Applicant & Employee Online Privacy Policy
Last Updated: October 2022
Here at TurboDebt, LLC (“TD,” “we,” “us,” “our”), we work hard to build and maintain a relationship of trust with you. This Privacy Policy (the “Privacy Policy”) governs our collection, use, and disclosure of your Personal Information (as defined below) in connection with prospective or actual employment.
This Privacy Policy explains what information we collect about you, how we use or disclose such information, how to exercise any rights you may have with respect to your Personal Information (including any rights to opt-out of certain uses of your information), and the safeguards we have in place to reduce the risk of unauthorized access and use.
Please carefully read this Privacy Policy before applying and/or agreeing to employment with us. If you do not agree with the terms of this Privacy Policy, you should refrain from submitting an application or entering into an employment relationship with us. By working for us, you agree to our use of your information consistent with this Privacy Policy.
Privacy Policy Changes
This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. Changes to this Privacy Policy will be posted on our website at www.turbodebt.com and copies of the current Privacy Policy will also be available from our Human Resources Department by calling 866-511-3395, or sending an email to HR@turbodebt.com. Any changes will be effective immediately upon posting. If we determine that a change to this Privacy Policy will result in using your Personal Information acquired before the change in a materially new and previously undisclosed manner, we will provide you notice and obtain your consent for the change.
Conflict Between This Policy And Local And Federal Laws And Regulations
When federal, state and/or local laws and regulations require a higher level of protection for your Personal Information, they take precedence over this Privacy Policy. In addition, the specific requirements of this Privacy Policy apply only when local laws and regulations permit.
Information We Collect
This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. Changes to this Privacy Policy will be posted on our website at www.turbodebt.com and copies of the current Privacy Policy will also be available from our Human Resources Department by calling 866-511-3395, or sending an email to HR@turbodebt.com. Any changes will be effective immediately upon posting. If we determine that a change to this Privacy Policy will result in using your Personal Information acquired before the change in a materially new and previously undisclosed manner, we will provide you notice and obtain your consent for the change.
Personal Information
We may collect information that personally identifies, relates to, describes or is capable of being associated with you and other individuals such as your dependents (“Personal Information”), including:
- Personal Identifiers (e.g., name, social security number, taxpayer identification number, driver’s license number, date of birth, IP address, security questions & answers);
- Biometric & Health Information (e.g., medical reports, illness excuse notes, disability accommodation requests, intrinsic human characteristics such as fingerprints and digital signatures, and behavioral identifiers such as typing, navigation, and engagement patterns);
- Contact Information (e.g., email address, mailing address, phone number);
- Financial Information (e.g., benefit elections, bank account number for direct deposit, wages earned, the existence of garnishment or levies on wages, tax exemptions, deductions, and withholdings);
- Educational Information (e.g., educational institutions attended, and degrees and grades received);
- Geolocation data;
- Professional/Employment Information (e.g., positions held, tenure, resume, references, skill assessments, performance evaluations, disciplinary records, and records of work-related disputes);
- Characteristics of Protected Classifications (e.g., gender, age, race, disability, nationality, and marital, veteran and citizenship status);
- Audio/Visual Information (e.g., call recordings, recordings from security cameras on work premises, employee photos); and
- Interferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
The types of Personal Information we collect about you may vary based on whether you are an applicant for employment or an actual employee, employment functions, and benefits provided.
Usage Data and Equipment Usage
We automatically collect information in connection with the actions you take on our equipment, including company computers, through our sites, and in connection with your employment activities (“Usage Data”). For example, each time you log into our systems we automatically collect your username, password, the date and time of your activities, and the duration of your access. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information. If this information is not capable of being individually associated with you, we treat it as Usage Data. Please note that when using company equipment, including email and messaging systems, you do not have a right to an expectation of privacy. We may monitor, record, and log your uses of company equipment and systems.
Call Recordings
We may record calls and retain the content of text messages or other written/electronic communications made through or to us or related to your prospective or actual employment.
Audio & Visual Recordings
We may monitor and record your activities while in our facilities such as through the use of video cameras.
How We Collect Information
Voluntary Disclosure
We may ask you to provide us with Personal Information when you communicate with us (online or offline), when you apply to a position or apply for a promotion, when you become an employee, when you access employee benefits, and at other times.
Third-Party Data Sources
We may collect Personal Information from third-party data sources such as recruitment services, job posting services, employee benefit providers, or Service Providers (as defined below) hired to provide identity verification services, conduct background checks, and/or drug screenings.
How We Use And Share Information
Generally
We use Personal Information for internal purposes, such as to:
- Advertise available positions or information about careers with us;
- Evaluate candidates for employment;
- Provide training and mentoring;
- Facilitate performance reviews;
- Provide employee benefits, services, and accommodations;
- Optimize our business and workforce;
- Maintain company security;
- Communicate with employees via mail, email, telephone, and/or text messaging;
- Facilitate compliance with company policies; and
- Comply with legal and contractual obligations.
Testimonials
If you provide a testimonial about your employment experience with us or your experience with any of the benefits or services we provide, we may post it publicly.
Sharing and Selling of Personal Information
We do not sell your Personal Information to third-party companies, but we do share Personal Information with our Service Providers and our benefits providers.
Service Providers
From time to time, we may establish a relationship with other businesses that we believe are trustworthy and that we believe have privacy practices consistent with ours (“Service Providers”). We contract with Service Providers to provide certain services to us, including:
- Online hosting and maintenance;
- Employee benefits and insurance;
- Staffing agencies;
- Management of HR systems;
- Professional services such as legal and accounting;
- Identity and contact information validation;
- Background checks;
- Drug screening;
- Data storage and management; and
- Business consulting.
We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.
We share the following types of Personal Information with one or more Service Providers: biometric & health information; contact information; educational information; financial information; geolocation data; personal identifiers; audio/visual information; professional/employment information; characteristics of protected classifications; Interferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Cookies & Other Automated Tools
Our Service Providers may use cookies (a small text file placed on your computer to identify your computer and browser) and other automated tools such as tracking pixels to facilitate the services they provide to us. Many web browsers are set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. Instructions for how to manage cookies in popular browsers are available at: Internet Explorer, Firefox, Chrome, Safari (iOS), Safari (Mac), and Opera. However, certain features of our or our Service Provider’s sites, systems, or employment functions may not work if you delete or disable cookies.
We use the following types of cookies:
- Session Cookies: Session cookies keep track of you or your information as you move from page to page within a site or system and are typically deleted once you close your browser. For example, a session cookie allows you to keep your progress.
- Persistent Cookies: Persistent cookies reside on your system and allow the cookie provider to customize your experience if you leave and later return to the site or system. For example, persistent cookies may allow a site owner to remember your preferences.
- Advertising Cookies: Advertising cookies are used to learn more about you and present you with information that might interest you. For example, an advertising cookie may help a Service Provider determine which services and benefits will best serve our employees.
- Analytics Cookies: Analytics cookies help a site owner understand how its sites and systems are working, who is using the sites and systems, and how the sites and systems are being used. Google Analytics is one commonly used tool, and you can learn more about it by reviewing Google’s Privacy Policy.
The following chart provides a summary of the categories of Personal Information we collect, from whom we collect it, and our business purposes for collecting, using, and disclosing it. It also provides a summary of whether we share or sell Personal Information to third parties who are not Service Providers, and, if so, the categories of Personal Information we disclose.
| Categories of PI we Collect | Categories of Sources from which we Collect PI | Our Business Purposes for Collecting, Using, Sharing, or Selling PI | Whether we Sell or Share PI to Non-Service Provider Third Parties for a Business Purpose | Categories of Non-Service Provider Third Parties to whom we Share or Sell PI |
|---|---|---|---|---|
| Audio/Visual Information | Employees | Business Security; Employee Security; Training; Performance Evaluations | No | None |
| Biometric & Health Information | Employees; Providers of Benefits | Business Security; Employee Security; Qualify for Benefits, Services, or Leave | No | None |
| Contact Information | Employees; Identity Verification Services; Service and Benefit Providers | Business Purposes; Employee Pay; Employee Benefits; Security | No | None |
| Educational Information | Employees; Identity Verification Services; References | Confirming Employment Qualifications | No | None |
| Financial Information | Employees; Employees’ Banks; Benefit Providers | Employee Paychecks; Employee Taxes;Employee Benefits | No | None |
| Geolocation Information | Employees; TD Computers and Equipment | Keeping Tracking of TD Equipment | No | None |
| Personal Identifiers | Employees; Identity Verification Services; Providers of Services and Benefits to Employees | Business Security; Employee Security; Business Purposes; Employee Pay; Employee Benefits; Employee Services; Performance Review; HR Complaints | No | None |
| Inferences from PI | TD; Non-Marketing Data Analytics Firms | Company, Business, Employee Auditing; Business consulting and efficiency | No | None |
| Professional/Employment Information | Employees; TD; Resumes; Skill Assessment Firms | Performance Review; Confirming Employment Qualifications; Department Auditing | No | None |
| Characteristics of Protected Classifications | Employee; Identity Verification Services; Providers of Services and Benefits to Employees | Identity Verification; Security; Discrimination Complaints | No | None |
Security
We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially-reasonable administrative, technical, and physical safeguards to protect such Personal Information from unauthorized access, use, and disclosure. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information you transmit to us relating to your employment and/or benefits and third-party beneficiaries of those benefits, you do so at your own risk.
Other Websites
Please be aware that third-party websites accessible through our website, company equipment, Service Providers, or employee benefits providers may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing information.
Other Transfers
We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.
Compliance With Laws And Law Enforcement
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas), to protect the safety, property, or rights of ourselves, Clients, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.
How Long We Retain Your Data
We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, and/or accounting obligations. Generally, we retain Personal Information for seven (7) years after our relationship with you has ended, but the term for which we retain your Personal Information may be longer or shorter. We do so in accordance with our data retention policies and applicable law.
Children’s Privacy
While we do not employ people under the age of sixteen (16) and we largely do not collect Personal Information on or about children under the age of sixteen (16), we do collect information on minor children for the limited purpose of extending benefits to our employees and their dependents.
Additional Privacy Rights
If you are a resident of California, you have additional rights to access and control your Personal Information, including a right to request that we disclose the Personal Information we collect, use, disclose, and sell. We have extended these rights to all of our employees regardless of state.
Right to Know
You have the right to request twice per 12-month period that we provide you (i) the categories and specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose for which we collected your Personal Information; (iv) the categories of third parties with whom we shared your Personal Information (if any); and (v) the categories of third parties to whom we sold your Personal Information (if any).
To request access to your Personal Information and the information listed above, you may submit a request through our Access Request Page or call us at 904-274-3790. Please review the Access Request Page first because it contains important descriptions of the process we use to verify and fulfill your request. You may also designate an authorized agent to submit a request on your behalf as described on the Access Request Page.
Right to Deletion
You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies or a policy exemption applies (in all other states) such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations.
To request deletion of your Personal Information and the information listed above, you may submit a request through our Deletion Request Page or call us at 904-274-3790. Please review the Deletion Request Page first because it contains important descriptions of the process we use to verify and fulfill your request. You may also designate an authorized agent to submit a request on your behalf as described on the Deletion Request Page.
Right to Opt-Out
We do not sell employee Personal Information to third parties.
Right to Non-Discrimination
We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy.
Authorized Agents
Authorized Agents are permitted to make requests on behalf of individuals. However, at a minimum, Authorized Agents must provide written authorization from the individual for the agent to submit the request and the agent must verify their own identity. In cases requiring a heightened verification level, the Authorized Agent may also be required to submit a signed declaration under penalty of perjury from the consumer that the Authorized Agent is permitted to act on their behalf.
California “Do Not Track” Disclosure
Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. At this time, our site does not respond to “Do Not Track” signals.
Contact Information
If you have any questions about this Privacy Policy, please email us at HR@TurboDebt.com, call us at 866-511-3395, or send us a letter to the following address:
Turbo Debt, LLC
Attn: HR Department
7159 Corklan Drive
Suite 100
Jacksonville, FL 32258