected; Communication with You Personalization; Advertising; Analytics Marketing Communications Evaluation and Improvement Quality Assurance Lawful Processes; Protection of Company	Affiliates Service Providers Marketing Providers At Your Direction Advisors Bankruptcy and Other Business Transactions
Internet or other similar network activity such as Usage Data (as defined above)
Approximate geolocation data such as IP address
Audio, electronic, visual, thermal, olfactory, or similar information such as photographs, video recordings and voice recordings
Professional or employment-related information such as title of profession or employer
Inferences drawn from other personal information

The criteria we use to determine how long to retain personal information about you is described in the section above, Data Security and Retention.

This Privacy Notice does not cover our collection and use of California job applicant data. California job applicants must accept a separate Applicant Privacy Notice that details what information we collect during their application process and why.

Right to Opt Out of Selling and/or Sharing of Personal Information

We do not have actual knowledge that we “sell” or “share” (as those terms are defined under the CCPA and used throughout this section) personal information of residents under 16 years of age. Additionally, we do not sell personal information as the term “sell” is commonly understood (i.e., to mean the exchange of something for monetary value). However, we do “sell” your personal information to, and “share” your personal information with, third parties for the purpose of cross-contextual behavioral advertising purposes (e.g., targeted advertising and remarketing). The CCPA holds such disclosures and sharing to be considered “selling” or “sharing”.

In the preceding 12 months, we have sold and/or shared the following categories of personal information about residents:

Category of Personal Information	Categories of Purposes	Categories of Recipients
Identifiers	Analytical and targeted advertising purposes (including, without limitation, cross-contextual behavioral advertising). Specifically, to target advertisements for goods and services and to display those advertisements on other websites.	Analytics, marketing, advertising, and remarketing partners and service providers
Internet or other similar network activity

You may have the right to opt out of the selling and targeted advertising as described herein. You may exercise this right to opt out by utilizing the Global Privacy Control as mentioned in the Do Not Track & Global Privacy Controls section above, or by clicking the “Cookie Preferences” link in the footer of the website and changing your cookie settings as described in the pop-up. If you have any questions or concerns, or would like more information on our ability to opt out, you can contact us by email: compliance@plansource.com.

11. your privacy rights

Certain jurisdictions (for example, California) provide their residents certain rights and options with respect to their personal information. Depending on your residence, location, and laws applicable to our processing of your personal information, you may have the ability to exercise the rights listed below. Subject to foregoing and all application limitations, exemptions, or exceptions, you may have the right to:

Right to Know: Know (1) the categories of personal information collected, disclosed, sold and/or shared; (2) the categories of sources from which the personal information was collected; (3) the business or commercial purpose for collecting, selling, and/or sharing personal information; (4) the categories of third parties with whom we disclosed, sold, and/or shared personal information; and (5) the specific pieces of personal information we have collected about you.
Right to Data Portability: Access and receive the specific personal information we process about you in a structured, commonly used and machine-readable format, and to transmit it to another entity where this is technically feasible.
Right to Delete: Delete personal information about you.
Right to Correct: Correct personal information about you.
Right to No Discrimination: Not be discriminated against due to your exercise of the rights provided under applicable law that are related to our processing of your personal information.
Right to Lodge a Complaint: Lodge a complaint with a government regulator (e.g., your state attorney general) or supervisory authority, in the jurisdiction that you reside in, if you consider that the collection or use of personal information about you violates this Privacy Notice or applicable law.

We do not use personal information about you in furtherance of automated profiling decisions that produce a legal or similarly significant effect.

To exercise these rights, please see the Exercise Your Rights section below.

12. EXERCISE YOUR RIGHTS

As noted above, you may have certain rights, or applicable law grants you certain rights as it relates to the Site and information we collect about. You may submit a request to us by:

Emailing: compliance@plansource.com
Visiting: https://info.plansource.com/privacy-policy

For clarity, to exercise your rights to opt-out of targeted advertising, or the “selling” or “sharing” of personal information about you, you must follow the instructions provided under the Right to Opt Out of Selling and/or Sharing of Personal Information section above.

To verify certain requests—for example, requests to know, delete, or correct—we may need to collect additional information to verify your identity and the request, such as your email address or phone number, before providing a substantive response to the request.

You may also authorize an agent to make requests on your behalf to exercise your rights. If you have a registered agent to act on your behalf, we have the right to authenticate such agent’s authority to act.

13. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Notice, please email us at compliance@plansource.com or contact us at 122 W. Pine Street, Suite 203, ATTN: Legal & Compliance, Orlando, FL 32801.

PlanSource Services Privacy Notice

Last Updated: October 9, 2026

INTRODUCTION

This Privacy Notice describes how PlanSource Holdings Inc. and its subsidiaries (“PlanSource”, “we”, “us”, “our”) collects, uses and discloses information about individuals who use our applications, portal, services, tools and features or otherwise interact with us as a user of our services (collectively, the “Services”). For the purposes of this Privacy Notice, “you” and “your” means you as the user of the Services, whether you are a customer or representative of a company with whom we do business, or another individual whose information we have collected pursuant to this Privacy Notice.

Please read this Privacy Notice carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice. If you do not agree to this Privacy Notice, please do not use or access the Services.

If you are an employee accessing the Services pursuant to your employer’s employee benefits plan or payroll, please also note that this Privacy Notice does not apply to your employer’s collection or use of information. Please consult your employer if you have questions about their data collection and use practices.

The English language version of this Privacy Notice shall control.

1. CHANGES TO THIS PRIVACY NOTICE

We may modify this Privacy Notice from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Notice. If we make material changes to the way in which we use or disclose information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Services.

2. BENEFITS PLATFORM DATA COLLECTION AND USAGE

When you use or access the Services, we collect certain information about you from a variety of sources that identifies you and/or your dependents and beneficiaries (“Personal Data”).

Information You Provide to Us

Some features of the Services may require you to directly provide us with certain information about yourself and/or your dependents and beneficiaries. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services includes:

Basic identifiers, such as your full legal name, date of birth, postal address, phone number, personal email address, and work email address.
Professional and employment information, such as your professional / employer contact information (e.g., work email or phone number), job title, the organization you represent, and your organization’s details and location.
Account information, such as username and password. If you choose to register an account, you are responsible for keeping your account credentials safe. We recommend that you do not share your access details with anyone else. If you believe your account has been compromised, please contact us immediately.
Demographic information, such as your age, gender, race, ethnicity, and/or marital status.
Government identifiers, such as your Social Security number.
Health Information, such as your health history or your family health history, and other information to determine appropriate insurance coverage as needed to deliver the Services.
Health Care Election/Coverage Information, such as your previous and current benefits enrollment selections as needed to deliver the Services.
Any other information you choose to include in communications with us, for example, when sending a message through the Services or submitting information to us (e.g., through a contact or request form on the Services).

All categories of personal information described above exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, excluding aggregators and providers necessary to deliver the text messaging service.

Information We Collect Automatically

We also automatically collect certain information about your interactions with the Services (“Usage Data”). To do this, we may use cookies or other tracking technologies used by Company such as, for example, cookies, pixels, web beacons/clear gif, and other tracking technologies. (“Tracking Technologies”). Usage Data includes:

Device information, such as device type, operating system, device ID numbers and unique device identifier, media access control (MAC) address, and internet protocol (IP) address.
Location information, such as imprecise geolocation (based on IP address).
Other information regarding your interaction with the Services, such as operating system, browser type, log data, date and time stamps, device screen resolution, the pages you access on the Services, the websites you access before and after visiting the Services, the length of time you spend on the Services, clickstream data, and ad impressions.

For more information on how we use Tracking Technologies and your choices, see the section below, Cookies and Other Tracking Technologies.

Information Collected from Other Sources

Your Employer. Information, such as your hire date, that we receive from your employer.
Analytics Data. Information such as aggregate information about your interactions with the Services that we receive from analytics providers.
Health Information. Collected via claims information at your present and past health carriers when you use the Services.

Finally, we may deidentify information about you such that it cannot reasonably be used to infer information about you or otherwise be linked to you (or we may collect information that has already been identified), and we may use such deidentified information for any purpose. To the extent we possess or process any deidentified information, we will maintain and use such information, we will maintain and use such information in deidentified form and not attempt to re-identify the information, except solely for the purpose of determining whether our deidentification process satisfies legal requirements.

Chatbot Functionality

In the use of the Services, you may interact with certain chatbot functionality. A “chatbot” or “bot” is a computer application that attempts to simulate human conversation, in order to allow people to interact with digital devices as if they were communicating with a real person. The data from the chats is retained for as long as the data is needed. Chat outputs or monitored and tested by humans for continuing accuracy. Chatbot functionality may be provided by a third party, and, therefore, such third party may have access to information about you based upon the information you disclose and/or your interaction with the chatbot. Although we have implemented technical safeguards to prevent your Personal Information from reaching third party chatbot providers, we suggest that you do not submit Personal Information or other sensitive information into these chatbots.

3. USES OF INFORMATION

With respect to the categories of information we collect, we use information about you as described below:

How we may use your Personal Information	The Reasons
Services Administration and Purpose Collected; Communication with You	For the purpose for which you disclosed and we collected information about you, for example, to process and communicate with you in connection with your use of the Services, to process your requests for information, to display requested content, our business activities, to provide user support to users of the Services.
Provision of Benefits	We use information we collected about you for the purpose of processing and managing employee benefits, employee payroll, and business-to-business transactions.
Personalization; Advertising; Analytics	To tailor the content and information that we may send or display to you, to suggest personalized help and instructions, and to personalize your experience while visiting or using our Services; sharing it with our third party service providers to understand how our Services are used and to improve the Services; so we and our third party service providers to target advertisements for goods and services and to display those advertisements on other websites. For more information, please see the Cookies and Other Tracking Technologies section below.
Marketing Communications	To send you marketing communications about our business, products, Services, and other programs that may be of interest to you. In order to provide you with a personalized experience, these communications may be tailored to your preferences based on, for example, inferences we make using your visits to the Services or the links you click on in our emails. Please note that pixel tags, cookies and other online trackers may be used within emails to track your interactions with those websites and when emails are opened. You may opt out of receiving marketing communications from us at any time by following the unsubscribe instructions contained in the applicable email. Specifically with regard to text messaging, if you opt in to receiving text messages (SMS and MMS) on the Services when prompted, we may send you autodialed and other text messages at the telephone number you provide relating to your use of the Services. Consenting to receiving text messages is not required to buy goods or Services or to do business with us. Message and data rates may apply. Note that, even if you opt out of receiving promotional communications from us, you may still receive administrative communications from us with respect to your use of the Services.
Evaluation and Improvement	To analyze, develop, and improve the content, materials, products, and the Services; to inform marketing and communication plans; to understand user demographics and preferences; to analyze the effectiveness of the Services; and to evaluate user experiences (e.g., analyzing which features and portions of the Services are most popular; for troubleshooting, for statistical purposes).
Quality Assurance	To perform quality assurance; to assist with fraud identification, and to assist our customer relationship representatives (for example, through representatives in our call center), we use tools to monitor and record certain user experience information, including, without limitation, audio of customer service calls and information resulting from such calls.
With Your Consent	With your consent, we may use and share information about you in ways not specifically described in this Privacy Notice.

COOKIES AND OTHER TRACKING TECHNOLOGIES

Cookies are an example of the automatic data collection technology that we use. A cookie is a text file placed on the browser to automatically store your preferences. The limited information that may be collected using cookies includes your browser type, the date and time of your visit, the pages you visit, and the amount of time spent on each device.

Information collected using cookies is anonymous and used for analytical purposes only.

Analytics Tools & Providers

As noted above, the Services uses third-party analytics tools to collect and process data about your use of the Services. Our analytics providers may set and read cookies to collect this data, and your web browser will automatically send data collected by those cookies to our analytics providers. Our analytics providers use this data to provide us with reports that we will use to improve the Services’ structure and content.

4. DISCLOSURE OF INFORMATION

We may disclose information about you to third parties for legitimate purposes subject to this Privacy Notice, including the following categories of third parties:

Affiliates: Our affiliates, subsidiaries, or others within our corporate group.
Service Providers: Vendors or other service providers who help us provide the Services, including for system administration, cloud storage, security, website hosting, mailing, customer relationship management, marketing communications, web analytics, payment networks, and payment processing.
Carriers & Point Solution Partners: Insurance carriers and providers for the purpose of sharing your coverage selections to fulfill the Services.
Your Employer: Your company platform Administrators or Human Resources or equivalent team.
At Your Direction: Third parties to whom you request or direct us to disclose information, such as through your login integration.
Advisors: Professional advisors, such as auditors, law firms, or accounting firms.
Bankruptcy and Other Business Transactions: Third parties in connection with or anticipation of an asset sale, merger, or other business transaction, including in the context of a bankruptcy.

5. THIRD PARTY WEBSITES, LINKS, AND EMBEDDED CONTENT

We may provide links to third party websites or platforms. If you follow links to sites or platforms that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies, and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. Information you provide on public or semi-public venues, such as third party social networking platforms, may also be viewable by other users of the Services and/or users of those third party platforms without limitation as to its use. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owner or operators.

The Services may also incorporate features, add-ons, portals, and content including feeds, scripts embedded in the Services’ code, and visible content (e.g., videos), provided by third parties. In some cases, those third parties collect data about how you interact with their content.

6. CHILDREN’S PRIVACY

The Services are designed for and directed to adults. Children under the age of 13 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children under 13 years of age. If we are notified that we have unknowingly collected personal information of a minor under the age of 13, except in connection with such minor being a dependent in connection with a benefit program to which you have enrolled them in or they are required to be enrolled in, we will promptly make commercially reasonable efforts to delete such information. If you submit personal information relating to a minor, you are consenting to allow us to process that information for purposes of administering the Services.

Parents or guardians of children under 13 years of age who have provided us with their personal information may contact us using the information below to request that such information be deleted. Such requests will be subject to authenticating the parental/guardian identity and status. If you believe we might have any information from or about a child under 13 that was not obtained voluntarily from the child’s parent or legal guardian in connection with the administration of our Services, please contact us at compliance@plansource.com.

7. DATA SECURITY AND RETENTION

Despite our reasonable efforts to protect information about you, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information.

8. CALIFORNIA RESIDENTS

Processing of Personal Information

Category	Categories of Purposes (defined in the Use of Information section above)	Categories of Recipients (defined in the Disclosure of Information section above)
Identifiers such as name, telephone number, e-mail address, IP address	Services Administration and Purpose Collected; Communication with You Provision of Benefits Personalization; Advertising; Analytics Marketing Communications Evaluation and Improvement Quality Assurance Lawful Processes; Protection of Company	Affiliates Service Providers Marketing Providers At Your Direction Advisors Bankruptcy and Other Business Transactions
Characteristics of protected classifications under California or federal law such as race, national origin or ancestry, sex (including gender, pregnancy, sexual orientation, and gender identity), age, physical or mental disability, and veteran status.	Services Administration and Purpose Collected; Communication with You Provision of Benefits	Affiliates Your Employer Carriers & Point Solution Partners
Sensitive personal information such as: Government identifiers such as drivers license numbers and social security numbers; Account access credentials such as account log-in and password; Sensitive demographic information such as race or ethnicity; Precise geolocation data;	Services Administration and Purpose Collected; Communication with You Provision of Benefits Lawful Processes; protection of Company	Affiliates Your Employer Carriers & Point Solution Partners
Commercial information such as records of products or services requested or that your requested information on	Services Administration and Purpose Collected; Communication with You Provision of Benefits Personalization; Advertising; Analytics Marketing Communications Evaluation and Improvement Quality Assurance Lawful Processes; Protection of Company	Affiliates Service Providers Marketing Providers At Your Direction Advisors Bankruptcy and Other Business Transactions
Internet or other similar network activity such as Usage Data (as defined above)
Approximate geolocation data, such as IP address
Visual information, such as photographs, you optionally elect to upload to the platform
Professional or employment-related information such as title of profession, employer, professional background

We only use and disclose sensitive personal information for the purposes specified in the CCPA. We do not sell or share sensitive personal information with third parties for cross-contextual behavioral advertising.

The criteria we use to determine how long to retain personal information about you is described in the section above, Data Security and Retention.

No Selling and/or Sharing of Personal Information

We do not “sell” or “share” (as those terms are defined under the CCPA and used throughout this section) personal information with respect to the Services.

9. YOUR PRIVACY RIGHTS

Right to Know: Know (1) the categories of personal information collected, disclosed, sold and/or shared; (2) the categories of sources from which the personal information was collected; (3) the business or commercial purpose for collecting, selling, and/or sharing personal information; (4) the categories of third parties with whom we disclosed, sold, and/or shared personal information; and (5) the specific pieces of personal information we have collected about you.
Right to Data Portability: Access and receive the specific personal information we process about you in a structured, commonly used and machine-readable format, and to transmit it to another entity where this is technically feasible.
Right to Delete: Delete personal information about you.
Right to Correct: Correct personal information about you.
Right to No Discrimination: Not be discriminated against due to your exercise of the rights provided under applicable California law that are applicable to our processing of your personal information.
Right to Lodge a Complaint: To lodge a complaint with a government regulator (e.g., your state attorney general) or supervisory authority, in the jurisdiction that you reside in, if you consider that the collection or use of personal information about you violates this Privacy Notice or applicable law.

We do not use personal information about you in furtherance of automated profiling decisions that produce a legal or similarly significant effect.

To exercise these rights, please see the Exercise Your Rights section below.

10. EXERCISE YOUR RIGHTS

As noted above, you may have certain rights, or applicable law grants you certain rights as it relates to the Services and information we collect about. You may submit a request to us by:

Visiting: https://info.plansource.com/privacy-policy
Emailing: compliance@plansource.com

For clarity, to exercise your right to opt-out of targeted advertising, or the “selling” or “sharing” of personal information about you, you must follow the instructions provided under the Right to Opt Out of Selling and/or Sharing of Personal Information section above.

11. HOW TO CONTACT US

PlanSource Applicant Privacy Notice

1. Introduction

PlanSource Benefits Administration, Inc. and its affiliated companies and subsidiaries (“PlanSource”, “we”, “our”, or “us”) will collect and process the information that we receive related to job applicants and employment candidates during the application process. This information may include information that identifies a particular individual, could be used to identify a particular individual (whether directly, indirectly or in combination with other data), or is otherwise linked or reasonably linkable to a particular individual (“Personal Data”). This PlanSource Applicant Privacy Notice (“Applicant Privacy Notice “) sets out which Personal Data we collect about you and how we use it.

Throughout this Applicant Privacy Notice, we may use the term “processing” to cover all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, disclosing, transferring and disposing of information.

The controller of your Personal Data will be the PlanSource entity to whom you apply for a position and PlanSource Benefits Administration, Inc. See Section 9 of this Applicant Privacy Notice for information about how to contact PlanSource about our information practices or this Applicant Privacy Notice.

If you are a resident of California, see Appendix A, California Applicant Notice.

This Applicant Privacy Notice is not intended and shall not be read to create any express or implied promise or contract for employment, for any benefit, or for specific treatment in specific situations. Nothing in this Applicant Privacy Notice should be construed to interfere with our ability to process personal data for purposes of complying with legal obligations or for investigating alleged misconduct or violations of PlanSource policy or law, subject to compliance with local applicable law.

Please note that this Applicant Privacy Notice does not apply to any personal data or other information we collect via your interactions with us through our services, platform, website, mobile applications, or other means outside of the job application process.

2. Purposes of processing your Personal Data

In this Section, we describe the purposes for which we collect and process Personal Data about applicants. Where required by applicable law, we will obtain your consent to the collection and processing of your Personal Data. If you do not provide Personal Data indicated as mandatory (for example, on our application form), we may not be able to process your application.

2.1. Administration of application process and assessment of your skills, qualifications and suitability for the vacancy, including information verification

PlanSource may process your Personal Data for the purpose of administrating the application process. This includes reviewing your Personal Data to assess your skills, qualifications and your suitability for our career opportunities, as well as to take measures to verify that the information you have provided is true and accurate, including by means of reference checks (where permitted by applicable local laws). Personal Data processed for these purposes may include:

name, address, email address, telephone number or other contact information;
position applied for, application letter and job preferences, how you heard about the position, your willingness to travel if the applied position so requires, eligibility to work in the jurisdiction in which the position(s) you apply for are located;
information about current employment;
your work visa, permit, or other documents evidencing authorization to work under the applicable immigration laws;
your educational background, references, CV and application details, interview and assessment data, vetting and verification information and previous experience;
your previous (job) experience and references;
photographs;
memberships of committees or other bodies;
language skills, computer knowledge, special skills including (driver) licenses, interests, leisure activities, other qualifications, activities;
any other Personal Data necessary or voluntarily given by you in connection with your application.

2.2. Record-keeping and communication of career opportunities

PlanSource may process your Personal Data for the purpose of keeping your record for current and future hiring processes, including for the purpose of communicating with you and providing you with information regarding potential career opportunities that suit your profile (with your consent where required by applicable law). Personal Data processed for this purpose includes:

name, address, email address, telephone number or other contact information;
position applied for, application letter and job preferences, how you heard about the position, your willingness to travel if the applied position so requires, eligibility to work in the jurisdiction in which the position(s) you apply for are located;
information about current employment;
education, previous (job) experience, CV and references;
memberships of committees or other bodies;
language skills, computer knowledge, special skills including (driver) licenses, interests, leisure activities, other qualifications and activities; and
any other Personal Data necessary or voluntarily given by you in connection with your application.

2.3. Establish, exercise and defend legal claims

PlanSource may process your Personal Data for the purposes of establishing, exercising and defending potential legal claims. Personal Data processed for these purposes include:

name, address, email address, telephone number or other contact information;
position applied for, application letter and job preferences, how you heard about the position, your willingness to travel if the applied position so requires, eligibility to work in the jurisdiction in which the position(s) you apply for are located;
information about current employment;
education, previous (job) experience and references;
photograph;
memberships of committees or other bodies;
language skills, computer knowledge, special skills including (driver) licenses, interests, leisure activities, other qualifications and activities; and
any other Personal Data necessary or voluntarily given by you in connection with your application.

2.4. Special Category Data

To the extent permitted by applicable laws, PlanSource collects and processes a limited amount of Personal Data that falls into the definition of special categories of Personal Data, sometimes called “sensitive personal data” or “sensitive data”, which may include:

physical or mental health (including details of accommodations or adjustments);
trade union membership;
sensitive demographic information such as ethnicity, race, and sexual orientation;
background check and drug testing results; and
criminal records and information regarding criminal offences or proceedings.

Where we process special categories of Personal Data it will be justified by a condition set out at Sections 2.1–2.3 above and also by one of the following additional conditions: (a) is necessary for the performance of the application and hiring review process; (b) the processing is necessary for the purposes of carrying out the obligations and exercising the rights of you or PlanSource in the field of employment law, social security and social protection law, to the extent permissible under applicable laws and there is no reason to believe that the data subject has an overriding legitimate interest in not processing the data; (c) the processing is necessary for the purposes of preventive or occupational medicine, for the assessment of your working capacity, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services, to the extent permitted by applicable laws; (d) the processing is necessary to protect your vital interests or of another person where you are physically or legally incapable of giving consent (for example in exceptional emergency situations, such as a medical emergency); and (e) the processing is necessary for purposes authorised by applicable law.

2.5. Retention of your Personal Data

The Personal Data processed pursuant to your application for employment will be processed in accordance with our data retention guidelines, which apply running from the date from when the hiring process related to the position(s) you have applied for is finished, unless a longer period is necessary for our legal obligations or related to a legal claim, or unless you consent to (or explicitly request) our continued processing of your Personal Data related to potential future career opportunities for which you may be interested.

3. Collection of Personal Data

PlanSource mainly obtains your Personal Data directly from you. You may provide this information directly to the hiring manager or relevant recruiter or enter it into our systems (for example, through your self-service access to our online recruitment system, your participation in the recruitment process, emails and instant messages you send or through verbal information which is recorded electronically or manually). In addition, further information about you may be generated by the relevant recruiter, hiring manager or other employees involved in the recruitment process.

To the extent permitted by applicable law, we may also obtain some information from third parties: for example, references from a previous employer, information from tax authorities, or where we employ a third party to carry out a background check (where permitted by applicable law). We may also receive Personal Data from government authorities.

In some circumstances, subject to applicable law, data is collected indirectly from monitoring by, for example, building and location access control and monitoring systems when you come to our premises for an interview, CCTV, telephone logs and recordings and email logs), if and to the extent permitted by applicable laws. In these circumstances, the data may be collected by PlanSource or a third-party provider of the relevant service. This type of data is generally not accessed on a routine basis but access is possible. Some data may be obtained from publicly accessible sources.

In the event that particular information is required by contract or statute this will be indicated at the time of collection. We will also let you know where there are consequences of you not providing the information requested. Failure to provide some information will mean that we cannot carry on with the recruitment process. For example, if you do not provide us with your name or background, we will not be able to consider you for employment. In some cases, it may mean that we are unable to engage further with you as PlanSource will not have the Personal Data we believe to be necessary to reach a recruitment decision.

4. Disclosure and transfer of Personal Data

For the purposes listed above, and with your consent (where required by applicable law) we may share your Personal Data on a need–to-know basis with PlanSource employees due to their function within PlanSource (in the country of the posted position and in other countries where we have operations (including countries outside your country or jurisdiction of residence, which may include India and the US), with external parties or associates, such as applicant verification vendors, data hosting providers, law enforcement, courts, regulatory authorities, and with PlanSource’ parent, subsidiaries and/or affiliates, where permitted by applicable law.

Additionally, PlanSource has centralized certain elements of its human resources management. As a result, we have centralized aspects of its processing of personal information. Accordingly, where we are permitted to do so under applicable law, we may transfer or provide your Personal Data both in and outside of the nation where you reside and/or work. Where required by applicable law, we have ensured that personal information subject to such a transfer is adequately protected through the use of contractual clauses and reasonable and appropriate security measures designed to safeguard such information. PlanSource has taken reasonable steps to ensure that your Personal Data is shared and treated securely and in accordance with this Applicant Privacy Notice and applicable legislation.

We may disclose your personal information to our private equity investor, Vista Equity Partners, and its affiliates (collectively, “Vista”) for administration, research, database development, workforce analytics, and business operations purposes in line with the terms of this Privacy Notice. Vista may process and share your personal information on the basis of its legitimate interests in managing, administering and improving its business, research and workforce analytics, overseeing the recruitment process, and, if applicable, your employment relationship with PlanSource. We and Vista may share your personal information with Vista and other Vista portfolio companies for the purpose of being considered for other job opportunities in the pooling system, both inside and outside of the European Economic Area (“EEA”) and United Kingdom (“UK”). Please find a list of Vista portfolio companies at https://www.vistaequitypartners.com/companies/ and Vista’s privacy notice at https://www.vistaequitypartners.com/privacy/. In connection with the recruitment process, your personal data may be transferred via our Applicant tracking system and Criteria Corp., which provide applicant tracking and evaluation services.

Transfers in accordance with this Section are based on the same legal ground as is applicable for the respective purpose (as set forth in Section 2 above).

Your Personal Data transferred or stored outside your country or jurisdiction of residence will be accessible to law enforcement and regulatory authorities according to the applicable laws of such foreign jurisdictions.

5. Revocation of consent

You may, at any time, revoke consents that you have given to PlanSource pertaining to any such processing of Personal Data that is based on your consent.

You may revoke your consent by contacting PlanSource via the contact details set forth below. Please indicate details of your consent revocation (which Personal Data, etc.). Upon such revocation, PlanSource will cease to process your Personal Data relating to the purposes for which your consent has been revoked.

6. Rights related to Personal Data

6.1. Your Rights

It is every applicant’s responsibility to provide PlanSource with accurate Personal Data. An applicant must notify PlanSource when there are changes to ensure the Personal Data collected is reliable for its intended use. Except as otherwise set forth in this Applicant Privacy Notice, we shall only use Personal Information in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. To the extent necessary for these purposes, PlanSource will take steps in accordance with the applicable legislation to keep your Personal Data accurate, complete and up-to-date.

If applicable law permits and is applicable to our processing of your Personal Data, then (subject to all applicable exemptions and exceptions) you may have the following rights:

To request that we have any inadequate, incomplete or incorrect Personal Data corrected.
To request access to the Personal Data that we store about you and to information about how we have processed your Personal Data.
To request that we delete such Personal Data under certain circumstances.

Please contact us via the information in the “Contact Us” section of this Applicant Privacy Notice below if you’d like to make a request pursuant to the above rights.

6.2. Complaints

You also have the right to lodge a complaint with us or a supervisory authority, in your jurisdiction of residence, if you consider that the processing of your Personal Data infringes applicable law or this Applicant Privacy Notice. For further information regarding your rights, or to exercise any of your rights, please contact us through the details below.

7. Security

We have implemented measures designed to secure Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of Applicant Personal Data also depends on you. Unfortunately, the transmission of information via the internet is not completely secure. Despite our measures, we cannot guarantee the security of Applicant Personal Data. Any transmission of personal information is at your own risk.

If you become aware of any breach regarding Applicant Personal Data security or of this Applicant Privacy Notice, please notify us at compliance@plansource.com immediately.

8. Confidentiality

Confidential Information means all non-public information disclosed by PlanSource, whether orally or in writing, that is designated as “confidential” at the time of disclosure or that reasonably should be understood to be confidential given the nature of the information and/or the circumstances of disclosure, including, without limitation: business and marketing plans, technology and technical information, products and product plans and designs, business processes, trade secrets, financial data, and know-how.

PlanSource may disclose Confidential Information to applicants during the application process. By submitting an employment application and accepting this Notice, applicants agree to protect PlanSource Confidential Information during and after the application process. Applicants may not divulge any such information outside of the PlanSource application process. PlanSource may be entitled to take legal action if you are responsible for the unauthorized sharing of confidential information to any external third parties, including other employers.

9. Use of Artificial Intelligence (AI)

Interviews may be transcribed using AI call recording tools, in which case you will be notified and given the right to opt-out. AI-generated call transcriptions are subject to the PlanSource Employee and Applicant Data Retention Policy and may be subject to state employment law retention requirements.

9.1. Automated Decision Making and Profiling

PlanSource does not leverage automated decision making or profiling in disqualification decisions, nor does it engage with third party applicant sourcing services that leverage automated decision making or profiling.

10. Notices of Changes and Additional Privacy Notices

PlanSource may change or update this Applicant Privacy Notice at any time. The most current version is available at plansource.com/privacy/#applicant for your review.

11. Contact Us

If you have any questions or concerns regarding the processing of your Personal Data, please contact our Privacy Team at compliance@plansource.com. You may also contact the relevant PlanSource controller in writing using the details below:

PlanSource Benefits Administration, Inc.
Registered Address: 122 W. Pine St., Suite 203, Orlando, FL 32801, USA

APPENDIX A – CALIFORNIA APPLICANT NOTICE

PURPOSE OF THIS NOTICE

This Appendix A (the “California Applicant Notice”) describes our collection and use of certain personal information relating to external job applicants and candidates for positions with PlanSource that reside in California (”Applicants”). This California Applicant Notice describes our collection and use of certain personal information about Applicants and is intended to satisfy our applicable notice requirements under the California Consumer Privacy Act (“CCPA”). We may provide Applicants additional notices about our data collection practices that are covered by other laws (e.g., if we conduct a background check or extend an employment offer).

SCOPE OF THIS NOTICE

This California Applicant Notice applies to the personal information that we collect from and about Applicants, in the context of reviewing, assessing, considering, managing, storing or processing their applications or otherwise considering them for a position with us.

What is personal information?

In this California Applicant Notice, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

What isn’t covered by this notice

This California Applicant Notice does not address or apply to our collection of personal information that is not subject to the CCPA, such as consumer credit reports and background checks, publicly available data lawfully made available from state or federal government records, or other information that is exempt under the CCPA. This California Applicant Notice also does not apply to the personal information we collect from employees (which is subject to a separate privacy notice).

Are our practices the same for all Applicants?

The categories of personal information that we collect and our use of personal information may vary depending upon the position(s) or location, as well as the associated qualifications and responsibilities. The information in this California Applicant Notice is intended to provide an overall description of our collection and use of personal information about Applicants. Also, in some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain personal information.

CATEGORIES OF PERSONAL INFORMATION COLLECTED

As addressed above in Purposes of processing your Personal Data, we may collect the below categories of personal information about Applicants to the extent permitted under applicable laws:

Identifiers: such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or account name.

Paper and electronic records: records containing personal information, such as name, signature, photo, contact information, education and employment history, Social Security number and other government identifiers, insurance policy number, financial or payment information, medical information, or health insurance information.

Characteristics of protected classifications: such as race, color, sex, sexual orientation, gender identity, age, religion, national origin, disability, citizenship status, military/veteran status, marital status, medical condition or other characteristics of protected classifications under California or federal law. (Note: generally, this information is collected on a voluntary basis and is used in support of our equal opportunity and diversity and inclusion efforts and reporting obligations, or where otherwise required by law.)

Internet or other electronic network activity information: such as browsing history, search history, and information regarding interactions with an internet website, application, or advertisement, as well as physical and network access logs and other network activity information related to your use of any PlanSource device, network or other information resource.

Geolocation data: imprecise location information about a particular individual or device.

Audio, video and other electronic data: audio, electronic, visual, thermal, olfactory, or similar information, such as, CCTV footage, photographs, and call recordings and other audio recording (e.g., recorded meetings and webinars).

Employment information: professional or employment-related information.

Education information: information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

Inferences: inferences drawn from any of the information identified above to create a profile about an individual regarding her or his preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

PURPOSES FOR COLLECTING AND USING PERSONAL INFORMATION

Subject to applicable legal restrictions, we use Applicant personal information for the following purposes:

Recruiting, hiring, and evaluating applicants: to review, assess, recruit, consider or otherwise manage applicants, candidates and job applications, including:

scheduling and conducting interviews;
identifying candidates, including by working with external recruiters;
reviewing, assessing and verifying information provided, to conduct criminal and background checks, and to otherwise screen or evaluate Applicants’ qualifications, suitability and relevant characteristics;
extending offers, negotiating the terms of offers, and assessing salary and compensation matters;
satisfying legal and regulatory obligations;
communicating with Applicants regarding their applications and about other similar position(s) for which they may be interested;
maintaining Applicant personal information for future consideration; and
in support of our equal opportunity employment policy and practices.

Security and monitoring: to monitor and secure our resources, network, premises and assets, including:

monitoring for, preventing and investigating suspected or alleged misconduct or violations of work rules;
monitoring for, preventing investigating and responding to security and privacy incidents;
providing and managing access to physical and technical access controls;
monitoring activities, access and use to ensure the security and functioning of our systems and assets;
securing our offices, premises and physical assets, including through the use of electronic access systems and video monitoring; and
conducting appropriate screenings of individuals prior to entering or accessing certain locations or premises.

Auditing, accounting and corporate governance: relating to financial, tax and accounting audits, and audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations, and for other internal business purposes such as administration of our records retention program.

M&A and other business transactions: for planning, due diligence and implementation of commercial transactions, for example mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization or other similar business transactions.

Defending and protecting rights: to protect and defend our rights and interests and those of third parties, including to manage and respond to employee and other legal disputes, to respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.

Complying with legal obligations: relating to compliance with applicable legal obligations (such as hiring eligibility, responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, Social security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions and guidance.

SOURCES

Consistent with the “Collection of Personal Data” section above, we collect certain categories of personal information directly from Applicants and, in some circumstances, third parties. The categories of sources that we collected personal information from in the prior 12 months includes the following:

The Company’s internal and external Website’s (including a job candidate’s email).
The Company’s third-party service providers.
Job candidate communication with the Company.
The U.S. Government (through E-Verify)

SENSITIVE PERSONAL INFORMATION

As noted in Section 2.4 of the Applicant Privacy Notice above, some personal information we collect may be considered sensitive. We will only collect the sensitive personal information identified in Section 2.4 of the Applicant Privacy Notice for the purposes specified in the Applicant Privacy Notice.

CALIFORNIA PRIVACY RIGHTS

The CCPA grants individuals that are California residents certain rights in regard to our collection of personal information. These rights include, only to the extent applicable and to the extent granted to you under the CCPA:

The right to request the disclosures of (1) what personal information about you has been collected; (2) the categories of sources from which personal information about you was collected; (3) the business or commercial purpose for collection or selling/sharing (if applicable) personal information about you; (4) the categories of third parties with whom we share personal information about you; and (5) the specific pieces of personal information about you we have collected;
The right to request the deletion of your personal information that has been collected;
The right to request the correction of your personal information that has been collected;
The right to not be discriminated against due to their exercise of their rights under the CCPA. We do not discriminate against job candidates for exercising the rights granted to them under the CCPA.

The above rights are only exercisable by you where the CCPA grants you the right to be exerted and where no exception or exemption under the CCPA applies. You may also have a registered agent (if and only as permitted under applicable law) that you authorize to act on your behalf. If you have a registered agent to act on your behalf, we have the right to authenticate such agent’s authority to act.

We do not sell your personal data to third parties, nor do we share your information for purposes of cross-contextual behavioral advertising as defined under the CCPA.

EXERCISING YOUR RIGHTS

To exercise your rights as described herein, you may submit a request to us (as described above) by either emailing compliance@plansource.com or using our online intake form. We will respond to requests within the applicable timeframe required by the CCPA.