California Consumer Privacy Act (CCPA) Notice for Employees and Candidates (Prospective Employees) and Independent Contractors

California Consumer Privacy Act (CCPA) Notice for Employees and Candidates (Prospective Employees) and Independent Contractors

Date: January 2020

This notice (“Notice”) describes how Solar Spectrum Holdings LLC, Solar Spectrum LLC, dba Sungevity, and HoSoPo Inc., dba Sungevity (the “Company”), including its representatives, agents, employees, affiliates, subsidiaries, any DBA’s, successors and assigns collect and use personal data, as applicable, of independent contractors, job applicants, and employees.

This Notice may supplement or be supplemented by other privacy or data protection related policies and notices. Individuals reading this Notice understand that if they oppose the collection and use of their personal data, they may not be eligible for employment with Company, or to work as an independent contractor, as applicable.

Personal Information Processed

Depending on your relationship with Company, we may process and store personal information about you in the ordinary course of business including, but not limited to, the following categories of personal data:

  • Name;
  • Direct Deposit Information;
  • Address;
  • Age;
  • Race;
  • Gender;
  • Sexual Orientation;
  • Religion(s);
  • Disability;
  • Internet Search/Browser usage and history;
  • Personal Cell usage and history;
  • Business Cell usage and history;
  • Business internet (Wi-Fi, etc.) usage and history;
  • Company email usage, history, and content;
  • Personal email (if accessed on Company internet service) usage, history, and content;
  • Job applications, including, but not limited to, past employment history, educational history,
    certifications, etc.;
  • Resumes, including, but not limited to, past employment history, educational history,
    certifications, etc.;
  • Background check forms, including, but not limited to, Social Security Number, past
    and current addresses, criminal and civil case histories, credit history, driving history, etc.;
  • Drug test, including, but not limited to, current medications, results of the drug test,
    which may include the presence of legal and illegal substances;
  • Job interview notes and/or evaluations;
  • Performance Improvement Plans and Evaluations, which may include specific and
    general examples of performance deficiencies, leave of absence information, etc.;
  • Employee Corrective Action Notices and other Disciplinary Records, , which may
    include specific and general examples;
  • Shirt size;
  • Driver’s license and/or other Governmental-issued form of Identification;
  • Date of Birth;
  • Internal Revenue Service form 8850;
  • Emergency contact information, including relationship with the named party(ies);
  • Public Assistance, Veteran status, and/or service connected disability information;
  • Identification and contact data;
  • Demographic information;
  • Marital status, family members, children’s names and age, details on dependents;
  • Salary, benefits, bonuses, reimbursement and payment data, including bank accounts;
  • Tax and social security information;
  • Function, grade, promotions and career history;
  • Training records;
  • Information on the use of the company Information Technology infrastructure;
  • Closed Circuit Television footage;
  • Photographs;
  • Travel information;
  • Telecommunication data including content of communications (email, instant messaging,
    VoIP, etc.);
  • Work permits;
  • Sensory data, such as may be used in ergonomic assessments;
  • Inferences drawn from other personal information; and,

Where required by law, Company may also collect sensitive personal data, such as data on health (e.g., sick leave, degree of disability, or information on work place accidents) for occupational health and safety assessments, workers’ compensation administration, safety/accident programs, investigations, and prevention, benefits and insurance plan purposes, leave of absence administration, reasonable accommodation request administration; and/or, data on race, gender, national origin, disability, gender identity, or veteran’s status and the like for purposes of Equal Employment Opportunity . We may also collect detailed location data (e.g., GPS tracking on a Company-issued device or when logged into Company systems, whether Company owned or owned by a third party), and/or biometric information for authentication purposes.

Purposes for Processing Personal Information

Company uses personal data described in this Notice for business purposes including, but not limited to:

  • for prospective employees, for the recruitment process and related purposes;
  • for employees, to enter into and for the performance of the employment arrangement, including for general employee management, salary and benefits administration, and termination of the employment relationship;
  • for independent contractors, to enter into a contract for services, to evaluate and assess the quality of the services and other work-related matters, and to provide payment for such services;
  • to meet its legal obligations, such as under federal, state, and local employment law, social security law, and tax law;
  • identification to verify eligibility for legal employment; for payroll, and for other such employment related matters;
  • background check; Equal Employment Opportunity and related laws;
  • Americans with Disabilities Act/Fair Employment and Housing Act and related laws;
  • for an evaluation of network security; job performance; job duties (where applicable);
  • for geolocation (expense reimbursement, job duties, and the like); personal cellphone records could also be used in discovery in litigation involving the Company or in governmental or regulatory investigations involving the Company;
  • to monitor business usage of company provided technology or auto;
  • for communications related to insurance coverage and taxation;
  • to pursue its legitimate interests in connection with common business operations, such as training, evaluating performance, monitoring usage of our internal network and IT systems, assessing competitive compensation and benefits, and researching other metrics related to our business; conducting disciplinary investigations; and,
  • for other specific purposes where we may seek your consent.

Disclosures of Personal Data

For the purposes set out above, Company may share personal data with third party recipients, including, but not limited to:

  • affiliated entities of Company;
  • service providers, such as companies providing consulting or payment services, including, but not limited to, payroll and expense reimbursement;
  • employee health and welfare benefits providers; retirement plans and their advisors and plan administrators; and brokers and their agents;
  • public bodies, such as Social Security Administration and federal, state, and local tax authorities;
  • banks, insurance companies, car leasing companies, vendors and suppliers, as required in common business processes;
  • Company insurance carriers who provide coverage for various company business activities;
  • Company legal, financial, and tax advisors, in their official capacities on behalf of the Company; and,
  • business partners in the context of the sale or merger of all or part of our business.

Company takes appropriate contractual, technical, and organizational measures, as required by law, to keep your data confidential and secure.

Your Rights

Subject to limitations set out in applicable law, you have certain rights with respect to Company’s use of your personal data, including a right of access and erasure, and a right to opt out of the sale of personal data (note that Company does not engage in the sale of employee, candidate or independent contractor personal data as defined under the CCPA). Requests to exercise your rights can be made to

Retention Period

Company retains personal data subject to this Notice in accordance with its data retention policies.


All employees, independent contractors or candidates for employment who have any questions or concerns in connection with Company’s collection and use of your personal data, should contact the Company’s HR Department at:

By continuing to use this website, I agree with, and consent to, the foregoing.