Effective Date: January 1, 2023
This California Privacy Notice addresses how we process the personal information of applicants, employees, and contractors who are residents of California. This Notice supplements our underlying Employee and Contractor Privacy Policy to ensure compliance with the law.
If you are an Employee or Contractor residing in California, you have rights regarding the how we collect and process your Personal Information under the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”). This Addendum will provide you with a summary of the categories of information we collect, the reasons that we collect each category of information, information regarding how we may disclose your personal information with third parties, and information regarding your rights under the CCPA. If you have any questions, please contact us via the Contact Us section, below.
Please note that we may not collect all categories of Personal Information about each Applicant/Employee/Contractor. For example, if the collection of Personal Information relates to a specific benefit that is not generally available, we would only collect that Personal Information from the Employees/Contractors who are eligible for and enroll in the benefit (and not for Applicants).
1. Information We Collect
In the preceding 12 months, we have collected the following categories (as defined by the CCPA) of Personal Information from Employees and Contractors:
| Categories (1) | Examples | Reasons for Collection |
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | Administer the Employee Relationship; Comply with Legal Obligations; Facilitate Communications and Efficiency; Provide Benefits; Ensure the Safety of Employees, Contractors, Facilities, and Property Ensure the Security of Our Systems |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories. | Administer the Employee Relationship; Comply with Legal Obligations; Facilitate Communications and Efficiency; Provide Benefits; Ensure the Safety of Employees, Contractors, Facilities, and Property Ensure the Security of Our Systems |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | Administer the Employee Relationship; Comply with Legal Obligations Facilitate Communications and Efficiency; Provide Benefits; Ensure the Safety of Employees, Contractors, Facilities, and Property |
| D. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | Facilitate Communications and Efficiency; Provide Benefits; Ensure the Security of Our Systems |
| E. Geolocation data. | Physical location or movements. | Facilitate Communications and Efficiency; Provide Benefits; Ensure the Safety of Employees, Contractors, Facilities, and Property |
| F. Sensory data. | Audio, electronic, visual, or similar information. | Administer the Employee Relationship; Comply with Legal Obligations Facilitate Communications and Efficiency; Provide Benefits; Ensure the Safety of Employees, Contractors, Facilities, and Property |
| G. Professional or employment-related information. | Current or past job history or performance evaluations. | Administer the Employee Relationship; Comply with Legal Obligations; Ensure the Safety of Employees, Contractors, Facilities, and Property |
| H. Inferences drawn of the consumer. | Inferences drawn from Personal Information identified above to create a profile about a consumer reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Facilitate Communications and Efficiency; Provide Benefits |
| I. Sensitive personal information | Personal information that reveals (a) Social Security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credential allowing access to an account; (c) precise geolocation; (d) racial or ethnic origin, religious or philosophical beliefs, or union membership; or (e) the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication. Some Sensitive Personal Information included in this category may overlap with other categories. | Administer the Employee Relationship; Provide Benefits; Ensure the Safety of Employees, Contractors, Facilities, and Property |
2. Sources of Personal Information
We collect the majority of the information that we process about you directly from you, through the applications or forms you submit and the information you provide at the time of hiring. In addition to the information that you provide to us, we may collect information about you from third parties, such as information from third parties that provide accreditation, educational institutions, benefits providers, and vendors that provide background checks or related information. Finally, we may automatically collect, store, or otherwise process information about you as you use our tools, systems, or resources.
3. How Your Personal Information Is Disclosed
In the preceding 12 months, we have disclosed the following categories of employment-related information with service providers, who are necessary for facilitating the employment relationship and providing you with benefits:
- A (Identifiers), B (Personal), C (Classification), D (Commercial), F (Internet), I (Professional), L (Sensitive).
We enter into written contracts with our service providers to ensure the privacy and security of your personal information. Under these contracts, we restrict the access to and processing of your personal information to that which is necessary for the purpose of the disclosure.
In certain circumstances, we may provide you with opportunities to sign up for certain benefits programs that involve the disclosure of your personal information to third party benefits providers. Any such program will be purely optional and based on your opt-in participation.
In the preceding 12 months, we have not sold or shared employment-related personal information to third parties for money or anything of monetary value.
We do not collect, process, or disclose sensitive personal information, as defined under the CCPA, for purposes other than those specified in Section 7027 of the CCPA regulations, or any employment related information regarding individuals under 16 years of age.
4. Individual Rights
The CCPA provides residents of California with a series of rights regarding the processing of their personal information. This section explains the scope of these rights and outlines how you may exercise them.
(a) Right to Know About Personal Information Collected, Disclosed, Shared, or Sold
You have the right to know whether we are processing your personal information and to request that we disclose the personal information we collect, use, and disclose to third parties. There are two types of Rights to Know requests that you can make: an Abbreviated Request and a Specific Information Request.
If you make a Right to Know (Abbreviated Request), you will receive the following information about you:
- Categories of personal information collected, sold, or shared;
- Categories of sources from which personal information is collected;
- Categories of third parties to whom the information is sold, shared or disclosed;
- Business or commercial purpose for collecting, sharing, or selling personal information;
- Categories of personal information disclosed for a business purpose and categories of persons to whom it was disclosed for a business purpose.
If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:
- Specific pieces of personal information collected about you.
We will provide this information to you free of charge, unless we determine that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.
There are certain exceptions to the Right to Know. We will state in our response if an exception applies.
(b) Right of Deletion
You have the right to request that we and our service providers delete personal information that we have collected about you by submitting a verifiable request. This right is subject to certain exceptions and does not require us to delete information that we are otherwise required to hold under applicable laws. We will state in our response if an exception applies.
(c) Right of Correction
You have the right to request that we correct inaccuracies in any personal information that we collect or process about you upon receipt of a verifiable request. When submitting a correction request, we request that you provide all of the information reasonably necessary to confirm that the accuracy of the correction request. This right is subject to certain exceptions. We will state in our response if an exception applies.
(d) Right to Opt-Out of the Sale or Sharing of Personal Information
You have the right to opt-out of the sale or sharing of your Personal Information by a business subject to certain laws and regulations. We do not sell or share information that we collect or process about you in your capacity as an Employee or Contractor.
To the extent you interact with the company outside of your capacity as an Employee or Contractor, please see our general online Privacy Policy, located at https://www.playboy.com/legal/privacy-policy.
(e) Right to Limit the Use and Disclosure of Sensitive Personal Information
You have the right to request that we limit the use and disclosure of your Sensitive Personal Information to only those purposes specifically authorized under California law. At this time, we do not process or disclose your Sensitive Personal Information for purposes that are not specifically authorized under California law. Should this change, we will notify you and provide you with an opportunity to limit our processing of your Sensitive Personal Information.
(f) Right to Non-Discrimination
We will not retaliate against any employee, applicant for employment, or independent contractor for exercising your rights under the CCPA. Additionally, we will not discriminate against you by: denying goods or services to you; charging different prices or rates for benefits, goods, or services, including through the use of discounts or other benefits or imposing penalties; providing a different level of quality of goods or services to you; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
(g) Submitting Requests
To submit a request, you may email us at [email protected] or call us at 833-350-1628.
We will provide responses to your requests free of charge unless exclusions apply, which we will identify in our response.
(h) Verifying Requests
To ensure the protection of your personal information, we must verify that the individual submitting a request is the contractor or employee to whom the request relates prior to processing the request. To verify your identity, we may request up to three pieces of personal information about you to compare against our records.
You will not be required to create an account with us to submit a verifiable request. However, you may be required to access an existing account to the extent accessing the account is necessary.
We will only use personal information provided in your request to verify your identity and will delete any information you provide after processing the request. We reserve the right to take additional steps as necessary to verify your identity where we have reason to believe a request is fraudulent.
(i) Authorized Agents
California residents may submit rights requests through the use of an Authorized Agent registered with the California Secretary of State to act on your behalf. If you choose to use an Authorized Agent, we require that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with us. Failure to do so may result in us denying your request.
5. Data Retention
We retain the information collected pursuant to this Addendum during the period of active employment of the employee or service relationship of the contractor, as well as during the post-employment period only as long as the personal information is required to serve its original purpose or as directed by applicable legislation or regulation. Personal Information that is no longer needed for its stated purpose will be destroyed, erased, or made anonymous.
We take appropriate measures to ensure that your Personal Information is processed and disposed of in a manner that maintains its confidentiality. All Personal Information disposal procedures, including the disposal of computerized data storage devices, are designed to ensure the complete destruction of Personal Information and eliminate the risk of subsequent unauthorized access or disclosure.
6. Changes to This Addendum
This California Privacy Notice is subject to occasional revision, and if we make any material changes in the categories of information we collect or the reasons we collect that information, we will notify you by sending you an e-mail and/or by prominently posting notice of the changes. This Notice will also be posted to the PLBY Intranet site, and you may reach out to People Ops for a copy of this Notice. You can review this Notice or consult the Privacy Policy at any time.
7. Contact Us
If you have any questions, comments, or concerns about this Addendum, please email us at [email protected] or call us at 833-350-1628.
[1] Categories of personal information as defined in Cal. Civ. Code § 1798.140(v).