Last Updated: January 1, 2023
Here at National Debt Relief, LLC (“NDR,” “we,” “us,” “our”), we work hard to build and maintain a relationship of trust with you. This Privacy Policy (the “Privacy Policy”) governs our collection, use, and disclosure of your Personal Information, including your Sensitive Personal Information (as those terms are defined below) in connection with prospective or actual employment.
This Privacy Policy explains what information we collect about you, how we use or disclose such information, how to exercise any rights you may have with respect to such information (including any rights to opt-out of certain uses of your information), and the safeguards we have in place to reduce the risk of unauthorized access and use.
Please carefully read this Privacy Policy before applying and/or agreeing to employment with us. If you do not agree with the terms of this Privacy Policy, you should refrain from applying or entering into an employment relationship with us. By working for us, you agree to our use of your information consistent with this Privacy Policy.
PRIVACY POLICY CHANGES
This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. Changes to this Privacy Policy will be posted on our website at ww6.wpengine.com/employment-opportunities and copies of the current Privacy Policy will also be available from our People Experience Department by calling 800-300-9550 ext. 8648, or sending an email to People@NationalDebtRelief.com. Any changes will be effective immediately upon posting. If we determine that a change to this Privacy Policy will result in using your Personal Information, including Sensitive Personal Information, acquired before the change in a materially new and previously undisclosed manner, we will provide you notice and obtain your consent for the change.
CONFLICT BETWEEN THIS POLICY AND LOCAL AND FEDERAL LAWS AND REGULATIONS
When federal, state and/or local laws and regulations require a higher level of protection for your Personal Information or Sensitive Personal Information, they take precedence over this Privacy Policy. In addition, the specific requirements of this Privacy Policy apply only when local laws and regulations permit.
INFORMATION WE COLLECT
Personal Information
We may collect information that personally identifies, relates to, describes or is reasonably capable of being associated with you and your household, such as your dependents (“Personal Information”), including:
- Personal Identifiers (e.g., name, social security number, taxpayer identification number, driver’s license number, date of birth, IP address, security questions & answers);
- Biometric & Health Information (e.g., medical reports, illness excuse notes, disability accommodation requests, intrinsic human characteristics such as fingerprints and digital signatures, and behavioral identifiers such as typing, navigation, and engagement patterns);
- Contact Information (e.g., email address, mailing address, phone number);
- Financial Information (e.g., benefit elections, bank account number for direct deposit, wages earned, the existence of garnishment or levies on wages, tax exemptions, deductions, and withholdings);
- Educational Information (e.g., educational institutions attended, and degrees and grades received);
- Geolocation data;
- Professional/Employment Information (e.g., positions held, tenure, resume, references, skill assessments, performance evaluations, disciplinary records, and records of work-related disputes);
- Characteristics of Protected Classifications (e.g., gender, age, race, disability, nationality, and marital, veteran and citizenship status);
- Audio/Visual Information (e.g., call recordings, recordings from security cameras on work premises, employee photos); and
- Interferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal information does not include de-identified or aggregated information about you. It also does not include information that is publicly available from federal, state, or local government records, or lawfully obtained, truthful information that is a matter of public concern.
Sensitive Personal Information
When we collect Personal Information about you, it may include one or more of the following categories of data, which we refer to in this Policy as “Sensitive Personal Information”:
- Government-issued identifiers (e.g., Social Security, driver’s license, state identification card, or passport number);
- Finances (e.g., financial account log‐in, debit card, or credit card number combined with any required security or access code, password, or credentials allowing access to an account);
- Geolocation (your precise geolocation, including address, ZIP code, and city);
- Race, ethnic origin, religion, and union membership (if applicable);
- Contents of your private communications via company email and text;
- Genetic data;
- Biometrics;
- Health-related information; and
- Sexual orientation.
The types of Personal Information (including Sensitive Personal Information) we collect about you may vary based on whether you are an applicant for employment or an actual employee, employment functions, and benefits provided.
Usage Data and Equipment Usage
We automatically collect information in connection with the actions you take on our equipment, including company computers, through our sites, and in connection with your employment activities (“Usage Data”). For example, each time you log into our systems we automatically collect your username, password, the date and time of your activities, and the duration of your access. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information. If it is capable of determining your geolocation, we treat it as Sensitive Personal Information. If this information is not capable of being individually associated with you or determining your geolocation, we treat it as Usage Data. Please note that when using company equipment, including email and messaging systems, you do not have a right to an expectation of privacy. We may monitor, record, and log your uses of company equipment and systems.
Call, Email and Text Records
We may record and retain the content of calls, emails, and text messages or other written/electronic communications coming through or made using Company resources, whether such communications are directed to us and related to your prospective or actual employment, or whether they are intended as private communications.
Audio & Visual Recordings
We may monitor and record your activities while in our facilities such as through the use of video cameras.
HOW WE COLLECT INFORMATION
Voluntary Disclosure
We may ask you to provide us with Personal Information, including Sensitive Personal Information, when you communicate with us (online or offline), when you apply to a position or apply for a promotion, when you become an employee, when you access employee benefits, and at other times.
Third-Party Data Sources
We may collect Personal Information, including Sensitive Personal Information, from third-party data sources such as recruitment services, job posting services, employee benefit providers, or Service Providers (as defined below) hired to provide identity verification services, conduct background checks, and/or drug screenings.
HOW WE USE INFORMATION
Generally
We use Personal Information, including Sensitive Personal Information, for internal purposes, such as to:
- Advertise available positions or information about careers with us;
- Evaluate candidates for employment;
- Provide training and mentoring;
- Facilitate performance reviews;
- Provide employee benefits, services, and accommodations;
- Optimize our business and workforce;
- Maintain company security;
- Communicate with employees via mail, email, telephone, and/or text messaging;
- Facilitate compliance with company policies; and
- Comply with legal and contractual obligations.
In all cases, we collect, use, retain and, where applicable, provide your Personal Information (including Sensitive Personal Information) to third parties only as reasonably necessary and proportionate to achieve the purposes for which your information was collected or processed.
Testimonials
If you provide a testimonial about your employment experience with us or your experience with any of the benefits or services we provide, we may post it publicly.
Sharing and Selling of Personal Information and Sensitive Personal Information
We do not sell your Personal Information or Sensitive Personal Information to third-parties. Although we do provide certain Personal Information, including Sensitive Personal Information, to our Service Providers as further explained below, we do not share such information for third-parties for cross-context behavioral advertising purposes.
Service Providers
We may enter into contracts with other businesses to provide employment-related benefits and services that are connected to your application for employment or employment with us (“Service Providers”). These Service Providers provide such things as:
- Online hosting and maintenance;
- Employee benefits and insurance;
- Staffing agencies;
- Management of HR systems;
- Professional services such as legal and accounting;
- Identity and contact information validation;
- Background checks;
- Drug screening;
- Data storage and management; and
- Business consulting.
We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information, including Sensitive Personal Information, from unauthorized access, use, or disclosure. Service Providers are not permitted to use Personal Information and Sensitive Personal Information other than as reasonably necessary and proportionate to achieve the purposes for which your information was collected or processed.
We provide the following types of Personal Information and Sensitive Personal Information to one or more Service Providers: biometric & health information; contact information; educational information; financial information; geolocation data; personal identifiers; audio/visual information; professional/employment information; characteristics of protected classifications; Interferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Cookies & Other Automated Tools
Our Service Providers may use cookies (a small text file placed on your computer to identify your computer and browser) and other automated tools such as tracking pixels to facilitate the services they provide to us. Many web browsers are set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. Instructions for how to manage cookies in popular browsers are available at: Internet Explorer, Firefox, Chrome, Safari (iOS), Safari (Mac), and Opera. However, certain features of our or our Service Provider’s sites, systems, or employment functions may not work if you delete or disable cookies.
We use the following types of cookies:
- Session Cookies: Session cookies keep track of you or your information as you move from page to page within a site or system and are typically deleted once you close your browser. For example, a session cookie allows you to keep your progress.
- Persistent Cookies: Persistent cookies reside on your system and allow the cookie provider to customize your experience if you leave and later return to the site or system. For example, persistent cookies may allow a site owner to remember your preferences.
- Advertising Cookies: Advertising cookies are used to learn more about you and present you with information that might interest you. For example, an advertising cookie may help a Service Provider determine which services and benefits will best serve our employees.
- Analytics Cookies: Analytics cookies help a site owner understand how its sites and systems are working, who is using the sites and systems, and how the sites and systems are being used. Google Analytics is one commonly used tool, and you can learn more about it by reviewing Google’s Privacy Policy.
SUMMARY OF OUR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION AND SENSITIVE PERSONAL INFORMATION
The following chart provides a summary of the categories of Personal Information, including Sensitive Personal Information (collectively, “PI”), that we collect, from whom we collect it, and our business purposes for collecting, using, and disclosing it. It also provides a summary of whether we sell, share, or provide such information to third parties who are not Service Providers, and, if so, the categories of such information we disclose.
|
Categories of PI we Collect |
Categories of Sources from which we Collect PI |
Our Business Purposes for Collecting, Using, Sharing, or Selling PI |
Whether we Sell or Share PI to Non-Service Provider Third Parties for a Business Purpose |
Categories of Non-Service Provider Third Parties to whom we Share or Sell PI |
| Audio, electronic, visual, thermal, olfactory, or similar information |
Employees |
Business Security; Employee Security; Training; Performance Evaluations |
No |
None |
|
Biometric & Health Information |
Employees; Providers of Benefits | Business Security; Employee Security; Qualify for Benefits, Services, or Leave |
No |
None |
|
Contact Information | Employees; Identity Verification Services; Service and Benefit Providers |
Business Purposes; Employee Pay; Employee Benefits; Security |
No |
None |
|
Educational Information |
Employees; Identity Verification Services; References |
Confirming Employment Qualifications |
No |
None |
| Employee Records/Financial Information |
Employees; Employees’ Banks; Benefit Providers | Employee Paychecks; Employee Taxes; Employee Benefits |
No |
None |
|
Geolocation Data |
Employees; NDR Computers and Equipment |
Keeping Tracking of NDR Equipment |
No |
None |
|
Personal Identifiers |
Employees; Identity Verification Services; Providers of Services and Benefits to Employees | Business Security; Employee Security; Business Purposes; Employee Pay; Employee Benefits; Employee Services; Performance Review; HR Complaints |
No |
None |
|
Inferences from PI |
NDR; Non-Marketing Data Analytics Firms |
Company, Business, Employee Auditing; Business consulting and efficiency |
No |
None |
|
Professional/Employment Information |
Employees; NDR; Resumes; Skill Assessment Firms |
Performance Review; Confirming Employment Qualifications; Department Auditing |
No |
None |
|
Characteristics of Protected Classifications |
Employee; Identity Verification Services; Providers of Services and Benefits to Employees |
Identity Verification; Security; Discrimination Complaints | No |
None |
| Internet or other Electronic Network Activity Information | NDR owned equipment/ virtual machines | Security and Employment Purposes | No | None |
SECURITY
We recognize the importance of safeguarding the confidentiality of Personal Information, including Sensitive Personal Information, from loss, misuse, or alteration. Accordingly, we employ commercially-reasonable administrative, technical, and physical safeguards to protect such information from unauthorized access, use, and disclosure. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information you transmit to us relating to your employment and/or benefits and third-party beneficiaries of those benefits, you do so at your own risk.
OTHER WEBSITES
Please be aware that third-party websites accessible through our website, company equipment, Service Providers, or employee benefits providers may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing information.
OTHER TRANSFERS
We may provide Personal Information, including Sensitive Personal Information, and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information, including Sensitive Personal Information, and Usage Data in connection with such transaction.
COMPLIANCE WITH LAWS AND LAW ENFORCEMENT
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information, including Sensitive Personal Information, and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas), to protect the safety, property, or rights of ourselves, Clients, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.
HOW LONG WE RETAIN YOUR DATA
We retain your Personal Information, including your Sensitive Personal Information, as long as necessary to achieve the purposes for which the information was collected or processed. This usually means that we retain such information for the duration or our relationship with you, and for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, and/or accounting obligations. Generally, we retain all categories of Personal Information, including Sensitive Personal Information, for seven (7) years after our relationship with you has ended, but the term for which we retain such information may be longer, in accordance with our data retention policies and applicable law.
CHILDREN’S PRIVACY
While we do not employ people under the age of sixteen (16), we do collect Personal Information, including Sensitive Personal Information, on minor children for the limited purpose of extending benefits to our employees and their dependents. We do not sell or share any such information of people under the age of sixteen (16).
ADDITIONAL PRIVACY RIGHTS
If you are a resident of California, you have additional rights regarding your Personal Information and Sensitive Personal Information, as set forth below.
Right to Know
You have the right to request, twice per 12-month period, that we provide you the following information about data we have collected on or after January 1, 2022: (i) the categories and specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose for which we collected your Personal Information; (iv) the categories of third parties with whom we shared your Personal Information (if any); and (v) the categories of third parties to whom we sold your Personal Information (if any).
Where your request seeks identification of information collected more than 12 months prior to the date of your request, we may decline to respond as to information collected more than 12 months prior to your request if responding would be impossible or involve a disproportionate effort.
To request access to your Personal Information and the information listed above, you may submit a request through our Right to Know Page or call us at 800-300-9550 ext. 8648. Please review the Right to Know Page first because it contains important descriptions of the process we use to verify and fulfill your request. You may also designate an authorized agent to submit a request on your behalf as described on the Right to Know Page.
Right to Delete or Correct
You have the right to request that we delete or correct any Personal Information we have collected about you. If we receive a correction request, we will take commercially reasonable efforts to correct the inaccurate information if we determined that such correction is warranted, after taking into consideration the nature of the Personal Information involved, the subjectivity involved in determining the accuracy of the information, the relevance of the information, and our purposes in processing that information.
If we receive a deletion request, please understand that we are not required to honor a deletion request if a legal exemption applies (in California) or a policy exemption applies (in all other states). Such exceptions include requests to delete the following information:
- Information that we collected from sources other than you;
- Information that we are required to retain to comply with a legal obligation;
- Information needed to pursue or defend against claims;
- Information we need for your employment with us;
- Information that is operationally necessary for us to carry out your employment relationship with us;
- Information that is reasonably necessary and proportionate to our need to ensure security and integrity of information;
- Information, the deletion of which would adversely affect the rights and freedoms of other natural persons.
To request deletion or correction of your Personal Information and the information listed above, you may submit a request through our Deletion or Correction Request Page or call us at 800-300-9550 ext. 8648. Please review the Deletion or Correction Request Page first because it contains important descriptions of the process we use to verify and fulfill your request. You may also designate an authorized agent to submit a request on your behalf as described on the Deletion or Correction Request Page.
Right to Restrict, Object, or Opt-Out of Sale or Sharing
We do not sell or share employee Personal Information to third parties.
Right to Limit the Use of Sensitive Personal Information
You have a right to request that we limit how your Sensitive Personal Information is used. If you make such a request, your Sensitive Personal Information may still be used for any of the following reasons:
- To perform services (and, where applicable, to provide goods) that would be reasonably expected by a job applicant or an employee;
- To ensure security and integrity, to the extent that use of the Sensitive Personal Information is reasonably necessary and proportionate to such purposes;
- For non-personalized advertising that is consistent with your current employment relationship with us;
- To verify or maintain the quality or safety of employment-related services that we provide;
- As otherwise authorized by law.
We reserve the right to deny any request to limit the use of your Sensitive Personal Information, where that information was collected or processed without the purpose of inferring characteristics about you.
To request that we limit the use of your Sensitive Personal Information, you may submit a request through our Limit the Use of My Sensitive Personal Information Page or call us at 800-300-9550 ext. 8648 Please review the Limit the Use of My Sensitive Personal Information Page first because it contains important descriptions of the process we use to verify and fulfill your request. You may also designate an authorized agent to submit a request on your behalf as described on the page.
Right to Data Portability
If we receive from you a verifiable request to receive a copy of the Personal Information, we have on you as described in this Policy, we may choose to deliver that by mail or electronically, and if provided electronically, the information shall be in a portable and, to the extent technically feasible, in a readily useable format that allows you to transmit this information to another entity without hindrance.
Right to Non-Discrimination
We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy.
Authorized Agents
Authorized Agents are permitted to make requests on behalf of individuals. However, at a minimum, Authorized Agents must provide written authorization from the individual for the agent to submit the request and the agent must verify their own identity. In cases requiring a heightened verification level, the Authorized Agent may also be required to submit a signed declaration under penalty of perjury from the consumer that the Authorized Agent is permitted to act on their behalf.
California “Do Not Track” Disclosure
Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. At this time, our site does not respond to “Do Not Track” signals.
CONTACT US
If you have any questions about this Privacy Policy, please email us at People@NationalDebtRelief.com, call us at 800-300-9550 ext. 8648 or send us a letter to the following address:
National Debt Relief, LLC
Attn: People Team – Privacy Policy Request
180 Maiden Lane
30th Floor
New York, NY 10038
