Last Modified February 6th, 2023 

Stellar Health Employment Privacy Notice

Your privacy and the protection of Personal Information are very important to us. This privacy notice (the “Privacy Notice”) describes the privacy practices of Stellar Health, including its subsidiaries and affiliates (collectively “Stellar”, “we”, “us”, or “our”) as they relate to the collection, use and sharing of Personal Information relating to prospective, current, and former employees, their family members, dependents, and beneficiaries in the United States of America (“you,” “Employee”, “Employees”). 

As used in this Privacy Notice, the term “Personal Information” (“PI”) means information about you that is personally identifiable, such as your name, address, email address, telephone number, and other non-public information that is personally identifiable. 

1. How We Collect Your Personal Information

We collect Personal Information about you in several ways and from several sources. We collect Personal Information directly from you, automatically when you visit a website or other online Stellar platforms (the “Sites”) and from third parties. We also create Personal Information about you in the context of a prospective or current employment relationship. The following explains the Personal Information under each of these categories of sources.

a. Personal Information Collected Directly from You:

We, and service providers working on our behalf, collect Personal Information from you directly as part of your employment relationship, or when you seek employment with Stellar. This includes, but is not limited to, collection done on a voluntary basis, and current Employees and prospective Employees are not required to provide this type of Personal Information unless it is necessary for us to collect it to comply with our legal obligations.

b. Personal Information Collected from Third Parties:

We collect Personal Information about you from third parties such as consumer reporting agencies in connection with employment background checks, job websites, professional social networking sites such as LinkedIn, application providers, and data providers for purposes of employment (prospective or current), to maintain applicable benefits and for other purposes stated below.

c. Personal Information Created About You:

We collect or create Personal Information about you based on our interaction with you as a prospective or current Employee such as interview notes, electronic communications, performance information, and wage and benefit information.

d. Personal Information Collected Automatically:

In compliance with applicable laws, we may monitor the use of our premises, equipment, devices, computers, network, applications, software, and similar assets and resources which may result in the collection of Personal Information about you. This monitoring may include the use of cameras in and around our premises or electronic monitoring technologies via our networks. Monitoring will be done in a manner that is proportionate to the purposes for which such monitoring is undertaken and only as required or permitted by applicable law.

2. Use of Personal Information About You

We use Personal Information collected from or about you (including Personal Information about your dependents, beneficiaries and emergency contacts) for specific, authorized Stellar business purposes including to:

a. Process your application for employment, request a background check, submit a screening assessment, assess qualifications for a job, and otherwise determine eligibility for employment;

b. Identify, review and manage candidacy for job opportunities;

c. Provide or administer wages, payments, tax, and benefits;

d. Conduct performance reviews, establish training requirements, and conduct investigations or pursue disciplinary actions including, but not limited to, termination;

e. Manage access to Stellar information systems and facilities;

f. Compile directories and establish contacts in the event of an emergency;

g. Comply with legal requirements, assist in an investigation, comply with requests from regulatory and law enforcement authorities and to meet contractual obligations;

h. Maintain and improve our cybersecurity program and our awareness of evolving threats;

i. Investigate and respond to cybersecurity and privacy incidents;

j. Verify compliance with our internal policies and procedures;

k. Communicate with you via email, mail or other methods about  \Stellar, benefits, wages, job opportunities, technology or services offered or other information relevant to employment status;

l. Provide you with employment-related services, tools, systems or applications;

m. Analyze, improve or develop our Employee-related processes or tools using algorithms, analytics software, research studies, surveys, and other similar methods;

n. Conduct studies to maintain, protect and develop our networks, tools, services, and products;

o. Protect the safety and security of our business, services, and Sites including to prevent suspected fraud, threats to our network or other illegal activities, prevent misuse or for any other reason permitted by law;

p. Exercise, establish, or defend the legal rights of Stellar;

q. Analyze employment data, and forecast workforce trends at the aggregate level;

r. Any other reason we provide at the time we collect your Personal Information

s. Update or correct our records including combining Personal Information we have with Personal Information received from other sources; and

t. Carry out other activities required in the normal course of our employment relationship with you.

3. Sharing of Personal Information About You

We may disclose Personal Information about you to our Stellar affiliate entities for specific, authorized Stellar business purposes consistent with the uses described in this Privacy Statement. We may also disclose Personal Information about you to third parties such as service providers, as described below, or whenever you direct such sharing.

We may disclose Personal Information to the following categories of third parties for specific, authorized Stellar business purposes or as required or permitted by law:

a. Service providers: Personal Information may be disclosed to service providers that perform services on our behalf to carry out the uses of Personal Information described above such as payroll support service providers, tax and travel management services, health and safety experts, and relocation companies.

b. Benefits providers: Personal Information may be disclosed to enable third parties to make services available to you such as financial investment service providers, insurance providers, and child care providers.

c. Third parties in connection with a business transaction: Personal Information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of any or all of our company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by an affiliate or third party, or in the event of a bankruptcy or related or similar proceedings.

d. Law enforcement, regulators and other parties for legal reasons: Personal Information may be disclosed to third parties, as required by law or subpoena, or if we reasonably believe such action is necessary to:

e. To comply with the law and the reasonable requests of regulators, court orders, law enforcement or other public authorities, such as a subpoena, government audit or search warrant;

f. To manage legal claims asserted against Stellar;

g. To comply with a contract or as necessary to establish, exercise or defend against potential, threatened or actual litigation;

h. To protect us, your vital interests, or those of another person; and

i. To investigate fraud or to protect the security or integrity of our Sites or any products or services that Stellar offers.

4. Categories of Information We Collect

 

5. Retention of Personal Information

We retain Personal Information about you for as long as it is needed for the purposes described above, or as otherwise required by law. Generally, this means we will retain Personal Information about you until the end of your employment with us, as well as a reasonable period of time after that where necessary to respond to any employment inquiries, deal with legal, tax, accounting or administrative matters, or to provide you with ongoing pensions or other benefits. Where we have no continuing legitimate business need to process Personal Information about you, we will either delete or anonymize it or, if this is not possible (for example, because Personal Information has been stored in backup archives), then we will securely store Personal Information about you and isolate it from any further processing until deletion is possible.

6. Protection of Personal Information

We implement reasonable and appropriate physical, technical, and administrative measures to protect information under our control. However, no method of transmission or electronic storage is fully secure, and we cannot guarantee absolute security.

7. Children’s Personal Information 

Stellar does not employ individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from such individuals. In the event we become aware of such processing, we will take steps to delete it.

8. Accessing and Correcting Your Information

Please email us at privacy@stellar.health to request access to, correct, or delete Personal Information that you have provided to us. Note that we may be required, by law or otherwise, to keep certain information, in which case we will comply with your deletion request only after we have fulfilled such requirements. When we delete Personal Information, it may remain in our archived data. We may also retain Non-Personal Information about use of the Sites. Note that once we have disclosed Personal Information to third parties, we cannot guarantee the deletion or modification of such information by the parties to whom we made the disclosure.

9. Updates

In the future, we may change this Privacy Notice from time to time. If we do, we will post the revised Privacy Notice on this page and update the “Last Modified” date at the top. By continuing to use the Sites following notice of such changes, you acknowledge such changes and agree to be bound by their terms and conditions.

10. Additional Privacy Notice for California Residents

Employees who are residents of California have certain additional rights under the California Consumer Privacy Act (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”).

This Privacy Notice describes the Personal Information we collect or process about California residents in connection with their employment as well as how we use, disclose, and protect that Personal Information. This Privacy Notice also outlines the rights you have with respect to Personal Information that we collect or process.

a. Supplemental Disclosures:

In the past 12 months, we have collected and/or disclosed the Personal Information discussed above in section 4. “Categories of Information We Collect.”  The chart above also sets forth the categories of third parties to which we disclosed Personal Information for our operational business purposes within the preceding 12 months.  

Please note that some of this Personal Information qualifies as Sensitive Personal Information under the CPRA. We do not use or disclose Sensitive Personal Information for purposes other than that which is necessary and proportionate to accomplish the objectives set forth in section 7027 of the Modified Proposed CPRA regulations.

Moreover, while we do not sell Employee Personal Information in the way the term “sell” is commonly used, we do disclose limited cookie data to our business partners in order to provide and maintain our Sites. Such a disclosure may constitute a “sale” for purposes of the CPRA.  We have made such disclosures in the past 12 months.

In the past 12 months, we have not “shared” Employee Personal Information as the term is defined by the CPRA.

b. Your CCPA/CPRA Rights

i. Right to Disclosure of Information: You have the right to request that we disclose certain information regarding our practices with respect to Personal Information. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction:

            1. The categories of Personal Information we have collected about you in the last 12 months;
            2. The categories of sources for the Personal Information we have collected about you in the last 12 months;
            3. Our business or commercial purpose for collecting that Personal Information;
            4. The categories of third parties with whom we share that Personal Information; and
            5. The specific pieces of Personal Information we collected about you.

ii. Right to Delete Personal Information: You have the right to request that we delete any of your Personal Information collected from you and retained, subject to certain exceptions. Upon receiving a verified request to delete your Personal Information, we will do so unless otherwise authorized by law.

iii. Right to Correct your Personal Information: If you find that we maintain any inaccurate Personal Information, you have the right to request that we correct such inaccuracy. 

iv. Right to Out of the Sale of your Personal Information: You have a right to opt-out of the sale of your Personal Information. You may, at any time, direct businesses that sell your Personal Information to third parties not to sell your Personal Information. You may do so by either contacting us as detailed below or by clicking on the “Do not sell or share my Personal Information” link in the footer of our website. As we do not “share” your information as defined in the CPRA, we do not provide you with a method to opt out of the sharing of your Personal Information.

v. Right to Non-Discrimination: You have the right not to be discriminated against for the exercise of your California privacy rights described above.

c. How to Exercise these Rights

If you wish to submit a request to exercise one or more of the rights listed above you can do this by emailing us at privacy@stellar.health or contacting us at (877) 509-2808. 

Please include your question or concerns in your letter to us. We will respond to verifiable requests for disclosure or deletion of Personal Information free of charge, within 45 days of receipt. In certain instances, we may require more than 45 days to respond to your request. In the event that we need additional time, we will inform you of this extension within the initial 45-day window. 

In order to protect your privacy and the security of your information, we verify consumer requests by requesting identification documents and other documentation necessary to confirm your identity.  Any additional information you provide will be used only to verify your identity and not for any other purpose. 

d. Authorized Agents

If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above.  As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent.  In addition, we may require the individual on whose behalf you are making the request to verify their own identity or your permission to submit the request.