Effective Date: June March 1, 2025

This California Employee and Job Applicant Privacy Policy (the "Employment Privacy Policy") applies solely to California residents whose personal information is collected by The Pasha Group, and/or any of its affiliated companies, ("Pasha", "we," "us," or "our") in the following situations:

  • In connection with a job application;
  • In connection with being an employee of, owner of, director of, or officer of Pasha (collectively referred to as "Workforce Member"), to the extent that the personal information is collected and used by Pasha solely within the context of such role or former role as a Workforce Member of Pasha.
  • In connection with emergency contact information of the Workforce Member, to the extent that the personal information is collected and used solely within the context of having an emergency contact on file.
  • Personal information that is necessary for the business to retain or to administer benefits for another natural person relating to the Workforce Member to the extent that the personal information is collected and used solely within the context of administering those benefits.

We refer to such California residents as "you" or "your" throughout this Employment Privacy Policy.

This Employment Privacy Policy is intended to comply with the California Consumer Privacy Act of 2018 ("CCPA") and any terms defined in the CCPA have the same meaning when used in this Employment Privacy Policy.

This Employment Privacy Policy does not address our treatment of certain of your personal information that is excluded from CCPA's scope.

Personal Information We May Collect

For the purposes of this Employment Privacy Policy, Pasha generally collects the following categories of your personal information:

  • 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 or other government ID number, passport number, employee ID number, or other similar identifiers.
  • 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, 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.
  • C. Characteristics of protected classifications under California or federal law:
    Age, race, color, ancestry, national origin, immigration status, citizenship, marital status, medical condition, physical or mental disability, sex, gender, pregnancy or childbirth and related medical conditions, or veteran or military status.
  • D. Audio, electronic, visual, or similar information:
    Pictures (e.g., photographs on government identification cards or passwords or photographs from Pasha's social or business events or photographs taken for employee ID purposes), video conferences, video recordings (e.g., videos captured for security purposes), telephone calls (e.g., if your tasks as a Workforce Member require you to participate in telephone calls that may be recorded).
  • E. Professional or employment- related information:
    Current or past job history or performance evaluations, professional license information and bar standings; corporate expense information, salary information, drug screen results, fitness-for-duty or pre- employment physical exam results, tax rates, retirement fund information, compensation information, bonus information, benefits information, or stock option information.
  • F. Education Information:
    Schools attended, degrees and certificates awarded or in process, grades achieved in education courses, vocational trainings and certifications and transcript information.
  • G. Geolocation:
    Information collected through GPS technology. data.
  • H. Biometric:
    Data Biometric data that may be collected by a service provider to identify Pasha Workforce Members.

Sensitive Personal Information

Pasha may collect sensitive personal information such as sensitive personal identifiers, sensitive protected characteristics, contents of communications and precise geolocation. Sensitive personal information is not used by us for any purpose other than as necessary and as disclosed in this Employment Privacy Policy.

How We Collect Your Personal Information

Pasha obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, we collect the personal information you provide to us in connection with your job application or application for Pasha benefits. We will also collect the personal information you provide to us throughout the duration of your employment with Pasha.
  • From your beneficiaries and dependents. For example, your beneficiaries and dependents may provide us with your personal information in the course of their receipt of benefits provided or administered by us. 
  • From our service providers. For example, we may collect your personal information from a service provider that conducts background checks for us. We may also receive your personal information from service providers who help us run our business, including payroll, software and travel management providers. 
  • From Workforce Members. For example, if a Workforce Member provides your personal information in connection with an application for Pasha-provided benefits. 
  • From benefits administrators. For example, we may receive personal information about you from the companies that administer the benefits plans offered by Pasha. 
  • From third parties. For example, a third-party recruiter may provide your personal information to us in connection with our search for a Workforce Member. 
  • Automatically.For example, we may automatically collect personal information from the computers and other devices that you use in the course of being a Workforce Member. We may also collect such personal information from the electronic platforms we provide to you, including Pasha's email, word processing and "chat" platforms.

How We Use Your Personal Information

We may use the categories of your personal information listed above for one or more of the following purposes:

  • To support our organizational and operational functions.
  • To provide services and benefits to you as a Pasha Workforce Member.
  • To properly administer our workforce and its benefits and compensation programs.
  • To evaluate your candidacy or performance as a Pasha Workforce Member.
  • To respond to law enforcement requests and as required or permitted by applicable law,
  • court order, subpoena, or governmental regulations.
  • To safeguard our information technology infrastructure, detect security incidents, conduct investigations and take other actions as required or permitted by applicable law to protect and defend Pasha, our affiliates and subsidiaries, and our Workforce Members, including in connection with legal proceedings.
  • As directed by you.

How We Share Your Personal Information

In connection with Pasha's collection and use of your personal information as described above, Pasha may disclose your personal information in the following ways:

  • With our subsidiaries and affiliates.
  • On our online platforms and/or in "Pasha People". For example, this may include sharing
  • pictures of you on our website and our social media pages.
  • With our service providers and benefits administrators.
  • With our auditors, actuaries, accountants, attorneys, governments or other third parties, as required or permitted by applicable law.
  • As directed by you.
  • To comply with the law or to protect our organization. This includes responding to court orders or subpoenas, or defending Pasha in a lawsuit. This may also include sharing your personal information if a government agency or investigatory body requests this data. We may share also your personal information when we are investigating a security incident, allegation, or a potential fraud or violation of law.
  • With any successors to all or part of our organization. For example, if we merge with, acquire or are acquired, or sell part of organization to another entity. This may include an asset sale, corporate reorganization or other change of control.

Security of Personal Information

Pasha uses reasonable security procedures and practices appropriate to the nature of the personal information collected and stored by us to protect the security of the personal information. Our security measures include industry-standard, reasonable physical, technical and administrative measures to prevent unauthorized access to, or disclosure of, your information. No method of transmission over the Internet or electronic storage is guaranteed to be secure, we cannot guarantee the absolute security of your information.

Retention of Personal Information

Pasha will retain your personal information as required to support our organizational and operational functions, provide services and benefits to Pasha Workforce Members, properly administer our workforce and its benefits and compensation programs, ensure that we comply with our legal obligations, are able to resolve disputes, and to enforce our legal agreements and policies. Pasha will not retain your personal information any longer than is reasonably necessary to meet these requirements.

Data Requests

  • a. Information Requests
    If Pasha has collected your personal information, you have the right to request that Pasha provide the following data: (i) the categories of personal information collected about you; (ii) the categories of sources from which the personal information about you was collected; (iii) the business or commercial purpose for collecting the personal information; (iv) the business or commercial purpose for disclosing the personal information to a third party; (v) the categories of personal information disclosed to third parties for a business purpose; (vi) the categories of third parties to whom your information has been disclosed; and (vii) the specific pieces of personal information collected about you.
  • b. Deletion and Correction Requests
    You may request that Pasha: (i) delete your personal information; and (ii) correct any inaccurate personal information maintained by Pasha about you.
  • c. Submitting Data Requests
    California Residents can exercise these rights by submitting a data request to us. To submit a data request, click here, or call +1 (888) 836-5713.
  • d. Request Verification
    We may ask you to confirm the details of personal information we already have on file for you in order to verify your identity before completing our response to your data request.
  • e. Authorized Agent Request
    Your authorized agent may submit a data request on your behalf. We will require the authorized agent to verify your identity and provide reasonable evidence of your authorization to submit the request.

Non-Discrimination

Pasha will not discriminate against you in any way for exercising your rights under this Privacy Policy or any applicable privacy laws.

Changes to Our Employment Privacy Policy

We may update this Employment Privacy Policy from time to time by posting the new Employment Privacy Policy on this webpage and updating the effective date at the top of this Employment Privacy Policy. You are advised to review this webpage periodically for any changes to the Employment Privacy Policy.

Contact Information

If you have any questions or comments about this Employment Privacy Policy, the ways in which Pasha collects, uses and shares your personal information, please do not hesitate to contact your human resources administrator, or privacy@pashanet.com.