PRIVACY POLICY

This Privacy Policy applies to the website (the “Site”) of Calzada Capital Partners, LLC and its affiliates (collectively, “Calzada”) and informs you of our policies regarding the collection, use and disclosure of personal information we receive from users of the Site. By accessing this Site, you agree to the collection and use of information in accordance with this Privacy Policy.

INFORMATION WE COLLECT

You may choose to submit information voluntarily to us through the contact form on the Site, in which case we may collect your name, company name, email address, telephone number and any other information that you chose to provide to us. Please do not provide personal information that you do not want us to have.

In addition, we may collect certain information when you access the Site by automated means, such as “cookies,” “web beacons” and IP addresses. We may use this information to better understand, customize and improve the user experience of our Site. For example, we may use third-party web analytics services, such as Google Analytics, that leverage tools to help us understand how visitors engage with and navigate our Site.

HOW WE USE THE INFORMATION

If you choose to provide information to us, the information is used for the purpose you provided it to us. For example, if you provide your contact information in an inquiry to us, we will use your contact information to process and respond to that inquiry and any related activity that may result from your inquiry.

HOW WE SHARE THE INFORMATION

We do not disclose your personal information, except as described in this Privacy Notice.

We may share your information with Calzada Capital Partners, LLC and its affiliates. We may also share your information with service providers that perform services on our behalf, such as analytics providers and hosting providers. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or to comply with applicable legal requirements.

In addition, we may disclose personal information about you (i) if we are required to do so by law or pursuant to legal process, (ii) in response to a request from law enforcement, regulatory or other governmental authorities, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual fraudulent or illegal activity.

LINKS TO OTHER WEBSITES

The Site may contain links to other websites owned and operated by other parties. We have no control over and are not responsible for the privacy policies or terms of use of such sites, and therefore you should familiarize yourself with that party’s privacy policy and terms of use.

DATA TRANSFER

The Site is controlled and operated from the United States and is not intended to be subject to the laws or jurisdiction of any country or territory other than that of the United States.

INFORMATION SECURITY

We maintain appropriate technical and organizational measures designed to protect your personal information against loss or accidental, unlawful or unauthorized, alteration, access, disclosure or use. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.

HOW LONG WE KEEP INFORMATION

We keep personal information for the time period necessary to achieve the purposes outlined in this Privacy Policy, taking into account applicable statute of limitation and records retention periods as required or permitted under applicable law.

GOVERNING LAW

This Privacy Policy forms part of our Terms of Use and as such shall be governed by and construed in accordance with the laws of the State of Illinois, as further provided in the Terms of Use.

HOW TO CONTACT US

If you have any questions about this Privacy Policy, please email us at info@calzadacap.com.

UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy at any time without prior notice to you. We will post the updated version on the Site and indicate when it was most recently updated.

This Privacy Policy was updated April 2019.

 

California Consumer Privacy Act

Effective Date: 1.1.2020

This Notice of Employment Privacy Practices (the “Notice”) applies solely to California “residents” as defined in Section 17014 of Title 18 of the California Code of Regulations, as that section read on September 1, 2017, whose personal information is collected by Calzada Capital Partners (“Calzada, “we,” “us,” or “our”) in the following situations:

  • In connection with a job application;
  • In connection with being an employee of, owner of, director of, officer of, or contractor of Calzada (collectively referred to as “Workforce Member”), to the extent that the personal information is collected and used by Calzada solely within the context of such role or former role as a Workforce Member of Calzada.
  • In connection with emergency contact information of the Workforce Member, to the extent that the personal information is collected and used solely within the context of having an emergency contact on file.
  • Personal information that is necessary for the business to retain or to administer benefits for another natural person relating to the Workforce Member to the extent that the personal information is collected and used solely within the context of administering those benefits.

We refer to such California residents as “you” or “your” throughout this Notice.

We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.

This notice does not address our treatment of certain personal information that is excluded from CCPA’s scope, including any protected health information that is regulated by the Health Insurance Portability and Accountability Act(“HIPAA”).

PERSONAL INFORMATION WE MAY COLLECT

For the purposes of this Notice, Calzada generally collects the following categories of your personal information:

Category & Examples Include:

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 or other government ID number, passport number, employee ID number, or other similar identifiers.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

C. Characteristics of protected classifications under California or federal law.
Age, race, color, ancestry, national origin, immigration status, citizenship, marital status, medical condition, physical or mental disability, sex, gender, pregnancy or childbirth and related medical conditions, or veteran or military status.

In certain limited circumstances, we may collect gender identity, gender expression, sexual orientation, genetic information (including familial genetic information), religion or creed. Please note that we strive to minimize our collection of this type of personal information.

D. Audio, electronic, visual, or similar information.
Pictures (e.g., photographs on government identification cards or passwords or photographs from Calzada social or business events or photographs taken for employee ID purposes), video conferences, video recordings (e.g., videos captured for security purposes), telephone calls(e.g., if your tasks as a Workforce Member require you to participate in telephone calls that may be recorded).

E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voice prints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

F. Professional or employment-related information.
Current or past job history or performance evaluations, professional license information and bar standings; corporate expense information, salary information, drug screen results, fitness-for-duty or pre-employment physical exam results, tax rates, retirement fund information, compensation information, bonus information, benefits information, or stock option information.

G. Education Information.
Schools attended, degrees and certificates awarded or in process, grades achieved in education courses, vocational trainings and certifications and transcript information.

H. Internet or other electronic network activity information.
Browsing history, search history, and information regarding a Workforce Member’s interaction with an internet web site, application, or advertisement.

I. Geolocation data.
Information collected through GPS technology.

J. Inferences.
We may include inferences drawn from any of the personal information identified in categories (A) through (I) in the records we keep about our Workforce Members. This personal information may include your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

HOW WE COLLECT YOUR PERSONAL INFORMATION

Calzada may obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, we collect the personal information you provide to us in connection with your job application or application for Calzada benefits. We will also collect the personal information you provide to us throughout the duration of your employment with Calzada.
  • From your beneficiaries and dependents. For example, your beneficiaries and dependents may provide us with your personal information in the course of their receipt of benefits provided or administered by us.
  • From our service providers. For example, we may collect your personal information from a service provider that conducts background checks for us. We may also receive your personal information from service providers who help us run our business, including payroll, software and travel management providers.
  • From Workforce Members. For example, if a Workforce Member provides your personal information in connection with an application for Calzada-provided benefits.
  • From benefits administrators. For example, we may receive personal information about you from the companies that administer the benefits plans offered by Calzada.
  • From third parties. For example, a third-party recruiter may provide your personal information to us in connection with our search for a Workforce Member.
  • Automatically. For example, we may automatically collect personal information from the computers and other devices that you use in the course of being a Workforce Member. We may also collect such personal information from the electronic platforms we provide to you, including Calzada’s email, word processing and communications platforms.

HOW WE USE YOUR PERSONAL INFORMATION

Calzada may use the categories of your personal information listed above for one or more of the following purposes:

  • To support our organizational and operational functions.
  • To provide services and benefits to you as a Calzada Workforce Member.
  • To properly administer our workforce and its benefits and compensation programs.
  • To evaluate your candidacy or performance as a Calzada Workforce Member.
  • To respond to law enforcement requests and as required or permitted by applicable law, court order, subpoena, or governmental regulations.
  • To safeguard our information technology infrastructure, detect security incidents, conduct investigations and take other actions as required or permitted by applicable law to protect and defend Calzada, our affiliates and subsidiaries, and our Workforce Members, including in connection with legal proceedings.
  • As directed by you.
  • As otherwise described to you when collecting your personal information or as otherwise set forth in the CCPA.

HOW WE SHARE YOUR PERSONAL INFORMATION

In connection with Calzada’s collection and use of your personal information as described above, Calzada may disclose your personal information in the following ways:

  • With our parent organization, subsidiaries and affiliates.
  • With our service providers and benefits administrators.
  • With our auditors, actuaries, accountants, attorneys, governments or other third parties, as required or permitted by applicable law.
  • As directed by you.
  • To comply with the law or to protect our organization. This includes responding to court orders or subpoenas or defending Calzada in a lawsuit. This may also include sharing your personal information if a government agency or investigatory body requests this data. We may share also your personal information when we are investigating a security incident, allegation, or a potential fraud or violation of law.
  • With any successors to all or part of our organization. For example, if we merge with, acquire or are acquired,or sell part of organization to another entity. This may include an asset sale, corporate reorganization or other change of control.
  • As otherwise described to you when collecting your personal information or as otherwise set forth in or permitted the CCPA.

CHANGES TO OUR NOTICE

Calzada reserves the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will update the Notice’s effective date and make available the updated Notice as required by law.