Updated: February 25, 2022
Ways & Wane LLC, a California corporation dba Ways & Wane and its affiliates (collectively, “we,” “our,” “us,” or “Ways & Wane”) value your privacy and trust and are committed to handling your information responsibly as we help employers (“Clients”) by providing employee leaves of absence and short term disability plans administration and related services (the “Services”).
If you have any questions relating to our privacy practices, please contact us at firstname.lastname@example.org.
I. Personal information we collect and how we collect it
- Categories of individuals of whom we collect personal information Visitors: Individuals who visit or use our Site(s).
Candidates for employment: Individuals who are seeking job opportunities with us or for whom we are actively recruiting for job opportunities.
Clients or prospective clients: Business entities in the United States or Canada to whom we offer and/or provide any of our Services, or who seek any such Services, and their employees.
Vendors, service providers or other third parties: Employees, contractors, representatives or agents of our Clients or Prospective Clients, as well as our own vendors, consultants, service providers, or other suppliers of goods and/or services, with whom we have a business relationship and/or who help us provide the Site(s) and/or the Service(s).
Not Intended for Children: Ways & Wane’s Site(s) and Services are not intended for, and we do not knowingly collect personal information of, children less than 16 years of age.
How we collect your personal information
Information you provide to us: Ways & Wane and/or our agents, vendors, consultants, service providers or other suppliers who help us provide the Site(s) and/or the Services may collect information that you provide to us directly. For example, if you use the “Contact” page on our Site(s) to send a message, we collect your name, email address, phone number, company name, what you are interested in discussing, and any other information you choose to provide. We may also collect information about you when you call us, send us an email or other written correspondence, or register for a newsletter or an event through any of our Sites or links in our emails, or through any of our vendors, service providers or suppliers who help us provide such newsletter(s) or event(s). The types of information we may collect include your contact information, such as your first and last name, email address, phone number, and other information you may choose to provide to us.
Information our Clients may provide to us: In order for us to provide our Services, your employer provides us information about you. In providing our Services, your medical providers also provide us information about you. We provide secure means for our Clients, medical providers and others to provide us information about you as part of our provision of Services. Your employer, medical provider and other third parties who provide us your personal information have their own policies and procedures with respect to the handling of your personal information, which we encourage you to learn about.
Information automatically collected: Ways & Wane and its third-party service providers may also collect certain information from Visitors to our Site(s) through the use of a variety of technologies, including cookies, to help improve Visitors’ online experience, to conduct website traffic and other data analytics, and to modify, improve and enhance our Site(s) and Services. Such information includes Internet Protocol (“IP”) addresses, Internet or other electronic network activity information, such as browsing history, search history, and other information regarding your interaction with an Internet website, application, or advertisement.
Information we collect from other sources
We may acquire or receive information about you from vendors, consultants or service providers with whom we have a business relationship, and who we use to help us provide our Services. We may collect information you submit to your public social network profiles such as LinkedIn, and other job board-type websites such as Zoom Info, Monster, Dice, Indeed and Crunchbase. We may combine such third-party data with other information we acquire or receive from or about you in connection with the provision of our Services. Any third-party data collection, storage and sharing, or other activities, are subject to those third parties’ policies and practices. Ways & Wane makes no representations regarding, and is not responsible or liable for, the accuracy of the information provided by third parties or for those third parties’ policies or practices.
- How we use Personal Information
|Categories of Personal Information||Our Business Purposes|
|Identifiers, including name, alias, postal address, email address, telephone number and other contact information, information of professional and personal references and referral sources, emergency contact information, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, social security number, driver’s license number, passport number and other similar identifiers||▪ To manage, administer and otherwise provide Ways & Wane Services
▪ To complete transactions, fulfill terms or obligations, and otherwise perform Ways & Wane Services
▪ Support the employee care navigation process
▪ To understand user issues, usage, and address application crash issues
▪ To provide employment, insurance and other benefits to our employees
▪ To meet legal obligations as an employer or potential employer
▪ To receive candidates for possible employment at Ways & Wane
▪ To understand the demographics of the visitors of the website and to provide a method for visitors to inquire of our services
▪ To respond to your inquiries
▪ To modify, enhance and improve the browsing experience for visitors to any of our Site(s)
|▪ To verify the identity of consumers or their Authorized Agents who submit requests relating to their personal information
▪ To send you emails, mail, messages and other communications about Ways & Wane for marketing, advertising and other promotional purposes
▪ To deidentify, aggregate and/or anonymize data for statistical analysis and reporting purposes
▪ To investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to physical safety of any person, and/or violations of Ways & Wane policies, procedures and/or contracts
▪ To comply with applicable laws and legal requirements, such as court orders, subpoenas, and search warrants, and cooperate with regulatory agencies and law enforcement
▪ To establish or exercise legal rights and/or defend against legal claims of Ways & Wane, of its Clients, and of others for whom Ways & Wane has a legal duty to do so
|Professional or employment- related information, and educational information, including information on your resume or CV, employment history, education history, certifications, languages, security clearance information, work authorization, past and expected compensation, and other work- related information||▪ Same as above|
|Inferences drawn from any other personal information, including assessment of aptitudes, abilitiesand preferences||▪ Same as above|
|Audio, electronic, visual or similar information, included voicemail messages, phone and/or video interviews, recorded phone calls, etc.||▪ Same as above|
|Characteristics of protected classes, including race, nationality, ethnic origin, gender, gender identity, gender expression, age, disability status, military and veteran status, and other protected classifications under California and federal law||▪ Same as above
▪ For purposes of equal opportunity or affirmative action programs, as required or permitted by law
|Commercial information, including records of personal property, and purchasing or consuming histories or tendencies||▪ We do not collect this information|
|Internet or other electronic network activity and geolocation data, including Internet Protocol (IP) address, browsing history, search history, interaction with websites, applications or advertisements||▪ To protect the Ways & Wane Site(s) and Services
▪ To modify, improve and enhance Ways & Wane Site and Services
▪ To analyze visits and activity on our Site(s)
▪ To promote and market Ways & Wane and its Site(s) and Services.
▪ To detect security incidents, protect against malware, illegal activity, and/or pursue those responsible
▪ Identify and repair errors that impair functionality
II. When, to whom and why we disclose or share this information
Ways & Wane does not sell your personal information, and it has not sold any personal information in the preceding 12 months.
We may share or disclose your personal information as follows:
- To perform our Services: We may share your information with service providers who are providing services on our behalf and/or otherwise need to access your information to assist us in providing our Services. We may also disclose your information to third parties, including government agencies, on your behalf and as you may instruct, in providing our Services.
- Vendors, consultants and other service providers: We use vendors, consultants and other service providers to assist us in providing our Site(s) and Services, and it may be necessary for us to provide them with access to your personal information, e.g., vendors, consultants and service providers who provide IT support, who provide background checks, and who provide online software solutions as part of our Services, such as any online platform(s) for our Clients and their employees.
- In compliance with laws, at your consent or direction, and to protect rights, property and safety: We may preserve and disclose your information if we believe doing so is legally required or appropriate: (i) to comply with applicable laws and regulations, law enforcement or national security requests and legal process, such as a court orders or subpoenas; (ii) in response to your consent or at your direction to disclose the information; (iii) to protect your, our, or another’s rights, property, or safety; or (iv) to enforce our policies or contracts.
- Merger, Sale, or Other Asset Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be shared as part of such a transaction as permitted by law and/or contract.
- With your consent: We may share or disclose your personal information for other purposes per your request or with your consent.
- Note re our Clients’ own policies and procedures: If you are an employee of one of our Clients, your employer will process your personal information in accordance with its own policies and procedures.
III. California Consumer’s Privacy Rights
If you are a resident of California, effective January 1, 2020, you have rights with respect to your personal information under the California Consumer Privacy Act (“CCPA”), as follows:
- Right to be informed: You have the right to be informed of the categories of personal information collected about you, the sources from which your personal information was collected, and the business or commercial purposes for which your information is used, disclose or sold, as well as the categories of third parties to whom your information is disclosed or sold.
- Right of access and to obtain a copy: You have the right to request access to and obtain a copy, no more than twice in a twelve-month period, of your personal information collected during the 12 months before your request.
- Right of deletion: You have the right to request that your personal information be deleted, subject to certain For example, your request to delete is subject to the need to complete transactions for which the personal information was collected and comply with legal obligations.
- Right to opt-out of the sale of personal information: Ways & Wane does not sell personal information to third parties.
- Right not to be discriminated against: In exercising any of the foregoing consumer privacy rights, you have the right not to be discriminated against. Ways & Wane will not deny you Services or provide you a different level of services for exercising our rights, unless the difference is reasonably related to the value of your information.
If you would like to exercise your rights, please contact Ways & Wane:
- By calling us at: 1-650-720-7262
- By emailing us at: email@example.com
- By writing to us at:
Ways & Wane
Attention: PRIVACY REQUEST
21395 Eaglestone Rd Grass Valley, CA 95949
You may also designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with your written and signed permission to act on your behalf and by directly confirming with us that you have provided the authorized agent permission to submit the request. As permitted by law, we may require you to verify your identity in response to a request even if you choose to use an agent. The authorized agent will also need to verify its own identity directly with us.
After you or your authorized agent submit a request, we require a high degree of certainty that we have verified that the requester is, in fact, the consumer whose personal information is the subject of the request. We will endeavor to do so using the personal information that we, or one of our vendors, consultants, or service providers, have about the consumer. We may need to obtain additional personal information from the consumer or from other third-party sources to verify the requester’s or authorized agent’s identity, in which case, such additional personal information will be used solely for verification purposes. If we are unable to verify your identity, we reserve the right to deny your requests.
Other California Privacy Rights: California’s “Shine the Light” law (California Civil Code section 1798.83) gives customers who are California residents the right to ask, once a year, (1) what personal information was disclosed to third parties for those third parties’ direct marketing purposes in the prior calendar year; and (2) the identities of the companies with whom the information was shared. The terms “customers” and “personal information” have the meaning given by the Shine the Light (California Civil Code Sec 1798.83).
We do not share personal information, as defined in California Code Civil Section 1798.83, with third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with California’s Shine the Light law by sending us a written request to firstname.lastname@example.org or by mailing us a letter to: Ways & Wane, 21395 Eaglestone Road, Grass Valley, CA 95949 (Attention: Privacy Inquiry). Any such written request must include “California Shine the Light Law Request” in the first line of the description and include your name, street address, city, state, and zip code. We are only required to respond to one Shine the Light law request per customer per year, and we are not required to respond to requests made by means other than through this email address and mailing address. Further note that “Shine the Light” rights and CCPA rights are provided under different statutes and must be exercised separately.
IV. Your Communication Choices
Marketing and Promotional Communications: In accord with your marketing preferences and applicable privacy and data protection laws, we may send you updates via email about opportunities or services we think may be of interest to you, such as active job postings that match your criteria, newsletters, articles, surveys, and event information. If you would like to discontinue receiving such marketing or promotional communications from us, you can unsubscribe or opt-out from receiving such marketing communications from us. Where you have consented to our processing of your information, you may withdraw that consent at any time and opt-out of further processing.
V. Cookies and Online Tracking; “Do Not Track”
Ways & Wane uses “cookies” and similar technologies to help us tailor our Site(s) and your online experiences, and for analytical purposes.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not recognize or respond to browser-initiated DNT signals.
VI. Children’s privacy
Our Site(s) are not directed to children under the age of 13. We do not knowingly collect, use or disclose personal information from anyone under 13 years of age. The terms “personal information” and “child” have the same meaning given to them by the Children’s Online Privacy Protection Act (COPPA). If we learn that a user is under this age, we will not use or maintain his/her personal information. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make reasonable efforts to delete such information from our records.
Children’s privacy for California consumers: Under the CCPA, if we learn that a California consumer using any of our Site(s) or interacting with us is younger than 16, we will not sell the consumer’s personal information without a consent from the consumer’s parent or guardian (for consumer younger than 13) or from the consumer (for consumer between 13 and 16 years old). Our Sites are not directed to children, and we do not sell any personal information, including personal information of children under 16, to third parties.
VII. Security of your information
We maintain reasonable safeguards to protect your information against unauthorized access, use, or disclosure or accidental loss or destruction, and we require third parties providing services on our behalf to do the same. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us.
VIII. Links to other websites and third-party content
IX. Data retention
We will retain your information for as long as needed to provide our Services or as otherwise required or permitted by law. We will retain and use this information as necessary to provide our Services, comply with our legal obligations, resolve disputes, and enforce our agreements.
Those who engage in transactions with Ways & Wane LLC by purchasing Ways & Wane LLC’s services or products, are asked to provide additional information, including as necessary the personal and financial information required to process those transactions. In each case, Ways & Wane LLC collects such information only insofar as is necessary or appropriate to fulfill the purpose of the visitor’s interaction with Ways & Wane LLC. Ways & Wane LLC does not disclose personally-identifying information other than as described above. And visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain website-related activities.
XI. Changes and policy updates
XII. Contact us