We have created this California Privacy Notice (“California Notice”) specifically for California residents. California residents have certain privacy rights as specified under California law, including the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act (the “CPRA”). Our privacy principles and the privacy controls we offer to all users are in line with these laws—this California Notice makes sure we cover the California-specific requirements when visiting and supplying information through our website. For example, all users of our website can request a copy of their data, request deletion, and control their privacy settings, among other things. To view the full picture, click on our Privacy Policy.
If you are a California resident, you may exercise certain privacy rights, some of which may be similar or in addition to those described in our Privacy Policy related to your “Personal Information.” Personal Information under California law is defined as information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household. Personal Information further includes under California law “Sensitive Personal Information” such as social security number, driver license number, state identification card, passport number, financial data, genetic data, biometric data, precise geolocation, and racial and ethnic origin, content of consumer communications (email, mail, or text), unless the business is the intended recipient, genetic data, and information collected concerning a consumer’s health, sex life, or sexual orientation.
Personal information does not include:
- Publicly available information that is lawfully made available from government records that a consumer has otherwise made available to the public.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s or CPRA’s scope such as 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.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. The section that follows describes your CCPA specific rights regarding your personal information and explains how to exercise those rights.
- The Right to Know, Access, Rectify, and/or Delete Personal Information: You may have the right to know, access, correct, and/or delete Personal Information about you that we have collected.
- The Right to Know/Access: You have the right to know about our Privacy Policy, and to request access to a copy of the Personal Information that we have collected about you directly or indirectly, including Personal Information collected by a service provider or contractor on our behalf.
- The Right to Correct: You may contact us at info@intechinvestments.com to request any changes to the information we have about you.
- The Right to Delete: You have the right to request that we delete your Personal Information, subject to certain limited exceptions. For example, we may retain an archived copy of your records consistent with applicable law, or for other legitimate business purposes.
- The Right to Opt-out of the Sale or Sharing of Personal Information or De-identified Personal Information:
- We do not sell your Personal Information for monetary or other valuable consideration.
- We do not sell any de-identified Personal Information. We may de-identify your Personal Information for internal use only.
- We do not share your Personal Information for the purposes of “cross-context behavioral advertising.”
- The Right to Limit the Use of Sensitive Personal Information: We do not obtain Sensitive Personal Information from you through our website.
- The Right to Non-Discrimination: We will not discriminate or retaliate against you for exercising your consumer rights under this section including by (a) denying you goods or services; (b) charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; or (c) providing you a different level or quality of goods or services (or suggesting that we will do so). We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information.
- Verification: As required or permitted under applicable law, we may take steps to verify your request before providing Personal Information to you, deleting Personal Information, or otherwise processing your request. To verify your request, you must provide your name, employer (if any), product or service, email address, phone number, and state of residence. You may also be asked to verify your ability to control the email address or phone number you have provided to us. If we believe we need further information to verify your request as required by law, we may ask you to provide additional information to us. We will review each request carefully and respond accordingly within the timeframe established by the law.
- Notice of Financial Incentive: We do not offer financial incentives to consumers for providing Personal Information.
- Requesting Notice in Alternative Format/Language: You may be able to request this California Notice in another language where we provide such notices in the ordinary course of business or in an alternative format if you have a disability. Please contact info@intechinvestments.com to request an alternative format.
- Changes to Our California Notice: We reserve the right to amend this California Notice at our discretion and at any time. We will do so by updating this California Notice. Amended terms take effect upon being incorporated into this California Notice, and your continued use of the website or participation in your employer’s covered benefit program following the posting of any changes constitutes acceptance of any new terms. If the changes will materially affect the way we use your Personal Information in connection with covered Services that we have already collected, we will notify you by sending you a message to your online account.
- Agent Authorization: You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as set forth in this California Notice. Even if you choose to use an agent, as permitted by law, we may require you to confirm you have authorized the agent to act on your behalf or require you to verify your own identity.
How to Exercise Your Rights
You may exercise these rights free of charge except as otherwise permitted under applicable law unless responding to the request is impossible, involves disproportionate effort, 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. We may limit our response to your exercise of these privacy rights as permitted under applicable law.
You may only make a verifiable request for access or data portability twice within a 12-month period. The verifiable request must provide enough information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
To submit the request, please complete the California Resident Personal Data Request Form located at the end of this document, and return along with the required identifying information via email to: info@intechinvestments.com. 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. We will only use personal information provided in a verifiable request to confirm the requestor’s identity or authority to make the request.
We endeavor to respond to a verifiable 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 by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.
Once we receive and confirm your verifiable request, we will disclose to you (where applicable):
- The categories of personal information and sensitive information we collected about you.
- The categories of sources for the personal and sensitive information we collected about you.
- Our business or commercial purpose for collecting, using, and/or disclosing that information.
- The categories of any third parties, contractors and service providers with whom we share, sell or disclose 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 of those disclosures, identifying the personal information categories that each category of recipient obtained.
- Whether your information was sold or shared.
- The retention period or criteria used for retention.
Supplemental California Consumer Privacy Notice For California Employees and Job Applicants
On November 3, 2020, California voters approved the California Privacy Rights Act of 2020 (“CPRA”), amended and expanded the CCPA’s requirements noted above effective January 1, 2023. This California Consumer Privacy Employee Notice (the “California Employee Privacy Notice”) supplements the CCPA section above, and applies to the personal information of California employees, interns, contractors, volunteers, and job applicants collected by Intech, which were previously exempt from the CCPA. This California Employee Privacy Notice also applies to information provided to us about employees’ relatives or others that is used for emergency contact or benefits administration purposes.
Please read this California Employee Privacy Notice to learn how we collect and process your personal information when you are employed by Intech, engaged to provide services to Intech or apply for a job with Intech.
Under the CCPA, as modified by the CPRA, you have the right to know and understand the categories of personal information we collect about you, and the purposes for which we use such personal information. Certain terms used in this California Privacy Notice have the meaning given to them in the CCPA or CPRA and their implementing regulations. This California Employee Privacy Notice applies only to employees, contractors and job applicants who are residents of the State of California. Intech does not sell or otherwise disclose Personal Information for monetary or other consideration to any third parties. If we disclose personal information for a particular business purpose, we enter 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.
Categories of Personal Information We Collect
In each case as permitted by applicable law, we may collect the following categories of personal information for the purposes described below:
- Personal identifiers, such as your name, preferred name, postal address, unique personal identifiers (such as device identifiers, cookies, beacons, pixel tags, mobile ad identifiers and similar technology), telephone number, online identifier, Internet Protocol address, email address, Social Security number, driver’s license number, passport number, date of birth, signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, other financial information, medical information and health insurance information.
- Characteristics of protected classifications, such as race, ethnicity, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status and military or veteran status. We only collect this information if you voluntarily disclose it and as permitted by applicable law, and we will not use this information to make hiring decisions.
- Online activity, such as your browsing history, search history, and information regarding your interaction with a website, application, or advertisement.
- Geolocation data that indicates your precise location.
- Sensory data, such as audio and visual information that we may obtain if you use video interviewing as part of the application process. If you visit, work, or perform services in our facilities or facilities in which we operate, your entry, exit, and actions in or around those facilities may be monitored by CCTV.
- Professional or employment-related information, such as your employment history, job application or resume, employment contract, references, information about skills and abilities, salary expectations, licenses and professional certifications, memberships, accomplishments and awards, training and development information, performance evaluation information and employment termination information.
- Non-public education information, such as your education history, education records (such as grades, transcripts and class lists) and other information included in your resume or cover letter.
- Inferences drawn from other personal information, including any information referenced above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Sensitive Personal Information, as defined.
- We also collect personal information included in job interview notes, responses to screening questions, assessment results and any other information you provide in connection with the recruitment process.
Sources of Personal Information
We collect personal information you voluntarily provide to us during the application process or when you otherwise contact us. We may also automatically collect certain information, such as IP addresses and device identifiers.
We may combine personal information you voluntarily provide to us with information we collect from other sources, such as:
- Recruiters;
- Job fairs;
- Prior employers and professional references;
- Educational institutions;
- Pre-employment screening and background check services;
- Credentialing and licensing organizations;
- Publicly available sources, such as public social media profiles; and
- Other sources as directed by you.
Business Purposes for Collecting Personal Information
We use the categories of personal information above for the following business purposes:
- Employees and Managing Job Applications: We use your personal information to process your job application, create an applicant profile, evaluate your qualifications, schedule and conduct interviews, and communicate with you.
- Conducting Pre-Employment Screening and Background Checks: In accordance with applicable law, we use your personal information to conduct employment screening and background checks.
- Emergency Assistance: This includes the maintenance of contact details for you, and your dependents in case of personal or business emergency.
- Monitor Eligibility to Work in the U.S.: We monitor and ensure compliance of your ability to work in the U.S.
- Compensation and Expense Management: We use your personal information to conduct payroll processing, salary administration, expense reimbursement, manage the corporate credit card program and other compensation purposes such as determining bonuses, equity, and other forms of employee compensation.
- Benefits Administration: We use your personal information we collect to administer benefits we provide, such as medical, dental, vision, disability insurance, retirement benefits and other employee benefit programs.
- General Human Resources Management: We use your personal information we collect to provide general HR management services, including managing employee on-boarding, termination and separation, travel administration and return-to-work screening (including any medical screening as required or permitted by applicable law).
- Training and Professional Development: We use your personal information to provide employment-related training, assisting with professional licensing and development.
- Internal Employment Purposes: We use your personal information to conduct internal investigations, conduct surveys, resolve disputes, prevent or detect fraud or security incidents, conduct employee performance reviews, enforce our policies and code of ethics, protect the rights and safety of employees or others, and manage our whistle-blower program.
- Monitor Work-Related Licenses and Credentials: This includes provisioning software licenses for use in the course of an employee’s work-related responsibilities, ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies.
- Maintain Security on Intech Websites and Internet Connected Assets: This category includes hosting and maintenance of computer systems and infrastructure; management of our software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; and monitoring email and Internet access.
- Compliance with Legal Requirements and Enforcement of Our Legal Rights: We use your personal information to comply with applicable laws, regulations and legal processes (such as responding to subpoenas or court orders), and to respond to legal claims, resolve disputes, enforce our legal rights contained in employment or other contracts, and comply with legal or regulatory recordkeeping requirements.
Disclosure of Personal Information
We may share your personal information for the business purposes described in this California Employee Privacy Notice with the following parties:
- Affiliates and Subsidiaries: We may share your personal information with our affiliates and subsidiaries, where applicable.
- Service Providers: We may share your personal information with service providers, such as recruiters, pre-employment screening services, third-party benefits administrators, payroll processors, background check providers, and others.
- Governmental Authorities/Self-Regulatory Authorities: As required by law or legal process, we may share your personal information with federal or state regulatory agencies, law enforcement, courts and other governmental authorities as well as self-regulatory authorities.
- Professional Advisors: We may share your personal information with professional advisors, such as auditors, consultants, and law firms.
- Parties Involved with Business Transfers: We may share your personal information to third parties in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation).
Intech does not sell or otherwise disclose your personal information for monetary or other consideration to any third parties.
In accordance with our policies and procedures, we will not discriminate or retaliate against you if you choose to exercise any of your rights under the CCPA or CPRA.
We retain your Personal Information pursuant to our records retention policy.
You may exercise your rights your rights to review your Personal Information free of charge in the same manner as described in the section above titled How to Exercise Your Rights. To submit the request, please complete the California Resident Personal Data Request Form located at the end of this document, and return along with the required identifying information via email to: info@intechinvestments.com.
Contact Information
If you have questions or comments about this California Privacy Notice or the California Employee Privacy Notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at:
Phone: 1-561-775-1100
Email: info@intechinvestments.com
Mail:
Intech
Attn: Chief Compliance Officer
250 S. Australian Avenue
Suite 1800
West Palm Beach, FL 33401
United States of America
We thank you for taking the time to read this California Privacy Notice. Download the California Resident Personal Data Request Form.
