Privacy Policy for California Residents

FrankCrum and/or any affiliated companies (the “Company” or “we”) has developed this privacy policy out of respect for the privacy of our customers, visitors to our website, job applicants, agents, brokers, producers, and independent contractors. This policy describes the personal information we collect, use, and disclose about individual consumers, applicants, and contractors who visit or interact with this website, visit any of our offices, stores, facilities, or locations, purchase or inquire about any of our products or services, contract with us to provide services, apply for a position of employment, or otherwise interact or do business with us.

Whenever you visit our website, we will collect some information from you automatically simply by you visiting and navigating through this site, and some voluntarily when you submit information using a form on the website, enroll in or subscribe to our newsletter or marketing communications, request information, or use any of the other interactive portions of our website. Through this website, we will collect information that can identify you and/or your activity. 

Additionally, whenever you communicate, interact, or do business with us, we will be collecting personal information from you or about you during our interaction or dealings with you, whether online or at any of our physical locations or facilities, or whether you are contracted to perform services for us or apply for a position of employment. 

This policy does not apply to our current and former employees, Covered Employees, their family members, dependents, and beneficiaries, or Clients. If you are a California resident (who is a current or former employee of the Company, current or former Covered Employee, current or former Client, or a family member, dependent, or beneficiary), please see the Privacy Policy for CA Residents posted in the footer on the MyFrankCrum portal or reach out directly to Privacy@FrankCrum.com.  

Children Under the Age of 16

Our website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at Privacy@FrankCrum.com.

Collection of Personal Information and Sensitive Personal Information

Based on your specific transactions and interactions with us or our website, we will or may collect, and we have in the last 12 months collected, the following categories of personal information about you. For each category of information, the categories of third parties and service providers to whom we have disclosed the information in the last 12 months are detailed in the chart below. The examples provided for each category are not intended to be an exhaustive list or an indication of all specific pieces of information we collect from or about you in each category, but rather the examples are to provide you a meaningful understanding of the types of information that may be collected within each category. 

 

Category	Personal Identifiers
Examples	Name and alias only if provided by you.
Disclosed To in Last 12 Months	Marketing support vendors and vendors that support managing or hosting the website. Communication providers/vendors that facilitate, manage, and send/receive communications on our behalf via email, text/SMS, and phone.  Lead providers (referral sources).  Transaction support vendors (e.g., check guaranty, payment processors).  Data analytics vendors.  Social media platforms.  Recruiting firms, and/or staffing agencies.  Talent acquisition management systems, and other vendors providing services for purposes of our human resources information system (HRIS) and management of job applicant data and recruiting process.
Sold To or Shared With	For data collected through our website, we sell some of this data to data analytics vendors (not for monetary consideration but for other valuable consideration), and we also share the data with social media platforms for cross-context behavioral advertising.   For all other data in this category collected through other sources (not through this Website), this data is neither sold for monetary or other valuable consideration, nor shared for cross-context behavioral advertising.
Retention Period	Duration of our relationship with you plus 4 years.  If you are a job applicant and are hired by the Company, then name will be retained permanently, and the rest will be retained for duration of employment plus 6 years. If you are not hired, this data will be retained for 4 years from when the position is filled or the date we receive your information, whichever is longer.

 

Category	Contact Information
Examples	Home, postal or mailing address, email address, home phone number, cell phone number only if provided by you.
Disclosed To in Last 12 Months	Marketing support vendors and vendors that support managing or hosting the website.  Communication providers/vendors that facilitate, manage, and send/receive communications on our behalf via email, text/SMS, and phone.  Lead providers (referral sources).  Transaction support vendors (e.g., check guaranty, payment processors).  Professional employer organizations, recruiting firms, and/or staffing agencies.  Talent acquisition management systems, and other vendors providing services for purposes of our human resources information system (HRIS) and management of job applicant data and recruiting process.
Sold To or Shared With	Not sold for monetary or other valuable consideration, and not shared for cross-context behavioral advertising.
Retention Period	Duration of our relationship with you plus 4 years.  If you are a job applicant and are hired by the Company, then name will be retained permanently, and the rest will be retained for duration of employment plus 6 years. If you are not hired, this data will be retained for 4 years from when the position is filled or the date we receive your information, whichever is longer.

 

Category	Credit/Financing Application Data
Examples	Information collected through credit or financing applications, including employment history, company name, role, salary, dates of employment, bank accounts, income sources only if provided by you.
Disclosed To in Last 12 Months	Financial institutions.  Government agencies.  Consumer reporting agencies or credit reporting agencies.  Corporate vendors (meaning an entity, as opposed to a natural person, that purchases, leases, or finances any of our products or services).
Sold To or Shared With	Not sold for monetary or other valuable consideration, and not shared for cross-context behavioral advertising.
Retention Period	Duration of our relationship with you plus 4 years

 

Category	Internet Network and Computer Activity
Examples	Date and time of your website visit; webpages visited; links clicked on the website; browser ID; browser type; device ID; operating system; form information downloaded; domain name from which our site was accessed; search history; cookies; internet or other electronic network activity information related to usage of Company networks, servers, intranet, or shared drives, as well as Company-owned computers and electronic devices, including system and file access logs, browsing history, search history, and usage history.
Disclosed To in Last 12 Months	Marketing support vendors and vendors that support managing or hosting the website and the Chat function on the website.  Communication providers/vendors that facilitate, manage, and send/receive communications on our behalf via email, text/SMS, or phone.  Lead providers (referral sources).  Security and risk management vendors, including IT, cybersecurity, and privacy vendors and consultants.  Data analytics vendors.  Social media platforms.
Sold To or Shared With	For data collected through our website, we sell some of this data to data analytics vendors (not for monetary consideration but for other valuable consideration), and we also share the data with social media platforms and data analytics vendors for cross-context behavioral advertising.   For all other data in this category collected through other sources (not through this website), this data is neither sold for monetary or other valuable consideration, nor shared for cross-context behavioral advertising.
Retention Period	3 years

 

Category	Geolocation Data
Examples	IP address, GPS location, and latitude and longitude.
Disclosed To in Last 12 Months	Security and risk management vendors, including IT, cybersecurity, and privacy vendors and consultants.  Marketing support vendors and vendors that support managing or hosting the website.  Communication providers/vendors that facilitate, manage, and send/receive communications on our behalf via email, text/SMS, or phone.  Lead providers (referral sources).  Data analytics vendors.  Social media platforms.
Sold To or Shared With	For data collected through our website, we sell some of this data to data analytics vendors (not for monetary consideration but for other valuable consideration), and we also share the data with social media platforms and data analytics vendors for cross-context behavioral advertising.   For all other data in this category collected through other sources (not through this website), this data is neither sold for monetary or other valuable consideration, nor shared for cross-context behavioral advertising.
Retention Period	3 years

 

Category	Mobile Device Data
Examples	Information collected when you navigate, access, or use any of our websites via mobile device, including device type, software type; data identifying your device if you access our business networks and systems.
Disclosed To in Last 12 Months	Marketing support vendors and vendors that support managing or hosting the website.  Data analytics vendors.  Communication providers/vendors that facilitate, manage, and send/receive communications on our behalf via email, text/SMS, or phone.
Sold To or Shared With	For data collected through our website, we sell some of this data to data analytics vendors (not for monetary consideration but for other valuable consideration), and we also share the data with data analytics vendors for cross-context behavioral advertising.   For all other data in this category collected through other sources (not through this website), this data is neither sold for monetary or other valuable consideration, nor shared for cross-context behavioral advertising.
Retention Period	3 years

 

Category	Online Portal Access and Usage Information
Examples	Username and password, account history, usage history, file access logs, and any information submitted through the account.
Disclosed To in Last 12 Months	Marketing support vendors and vendors that support managing or hosting the website.  Communication providers/vendors that facilitate, manage, and send/receive communications on our behalf via email, text/SMS, or phone.  Talent acquisition management systems, and other vendors providing services for purposes of our human resources information system (HRIS) and management of job applicant data and recruiting process.  Data Analytics Vendors.  Security and risk management vendors, including IT, cybersecurity, and privacy vendors and consultants.
Sold To or Shared With	For data collected through our website, we sell some of this data to data analytics vendors (not for monetary consideration but for other valuable consideration), and we also share the data with data analytics vendors for cross-context behavioral advertising.   For all other data in this category collected through other sources (not through this website), this data is neither sold for monetary or other valuable consideration, nor shared for cross-context behavioral advertising.
Retention Period	3 years

 

Category	Visual, Audio, or Video Recordings
Examples	Your image when recorded or captured in surveillance camera footage or pictures of you had taken on our premises or at our events or that you share with us; video and audio recordings of calls and virtual meetings as disclosed to you at the time of the call.
Disclosed To in Last 12 Months	Security and risk management vendors, including IT, cybersecurity, and privacy vendors and consultants.
Sold To or Shared With	Not sold for monetary or other valuable consideration, and not shared for cross-context behavioral advertising.
Retention Period	Surveillance video: 90 days; the rest of this category is retained for the duration of our relationship with you plus 4 years.   For Teams Video Recordings: users have 60 days to save their recordings locally or in SharePoint before the recording link expires automatically.  Job Applicants: If hired, this data will be retained for duration of employment plus 6 years. If not hired, it will be retained for 4 years from when position is filled or the date we receive your information, whichever is longer.

 

Category	Pre-Hire Information/Pre-Contract Information
Examples	Information gathered on job applicants, recorded job interview notes, information contained in candidate evaluation records and assessments, information in work product samples you provided, and voluntary disclosures by you.   Information gathered as part of vendor evaluation, and other assessments of your qualifications to provide services to the Company.
Disclosed To in Last 12 Months	Communication providers/vendors that facilitate, manage, and send/receive communications on our behalf via email, text/SMS, phone.  Professional employer organizations, recruiting firms, and/or staffing agencies.  Talent acquisition management systems, and other vendors providing services for purposes of our human resources information system (HRIS) and management of job applicant data and recruiting process.  Corporate vendors (meaning an entity, as opposed to a natural person, that purchases, leases, or finances any of our products or services).
Sold To or Shared With	Not sold for monetary or other valuable consideration, and not shared for cross-context behavioral advertising.
Retention Period	Job Applicants: If hired, this data will be retained for duration of employment plus 6 years. If not hired, it will be retained for 4 years from when position is filled or the date we receive your information, whichever is longer.

 

Category	Employment and Education History
Examples	Information contained in job applicants’ resumes regarding educational history, information in transcripts or records of degrees, vocational certifications obtained, and information regarding prior job experience, positions held, and when permitted by applicable law your salary history or expectations.
Disclosed To in Last 12 Months	Communication providers/vendors that facilitate, manage, and send/receive communications on our behalf via email, text/SMS, phone.  Consumer reporting agencies or credit reporting agencies.  Professional employer organizations, recruiting firms, and/or staffing agencies.  Talent acquisition management systems, and other vendors providing services for purposes of our human resources information system (HRIS) and management of job applicant data and recruiting process.  Corporate vendors (meaning an entity, as opposed to a natural person, that purchases, leases, or finances any of our products or services).
Sold To or Shared With	Not sold for monetary or other valuable consideration, and not shared for cross-context behavioral advertising.
Retention Period	Job Applicants: If hired, this data will be retained for duration of employment plus 6 years.   If not hired, it will be retained for 4 years from when position is filled or the date we receive your information, whichever is longer.

 

Category	Professional Related Information
Examples	Information on job applicants contained on applications.
Disclosed To in Last 12 Months	Communication providers/vendors that facilitate, manage, and send/receive communications on our behalf via email, text/SMS, phone.  Consumer reporting agencies or credit reporting agencies.  Professional employer organizations, recruiting firms, and/or staffing agencies.  Talent acquisition management systems, and other vendors providing services for purposes of our human resources information system (HRIS) and management of job applicant data and recruiting process.  Corporate vendors (meaning an entity, as opposed to a natural person, that purchases, leases, or finances any of our products or services).
Sold To or Shared With	Not sold for monetary or other valuable consideration, and not shared for cross-context behavioral advertising.
Retention Period	Job Applicants: If hired, this data will be retained for duration of employment plus 6 years.   If not hired, it will be retained for 4 years from when position is filled or the date we receive your information, whichever is longer.

 

Category	Financial Information
Examples	Information contained in invoices billed and in records of payments or other financial account information.
Disclosed To in Last 12 Months	Government agencies.  Financial institutions.  Professional employer organizations, recruiting firms, and/or staffing agencies  Corporate vendors (meaning an entity, as opposed to a natural person, that purchases, leases, or finances any of our products or services).  Transaction support vendors (e.g., check guaranty, payment processors).  Consulting and investigation firms, including HR consultants, safety consultants, and workplace investigators.  Security and risk management vendors, including IT, cybersecurity, and privacy vendors and consultants.  Insurance carriers, administrators, and brokers.
Sold To or Shared With	Not sold for monetary or other valuable consideration, and not shared for cross-context behavioral advertising.
Retention Period	Duration of our relationship with you plus 4 years.

 

Category	Facility & Systems Access Information
Examples	Information identifying you, if you accessed our secure company facilities, systems, networks, computers, and equipment, and at what times, login credentials, or other security access method.
Disclosed To in Last 12 Months	Security and risk management vendors, including IT, cybersecurity, and privacy vendors and consultants.  Corporate vendors (meaning an entity, as opposed to a natural person, that purchases, leases, or finances any of our products or services).  Original equipment manufacturers (OEM) (suppliers and makers of the products we sell or lease to our customers).
Sold To or Shared With	Not sold for monetary or other valuable consideration, and not shared for cross-context behavioral advertising.
Retention Period	Duration of our relationship with you plus 3 years.

 

Category	Inferences
Examples	Based on analysis of your activity on the website, we may develop inferences regarding product or website usage, patterns and interaction.   For job applicants, based on analysis of the personal information collected, we may develop inferences regarding predispositions, behavior, attitudes, intelligence, abilities, and aptitudes for recruiting and hiring assessments and decisions.
Disclosed To in Last 12 Months	Data analytics vendors.  Not Disclosed for job applicants.
Sold To or Shared With	Not sold for monetary or other valuable consideration, and not shared for cross-context behavioral advertising.
Retention Period	Duration of our relationship with you plus 4 years.  Job Applicants: If hired, this data will be retained for duration of employment plus 6 years. If not hired, it will be retained for 4 years from when position is filled or the date we receive your information, whichever is longer.

 

Of the above categories of Personal Information, the following are categories of Sensitive Personal Information the Company may collect from or about consumers or job applicants:

1. Personal Identifiers (social security number, driver’s license or state identification card number, passport number).
2. Account Information (your Company account log-in, in combination with any required security or access code, password, or credentials allowing access to the account).
3. Protected Classifications (racial or ethnic origin, religious or philosophical beliefs, union membership, or sexual orientation).
4. Geolocation Data (IP address and/or GPS location, latitude & longitude). 

Personal information does not include: 

• • • Publicly available information from government records. 

• • • Information that a business has a reasonable basis to believe is lawfully made available to the public by the consumer or applicant, or from widely distributed media.  

• • • Information made available by a person to whom the consumer or applicant has disclosed the information if the consumer or job applicant has not restricted the information to a specific audience.  

• • • Deidentified or aggregated information. 

We may collect your personal information from the following sources: 

• • • You the consumer or job applicant, when you visit the website and voluntarily submit information through forms on the website or social media, when you visit any of our stores or physical locations, when you purchase or inquire about any of our products or services, when you enter a contract to perform services for us, or when you apply for a position of employment. 

• • • Our employees, contractors, vendors, agents, producers, brokers, suppliers, guests, visitors, other consumers, and customers based on your interactions with them (if any).

• • • We utilize cookies to automatically collect information about our website visitors. 

• • • Surveillance cameras at our physical locations. 

• • • Lead generators and referral sources. 

• • • Credit and consumer reporting agencies. 

• • • HR support vendors. 

• • • Social media platforms. 

• • • Career sites or platforms like LinkedIn, Facebook, JazzHR, and Avionte. 

• • • Company-issued computers, electronic devices, and vehicles. 

• • • Company systems, networks, software applications, and databases you log into or use. 

• • • Company systems, networks, software applications, and databases you log into or use while applying for a position with the Company, interacting with our website, or otherwise interacting with us in any other capacity, including from vendors the Company engages to manage or host such systems, networks, applications or databases. 

• • • Personal references and former employers (if you are a job applicant). 

• • • Schools, universities, or other educational institutions which you attended (if you are a job applicant). 

• • • From friends, family, or colleagues who choose to email you job postings that they think you may be interested in from our application platform or careers page. 

• • • Third party customer databases. 

We may disclose your personal information to the following categories of service providers, contractors or third parties:

• • • Financial institutions. 

• • • Government agencies. 

• • • Promotional or other fulfilment vendors. 

• • • Marketing support vendors and vendors that support managing or hosting the website. 

• • • Communication providers/vendors that facilitate, manage, and send/receive communications on our behalf via email, text/SMS, and phone. 

• • • Lead providers (referral sources). 

• • • Transaction support vendors (e.g., check guaranty, payment processors). 

• • • Data analytics vendors. 

• • • Social media platforms. 

• • • Consumer reporting agencies or credit reporting agencies. 

• • • Recruiting firms, and/or staffing agencies. 

• • • Talent acquisition management systems, and other vendors providing services for purposes of our human resources information system (HRIS) and management of job applicant data and recruiting process. 

• • • Consulting and investigation firms, including HR consultants, safety consultants, and workplace investigators. 

• • • Security and risk management vendors, including IT, cybersecurity, and privacy vendors and consultants.

• • • Insurance carriers, administrators, and brokers. 

• • • Corporate vendor (meaning an entity, as opposed to a natural person, that purchases, leases, or finances any of our products or services). 

We may collect and disclose your personal information for any of the following business purposes: 

• • • To fulfill or meet the purpose for which you provided the information.  
    • To process and submit financing applications, including to apply for credit, or credit pre-qualification. 
    • To process, complete, and maintain records on transactions. 
    • To provide warranty coverage on products and services. 
    • To retain your selection for text, opt in/opt out to ensure customers who opted out are not sent any text messages. 
    • To provide and communicate recall notifications to customers. 
    • To schedule, manage and keep track of customer appointments. 
    • To complete appraisals. 
    • To maintain records of when customers decline a service or sale. 
    • To respond to consumer inquiries, including requests for information, customer support online, phone calls, and in-store inquiries. 
    • To provide interest-based and targeted advertising. 
    • To contact you by email, telephone calls, mail, SMS, or other equivalent forms of communication regarding updates or informative communications related to the functionalities, services, or other information you requested or asked the Company to provide to you. 
    • To improve the user experience on our website. 
    • To understand the demographics of our website visitors. 
    • To detect security incidents. 
    • To debug, identify, and repair errors that impair existing intended functionality of our website. 
    • To protect against malicious or illegal activity and prosecute those responsible. 
    • To verify and respond to consumer requests. 
    • To prevent identity theft. 

JOB APPLICANT PURPOSES: 

• • To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to apply for a job with the Company, we will use that Personal Information in connection with your candidacy for employment
  • To comply with local, state, and federal law and regulations requiring employers to maintain certain records, as well as local, state, and federal law, regulations, ordinances, guidelines, and orders relating to infectious diseases, pandemics, outbreaks, and public health emergencies, including applicable reporting requirements.
  • To evaluate your job application and candidacy for employment.
  • To obtain and verify background check and references.
  • To communicate with you regarding your candidacy for employment.
  • To permit you to create a job applicant profile, which you can use for filling out future applications if you do not get the job you are applying for.
  • To keep your application on file even if you did not get the job applied for, in case there is another position for which we want to consider you as a candidate even if you do not formally apply.
  • To evaluate and improve our recruiting methods and strategies.
  • To engage in lawful monitoring of job applicant activities and communications when they are on Company premises, or utilizing Company internet and Wi-Fi connections, computers, networks, devices, software applications or systems.
  • To engage in corporate transactions requiring review or disclosure of job applicant records subject to non-disclosure agreements, such as for evaluating potential mergers and acquisitions of the Company.
  • To evaluate, assess, and manage the Company’s business relationship with vendors, service providers, and contractors that provide services to the Company related to recruiting or processing of data from or about job applicants.
  • To improve job applicant experience on Company computers, networks, devices, software applications or systems, and to debug, identify, and repair errors that impair existing intended functionality of our systems.
    
  • To reduce the risk of spreading infectious diseases in or through the workplace.

BUSINESS-TO-BUSINESS PURPOSES: 

• • To fulfill or meet the purpose for which you provided the information. 
  • To comply with state and federal law and regulations requiring businesses to maintain certain records (accident or safety records, and tax records/1099 forms). 
  • To implement, monitor, and manage electronic security measures on independent contractor devices that are used to access Company networks and systems. 
  • To evaluate, assess, and manage the Company’s business relationship with vendors, service providers, and contractors that provide services to the Company. 
  • To improve user experience on Company computers, networks, devices, software applications or systems, and to debug, identify, and repair errors that impair existing intended functionality of our systems. 

We do NOT sell or share your personal information in exchange for monetary consideration. However, we may sell or share your personal information to third parties for other valuable considerations such as cross context behavioral advertising.  

We do NOT and will not use or disclose your sensitive personal information for purposes other than the following: 

• • To perform the services reasonably expected by an average employee who requests those services. 
  • To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information. 
  • To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions. 
  • To ensure the physical safety of natural persons. 
  • For short-term, transient use.  
  • To perform services on behalf of FrankCrum. 
  • To verify or maintain the quality or safety of a product, service or device that is owned, manufactured, manufactured for, or controlled by the FrankCrum, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the FrankCrum. 
  • For purposes that do not involve inferring characteristics about the consumers. 

Notice of Right of California Residents to Opt-Out of the Selling and Sharing of Your Information

 

Opt-Out Preference Signals

Opt-out preference signals provide consumers with a simple and easy-to-use method by which to exercise the right to opt-out of the selling and sharing of their information. Global Privacy Controls (GPC) is a user-enabled opt-out preference signal which can communicate a user’s “Do Not Sell or Share” request on behalf of the person or device. We will process opt-out preferences from GPC signals which are in formats commonly used and recognized by businesses, such as an HTTP field header. We will treat a consumer’s use of GPCs as a valid request to opt-out of the selling and sharing of information for that browser. We currently do not connect browser use to consumers and, as such, you will need to use GPCs on all browsers in which you access our website and use our opt-out form to opt-out of offline sales. 

Do Not Track (DNT) is a privacy preference that users can set if they do not want web services to collect information about their online activity. We do not respond to DNT signals or other mechanisms (except for GPCs) that provide a choice regarding the collection of personal information about activities over time and across different websites or online services. We encourage users who have DNTs to use GPCs. 

Retention of Personal Information

We will retain each category of Personal Information in accordance with our established data retention schedule as indicated above. Some of the retention periods in the retention schedule above are measured from a particular point in time that has not occurred yet, such as the end of employment or end of a relationship (whether business, contractual, or transactional) plus a certain number of years. Where no particular event is defined in the retention schedule as the point from which the retention period is measured, we will measure the retention period from either:

(1) the date the record or data was collected, created, or last modified;

(2) the date of the particular transaction to which the record or data pertains; or

(3) another triggering event that is determined to be reasonable and appropriate based on the nature of the data and the legal/business needs for its continued use. 

In deciding how long to retain each category of personal information that we collect, we consider many criteria, including, but not limited to the business purposes for which the Personal Information was collected; relevant federal, state and local recordkeeping laws; applicable statutes of limitations for claims to which the information may be relevant; and legal preservation of evidence obligations.  

We apply our data retention procedures on an annual basis to determine if the business purposes for collecting the personal information, and legal reasons for retaining the personal information, have both expired. If so, we will purge the information in a secure manner.  

Third Party Vendors

We may use other companies and individuals to perform certain functions on our behalf. Examples include administering e-mail services and running special promotions. Such parties only have access to the personal information needed to perform these functions and may not use or store the information for any other purpose. Subscribers or site visitors will never receive unsolicited e-mail messages from vendors working on our behalf. 

Business Transfers

In the event we sell or transfer a particular portion of our business assets, information about consumers, contractors and applicants may be one of the business assets transferred as part of the transaction. If substantially all our assets are acquired, information about consumers, contractors and applicants may be transferred as part of the acquisition. 

Compliance with Law and Safety

We may disclose specific personal and/or sensitive personal information based on a good faith belief that such disclosure is necessary to comply with or conform to the law or that such disclosure is necessary to protect our employees or the public. 

Use of Cookies, Pixels, and Other Tracking Technologies

Cookies are small files that a website may transfer to a user’s computer that reside there for either the duration of the browsing session (session cookies) or on a permanent, until deleted, basis (persistent cookies) that may be used to identify a user, a user’s machine, or a user’s behavior. We make use of cookies under the following circumstances and for the following reasons: 

• • • Provide you with services available through the website and to enable you to use some of its features 

• • • Authenticate users and prevent fraudulent use of user accounts 

• • • Identify if users have accepted the use of cookies on the website 

• • • Compile data about website traffic and how users use the website to offer a better website experience 

• • • Understand and save visitor preferences for future visits, such as remembering your login details or language preference, to provide you with a more personal experience, or to avoid you having to re-enter your preferences every time you use the website 

• • • Track your browsing habits to enable us to show advertising which is more likely to be of interest to you, including advertising by third parties on our website 

You may delete cookies from your web browser at any time or block cookies on your equipment, but this may affect the functioning of or even block the website. You can prevent saving cookies (disable and delete them) by changing your browser settings accordingly at any time. It is possible that some functions will not be available on our website when the use of cookies are deactivated. Check the settings of your browser. Below you can find some guidance:  

• • • Safari 

• • • Opera

• • • Internet Explorer

• • • Google Chrome

• • • Mozilla

Do Not Track (DNT) is a privacy preference that users can set if they do not want web services to collect information about their online activity. We do not respond to DNT signals. 

External Links

Our website contains links to other sites. We are not responsible for the privacy practices or the content of such websites. To help ensure the protection of your privacy, we recommend that you review the Privacy Policy of any site you visit via a link from our website. 

Passwords 

The personal data record created through your registration with our website can only be accessed with the unique password associated with that record. To protect the integrity of the information contained in this record, you should not disclose or otherwise reveal your password to third parties. 

How We Protect the Information that We Collect 

The protection of the information that we collect about visitors to our websites is of the utmost importance to us and we take every reasonable measure to ensure that protection, including: 

• • • We keep automatically collected data and voluntarily collected data always separate.  

• • • We use internal encryption on all data stores that house voluntarily captured data. 

• • • We use commercially reasonable tools and techniques to protect against unauthorized access to our systems. 

• • • We restrict access to private information to those who need such access in the course of their duties for us. 

• • • Database level encryption is adopted on all data captured from the visitor and customer.  

• • • HTTPS, only TLS 1.2, is adopted for data transferring. 

• • • Access control mechanism is adopted to prevent unauthorized access and modification. 

• • • Monitoring and Early Warning System is adopted to help ensure fraudulent behaviors can be inspected. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the website. 

International Visitors 

We do not target, market to, or offer our products or services to consumers outside of the United States. You agree not to submit your personally identifiable information through the website if you reside outside the United States. If we become aware that a person residing inside the European Economic Area, European Union, Great Britain, or Switzerland has submitted their personal information to us, we will delete it.  

Rights Under the CCPA and CPRA 

This section of the Privacy Policy applies only to California residents who are natural people. If you are a California resident, you have the following rights pursuant to the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):  

• Right to Know. The right to request, up to 2 times in a 12-month period, that we identify to you

1. the categories of personal information we have collected about you going back to January 1, 2022, unless doing so would be impossible or involve disproportionate effort, or unless you request a specific time period,
2. the categories of sources from which the personal information was collected,
3. the business or commercial purpose for collecting, selling, or sharing this information,
4.  the categories of third parties with whom we share or have shared your personal information,
5. the categories of personal information that we have sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared, and
6. the categories of personal information that we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose; 

• Right to Access. The right to request, up to 2 times in a 12-month period, that we disclose to you, free of charge, the specific pieces of personal information we have collected about you going back to January 1, 2022, unless doing so would be impossible or involve disproportionate effort, or unless you request a specific time. 

1. Right to Delete. The right to request, up to 2 times in a 12-month period, that we delete personal information that we collected from you, subject to certain exceptions. 
2. Right to Correct. The right to request that we correct inaccurate personal information (to the extent such an inaccuracy exists) that we maintain about you.  
3. Right to Opt-Out. The right to opt-out of the selling or sharing of your personal information to third parties. 
4. The right to designate an authorized agent to submit one of the above requests on your behalf. See below for how you can designate an authorized agent; and 
5. The right to not be discriminated against or retaliated against for exercising any of the above rights, including an applicant’s and independent contractor’s right not to be retaliated against for exercising the above rights. 

You can submit any of the above types of consumer requests through any of the 3 options below: 

1. Submit an online request on our website at Data Subject Requests Link.  

1. Call our privacy toll-free line at 1-800-393-0815, Option 21.  

1. Email Privacy@FrankCrum.com 

Gramm-Leach-Bliley Act Exemption 

Portions of our services are subject to the Gramm-Leach-Bliley Act. When we are extending credit, or providing financial advice or counseling, those activities are covered by the Gramm-Leach-Bliley Act. The CCPA does not apply to personal information to the extent that we collect, process, sell, or disclose it subject to the Gramm-Leach-Bliley Act. Therefore, certain rights under the CCPA may be limited to the extent such requests to exercise CCPA rights relate to the collection, processing, selling, or disclosure of personal information in connection with financial activities covered by the Gramm-Leach-Bliley Act.  

How We Will Verify That it is Really You Submitting the Request 

If you are a California resident, when you submit a Right to Know, Right to Access, Right to Delete, or Right to Correct request through one of the methods provided above, we will ask you to provide some information to verify your identity and respond to your request. Specifically, we will ask you to verify information that can be used to link your identity to records in our possession, which depends on the nature of your relationship and interaction with us.  

Responding to Your Right to Know, Right to Access, Right to Delete, and Right to Correct Requests 

Upon receiving a verifiable request from a California resident, we will confirm receipt of the request no later than 10 business days after receiving it. We endeavor to respond to a verifiable request within 45 calendar days of its receipt. If we require more time (up to an additional 45 calendar days, or 90 calendar days total from the date we receive your request), 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. 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 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. 

For a request to correct inaccurate personal information, we will accept, review, and consider any documentation that you provide, and we may require that you provide documentation to rebut our own documentation that the personal information is accurate. You should make a good-faith effort to provide us with all necessary information at the time that you make the request to correct. We may deny a request to correct if we have a good-faith, reasonable, and documented belief that a request to correct is fraudulent or abusive. If we deny your request to correct, we shall inform you of our decision not to comply and provide an explanation as to why we cannot comply with a request, if applicable.  

Responding to Your Request to Opt-Out of the Selling or Sharing of Your Personal Information 

We will act upon a consumer request to opt-out within 15 days of its receipt. We will notify all third parties to whom we have sold or shared personal information of your request and instruct them to comply with the request within the same time frame. We will notify you when this has been completed by mail or electronically, at your option.  

A request to opt-out need not be a verifiable consumer request. However, we may deny a request to opt-out if we have a good faith, reasonable, and documented belief that a request to opt-out is fraudulent. If we deny your request to opt out, we shall inform you of our decision not to comply and provide an explanation as to why we believe the request is fraudulent. 

If You Have an Authorized Agent: 

If you are a California resident, you can authorize someone else as an authorized agent who can submit a request on your behalf.  

To do so, you must either:  

(a) execute a valid, verifiable, and notarized power of attorney; or  

(b) provide other written, signed authorizations that we can then verify. When we receive a request submitted on your behalf by an authorized agent who does not have a power of attorney, that person will be asked to provide written proof that they have your permission to act on your behalf, and we will also contact you and ask you for information to verify your own identity directly with us and not through your authorized agent. We may deny a request from an authorized agent if the agent does not provide your signed permission demonstrating that they have been authorized by you to act on your behalf.  

Other California Privacy Rights

The California Civil Code permits California residents with whom we have an established business relationship to request that we provide you with a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the preceding calendar year. To make such a request, please send an email to Privacy@FrankCrum.com or write to us at the address listed below. Please mention that you are making a “California Shine the Light” inquiry. 

Consent to Terms and Conditions 

By using this website, you consent to all terms and conditions expressed in this Privacy Policy. 

Changes to Our Privacy Policy 

As our services evolve and we perceive the need or desirability of using information collected in other ways, we may from time to time amend this Privacy Policy. We encourage you to check our website frequently to see the current Privacy Policy in effect and any changes that may have been made to it. If we make material changes to this Privacy Policy, we will post the revised Privacy Policy and the revised effective date on this website. Please check back here periodically or contact us at the address listed at the end of this Privacy Policy. 

Consumers With Disabilities 

This policy is in a form that is accessible to consumers with disabilities. 

Questions About the Policy 

This website is owned and operated by FrankCrum. If you have any questions about this Privacy Policy, please contact us at Privacy@FrankCrum.com or call 1-800-393-0815, Option 21. 

Policy Last Updated on: January 1, 2025 (reviewed annually) 

Policy Details – Table of Revision
Revised on	Version	Description	Approved by
October 25, 2024	2.0	Revision of Privacy Policy with new CPRA requirements	Danielle Grubb  Corporate Counsel
December 1, 2023	1.0	Annual review and revision of Privacy Policy	Danielle Grubb  Corporate Counsel