MJH LIFE SCIENCES
CALIFORNIA EMPLOYEE PRIVACY POLICY
Last updated [07/03/2023]
This California Employee Policy (this “Policy”) sets forth our privacy practices as required by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the “CPRA”). This Policy applies only to MJH Life Sciences (“MJH,” “we,” or “us”) employees residing in California. Pursuant to the CPRA, MJH must deliver this policy at or before the point we collect your personal information, and identify the categories of personal information that we collect and why we collect such information.
The Information We Collect
The CPRA defines “Personal information” as information that identifies relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident. Personal information does not include:
- Publicly available information from government records;
- Deidentified or aggregate information; and
- Personal information covered by certain sector-specific privacy laws, such as the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA).
Within the last twelve (12) months, MJH has collected the following categories of personal information about its employees:
|
Category |
Examples May Include |
Collected |
|
A. Identifiers |
A name, alias, postal address, unique personal identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. |
Yes |
|
B. Customer Records Personal Information Categories |
A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health. insurance information. |
Yes |
|
C. Protected Classification Characteristics |
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), and requests for parental, pregnancy, disability or sick leave. |
Yes |
|
D. Commercial Information |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
No |
|
E. Biometric Information |
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
No |
|
F. Internet or Other Electronic Activity Information |
Browsing history, search history, and information regarding your interaction with an Internet website, application, or advertisement. |
Yes |
|
G. Geolocation data |
Physical location or movements, such as tracking building and office entry. |
Yes |
|
H. Sensory Data |
Internal news recordings, KOL interviews, or onboarding introductions |
Yes |
|
I. Professional or Employment-related Information |
Job related data, maintained as part of the employment relationship that could be contained in a job application or resume; an employment contract; a contractor agreement; a performance review; a disciplinary record; photos; information from employee expenses; browsing and search history; payroll and benefits related data; internal and external contact information; or information captured from video, audio, systems, or other forms of monitoring or surveillance. |
Yes |
|
J. Non-public Education Information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)). |
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades or transcripts. |
Yes |
|
K. Inferences Drawn from Other Personal Information Collected |
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
Yes |
|
L. Sensitive Personal Information |
For the purpose of inferring characteristics about consumers, Social Security, driver’s license, state identification card, or passport number; 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; your precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of mail, email, or text messages; genetic data; health information |
No |
Sources from which We Collect Personal Information
MJH obtains the categories of personal information listed above from the following categories of sources:
- Directly from you, such as through forms you complete as an employee.
- Indirectly from you, such as monitoring information that your work computer or mobile device transmits when interacting with our applications.
- Third parties, including organizations that assist us with periodic background checks, fitness for duty checks, and credentialing and privileging matters.
- Other employees, such as individuals providing information about your performance.
How MJH Uses Your Personal Information
MJH may use or disclose personal information that we collect about you for one or more of the following business purposes:
- To administer benefits, such as medical, dental, optical, commuter, and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, and insurance.
- To maintain a safe and healthy work environment.
- To pay or reimburse for expenses, including salary administration, payroll management, payment of expenses, to administer other compensation related payments, including assigning amounts of bonus payments to individuals, administration of departmental bonus pools and administration of stock option plans.
- To conduct performance-related reviews, including performance appraisals, career planning, skills monitoring, job moves, promotions and staff re-structuring.
- To monitor work-related licenses and credentials, including 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.
- To provide human resources management services, including providing employee data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of employee claims, and travel administration.
- To maintain your contact information.
- To receive, investigate and handle employee-related complaints.
- To assist you in the case of an emergency, including maintenance of contact details for you, and your dependents or emergency contacts in the case of a personal or business emergency.
- To monitor eligibility to work in the United States.
- To foster and improve our culture and working environment, including conducting staff surveys, providing senior management information about other employees, and conducting training.
- To ensure a safe working environment, which includes information collected relating to disciplinary actions, and code of ethics conduct processes and investigations.
- To protect health and safety in the workplace, including conducting surveys and health screenings involving collection of personal health information about you and your household, to permit contact tracing and reduce the risk of spreading viruses or other diseases during a pandemic or public health emergency.
- To maintain security on MJH systems and infrastructure, which includes hosting; 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.
- To comply with applicable law or regulatory requirements, such as legal (state and federal) and internal company reporting obligations, including headcount, management information, demographic and other required reporting.
How MJH Discloses Your Personal Information
When disclosing your personal information to a third party for a business purpose, MJH takes reasonable measures to require that such personal information be kept confidential and not used for any purpose except to perform the services under the contract or respond to regulatory or law enforcement requests.
In the preceding twelve (12) months, MJH has disclosed the following categories of personal information for a business purpose:
|
Categories of Third Parties to Whom Personal Information Was Disclosed for a Business or Commercial Purpose |
Categories of Personal Information Disclosed for a Commercial Purpose |
Business Purpose for Disclosure |
|
Our affiliates, subsidiaries and any joint venture partners |
|
Employment |
|
Our vendors and service providers (e.g., website hosting, travel agents, information technology and security, cloud storage, etc.).
|
|
Employment |
|
Third parties who provide professional services such as attorneys, auditors, etc. |
|
Employee safety |
|
Third parties to whom you or your representatives authorize us to disclose personal information in connection with products or services they or we provide to you, such as certain employee benefit providers. |
|
Employment & Benefits |
|
Government agencies as required by laws and regulations or otherwise to comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal information necessary for the specific purpose and circumstances. |
|
Employment & Benefits |
No Selling of Your Personal Information
In the preceding twelve (12) months, MJH has not sold or shared any personal information of its employees, and we have no future intention of selling or sharing such information, within the meaning of the CPRA.
Individuals under 16 Years of Age
MJH does not intentionally collect the personal information of individuals under 16 years of age.
Data Retention
We retain personal information about you necessary to fulfill the purpose for which that information was collected, consistent with applicable laws. When we destroy your personal information, we do so in a secure manner in compliance with applicable laws, such that the personal information may not be reconstructed.
My Rights under the CPRA
If you are a California resident, you may exercise certain privacy rights related to the personal information we collect about you. You may exercise these rights free of charge, except as otherwise permitted under applicable law.
- Right to Know/Access Personal Information
You have the right to request that we disclose to you what Personal Information we collect, use, and disclose. This information includes (a) the categories of your Personal Information that we have collected and sold or shared for a business purpose; (b) the categories of sources from which we have collected your Personal Information; (c) the categories of third parties with whom we shared or sold your Personal Information; (d) the business or commercial purpose for collecting, selling, or sharing your Personal Information; and (e) the specific pieces of Personal Information we have collected about you.
- Right to Deletion of Personal Information
You have the right to request that we delete your Personal Information, subject to certain limited exceptions. For example, we may deny your request to delete Personal Information that we are required to maintain to fulfill a legal obligation.
- Right to Correct Inaccurate Personal Information
You have the right to request that we correct inaccurate Personal Information that we maintain about you.
- Right to Non-Discrimination
We will not discriminate or retaliate against you for exercising your rights under the CPRA.
How to Submit a Request
You may submit your request to access, delete, or correct Personal Information collected about you by contacting us at 1 (800) 598-6115,by email at Info@MJHPrivacy.com , or by visiting https://www.mjhlifesciences.com/contact/.
Verification of Identity and Processing of Requests
As required or permitted under applicable law, we may take steps to verify your identity before processing your request to access, delete, or correct Personal Information collected about you as set forth above. In order for your request to be processed, you must provide us with enough information to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of that person. We will confirm receipt of your request within 10 business days and provide information about how we will process your request. We will review each request for access, deletion, or correction carefully and respond to most requests within 45 calendar days if we are able to verify your identify based on the information you have provided; however, we may extend this time period once by an additional 45 calendar days when reasonably necessary, provided that we provide you with notice of this extension.
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 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.
Changes to this California Employee Policy
We reserve the right to amend this policy at our discretion and at any time. When we make changes, we will notify employees through an email or other notice and reflect on the date it was updated.
Questions or Concerns?
If you have any questions, you may contact us at 1 (800) 598-6115, by email at Info@MJHPrivacy.com, or by visiting https://www.mjhlifesciences.com/contact/.