Privacy

This Privacy Notice applies to current and former (full or part-time) employees, workers, and contractors. SFHG, whether as your employer or the entity with which you have a contract, is responsible for deciding how we collect and use personal information about you, and this Privacy Policy describes how we collect and use personal information about you during and after your working relationship with SFHG in accordance with applicable data protection laws, statutes, and regulations (“Data Protection Legislation”).

This Privacy Policy does not form part of any contract of employment or other agreement to provide services, and nothing in this Privacy Policy shall be construed to in any way terminate, supersede, undermine, or otherwise modify the status of the employment or professional relationship between you and SFHG, pursuant to which SFHG may terminate the employment or professional relationship at any time, with or without cause, and with or without notice. This Privacy Policy imposes no independent obligation on SFHG to proceed with any business transaction or agreement, and does not create any employment or professional relationship between you and SFHG.

SFHG may amend or update this notice from time to time and we will, when necessary and appropriate, notify you of such amendments and updates.

TYPES OF INFORMATION   WE HOLD ABOUT YOU AND FOR HOW LONG

Personal information, or personal data, means any information that is subject to Data Protection Legislation and that relates to an identified, or identifiable, living individual. It does not include data, which has been anonymized.

EXAMPLES OF CATEGORIES   OF PERSONAL INFORMATION   WE COLLECT

By way of example, we may collect,   store, and use the following categories of personal information about you:

Personal contact details, such as the following: name, date of birth, title, addresses, telephone numbers, and personal email addresses

• Gender
• Marital status and dependents
• Next of kin and emergency contact information
• Social security numbers and passport information
• Bank account details, payroll records, and tax-related information
• Salary, annual leave, pension, and benefits information
• Start date
• Location of employment or workplace, and other general business contact information
• Driver’s license information, including the following: license numbers, state of issue, status, and expiration dates
• Online identifiers and use of SFHG’s systems, networks, and environment, including internet, intranet, and email communications
• Recruitment data,  including  the  following: resume  or  CV, right to  work  documentation, references, background check records, and other information in a CV or cover letter or as part of the application process
• Employment records and information, such as the following: business contact information, professional titles, work history, working hours, training records, start/appointment date, and professional memberships and designations
• Military or similar leave or jury service
• Leaver’s records, termination/exit arrangements
• Commission information
• Compensation history
• Work performance information
• Disciplinary and grievance information
• Information about your use of our information and communications  systems
• Photographs

We   may   collect,   store   and,   use   the   following    “special    categories”    of   sensitive   personal information.

TYPE OF SPECIAL CATEGORY OF DATA

• Information about your race or ethnicity, religious/philosophical beliefs, sex life/sexual orientation, and political opinions
• Trade union membership
• Information about your health, including any medical condition, health and sickness records
• Genetic information and bio-metric data
• Information about criminal convictions and offenses

HOW WE COLLECT YOUR PERSONAL  INFORMATION

We collect personal information about our employees, workers, contractors, and agents through the recruitment process, either directly from you or an employment agency. We may, in our discretion, collect additional personal information about you from third parties, including former employers and references, if we believe such information will assist in the employment process.

We also collect additional personal information about you in the course of your employment-related activities throughout the period you work for us, and this information came directly from you, or from other sources, such as your colleagues, supervisors, or third party service providers.

HOW WE USE YOUR PERSONAL INFORMATION

We only use (or process) your personal information in accordance with all Data Protection Legislation and we do not sell your personal information for any business reason or other purpose.  Most commonly, we use your personal information in the following circumstances:

• perform the contract we have entered into with you (including employment-related benefits, bonuses, and incentive schemes);
• comply with a legal obligation; or
• act in accordance with  our legitimate interests (or those of a third party),  such as: the operation of our business, business development, and publicizing our business; protecting our networks, and personal data of employees and customers/clients, against unauthorized access or data leakage; checking compliance with policies and terms of employment agreements or agreements  with  contractors,  including  with  compliance  with  our  Employee Handbook; operational matters and other matters related to human resources and administrative functions, such as background checks and employment screening, maintaining employment records, recording transactions, training, and quality control; monitoring and managing access to, and use of, our networks and systems, including monitoring and tracking of email use and communications, and activity on SFHG’ s intranet and portal; managing and securing facility access and physical security; for security vetting and investigating complaints and allegations of criminal offences; as part of investigations by regulatory bodies, or in connection with legal proceedings or requests; complying with legal, regulatory and corporate governance obligations and good employment practice and ensuring safe working practices; investigating disciplinary and grievance matters and taking steps in accordance with our disciplinary and grievance  policies.  We will only rely on legitimate interests where your interests and fundamental rights do not override those interests.

In rare cases, we use your personal information in order to perform the following:

• protect your interests (or someone else’s interests); or
• act in the public interest or for official purposes.

We may also use your personal information in any other circumstances in which you have provided consent to our data processing after being accurately informed of the purposes of such processing, and any risks thereto.

HOW WE USE YOUR SPECIAL CATEGORIES OF PERSONAL DATA

Special categories of personal information (such as medical records), often known as “sensitive personal data,” require higher levels of protection.  We may, under certain Data Protection Legislation, need to have further justification for collecting, storing, and using this type of information. We only use your sensitive personal data:

• In limited circumstances, with your explicit written consent;
• in order to comply with a legal obligation;
• in order to act in the public interest;or
• if required to assess your working capacity on health grounds, subject to appropriate confidentiality

In rare cases, we use your  sensitive  personal  information  in relation  to legal claims  or to protect your  interests  (or someone  else’s  interests)  when you  are not capable  of giving  your  consent,  or where  you have  already  made  the information  public.  Examples of when we use your personal data and special categories of personal data are listed in below. If we rely on your consent, this will be obtained from you separately.

We may share your personal information with third parties when required to do so by law or regulatory requirements to which you or we are subject, where it is necessary to administer our working relationship with you, or where we have another legitimate interest in doing so, such as where it is necessary for the operation of our business.

As part of our data sharing practices, we may provide information to immigration and custom officials, the police, any applicable regulatory bodies, the Company’s legal advisers, auditors, and other professional advisors. We may also disclose your personal information to our third party administrators and service providers, including (but not limited to) the payroll company we  use  to facilitate payment  obligations, the  organizations that  administer or facilitate our health, wellness, financial, and other benefit programs (e.g., group pension plan, brokers who we use to obtain insurance for your benefit, our private medical care provider, our private dental care provider), providers of online training services and external training providers, employment screening and verification support services, and other types of service providers (e.g., our cloud storage providers).

We may also share your personal data with potential acquirers or investors of SFHG, or the business area in which you work. We may share your personal information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all  of  SFHG’s  practice  or  assets,  whether  as  a  going  concern  or  as  part  of  bankruptcy, liquidation, or similar proceeding, in which personal information held by SFHG, in any form or format, is among the assets transferred.

SFHG does not use personal information to subject any individual to a decision based solely on automated processing, including profiling, which produces legal, or similarly significantly effects.

THE CALIFORNIA CONSUMER PRIVACY ACT

The California Consumer Privacy Act (CCPA) requires certain businesses that collect personal information on California “consumers” (as defined within the CCPA) to, at or before the point of collection, inform the consumer as to the categories of personal information to be collected and the purposes for which the categories of personal information shall be used.  The types of personal information that SFHG collects from its employees, workers, contractors, and agents, and the purposes for which such information is used, is set forth in this Privacy Policy. We do not sell or rent personal information that we have collected or retain about you to any other third-party for any purpose.  Accordingly, we do not offer individuals the ability to “opt-out” of the selling or renting of personal information because we do not engage in those practices.

DISCLAIMER

With regard to any personal information that you provide SFHG, regardless of whether that personal  information  relates  to  you  or  a  third  party,  you  represent  that  (i)  such personal information is accurate and complete, (ii) you have the lawful basis to provide SFHG with such personal information, and (iii) you have provided this Privacy Policy to, and received consent from, any third party whose personal information you have provided SFHG.

If you choose not to provide us with the personal information identified herein, then SFHG may not be able to satisfy our own contractual or legal obligations, and in such circumstances, continued employment with SFHG may not be permissible. You acknowledge and agree that SFHG shall not be held liable for any consequence directly resulting from these circumstances.

UPDATES

This Privacy Policy may be updated periodically and without prior notice to reflect changes in SFHG’s personal information practices. SFHG will post the updated version on the intranet and indicate therein when it was most recently updated.

CONTACT

If you have any questions or concerns related to this Privacy Policy, or would like to exercise any of the rights set forth herein, please contact privacy@synergyfinancialholdings.com.

In the alternative, you can write to us at: Synergy Financial Holdings Group, Inc., ATTN: Privacy Inquiry, 301 E Ocean Blvd Ste 1170, Long Beach, CA 90802