CPCA Notice

PK Privacy Notice for California Residents

Applicants, Employees and Contractors

Effective Date: January 1, 2020

Last Reviewed on: November 13, 2019

This Privacy Notice for California Residents applies to individuals who apply for PK positions, employees and contractors who reside in the State of California (“Applicable Persons” or “you”). ProKarma Inc. (“we” or “PK” or “us”) 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. PK reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you and update this notice


We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with an Applicable Person (“personal information”). PK has collected the following categories of personal information from Applicable Persons within the last twelve (12) months:

Category Examples Collected Purpose Collected For
A. Identifiers.


A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.




To identify Applicable Persons, to communicate with Applicable Persons, to process employment applications, to process and administer benefits, to conduct background checks, to process payroll or invoicing, ensure proper withholdings, to comply with applicable laws, to conduct other necessary business activities in connection with an Applicable Person’s application, employment or service to PK.


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 number, 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.




We collect this information to process employment applications, to process and administer benefits, to conduct background checks, to process payroll or invoicing, to comply with applicable law to ensure proper withholdings, to ensure an individual is authorized to work in the United States.
C. Protected classification characteristics under California or federal law.


Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).




If this information is provided, we use this information to comply with applicable law, such as to provide legally required EEOC reports, to administer benefits or determine whether or not an individual is qualified for benefits, in connection with health and safety reports.
D. Commercial information.


Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.


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 voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.




F. Internet or other similar network activity.


Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.




We or our customers may track employee or contractor browser or internet history if the employee or contractor uses the PK or customer network, devices, equipment, software, hardware or similar materials.
G. Geolocation data.


Physical location or movements.




We use your home address and work address, as well as changes to those addresses to communicate with you, for payroll withholding purpose and compliance with applicable laws.


H. Sensory data.


Audio, electronic, visual, thermal, olfactory, or similar information.




I. Professional or employment-related information.


Current or past job history or performance evaluations.




We use this information to process job applications, to assess contractor or employee skills, for performance reviews, promotions/terminations, discipline or other necessary business uses.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).


Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.




K. Inferences drawn from other personal information.


Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.




We may use certain information to analyze or assess the effectiveness of corporate functions, programs or projects. We may conduct surveys to gain insight into these items to improve corporate functions, programs, projects etc.


Personal information does not include and this policy does not apply to:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the scope of CCPA, like: (a) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or (b) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

PK obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete.
  • Indirectly from you. For example, from observing your actions.
  • From our vendors or suppliers. For example, from our 401(k) plan vendor.


We may use, or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information
  • To provide, screen, interview, assess, communicate with, hire, onboard and support through the application or employment process
  • To screen, assess, communicate with onboard and support contractors
  • To provide benefits programs
  • To provide payment
  • To help maintain the safety, security, and integrity of our Company, technology assets, and business
  • For testing, research, analysis
  • To respond to law enforcement requests, litigation or regulatory requests, examinations or audits
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA
  • For any other lawful purpose which is necessary to our business


PK may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

  • Category A: Identifiers.
  • Category B: California Customer Records personal information categories.
  • Category C: Protected classification characteristics under California or federal law.
  • Category F: Internet or other similar network activity.
  • Category G: Geolocation data.
  • Category I: Professional or employment-related information.
  • Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties: Service providers, Government entities.


We do not sell your personal information.