Sono Bello Privacy Notice for California Employees and Job Applicants

Sono Bello Privacy Notice for California Employees and Job Applicants


Last Updated and Effective Date: August 18, 2023


The California Consumer Privacy Act (“CCPA”) provides California employees and job applicants with the following privacy rights regarding their personal information:


  • Knowledge of information collected;
  • Deletion of information collected;
  • Opt-out of information collected;
  • Correction of information collected;
  • Limit use of information collected; and
  • Not to be discriminated or retaliated against for exercising rights under the law.


The CCPA requires Sono Bello to disclose to California employees and job applicants, at or before the point of collection, the categories of personal information to be collected, the purposes for which that information is to be collected or used, whether that information is sold or shared for cross context behavioral purposes, and the length of time a business intends to retain that information. If sensitive personal information is to be collected, the CCPA requires Sono Bello to disclose the purposes for which it is collected or used and whether such information is sold or shared. This Privacy Notice is intended to meet these requirements.


  1. Definitions


The CCPA defines “personal information” as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.


The CCPA also recognizes “sensitive personal information,” which is a subset of personal information that reveals a person’s social security, driver’s license, state identification card or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password or credentials allowing access to the account; precise geolocation, race or ethnic origin, religious or philosophical beliefs, union membership, contents of a person’s mail, email and text messages unless the business is the intended recipient; genetic data; processing biometric information for the purpose of uniquely identifying a person; information collected and analyzed concerning a person’s health, sex life or sexual orientation.


  1. Where We Get Your Information From


Sono Bello collects information about you from the following sources: (1) you; (2) prior employers, references, recruiters, social media platforms; (3) third-party sources of demographic information; and (4) third-party companies, such as background check companies.


  1. Personal and Sensitive Personal Information Collected


Sono Bello collects the following information about you:


  • Identifiers, such as name, government-issued identifier (e.g., Social Security number), and unique identifiers (e.g., employee ID);
  • Personal information, such as real name, signature, SSN, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, passport number, federal identification authorizing work in the United States, access and/or passcodes, insurance policy number, education, employment, employment history, bank account number, other financial information, medical information, or health insurance information;
  • Characteristics of protected classifications under California or federal law, such as age, marital status, gender, sex, race, color, disability, citizenship, primary language, immigration status, military/veteran status, disability, request for leave, and medical conditions;
  • Commercial information, such as transaction information and purchase history (e.g., in connection with travel or other reimbursements or purchases from Sono Bello);
  • Internet or network activity information, such as browsing history and interactions with our online systems and websites and any personal information that you provide while accessing Sono Bello’s computer systems, such as personal credit card information and passwords;
  • Geolocation data, such as device location from usage of Sono Bello’s devices;
  • Audio, electronic, visual, and similar information;
  • Professional or employment-related information, such as work history and prior employer; and
  • Non-public education information.


Sono Bello treats Sensitive Personal Information we collect as Personal Information given that the collection purpose is not for inferring characteristics about you.


  1. How Your Personal and Sensitive Personal Information is Used


We may use Personal and Sensitive Personal Information:


  • To operate, manage, and maintain our business;
  • For hiring, retention, and employment purposes;
  • To make salary payments, other payments, direct deposits or necessary calculations;
  • To evaluate and permit your participation in any retirement or other benefits plan offered by Sono Bello in which you are eligible to participate under the terms of that plan;
  • To otherwise accomplish our business purposes and objectives, including, for example:
    • Administering our personnel policies and procedures;
    • Conducting research, analytics, and data analysis;
    • Maintaining our facilities and infrastructure;
    • Quality and safety assurance measures;
    • Conducting risk and security controls and monitoring;
    • Protecting confidential and trade secret information;
    • Detecting and preventing fraud;
    • Performing identity verification;
    • Performing accounting, audit, and other internal functions, such as internal investigations;
    • Complying with the law, legal process, and internal policies;
      • Maintaining records;
      • Responding to legal requests for information and subpoenas; and
      • Exercising and defending legal claims.
  • Any other purposes authorized by the California Privacy Protection Agency, California or Federal law.


  1. Sharing of Personal Information


We may share personal data received when necessary to administer background checks, our payroll, benefits or plans with vendors or other service providers with whom we contract to assist in the provision of those benefits or payments. This may require that we share your information with vendors, accountants, insurers or third-party administrators or consultants used by the insurer, benefit provider, or vendors we retain to assist us when necessary to accompany these purposes. We may also share your personal information with our affiliates and partners, including the professional practice entities to whom Sono Bello provides business and administrative services. We may also share your information with government entities and regulators, courts of law, law enforcement authorities, attorneys or other third parties when it is reasonably necessary to the exercise or defense of a legal or equitable claim, for an alternative dispute resolution process, to investigate or prosecute the violation of any law or regulation, to recover any Sono Bello property, to comply with a subpoena or court order, or other legal requirement, or when we believe in good faith that such disclosure is necessary to comply with the law, to prevent physical harm or financial loss, or other unlawful activity.


Sono Bello does not sell your personal information. Sono Bello also does not share your personal information with third parties for cross-context behavioral advertising purposes.


  1. Data Retention


The length of time we retain information depends on the nature of the information and the context in which it was received. Sono Bello retains the information it receives about you for the time period required by applicable California or Federal law.


  1. How to Contact Us


Please contact or 1-800-902-1805 for inquiries about this Privacy Notice, or to exercise your rights under the CCPA.