California Privacy Notice

Updated time: 04 Oct, 2024, 15:12 (UTC+08:00)

PERSONAL INFORMATION PROCESSED UNDER THE CALIFORNIA PRIVACY RIGHTS ACT (“CPRA”)

Scope: This notice applies to the handling of Personal Information (“PI”) and Sensitive Personal Information (“SPI”) of Consumers by One IBC® Group (“One IBC®”, “we”, “our” “us”).

Acting as a California Business, we may process PI and SPI of the following Consumers: One IBC® website users, One IBC® employees (current and former employees, full-time, part-time and temporary employees, staff, officers, directors and owners of One IBC®), One IBC® employees related persons (employee family members, dependents, emergency contacts and beneficiaries), One IBC® candidate employees, and One IBC® commercial partners (clients, prospective clients, vendors, prospective vendors or any other One IBC® commercial partners).

This notice does not address or apply to our handling of:

Publicly available information made lawfully available by state or federal governments.
PI or SPI that is subject to an exemption under the CPRA.

This California Privacy Notice is divided into the following sections:

Information about how we process our Consumers PI and SPI;
Consumers rights under the CPRA;
Annex 1: Definitions used in the California Privacy Notice.

1. INFORMATION ABOUT HOW WE PROCESS OUR CONSUMERS PI AND SPI

In line with the requirements of the CPRA, the table below provides information about the PI and SPI we process from our Consumers: the categories of PI and SPI we collected (or disclosed or shared where applicable) about our Consumers in the preceding 12 months, the sources of collection, the purposes of processing, the data retention periods, the third parties to whom we may have disclosed (or shared if applicable) Consumers PI or SPI in the preceding 12 months, and the purposes of such disclosure or sharing:

Table 1

Categories of PI collected in the preceding 12 months
Website Users	Employees	Employees Related Persons	Candidate Employees	Commercial Partners or Clients
Identifiers (see Definitions for details); Internet or other electronic network activity data, including, but not limited to, browsing history, search history, and information regarding users interaction with the website; Inferences that may reveal website user´s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes; Data shared in communications with One IBC®.	Identifiers (see Definitions for details); Compensation and benefits data; Banking details; Commercial data (for example, business travel and expense records); Preferences; Memberships in charitable and public organizations; Inferences that may reveal preferences or predispositions; Background check data; Data of employee related persons; Internet or other electronic network activity data; Audio, electronic and visual data; Professional or employment related data.	Identifiers (see Definitions for details); Compensation and benefits data; Banking details; Preferences; Data shared in communications with One IBC®; Audio, electronic and visual data.	Identifiers (see Definitions for details); Inferences that may reveal preferences or predispositions; Data shared in communications with One IBC®; Background check data; Internet or other electronic network activity data; Education and other recruitment-related data; Audio, electronic and visual data.	Identifiers (see Definitions for details); Data shared in communications with One IBC®; Data relevant for Know Your Client “KYC” purposes (including annual income, estimated wealth or source of wealth and tax residence if you are a One IBC® client Ultimate Beneficial Owner “UBO” or an executive); Professional or employment related data; Audio, electronic and visual data.

Table 2

Categories of SPI collected in the preceding 12 months
Website Users	Employees	Employees Related Persons	Candidate Employees	Commercial Partners or Clients
Precise geolocation data about a particular individual or device.	ID document; One IBC®´s account log-in data; Geolocation data; E-mails where One IBC® is not the intended recipient (for backup purposes or where we are compelled to do so in accordance with applicable laws); Health data; Racial or ethnic origin data; Religious or philosophical beliefs; Union membership data; Sex data (data about employees related persons that may reveal sexual preferences); Data on former criminal convictions.	ID document; Health data; Sex data (data about related employees that may reveal sexual preferences).	ID document; One IBC®´s account log-in data; Health data; Racial or ethnic origin data; Religious or philosophical beliefs data; Union membership data; Data on former criminal convictions.	ID document; Health data.

Table 3

Sources of collection
Website Users	Employees	Employees Related Persons	Candidate Employees	Commercial Partners or Clients
One IBC® website.	Internally generated by One IBC®;	One IBC® employee.	During the recruitment process; Third parties; Public sources or public records.	Please review Section 2 of One IBC® Privacy Policy to see this information.

Table 4

Purposes for processing
Website Users	Employees	Employees Related Persons	Candidate Employees	Commercial Partners or Clients
Please review One IBC® Privacy Policy to obtain this information.	Compliance with our legal obligations; Management and administration of employment benefits; Performance of the employment contract; Our legitimate interests; Protection of vital interests of employees; Marketing and promotional activities. Team building, bonding and other similar internal social activities.	Management and administration of benefits; Our legitimate interests; Protection of vital interests of employees or employees related persons; Team building, bonding and other similar internal social activities.	to manage and process your application including evaluating your skills and suitability for the role you may have applied for; for the administration of the contract we are entering with you; to conduct reference checks to validate your qualifications, experience, and suitability for a role; for certain roles, we may also conduct background checks (as permitted by applicable law); for making decisions about employment with us; for complying with applicable laws and regulations, such as taxation rules, compliance with requests from governmental agencies or judicial services (including the provision of your data to governmental agencies for statistical purposes where required by law), other employment laws and regulations applicable to us; dealing with a legal dispute and to establish, exercise and defend (potential) legal claims because of your recruitment process; for the management of your data within IT systems and operational processes within the company (e.g. our recruitment and HR systems); when visiting our offices to register you as a visitor and temporary record your access to office areas in CCTV for security purposes; providing you with more suitable career opportunities at One IBC® Group; identifying for future positions that may become available.	Please review section 3 of One IBC® Privacy Policy to see this information.

Table 5

Data retention period

Website Users

Employees

Employees Related Persons

Candidate Employees

Commercial Partners or Clients

Please review One IBC® Privacy Policy to see this information.

As long as required to satisfy the purpose for which the PI/SPI was initially collected and used, or for the establishment, exercise or defense of legal claims.

As long as required to satisfy the purpose for which they were collected and used for the time necessary to complete the recruitment process unless:

you have been hired, in which case your data may be retained pursuant to other legal ground i.e. employment contract; or
if you have provided consent to One IBC® Group to retain your data for a longer period; provided consent shall satisfy the legal requirements for valid consent.

Please review section 8 of One IBC® Privacy Policy to see this information.

Table 6

Categories of 3rd parties to which PI/SPI has been disclosed in the preceding 12 months
Website Users	Employees	Employees Related Persons	Candidate Employees	Commercial Partners or Clients
Please review One IBC® Privacy Policy to see this information.	One IBC® Affiliates; Successors in title of One IBC® business in case of a corporate transaction; Vendors and suppliers that process PI/SPI on our behalf; Third parties with whom One IBC® has a contractual relationship with; Public authorities.	One IBC® Affiliates; Successors in title of One IBC® business in case of a corporate transaction; Vendors and suppliers that process PI/SPI on our behalf; Third parties with whom One IBC® has a contractual relationship with; Public authorities.	Third parties which assist One IBC® Group for candidate employee selection and evaluation purposes, background check.	Please review section 4 of One IBC® Privacy Policy to see this information.

Table 7

Purposes of disclosure
Website Users	Employees	Employees Related Persons	Candidate Employees	Commercial Partners or Clients
To help us achieve the purposes described above.	To help us achieve the purposes described above.	To help us achieve the purposes described above.	To help us achieve the purposes described above.	To help us achieve the purposes described above.

Table 8

Categories of 3rd parties to which PI/SPI has been shared in the preceding 12 months
Website Users	Employees	Employees Related Persons	Candidate Employees	Commercial Partners or Clients
One IBC® Affiliates, service providers; Analytics companies; Public authorities; Entities in connection with corporate transaction; Other third parties as required by law.	N/A	N/A	N/A	N/A

Table 9

Purposes of sharing
Website Users	Employees	Employees Related Persons	Candidate Employees	Commercial Partners or Clients
Receive certain services or benefits from them (such as when One IBC® allows third-party tags to collect data by making browsing data available to third party ad companies): To improve and measure ad campaigns and reach users with more relevant ads and content. Ensure compliance with legal requirements.	N/A	N/A	N/A	N/A

More information about the processing of PI/SPI related to One IBC® employees is provided to them at the moment of contracting with One IBC®, and is available to them at all times on One IBC®´s internal intranet.

We do not sell any PI or SPI and we do not knowingly disclose or share any PI or SPI from individuals under the age of 16.

2. CPRA RIGHTS

If you reside in California, you have the right:

With respect to the PI/SPI One IBC® has collected about you in the prior twelve (12) months, to require that One IBC® discloses the following to you, up to twice per year and subject to the exemptions set out in the CPRA:
- Categories of PI/SPI collected;
- Categories of sources of PI/SPI;
- Categories of PI/SPI about you One IBC® has disclosed, shared or sold;
- Categories of third parties to whom One IBC® has sold, shared or disclosed your PI/SPI;
- The purposes for collecting, disclosing or sharing PI/SPI;
- A copy of the specific pieces of PI/SPI One IBC® has collected about you;
Request the deletion of your PI/SPI that One IBC® collected, subject to the exceptions set forth in the CPRA;
Request the correction of any inaccurate PI/SPI, taking into account the nature of the PI/SPI and the purposes of the processing;
Opt-out of the sale, share or disclose of your PI/SPI. To opt-out from sharing your web-users data, click on the Cookie Settings button at the bottom of this page and disable all options;
Request to limit the use and disclosure of SPI only to what is necessary and proportionate to achieve the purposes required to maintain the relationship with One IBC® (as employee, as an employee related person, as candidate, or as a client, prospective client, vendors, prospective vendor or other individual commercial partner of One IBC®);
Be free from discriminatory adverse treatment for exercising these rights.

You or your authorized agent can submit your request to exercise your California Privacy Rights by going to One IBC® Privacy Policy and contact One IBC® at [email protected] or by calling One IBC® at +1 949 524 4399.

In some cases, One IBC® may request additional information in order to verify your request or where necessary to process your request. If One IBC® is unable to adequately verify a request, One IBC® will notify the requestor.

Authorized agents will be required to provide proof of their authorization and One IBC® may also require that the relevant Consumer directly verify their identity and the authority of the authorized agent.
If you have questions or concerns about One IBC® privacy practices, you may contact One IBC® at [email protected].

Third parties which assist One IBC® Group for candidate employee selection and evaluation purposes, background check.

3. ANNEX 1: DEFINITIONS

The terms and abbreviations listed below, have the following meaning in this Policy:

Definition	Meaning
Affiliates / One IBC® Affiliates	means with respect to One IBC®, any entity directly or indirectly controlling or controlled by or under direct or indirect common control by One IBC® Group. Specifically excluded from this definition are the shareholding companies controlling One IBC® Group.
Business	has the meaning: “A sole proprietorship, partnership, limited liability company, corporation, association, or other legal entity that is organized or operated for the profit or financial benefit of its shareholders or other owners, that collects consumers’ personal information, or on the behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information that does business in the State of California, and that satisfies one or more of the following thresholds […]”
Consumer	has the meaning: “a natural person who is a California resident, as defined in Section 17014 of Title 18 of the California Code of Regulations, as that section read on September 1, 2017, however identified, including by any unique identifier.”
CPRA	means the California Privacy Rights Act that was passed into law on November 3, 2020 in California, United States of America.
Identifiers	has the meaning: “[…] a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers […]”
Personal Information (“PI”)	has the meaning: “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household […]”.
process / processing	has the meaning: “any operation or set of operations that are performed on Personal Information or on sets of Personal Information, whether or not by automated means.”
Sensitive Personal Information	has the meaning: 1. Personal information that reveals: (a) a Consumer’s social security, driver’s license, state identification card, or passport number, (b) a Consumer’s 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, (c) a Consumer’s precise geolocation, (d) a Consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership, (e) the contents of a Consumer’s mail, email, and text messages unless the business is the intended recipient of the communication, (f) a Consumer’s genetic data; 2. (i) the processing of biometric information for the purpose of uniquely identifying a Consumer, (ii) Personal information collected and analyzed concerning a Consumer’s health, and (iii) Personal information collected and analyzed concerning a Consumer’s sex life or sexual orientation. 3. Sensitive Personal Information that is “publicly available” pursuant to paragraph (2) of subdivision (v)of the CPRA shall not be considered sensitive Personal Information or Personal Information.”
One IBC® Privacy Statement	means the policy published on One IBC®´s website and accessible through the link: https://www.oneibc.com/us/en/info/privacy-policy
sell / sold / selling	has the meaning: “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal Information by the business to a third party for monetary or other valuable consideration. For purposes of this title, a business does not sell personal information when A consumer uses or directs the business to intentionally (i) disclose Personal Information, or (ii) interact with one or more third parties. […]”
share / shared /sharing	has the meaning: “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal Information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged […]”

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California Privacy Notice

PERSONAL INFORMATION PROCESSED UNDER THE CALIFORNIA PRIVACY RIGHTS ACT (“CPRA”)

1. INFORMATION ABOUT HOW WE PROCESS OUR CONSUMERS PI AND SPI

Categories of PI collected in the preceding 12 months

Categories of SPI collected in the preceding 12 months

Sources of collection

Purposes for processing

Data retention period

Categories of 3rd parties to which PI/SPI has been disclosed in the preceding 12 months

Purposes of disclosure

Categories of 3rd parties to which PI/SPI has been shared in the preceding 12 months

Purposes of sharing

2. CPRA RIGHTS

3. ANNEX 1: DEFINITIONS

Definition

Meaning

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