Personal information does not include: 

• Publicly available information from government records. 
• Deidentified or aggregated consumer information. 
• Information excluded from the CCPA’s scope, like: 
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; 
• Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994. 

How We Collect Personal Information 

We use different methods and sources to collect personal information about you including:  

• Directly from you. For example, from information you provide us or communications you have with us. 
• Third parties. For example, personal or anonymized information about you from third-party companies that provide services that are used in together with our Services. For example, we may collect information such as your name, location, email address, and publicly available information for contacts from social networking sites, including Facebook, X (formerly Twitter), YouTube, and LinkedIn if you subscribe or follow our page on such social networks. We may also collect Aggregated Data (described below) via Google Analytics. 
• Technical and Communication Data. For example, automatically collected information about your devices, software, and web browser to provide you with a personalized experience.  

Aggregated Information: 

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Information”). Aggregated Information could be derived from your personal data but is not considered personal data as this data will not directly or indirectly reveal your identity. For example, we may aggregate your website usage data to calculate the percentage of users accessing our websites and Services. However, if we combine or connect Aggregated Information with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy. 

Using of Your Personal Information 

We may use your information for the purpose of conducting our business operations including, for the following purposes:  

• To communicate with you regarding our services. 
• To complete the payment transactions for the purchase of our services. 
• To respond to your general inquiries. 
• To receive your job application for an open job position and communicate with a job applicant.  
• To improve our Services. 
• To make our website more compatible with your devices and browsers. 
• To allow you to exercise your consumer access rights when applicable.  
• To maintain the security of our Services.  
• To comply with laws, regulations, court orders, or other legal processes. 
• To carry out our obligations and enforce our rights. 
• To process your personal information for any other purpose with your consent. 

In the preceding twelve (12) months, we have used your personal information from the following categories for business purposes: 

• 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 F: Internet or other similar network activity. 
• Category G: Geolocation data. 
• Category H: Sensory data. 
• Category I:  Professional or employment-related information. 
• Category J: Non-public education information. 
• Category L: Sensitive Personal Information. 

Disclosing of Personal Information 

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. 

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: 

• Category A: Identifiers. 
• Category B: California Customer Records personal information categories. 
• Category D: Commercial information 
• Category F: Internet or other similar network activity. 
• Category I:  Professional or employment-related information. 

We disclose your personal information for a business purpose to the following categories of third parties: 

• Affiliates: Any member of our corporate group, which means our affiliates, our ultimate holding company and its affiliates. When we do so, our affiliates will use your data in a manner consistent with this Policy and all applicable data privacy laws. 

• Service Providers: Contractors, service providers, and other third parties (“Service Providers”) we use to support our business. This includes IT infrastructure providers, payment processors, service providers (e.g., job applicant background checks, HR management, and benefits providers), vendors, and consultants. These Service Providers are bound by contractual obligations to keep personal information in accordance with our Policy and applicable privacy laws.   
• Government, Agencies, Courts, or Litigants: We may share your personal data with third parties when we have a good faith belief that disclosure is necessary to comply with a law, regulation, court order, or other legal processes or to detect, prevent, investigate and respond to fraud or intellectual property infringement claims, violations of our contracts or agreements, violations of law, or other misuse of our website or Products and Services. 

Sale of Personal Information/Targeted Advertising 

In the preceding twelve (12) months, we have not sold any personal information or shared any personal information for cross-context behavioral advertising/targeted advertising. 

Sensitive Personal Information 

Sensitive personal information means personal information that reveals (A) a consumer’s social security number, driver’s license, state identification card, or passport number; (B) a consumer’s 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 an account; (C) a consumer’s precise geolocation; (D) a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; (F) consumer’s genetic data; (G) biometric information for the purpose of uniquely identifying a consumer; (H) personal information collected and analyzed concerning a consumer’s health; or (I) personal information collected and analyzed concerning a consumer’s sex life or sexual orientation. 

In the preceding twelve (12) months, we may have collected and used the following sensitive personal information: 

• Driver’s license, state identification cards, or passport number (when collected). 
• Social Security Number (when collected). 
• Race and ethnic origin (when collected). 

Your Rights and Choices  

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. 

Access to Specific Information and Data Portability Rights 

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you the following:  

• The categories of personal information we collected about you. 
• The categories of sources for the personal information we collected about you. 
• Our business or commercial purpose for collecting or selling that personal information. 
• The categories of third parties with whom we share that personal information. 
• The specific pieces of personal information we collected about you (also called a data portability request). 
• If we disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.  

Deletion Request Rights  

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers/contractors to delete) your personal information from our records unless an exception applies.  

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:  

1. Complete the transaction for which we collected the personal information, provide goods or services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform services for you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
7. Comply with a legal obligation.
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Correction Requests 

If you think some of the personal information we have about you is incorrect, you have the right to request that we correct the personal information in compliance with the California Consumer Privacy Act.  

Your Right to Opt-Out of Sale or Sharing Your Information 

We do not sell or disclose personal information with third parties that would be considered a “sale” under the CCPA. Since we do share your personal information for targeted advertising or cross-context behavioral advertising, you are opted-out of “sale” or “sharing” (as defined by the CCPA) your personal information. 

Retention Criteria 

We will retain your personal information as reasonably necessary for the disclosed purpose. The retention periods for each category of personal information, including sensitive information, vary depending on compliance with relevant laws, your request for deletion, and our retention policies. For example, we may need to retain your personal information to comply with our legal or reporting obligations in accordance with the laws or to defend against claims. Consequently, it is not possible for us to provide a definitive length of time. Our retention periods are determined by using and balancing the following criteria: 

• The volume, nature, and sensitivity of your information; 
• The potential risk of unauthorized access, use or disclosure, or misappropriation; 
• The purposes for which we process your personal information; and 
• The retention obligations under applicable legal requirements. 

Exercising Access, Data Portability, Deletion, and Correction Rights 

To exercise the access, data portability, deletion, and correction rights described above, please submit a verifiable consumer request to us by:  

• Emailing us at: privacy-request@worldlink-us.com 
• Calling us at 1-800-673-6155 
• Use the following link to submit your request: REQUEST FORM

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: 

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. 
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create a business relationship with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.  

Response Timing and Format 

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response to the email address from which you submit it.  

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.  

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.  

Non-Discrimination 

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:  

• Deny you goods or services. 
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. 
• Provide you with a different level or quality of goods or services. 
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. 

Notice of Financial Incentives 

We do not offer financial incentives or pricing discounts for providing your personal information. 

Contact Information 

If you have any questions or comments about this notice, our Privacy Notice, any other notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: 

Address: 

Attn: Legal Department 

WorldLink 

3880 Parkwood Blvd, Suite 204 

Frisco, TX 75034 

Email: privacy-request@worldlink-us.com 

Phone: 1-800-673-6155 

Consumer Access Request: Consumer Access Request

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