Privacy Policy. 

Contractor Management Services, LLC DBA Openforce, (“Openforce” “we,” “our,” or “us”) values your privacy. This Privacy Policy (“Policy”) describes how Openforce collects, uses, discloses, and otherwise processes personal information described in this Policy, as well as the rights and choices individuals may have regarding such personal information. 

For additional information about the privacy choices you may have regarding your personal information, please review the Your Privacy Choices section below. If you are a resident of California, please refer to the California Privacy Rights and Notice of Collection section below for information about the categories of personal information we may collect and your rights under California privacy laws.

By using our Services (as defined below), you agree that your personal information will be handled as described in this Policy. Your use of our Services and any dispute over privacy, is subject to this Policy and our Terms and Conditions, available at https://oforce.com/terms-conditions, including their applicable terms governing limitations on damages and the resolution of disputes.

Table of Contents

1.    Scope

2.    Personal Information Collected

3.    How We May Use Personal Information

4.    Disclosures of Personal Information

5.    Cookies and Other Tracking Mechanisms

6.     Artificial Intelligence

7.     Your Privacy Choices

8.     External Links and Features

9.     Children’s Privacy

10.     Security

11.     Additional Information for Residents of Canada

12.     California Privacy Rights and Notice of Collection

13.     Other U.S. State Privacy Rights

14.     Changes to this Policy

15.     Contact Us

1.    Scope

Openforce provides solutions for contracting companies and independent contractors via its contractor management platforms known as Manage, Pay, Marketplace, and others. These solutions include, but are not limited to, contract administration solutions, payment and expense deduction solutions, online marketplace solutions, and insurance management solutions. This Policy applies to the personal data we collect in the course of our business.

Openforce acts in different ways when processing data. This Policy applies to the extent we process personal data on our own behalf as a “controller”.  It does not apply to personal information we process as a “processor” or “service provider” on behalf of our customers (contracting companies and independent contractors).   

Except as otherwise described below, Openforce acts as a “controller” and this Policy applies, to our online and offline personal information processing activities including, but not limited to: visitors to our website where this Policy is posted, including https://oforce.com  (the “Site”); individuals who sign up for, or create an account with us to access and use certain features of our services (subject to a separate End User Agreement); individuals who receive news, information, and marketing communications and materials from us; current, former, and prospective business partners, and service providers; and individuals who communicate or otherwise interact or engage with us or the services available through our Site, or other online services (collectively referred to as the “Services”). 

Openforce acts as a “processor” (or “service provider”) when customers use our Services for their contractor management, payment processing, sales, marketing, and other business activities. For example, where we process personal data required by customers in connection with the Services, such as driver’s license numbers, government ID images, telephone numbers, background check data, and banking information to facilitate payments, we process such data solely on behalf of and under the instructions of the customer in order to provide the Services. In these circumstances, we process such personal information in accordance with our agreements with our customers, including any applicable Data Processing Addendum. We do not use this data for our own purposes and retain it only as necessary to provide the Services, comply with applicable law, enforce our agreements, and as otherwise permitted by our customer agreements.

Additional Notices. 
Depending on how you interact or engage with us, we may provide you with additional or supplemental privacy notices. These additional notices will control to the extent there is a conflict with this Policy. For example, this Policy does not apply to the personal information we collect and process about job applicants and candidates for employment with Openforce, or to employees or contractors with whom we work.

2.    Personal Information Collected

We collect personal information directly from you, from third-party sources, and automatically through your use of the Services. To the extent permitted by applicable law, we may combine the personal information we collect from publicly available or third-party sources. The personal information we collect varies depending upon your use of our Services and our interactions with you.

Personal Information Collected Directly. We may collect the following personal information directly from you:

• Communications and Interactions. When you communicate or interact with us or our Services, including if you sign up for our newsletter, complete forms on our Site, contact our support team, interact with our social media pages, post a product review or testimonial, submit content to the Services, or otherwise engage with us or our sponsored content, we may collect your name, email address, phone number, or other similar identifiers, as well as your message, the nature of your inquiry and any other information you choose to provide.

• Account and Profile Information. When you sign in or create an account in connection with our Services, we may collect your name, email address, phone number, username and password as well as any other information used in connection with accessing your account or that you otherwise submit to us through your account. 

• Chat Function or Virtual Assistant. We may collect information you submit through our chat functions, virtual assistants, or other AI-enabled support features made available through the Services. We and any service providers we use to administer these features may monitor and record your communications with us and may maintain records of information you provide through these features.

• Professional Information. If you sign up to join any of our affiliate programs, we may collect certain contact details, account and profile information, company or professional-related information, and other similar information related to your registration for, or participation in, these programs. 

• Business Development Information. To assess and pursue potential business opportunities, we may collect and receive personal information about current, former, and prospective business partners, and vendors and service providers, including contact information and other similar identifiers, company and professional-related information, and communications records.

Personal Information Collected from Third Parties. We may collect and receive personal information from third party sources, such as business partners, operating systems, customers and other users, and service providers or other third parties who provide services or perform functions on our behalf. We may collect the following information from third-party sources:

• Lead and Prospect Information. We may receive lead information from third parties about prospective customers that may be interested in our Services. We may also engage with third parties to enhance or update our customer information. For example, we may receive certain personal information from data analytics and marketing providers for marketing and advertising purposes, and for purposes of reaching new customers.

• Integrated Service Information. We may use integrated services that allow you to access, register for, place orders, or otherwise interact with the Services. If you access or interact with our Services via these integrated services, we may collect or obtain certain personal information from these integrated services. For example, if you access our Services through a third-party service, or if you access a third-party service through our Services, we may collect information about you from that third-party service that you have made available via your privacy settings, or engagements with or through that third party. You should check the privacy settings and terms of engagement on each integrated service to better understand how your personal information may be used, disclosed, or otherwise processed by these parties.

Personal Information Collected Automatically. We may automatically collect or derive personal information related to your use of our Services, including through the use of cookies, pixel tags, and other similar technologies. This may include:

• Device and Browsing Information. When you use our Services, we may collect browser type, domain name, page views, access times, date/time stamps, operating system, language, device type, unique ID, Internet service provider, referring and exiting URLs, clickstream data, and other similar device and browsing information. 

• Activities and Usage. We also may collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, time spent within the Services, your interactions with us within the Services, and other similar activity and usage information.

• Location Information. We also may collect or derive general location information, such as through your IP address. Additionally, with your permission, we may collect geolocation information from your device. You may turn off location data sharing through your device settings.

• Derived or Inferred Information: We may also derive information about you based upon the information we collect automatically and from other sources.  For example, information (about your interests, estimated age, or other demographic information).

For more information about our use of cookies and other similar technologies, please see the Cookies and Other Tracking Mechanisms section below.

3.    How We May Use Personal Information

We may collect, use, disclose and otherwise process personal information for the following purposes:

• Services and Support. To enable our Services, communicate with you about your use of the Services, provide troubleshooting, technical support, and for similar support purposes, respond to your inquiries, fulfill your requests, and to otherwise run our day-to-day operations.

• Account Creation and Management. To enable account creation and management, including allowing you to create a profile and set preferences.

• Analytics and Improvement. To better understand how users access and use the Services, and for other research and analytical purposes, such as to evaluate, develop, and improve our Services and business operations, and for internal quality control and training purposes. Where permitted by applicable law, this may include using de-identified and aggregated information to improve our Services and AI-enabled tools.

• Communication. To respond to your questions, send you requested materials and newsletters, as well as information and materials regarding our Services, our offerings, the services and offerings of third parties, and offerings and business communications from your customers and prospective customers. We may also use this information to send administrative information to you, for example, information regarding the Services and changes to our terms and policies.

• Customization and Personalization. To tailor content we may send or display on or related to the Services, including to offer location customization and to otherwise personalize your experiences and offerings.

• Marketing and Advertising. For marketing, advertising, and promotional purposes. For example, to send you promotional information about our Services and those of third parties, including information about sales, discounts, and new offerings, as well any other information that you sign up to receive.

• Security and Protection of Rights. To protect the Services and our business operations, and to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use. 

• Compliance and Legal Process. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding, to respond to a subpoena, warrant, court order, or other legal process, or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.

• Auditing, Reporting, and Other Internal Operations. To conduct financial, tax and accounting audits, audits and assessments of our operations, including our privacy, security and financial controls, as well as for risk and compliance purposes. We may also use personal information to maintain appropriate business records and enforce our policies and procedures.

• General Business and Operational Support. To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions.

4.    Disclosures of Personal Information

We may disclose the personal information we collect for the purposes described above and as follows:

• Vendors and Services Providers. We may disclose personal information we collect to our service providers, processors, and others who perform functions on our behalf. These may include, for example, IT service providers, help desk providers, payment processors, analytics providers, third-party providers that support certain service features, including AI-enabled features, consultants, auditors, and legal counsel.

• Business Clients. Any information that we collect and process on behalf of, or related to, a business client, including your contracting company customer may be disclosed to the business client and otherwise shared as directed by that business client. 

• Other Users. We may disclose personal information to other users of the Services to support specific features, or when you request that we do so (implicitly or explicitly). For example, if you use features that allow you to post publicly on the Services, your information may be available to, and searchable by, others. 

• Third Party Marketing and Analytics Providers. We may disclose or make available personal information to third party platforms and providers that we use to provide or make available certain offerings, programs, tools, discounts, features or portions of the Services, or as necessary to respond to your requests. We may also make personal information available to third parties to support our marketing, analytics, advertising, and campaign management.

• Compliance and Legal Obligations. We may disclose personal information to third parties to comply with our legal and compliance obligations and to respond to legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. This may include regulators, government entities, and law enforcement as required by law or legal process. Additionally, it may include certain disclosures that we are required to make under applicable laws, such as the names of sweepstakes and contest winners.

• Security and Protection of Rights. We may disclose personal information where we believe it is necessary to protect the Services, our rights and property, or the rights, property and safety of others. For example, we may disclose personal information in order to (i) prevent, detect, investigate and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, and detect, investigate and take action in response to violations of our Terms and Conditions location here: https://oforce.com/terms-conditions . We may also disclose information, including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.

• In Support of Business Transfers. If we, or our affiliates are, or may be acquired by, merged with, or invested in by another company, or if any of our assets are, or may be, transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company.  We may also share certain personal information as necessary prior to the completion of such a transaction or corporate transactions such as financings or restructurings, to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for a transaction.

• Aggregate and Deidentified Information. Notwithstanding anything else in this Policy, we may use, disclose, and otherwise process aggregate and deidentified information related to our business and the Services with third parties for quality control, analytics, research, development, and other purposes. 

• Other Disclosures. We may disclose personal information in other ways not described above, but will notify you and, if necessary, obtain your consent.

5.    Cookies and Other Tracking Mechanisms

We use cookies, pixels, local storage objects, log files, APIs, and other mechanisms to automatically collect browsing, activity, device, and similar information within our Services and to target advertising and content. We may also engage third-parties or service providers to do the same. We use this information to, for example, analyze and understand how visitors interact with our Services; identify and resolve bugs and errors in our Services; assess, secure, protect, optimize and improve the performance of our Services; conduct marketing and analytics activities; and personalize content in our Services. To manage your preferences regarding cookies, targeted advertising, and other tracking mechanisms within our Services, please see Your Privacy Choices below.

Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within Service. 

Pixel Tags. Pixel tags (sometimes called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services, to, among other things, track the activities of users, help us manage content, and compile usage statistics. We may also use these in HTML emails we send to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Local Storage Objects. Local storage is a web storage mechanism that allows us to store data in a browser that persists even after the browser window is closed. Local storage may be used by our web servers to cache certain information in order to enable faster loading of pages and content when you return to our websites. You can clear data stored in local storage through your browser. Please consult your browser help menu for more information.

Third-Party Analytics and Tools. We use third party tools, such as Google Analytics, which are operated by third party companies. These third-party analytics companies may use cookies, pixels, and other similar tools to collect usage data about our Services in order to provide us with reports and metrics that help us evaluate usage of our Services and improve performance and user experiences. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Targeted Advertising. We work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services and others (“third-party ad companies”) to personalize content and display advertising within our Services, as well as to manage our advertising on third-party sites, mobile apps, and online services. We may share certain information with these third-party ad companies, and we and them may use cookies, pixels tags, and other tools to collect usage and browsing information within our Services, as well as on third-party sites, apps and services, such as IP address, location information, device ID, cookie and advertising IDs, and other identifiers, as well as browsing information.  We and these third-party ad companies use this information to provide you more relevant ads and content within our Services and on third-party sites and apps, and to evaluate the success of such ads and content.

Cross-Device Tracking. We and our third-party providers may use the information we collect within our Services and on other third-party sites and services to help us and these third parties to identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.).

Custom Lists and Matching. We may share or make available certain customer list information (such as your name, email, and other contact information) with third parties (i) so that we can better target ads and content to you across third party sites, platforms and services, and (ii) in some cases, these third parties may help us to enhance our customer lists with additional demographic or other information, so we can better target our advertising and marketing campaigns.  

6.     Artificial Intelligence

Certain features of our Services may use artificial intelligence, machine learning, or other automated tools to support functions such as onboarding assistance, document classification and validation, compliance support, workforce oversight, reporting, and similar operational activities. For example, we may offer AI-enabled tools that help guide independent contractors through onboarding and compliance document submission, support client administrator oversight and reporting, or automate the classification, validation, and routing of documents during enrollment. These tools are designed to assist, and not to replace, our Services and personnel. Where an AI-enabled tool is used in connection with a decision that affects your onboarding eligibility, the steps or clearances required of you, your access to projects, or the timing of your contracting or onboarding with your contracting company customer, a member of the contracting company’s team reviews the matter and makes the final determination, and that person may override or disregard any output of the tool. You may request a human from your contracting company customer review any such determination, request an explanation of the logic involved, and correct inaccurate personal information used in the process, as described in the Your Privacy Choices section below. We may use third-party providers to support these capabilities. 

We may use information collected through your use of the Services, including personal information, to develop, train, evaluate, and improve these tools and our Services. We use commercially reasonable efforts to de-identify or aggregate personal information before using it for these purposes, except where identifiable information is necessary for a tool to function as intended. We do not use your personal information to train generally available third-party artificial intelligence models. You may opt out of the use of your personal information for training and model-improvement purposes as described in the Your Privacy Choices section below. An opt-out applies going forward. Where personal information has already been used in a completed training process, removing it from a model that has already been trained may not be technically feasible; however, we will exclude your personal information from future training.

Identity Verification and Biometric Information. To confirm that you are who you say you are, to prevent fraud, and to meet your contracting company customers' compliance obligations, we use a third-party identity verification provider called Persona to verify identity documents you submit (such as a driver's license or other government-issued identification) and, where you consent, to perform a liveness check confirming that a live person is present, and to compare a self-captured photograph or short video of your face against the photograph on that document. Persona will store your biometric information, not Openforce. This process involves the creation of a facial template or similar biometric identifier, which is biometric information under law including the Illinois Biometric Information Privacy Act, the Texas Capture or Use of Biometric Identifier Act, Washington's biometric identifiers statute (RCW 19.375), and the biometric provisions of other state privacy laws.

We collect, use, and disclose biometric information only for the purpose of verifying your identity and detecting and preventing fraud. We do not sell biometric information, nor do we disclose it for cross-context behavioral advertising, and we do not use it to train artificial intelligence models. Where required by applicable law, we will provide you with a separate written notice and obtain your written consent before any biometric identifier is captured, and you may decline. If you decline, we will tell you what alternative methods of verifying your identity are available to you. 

Persona destroys your biometric information 1 year after identity verification. 

You can learn more about Persona’s privacy practices here: https://withpersona.com/legal/privacy-policy/

7.     Your Privacy Choices

We make available several ways that you can manage your privacy choices and submit privacy requests related to your personal information. Some of these choices are browser and device specific, which means that you need to set the preference for each browser and device you use to access our Services. In addition, if you delete or block cookies, you may need to reapply these preferences to each browser and/or device used to access our Services. 

These options include:

• Account and Profile Information. You can review and update some of the personal information we maintain about you by logging into your account and updating your profile information directly within our Services.

• Artificial Intelligence, Profiling, and Automated Decisions. Where we use AI-enabled tools in connection with a decision by your contracting company customer that produces legal or similarly significant effects concerning you, including a decision affecting your contracting eligibility or your access to business opportunities from your contracting company customers, you may (i) opt out of that use, (ii) request information about the logic involved, (iii) request that a qualified person from your contracting company customer review the decision, and (iv) request correction of inaccurate personal information used in the process. You may also opt out of the use of your personal information to train or improve our AI-enabled tools. To exercise any of these choices, email us at privacy@oforce.com.

• Marketing Communications. We may send periodic promotional emails, text (SMS), or other similar communications to you, in accordance with applicable law. You may opt-out of these communications by following the instructions provided to you in the communication. If you opt-out of receiving promotional content from us, we may still send you communications about your account or any services you have requested or received from us. Additionally, you can manage your communication preferences in your account settings.

• Push Notifications. You can manage the type of push notifications you receive from us by adjusting your device settings or by modifying the settings within our Services.

• Cookie Settings. To prevent cookies from tracking your activity on our Site or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The "Help" portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Site who disable cookies will be able to browse the Site, but some features may not function.

• Browser Signals/Do Not Track. Our Site currently does not respond to “Do Not Track” signals. However, where required by applicable law, we honor opt-out preference signals, such as the Global Privacy Control (“GPC”), as described below. You may also disable certain tracking as discussed in this section (e.g., by disabling cookies), and you may opt out of targeted advertising by following the instructions in the Industry Ad Choice Programs section below.

• Industry Ad Choice Programs. You can also control how participating third-party ad companies use the information that they collect about your visits to our Site and those of third parties, in order to display more relevant targeted advertising to you. If you are in the U.S., you can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at aboutads.info/choices (Digital Advertising Alliance). Opting out of participating third party ad networks does not opt you out of being served advertising. You may continue to receive generic or "contextual" ads on our Site. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.
  
  

8.     External Links and Features

Our Service may contain links to third-party websites or features or provide certain third-party connections or integrated services. Any access to and use of such linked websites, features, or third-party services is not governed by this Policy. We are not responsible for the information practices of such third parties, including their collection, use, and disclosure of your personal information. You should review the privacy policies and terms for any third parties before proceeding to those websites or using those third-party features or services.

9.     Children’s Privacy

Our Services are not directed to individuals under 18, and we do not knowingly collect personal information from minors under the age of 18. If you are a parent or legal guardian and you believe we have collected your child’s information in violation of applicable law, please contact us using the contact information in the Contact Us section below.

10.     Security

We have implemented safeguards intended to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

11.     Additional Information for Residents of Canada

Your rights under PIPEDA and, where applicable, Quebec Law 25 include: (i) access to the personal information we hold about you; (ii) the right to request correction of inaccurate or incomplete personal information; (iii) the right to withdraw your consent to our collection, use, or disclosure of your personal information, subject to legal or contractual restrictions; (iv) the right to file a complaint with the Office of the Privacy Commissioner of Canada or the applicable provincial commissioner; and (v) where a decision about you is based exclusively on automated processing, the right to be informed of that fact, to be informed of the personal information used and the principal factors that led to the decision, to submit observations, and to have the decision reviewed by a person. Where we use a biometric process to verify or confirm your identity, we will obtain your express consent. To exercise any Canadian rights, contact us at privacy@oforce.com.

12.     California Privacy Rights and Notice of Collection

This section of the Policy provides additional information for California residents and describes our information practices pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act 2020, and its implementing regulations (the “CCPA”). Depending on how you interact or engage with us, we may provide you with other privacy notices with additional details about our privacy practices. 

This section applies to “personal information” as defined in the CCPA, whether collected online or offline. This section does not address or apply to our handling of personal information that is exempt under the CCPA. 

Categories of Personal Information Collected and Disclosed. Depending on how you use the Services, we may collect (and have collected in the prior 12 months) the following categories of personal information:

We have also disclosed the above categories of personal information to our service providers and Business Clients for business purposes in the past 12 months.

Source of Personal Information. We generally collect personal information from the following categories of sources:

• Directly from You

• Cookies and Other Tracking Technologies

• Third Parties (such as service providers and other users)

Purposes of Collection, Use, and Disclosure. As described in the How We May Use Personal Information section above, in general, we collect and otherwise process personal information for the following business or commercial purposes, or as otherwise directed or consented to by you:

• Services and support;

• Account creation and management;

• Analytics and improvement;

• Communication;

• Customization and personalization;

• Marketing and advertising;

• Security and protection of rights; 

• Compliance and legal process;

• Auditing, reporting, and other internal operations; and

• General business and operational support.

Sensitive Personal Information. We collect and use sensitive personal information, including government identifiers and biometric information used to verify your identity, only for the purposes authorized by the CCPA — including performing the services you or your client requested, verifying your identity, and preventing, detecting, and investigating fraud and security incidents — and we do not use or disclose it to infer characteristics about you.

Retention of Personal Information. We retain your personal information for as long as needed or permitted, based on the reason we obtained it (consistent with applicable law). When deciding how long to keep your personal information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period before we can delete them) or whether we have taken any legal positions (e.g., issued any legal holds or otherwise need to preserve the information). Rather than delete your data, we may also deidentify it by removing identifying details. Where we have committed to maintaining and using personal information in a deidentified form, we agree not to reidentify deidentified data except as permitted by applicable law.

Sales and Sharing of Personal Information. The CCPA defines "sale" as disclosing or making available personal information to a third-party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third-party for purposes of cross-contextual behavioral advertising.

While we do not disclose personal information to third parties in exchange for monetary compensation, we may be considered as “selling” or “sharing” personal information under the CCPA because of our use of third-party ad or analytics cookies and other tools. We “sell” or “share” the following categories of personal information: identifiers, and Internet or other electronic network activity information. We disclose these categories to third-party vendors and service providers, advertising networks, analytics providers, and social networks for purposes of marketing and advertising. Our Services are not directed to individuals under 18. We do not knowingly collect personal information from minors under 18 or knowingly sell or share personal information about individuals we know are under the age of 16.

California Privacy Rights. The CCPA provides California residents with specific rights regarding personal information. Subject to certain conditions and exceptions, California residents have the following rights with respect to their personal information:

1.    Right to Know (Access & Portability). You have the right to request: 

(i)    the categories of personal information we collected about you;

(ii)    the categories of sources from which the personal information is collected; 

(iii)    our business or commercial purposes for collecting, selling, or sharing personal information; the categories of third parties to whom we have disclosed personal information; and 

(iv)    a copy of the specific pieces of personal information we have collected about you.

2.    Right to Correct. You have the right to request we correct inaccurate personal information.

3.    Right to Delete. You have the right to request we delete your personal information.

4.    Right to Opt-Out of Sales and Sharing. You have the right to opt out of “sales” and “sharing” of your personal information as those terms are defined under the CCPA. To exercise these rights, please use the Do Not Sell or Share My Personal Information/Your Privacy Choices link at the bottom of our website.

You also have the right to opt out of “sales” and “sharing” of your personal information using an opt-out preference signal. If our site detects that your browser or device is transmitting an opt-out preference signal, such as the Global Privacy Control (“GPC”), we will opt that browser or device out of the use of cookies or other tools on our site that result in a “sale” or “sharing” of your personal information. If you come to our site from a different device or from a different browser on the same device, or if you clear your cookies, you will need to opt out again, or use an opt-out preference signal, for that browser and/or device as well.

5.    Right to Limit Use and Disclosure. We use and disclose sensitive personal information only for purposes the CCPA permits without a right to limit, including performing the services requested, verifying your identity, and preventing and investigating fraud and security incidents. If you believe we have used your sensitive personal information for any other purpose, you may email us at privacy@oforce.com and we will honor your request to limit that use.

6.    Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.

Exercising Your Privacy Rights. If you are a California resident and would like to exercise your CCPA rights, you may email us at privacy@oforce.com.

Verification. Before responding to your request, we must first verify your identity using the personal information you recently provided to us. You must provide us with your full name and email address. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

Authorized Agents. You may designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

California Shine the Light Law. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email us using the Contact Us information below, and include in your request a current California address and your attestation that you are a California resident.

13.     Other U.S. State Privacy Rights

If you are a resident of Colorado, Connecticut, Florida, Montana, Oregon, Texas, Virginia, Utah, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Kentucky, Indiana, or Rhode Island, you may have the following rights, depending on the state in which you reside. The exact scope of these rights may vary by state. You may exercise such rights by emailing us at privacy@oforce.com.

Right to Know. You have the right to know and see what personal data we have collected about you.

Right to Data Portability. You have the right to obtain a copy of your personal information that you previously provided to us in a portable and, when feasible, readily usable format, where the processing is carried out by automated means.

Right to Correct. Residents of Colorado, Connecticut, Florida, Montana, Oregon, Texas, Virginia, Delaware, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Kentucky, Indiana, and Rhode Island have the right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information.

Right to Delete. Residents of Colorado, Connecticut, Florida, Montana, Oregon, Texas, Virginia, Delaware, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Kentucky, Indiana, and Rhode Island have the right to request that we delete personal information provided by, or obtained about, you.

Right to Opt Out of Processing. You have the right to opt out of the sale of your personal information and/or the processing of your personal information for purposes of (i) targeted advertising (excluding Iowa) and (ii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you (residents of Colorado, Connecticut, Florida, Montana, Oregon, Texas, Virginia, Delaware, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Kentucky, Indiana, and Rhode Island). As of the date of this Privacy Policy:

• We do process personal information for the purposes of targeted advertising.

• We do not sell your personal information in exchange for monetary consideration.

• We do use AI-enabled tools that process your personal information to produce outputs used to support decisions affecting your contracting eligibility with your contracting company customers, the steps required of you, your access to projects, and your contracting timing. A member of the contracting company customer makes the final determination in each case. To the extent this constitutes profiling in furtherance of decisions that produce legal or similarly significant effects, you may opt out, request an explanation of the logic involved, request human review, and correct inaccurate personal information, as described in the Your Privacy Choices section above.

Residents of California, Colorado, Connecticut, Montana, Nebraska, New Hampshire, and Texas may also use an opt-out preference signal, such as the Global Privacy Control (“GPC”), to opt out of the “sale” or “sharing” of your personal information for targeted advertising for each participating browser system that you use.

Right to limit use or disclosure of sensitive personal information. You may have the right to either limit (opt-out of) or require consent to process sensitive personal data. Florida residents have the right to opt out of the collection or processing of sensitive data and to opt out of the collection of personal data collected through the operation of a voice recognition or facial recognition feature.  

Right to Nondiscrimination. The right to not be discriminated against for exercising the aforementioned rights.

Appeal a denial of your request. Some states provide additional rights to their residents. If we decline to process your request, you may have the right to appeal our decision. You can do so by replying directly to our denial or emailing privacy@oforce.com.

NEVADA RESIDENTS

If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of certain personal information. Please note, we do not currently sell any of your personal information triggering Nevada’s opt-out requirements, nor do we plan to do so in the future. However, you can submit a request to opt-out of future sales, as defined by Nevada law, by contacting us at privacy@oforce.com (please include “Opt-Out Request Under Nevada Law” in the subject line and body of your message).

14.     Changes to this Policy

This Policy is current as of the effective date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any updates to this Policy on this page. If we make material changes to how we collect, use, or disclose the personal information we have previously collected, we will endeavor to provide you prior notice as required by applicable law, such as by emailing you or posting prominent notice on our website or within the Services.

15.     Contact Us

If you have any questions or concerns regarding this Policy or our privacy practices, you may contact us at privacy@oforce.com.