Effective Date: January 1, 2020

Last Reviewed:  February 24, 2020

Gavel International Corporation and its parent, affiliates and subsidiaries (“Gavel,” “we,” “us,” or “our”) provide this Privacy Notice for California Consumers/Employees (the “CCPA Employee Privacy Notice”) to supplement the information contained in the Gavel Privacy Policy. This CCPA Employee Privacy Notice sets forth our privacy practices as required by the California Consumer Privacy Act of 2018 (“CCPA”).

The CCPA Employee Privacy Notice applies only to individuals residing in the State of California who are considered “Consumers” under the CCPA and from whom we collect “Personal Information” as described in the CCPA (“Consumers”). We provide you this notice because under the CCPA, California Residents who are employees, employee applicants, or contractors qualify as Consumers. For purposes of this CCPA Employee Privacy Notice, when we refer to Consumers, we mean you to the extent you are a California employee, employee applicant, or contractor.

Information We Collect

We may collect Personal Information from you in a variety of different situations, including, but not limited to on our website, your mobile device, through email, in physical locations, through the mail, and/or over the telephone. More specifically, Gavel collects the following categories of Personal Information from California employees or potential employees, which will depend on the particular Business Purpose for which we collect it:

Category Examples of Personal Information Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, , Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport 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, or, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, or any other financial information, medical information, or health insurance information.
C. Protected classification characteristics under California or federal law. Age, race, national origin, citizenship, , marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), information relating to same sex benefits, veteran or military status.
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.
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data. Physical location.
H. Sensory data. Audio information.
I. Professional or employment-related information. Current or past job history or performance evaluations.
J. Education information, as defined by the Family Educational Rights and Privacy Act None.
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, predispositions, attitudes, abilities, and aptitudes.

Personal Information does not include deidentified or aggregated consumer information.

Gavel obtains the categories of Personal Information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or services we provide you.
  • Indirectly from you. For example, from observing your actions on our website or from information your computer or mobile device transmits when interacting with our website or mobile applications, among other things.
  • Third parties. For example, staffing and recruiting agencies with whom we contract for services and consumer reporting agencies when we perform employee background screenings.

How We Use Personal Information

We may use or disclose the Personal Information we collect from you or about you to do one or more of the following:

  • To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to apply for a job or become an employee, we will use that Personal Information in connection with your employment or potential employment.
  • To contact you and to inform you about benefits or information relating to your employment or potential employment.
  • To provide, support, personalize, and develop our website and services relating to your employment or potential employment.
  • To create, maintain, customize, and secure your information or account with us.
  • To process your requests or transactions and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To help maintain the safety, security, and integrity of our systems, App or Website, services, databases and other technology assets, and business.
  • For research, analysis, and business development, including to develop and improve our business processes, Website and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your Personal Information or as otherwise set forth in the CCPA or subsequently agreed to by you.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Conagra’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Gavel about our Consumers is among the assets transferred.

How We Share Personal Information

Gavel may disclose your Personal Information to a third party for a business purpose, including to our service providers.

We share your Personal Information with the following categories of third parties:

  • Service providers.
  • Third parties with whom you direct us to share your Personal Information.
  • Other third parties such as consumer reporting agencies when we perform employee background screenings.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Gavel 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 D: Commercial information.
  • Category E: Biometric information.
  • Category F: Internet or other similar network activity.
  • Category H: Sensory data.
  • Category I: Professional or employment-related information.
  • Category K: Inferences drawn from other Personal Information.

Sales of Personal Information

In the preceding twelve (12) months, Company has not sold Personal Information.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. We do not disclose your Personal Information to third parties for their direct marketing purposes.

Privacy Rights for California Minors in the Digital World

If you are a registered user and under eighteen (18) years old, you can request that we remove content or information that you have posted to our website or other online services. Note that fulfillment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been shared or reposted by another user). To request removal of content or information, please send a notice to [email address] or write us at the address below.

Changes to Our CCPA Employee Privacy Notice

Gavel 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 post the updated notice on the App and Website and update the notice’s Effective Date above. Your continued use of our App or Website or interaction with us through other methods following the posting of changes and/or our directing you to the updated CCPA Employee Privacy Notice constitutes your acknowledgment of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Gavel collects and uses your information described above (and in the Gavel Privacy Policy), your choices and rights regarding such use, or how to exercise your rights under California law, please do not hesitate to contact us at:

  • Emailing us at:
    • PrivacyManagement@gavelintl.com
  • Writing us at:
    • Gavel International, ATTN: Privacy Management 935 Lakeview Parkway Suite 190 Vernon Hills IL 60061
  • Calling us at:
    • 800-544-2835, ATTN: Privacy Management and/or General Manager