1FBUSA Privacy

Last Updated: 3/27/2023

California Privacy Policy for

Job Applicants, Employees and Independent Contractors

Who Are California Residents

This California Privacy Policy (“Privacy Policy”) explains how 1st Financial Bank USA and its wholly-owned subsidiaries, Premier Financial Services and 1fb.net inc. (“Bank”, “we,” “us” or “our”), collect, use and disclose Personal Information (defined below) about job applicants, employees and independent contractors who reside in California (“California workforce member”, “you” or “your”), as required by the California Consumer Privacy Act of 2018 and amended by the California Privacy Rights Act of 2020 (together, the “CCPA”).

1. Personal Information

For purposes of this Privacy Policy, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household and that we collect, use, and disclose in the context of their current or former role as our employees, job applicants, and independent contractors. The Privacy Policy also applies to the beneficiaries of your employment benefits, such as the individuals who are on your health plan and the beneficiaries of your retirement accounts, as well as your emergency contacts. It is your responsibility to inform any such individuals about this Privacy Policy and ensure that you have the right to provide their Personal Information to us.

2. Our Collection of Personal Information

The following chart details which categories of Personal Information we collect and process, as well as which categories of Personal Information we disclose to third parties for our operational business and hiring and recruitment purposes, including within the 12 months preceding the date this Privacy Policy was last updated.

Categories of Personal Information	Disclosed to Which Categories of Third Parties for Operational Business Purposes
Identifiers, such as real name, alias, postal address, unique personal identifiers, email address, photo badges, beneficiary designations and government-issued identifiers (e.g., Social Security number and driver’s license)	Our affiliates; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; and public and governmental authorities, such as regulatory, tax or other authorities and law enforcement agencies, courts, arbitrational bodies, fraud prevention agencies
Personal information as defined in the California customer records law, such as name, contact information, signature, medical, insurance, financial, education and employment information and history, and physical characteristics or description	Our affiliates; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; and public and governmental authorities, such as regulatory, tax or other authorities and law enforcement agencies, courts, arbitrational bodies, fraud prevention agencies
Protected Class Information, such as characteristics of protected classifications under California or federal law, such as sex, age, gender, race, disability, citizenship, military/veteran status, primary language, immigration status, marital status, and requests for leave	Our affiliates; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; and public and governmental authorities, such as regulatory, tax or other authorities and law enforcement agencies, courts, arbitrational bodies, fraud prevention agencies
Commercial Information, such as transaction information and purchase history, such as travel expenses, including information about corporate credit card purchases and travel-related programs and expenses	Our affiliates; professional advisors, such as accountants, auditors, bankers, and lawyers; and public and governmental authorities, such as regulatory, tax or other authorities and law enforcement agencies, courts, arbitrational bodies, fraud prevention agencies
Biometric Information, such as fingerprints	Service providers that provide services such as background checks
Internet or network activity information, such as access and usage information regarding websites, applications and systems, information about online communications, including browsing and search history, timestamp information, and access and activity logs	Our affiliates; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; and public and governmental authorities, such as regulatory authorities and law enforcement agencies, courts, arbitrational bodies, fraud prevention agencies
Geolocation Data, such as building access cards, device location, Bank-owned vehicle location, and approximate location derived from IP address, or GPS, Wi Fi or BLE tracking	Our affiliates; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; and public and governmental authorities, such as regulatory, tax or other authorities and law enforcement agencies, courts, arbitrational bodies, fraud prevention agencies
Audio or Video Data, such as audio, electronic, visual and similar information, such as call and video recordings created in connection with our business activities, including voicemail and security camera footage, information about the use of electronic devices and systems, key card usage; and photos on websites or in employee directories	Our affiliates; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; and public and governmental authorities, such as regulatory, tax or other authorities and law enforcement agencies, courts, arbitrational bodies, fraud prevention agencies
Professional or Employment-Related Information, such as work history and prior employer, information from reference checks, background screening information, employment application, membership in professional organizations, personnel files, personal qualifications and training, eligibility for promotions and other career-related information, work preferences, business expenses, wage and payroll information, benefit information, information on leaves of absence or PTO, performance reviews, and information on internal investigations or disciplinary actions	Our affiliates; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; and public and governmental authorities, such as regulatory, tax or other authorities and law enforcement agencies, courts, arbitrational bodies, fraud prevention agencies
Inferences drawn from any of the Personal Information listed above to create a profile about, for example, a California workforce member’s preferences, characteristics, predispositions, and abilities	Our affiliates; and professional advisors, such as accountants, auditors, bankers, and lawyers
Sensitive Personal Information. Personal Information that reveals an individual’s Social Security, driver’s license, state identification card, or passport number; precise geolocation; racial or ethnic origin, citizenship, immigration status, the contents of mail, email, and text messages unless the Bank is the intended recipient of the communication; The processing of biometric information for the purpose of uniquely identifying an individual; and Personal Information collected and analyzed concerning an individual’s health.	Our affiliates; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; and public and governmental authorities, such as regulatory, tax or other authorities and law enforcement agencies, courts, arbitrational bodies, fraud prevention agencies

Categories of Personal Information

Disclosed to Which Categories of Third Parties for Operational Business Purposes

Identifiers, such as real name, alias, postal address, unique personal identifiers, email address, photo badges, beneficiary designations and government-issued identifiers (e.g., Social Security number and driver’s license)

Our affiliates; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; and public and governmental authorities, such as regulatory, tax or other authorities and law enforcement agencies, courts, arbitrational bodies, fraud prevention agencies

Personal information as defined in the California customer records law, such as name, contact information, signature, medical, insurance, financial, education and employment information and history, and physical characteristics or description

Protected Class Information, such as characteristics of protected classifications under California or federal law, such as sex, age, gender, race, disability, citizenship, military/veteran status, primary language, immigration status, marital status, and requests for leave

Commercial Information, such as transaction information and purchase history, such as travel expenses, including information about corporate credit card purchases and travel-related programs and expenses

Our affiliates; professional advisors, such as accountants, auditors, bankers, and lawyers; and public and governmental authorities, such as regulatory, tax or other authorities and law enforcement agencies, courts, arbitrational bodies, fraud prevention agencies

Biometric Information, such as fingerprints

Service providers that provide services such as background checks

Internet or network activity information, such as access and usage information regarding websites, applications and systems, information about online communications, including browsing and search history, timestamp information, and access and activity logs

Our affiliates; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; and public and governmental authorities, such as regulatory authorities and law enforcement agencies, courts, arbitrational bodies, fraud prevention agencies

Geolocation Data, such as building access cards, device location, Bank-owned vehicle location, and approximate location derived from IP address, or GPS, Wi Fi or BLE tracking

Audio or Video Data, such as audio, electronic, visual and similar information, such as call and video recordings created in connection with our business activities, including voicemail and security camera footage, information about the use of electronic devices and systems, key card usage; and photos on websites or in employee directories

Professional or Employment-Related Information, such as work history and prior employer, information from reference checks, background screening information, employment application, membership in professional organizations, personnel files, personal qualifications and training, eligibility for promotions and other career-related information, work preferences, business expenses, wage and payroll information, benefit information, information on leaves of absence or PTO, performance reviews, and information on internal investigations or disciplinary actions

Inferences drawn from any of the Personal Information listed above to create a profile about, for example, a California workforce member’s preferences, characteristics, predispositions, and abilities

Our affiliates; and professional advisors, such as accountants, auditors, bankers, and lawyers

Sensitive Personal Information.

Personal Information that reveals an individual’s Social Security, driver’s license, state identification card, or passport number; precise geolocation; racial or ethnic origin, citizenship, immigration status, the contents of mail, email, and text messages unless the Bank is the intended recipient of the communication;
The processing of biometric information for the purpose of uniquely identifying an individual; and
Personal Information collected and analyzed concerning an individual’s health.

We may also disclose the above categories of Personal Information to a third party in the context of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business assets, or stock (including in connection with any bankruptcy or similar proceedings).

We do not “sell” Personal Information, and we do not “share” or otherwise process Personal Information for purposes of cross-context behavioral advertising, as defined under the CCPA. We have not engaged in such activities in the 12 months preceding the date that this Privacy Policy was last updated. Without limiting the foregoing, we do not sell or share Personal Information of minors under 16 years of age.

3. Purposes for the Collection and Use of Personal Information

We may collect, use, or disclose the foregoing categories of Personal Information for the purposes of operating, managing, and maintaining our business, sourcing talent and recruiting employees, and accomplishing our business purposes and objective, including, for example, using Personal Information:

To manage and document your employment with us and for employment-related actions;
To comply with state and federal law and regulations;
To process payroll, manage wages and other awards such and bonuses, reimburse expenses;
To track time and attendance, and manage leaves of absence and vacation;
To manage workers’ compensation claims;
To administer and maintain benefits, including group health insurance;
To administer and maintain retirement services;
To evaluate requests for reasonable accommodations related to disability, medical leave of absence, and religion;
To manage employee performance for promotions, discipline and/or termination;
To conduct workplace investigations;
To receive and evaluate job applicants and candidates for employment;
To communicate with you about your application, respond to your inquiries and notify you of applicable terms and policies;
To contact you about future career opportunities;
To obtain and verify background, credit, and reference checks, consistent with applicable law;
To grant and monitor access to our secure facilities, systems and applications;
To fulfill administrative functions, such as aggregate management reporting, statistical analyses, internal training, and as generally required to conduct our business
To maintain emergency contact and beneficiary details;
To conduct research, analytics, and data analysis, such as to assist in succession planning and to ensure business continuity, as well as to design employee retention programs and diversity initiatives;
To maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance;
To protect the safety and security of our workforce, customers, visitors, property and assets, including monitoring activities in our facilities and on our computers, devices, networks, communications and other assets and resources;
To detect security incidents and other fraudulent activity;
To facilitate and implement any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
To comply with law, legal process, requests from governmental or regulatory authorities, internal policies and other requirements, such as record-keeping, equal employment opportunity laws, work permit and immigration regulations, reporting obligations, and the exercise or defense of legal claims.

4. Use of Sensitive Personal Information

We may use Sensitive Personal Information for purposes of performing services for our business, providing services as requested by you, and ensuring the security and integrity of our business, infrastructure and the individuals we interact with. This includes, without limitation, receiving and processing your job application, evaluating your suitability for the position(s) you are applying for, conducting background checks, analyzing and monitoring diversity, making you an offer (subject to our discretion), fulfilling administrative functions, complying with law, legal process or requests from governmental or regulatory authorities, and exercising or defending legal claims.

5. Retention Period

We retain Personal Information including, without limitation, Sensitive Personal Information for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

The duration of the job application and employment process;
Whether your job application is successful and you become and employee;
Whether, if your application is not successful, you would like to be notified of future job opportunities with us or our affiliates;
The length of time we have an ongoing relationship with you and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
Whether there is a legal obligation to which we are subject (for example, certain laws may require us to keep your application records for a certain period of time); and
Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

6. Sources of Personal Information

We collect the categories of Personal Information listed in Section 2 from the following categories of sources:

Directly from you, such as from paper or electronic forms you complete;
Indirectly from you, such as information you authorize a service provider to provide to us;
From service providers that interact with us, such as for background screening and verification including education, past employment, criminal background, and references; and
From public sources, such as the Internet or public records.

7. Individual Requests

The CCPA gives you specific rights regarding your Personal Information. These rights are described below.

Access to Information. You may request that we disclose to you the following information covering the 12 months preceding your request:

The categories of Personal Information we have collected about you;
The categories of sources from which we collected Personal Information about you;
The business purpose for collecting Personal Information about you;
The categories of Personal Information about you that we disclosed to third parties for a business purpose and the categories of third parties to whom we disclosed such Personal Information; and
A copy of your Personal Information, including the specific pieces of Personal Information we have collected about you, including a copy of the Personal Information you provided to us in a portable format.

Deletion of Personal Information. You may request that we delete any of the Personal Information that we collected from you, subject to certain exceptions.

Correct Inaccurate Information. You may request that we correct inaccurate Personal Information that we collect or maintain about you.

We will not unlawfully retaliate against you for making a request under the CCPA. In some instances, we may decline to honor your request where the law or right you are invoking does not apply or where an exception applies. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request.

8. How to Make a Request

You may make a privacy request by calling us at 1-866-683-1674 or sending an email to cbraunger@1fbusa.com.

We cannot respond to a privacy request unless we are able to verify that the requestor is the California workforce member about whom we have collected Personal Information or the member’s authorized agent (“verifiable consumer request”). To enable us to determine whether a request is a verifiable consumer request, we may need to request additional Personal Information from you, such as name, address, date of birth and/or Social Security number, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.

Only you or an agent that you have authorized to act on your behalf may make a verifiable consumer request related to the Personal Information we collect about you. You may also make a request on behalf of your minor child. Before acting on a request from an authorized agent, we may require that you verify your identity and provide your written permission authorizing the agent to make a request on your behalf. We may deny a request from an authorized agent who does not submit proof that you authorized him, her or it to act on your behalf.

9. Diversity

In certain cases, we will ask questions about race/ethnic origin, gender, and disability of our job applicants, for monitoring equal opportunity. We may also inquire about criminal records, where permitted by applicable law. Otherwise, we ask that you avoid submitting information that may qualify as sensitive information under applicable law, except where such information is legally required. We are an equal opportunity employer, which means we offer equal treatment to all job applicants consistent with applicable law. We do not unlawfully discriminate, either directly or indirectly, based on characteristics protected by applicable law, such as race, ethnicity, sex, gender identity, sexual orientation, nationality, national origin, ethnic origin, religion, beliefs or creed, age, disability, marital status, veteran status or genetic information in any area of recruitment.

10. Applicant Obligations

Any information you submit to us must be true, complete and not misleading. Submitting inaccurate, incomplete, or misleading information may lead to a rejection of your job application during the application process or disciplinary action including immediate termination of employment. In addition, it is your responsibility to ensure that information you submit does not violate any third party’s rights. If you provide us with Personal Information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.

11. Contact for More Information

For questions or concerns about our privacy policies or practices, the ways in which we collect and use your Personal Information, your rights and choices regarding the collection and use of your Personal Information, or to exercise your rights under the CCPA, you may call us at 1-866-683-1674 or send an email to cbraunger@1fbusa.com.

12. Changes to this Privacy Policy

We may, at any time and from time to time in our sole discretion, amend this Privacy Policy. When we do, we will post the revised Privacy Policy on this page with a new “Last Updated” date.

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