Privacy Notice

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HR Privacy Notice for California Residents

Delta Star, Inc. [and its subsidiaries and affiliates] (collectively, “Delta Star,” “we,” “us,” or “our”) respect[s] your concerns about privacy. This HR Privacy Notice for California Residents (“HR Privacy Notice”) describes the types of personal information we collect about California residents who are (1) Delta Star employees, owners, directors, officers or contractors (collectively, “Delta Star Personnel”), (2) emergency contacts of Delta Star Personnel, and (3) individuals related to Delta Star Personnel for whom Delta Star administers benefits (collectively with Delta StarPersonnel, “HR Covered Individuals”). 

Delta Star Personnel are responsible for providing this HR Privacy Notice to any HR Covered Individual whose personal information is provided to Delta Star by Delta Star Personnel. Certain terms used in this HR Privacy Notice have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020), and its implementing regulations (collectively, the “CCPA”).

Notice of Collection and Use of Personal Information

Delta Star may collect (and may have collected during the 12-month period prior to the Last Updated date of this HR Privacy Notice) the following categories of personal information about HR Covered Individuals:

  • Identifiers: identifiers, such as real name, alias, postal address, unique personal identifier (such as device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; employee number, unique pseudonym, user alias/ID; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, employee account name, Social Security number, driver’s license number, passport number, date of birth, and other similar identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, other financial information, medical information, and health insurance information
  • Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender expression, sexual orientation, marital status, medical condition, ancestry, disability, citizenship status, and military and veteran status
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding HR Covered Individuals’ interaction with websites or applications 
  • Geolocation Data
  • Sensory Information: audio, electronic, visual, and similar information 
  • Employment Information: professional or employment-related information, such as compensation, benefits and payroll information (such as salary-related information, tax-related information, benefits elections and details regarding leaves of absence), information relating to an HR Covered Individual’s position (such as job title and job description), performance-related information (such as evaluations and training certificates), talent management information (such as résumé information, occupation details, education details, certifications, professional association affiliations, historical compensation details, previous employment details, behavioral-based assessments, professional social media information, pre-employment screening details, and background check information, including criminal records information), emergency contact information, and dependent information
  • Inferences: inferences drawn from any of the information identified above to create a profile about HR Covered Individuals reflecting their preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

Delta Star may use (and may have used during the 12-month period prior to the Last Updated date of this HR Privacy Notice) HR Covered Individuals’ personal information for the purpose of carrying out and supporting HR functions and activities, including the uses described below. In addition to general HR purposes, we list below relevant “business purposes” as they are described in the CCPA.

  • Managing work activities and Delta Star Personnel generally, including: recruiting; performing background checks; determining suitability for employment or promotion; determining physical and/or mental fitness for work; managing onboarding activities; reviewing and evaluating performance; determining eligibility for and processing salary increases, bonuses, and other incentive-based compensation; providing references; managing attendance, absences, leaves of absence, and vacations; administering payroll services; reimbursing expenses; administering health, dental, and other benefits; accommodating disabilities or illnesses; training and talent development; facilitating employee relocations and international assignments; making travel arrangements; securing immigration statuses; monitoring staff; creating staff directories; managing headcount, work planning, and office allocation; investigating suspected misconduct or non-performance of duties; managing disciplinary matters, grievances, and terminations; reviewing staffing decisions; providing access to facilities; managing communications and relations with HR Covered Individuals; and carrying out obligations under employment contracts. 
  • Ensuring business continuity; protecting the health and safety of Delta Star Personnel and others; safeguarding, monitoring, and maintaining our IT infrastructure, office equipment, facilities, and other property; providing technical support; detecting or preventing theft or fraud, or attempted theft or fraud; and facilitating communication with HR Covered Individuals in an emergency. 
  • Operating and managing our IT, communications systems and facilities, and monitoring the use of these resources; performing data analytics; improving our services; allocating and managing company assets and human resources; strategic planning; project management; compiling audit trails and other reporting tools; maintaining records relating to business activities, budgeting, and financial management; managing mergers, acquisitions, sales, reorganizations or disposals, and integration with business partners. 
  • Complying with legal requirements, such as tax, record-keeping and reporting obligations; conducting audits, management and resolution of health and safety matters; complying with requests from government or other public authorities; responding to legal process, such as subpoenas and court orders; pursuing our legal rights and remedies; defending litigation and managing internal complaints or claims; conducting investigations; and complying with our internal policies and procedures. 
  • Performing services, including: maintaining or servicing accounts; providing services to HR Covered Individuals; verifying HR Covered Individuals’ information; or providing similar services. 
  • Auditing, including auditing compliance.
  • Certain short-term, transient uses.
  • Helping to ensure security and integrity. 
  • Debugging to identify and repair errors that impair existing intended functionality.
  • Undertaking internal research for technological development and demonstration.
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance such services or devices.

Delta Star does not collect or process sensitive personal information with the purpose of inferring characteristics about HR Covered Individuals.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Retention of Personal Information

We retain personal information about HR Covered Individuals for the time period reasonably necessary to achieve the purposes described in this HR Privacy Notice, or any other notice provided at the time of collection, unless a longer retention period is required or permitted by applicable law, taking into account applicable statutes of limitation and our records retention requirements and policies.

Sources of Personal Information

During the 12-month period prior to the Last Updated date of this HR Privacy Notice, Delta Star may have obtained personal information about HR Covered Individuals from the following categories of sources:

  • Directly from HR Covered Individuals;
  • HR Covered Individuals’ devices;
  • Family or friends who provide information about HR Covered Individuals, for example, in connection with our provision of benefits or services;
  • Our affiliates and subsidiaries;
  • Service providers, contractors and other vendors who provide services on our behalf; 
  • Customers or business partners who provide information about HR Covered Individuals, such as when they provide feedback;
  • Government entities; 
  • Social networks; and
  • Data brokers, such as credit bureaus, credit reporting service providers, and background check services.

Disclosure of Personal Information

During the 12-month period prior to the Last Updated date of this HR Privacy Notice, Delta Star may have disclosed the following categories of personal information about HR Covered Individuals for the business purposes listed above to service providers and contractors: 

  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Inferences

Delta Star does not sell or share for cross-context behavioral advertising purposes the personal information of HR Covered Individuals. 

California Consumer Privacy Rights

If you are an HR Covered Individual, you have certain choices regarding your personal information, as described below.

  • Access: You have the right to request, twice in a 12-month period, that we disclose to you the categories of personal information we have collected about you, the categories of sources from which the information was collected, the business or commercial purposes for collecting the information, the categories of third parties to whom we disclosed your personal information, and the specific pieces of personal information we have collected about you. 
  • Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate. 
  • Deletion: You have the right to request that we delete certain personal information we have collected from you.

How to Submit a Request. To submit an access, correction or deletion request, please call 1-800-368-3017.  To submit a request on behalf of an HR Covered Individual as an authorized agent, please email us at humanresources@deltastar.com with the subject line “Authorized Agent Request”.  

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may verify your identity by requiring you to sign in to your account with us. If you do not have an account and you request access to, or correction or deletion of, your personal information, we may require you to verify your email address or certain of your information in our records, such as your [employment dates with Delta Star, prior payments from Delta Star, or other details about your work for or relationship to Delta Star.]  In addition, if you do not have an account and you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the HR Covered Individual whose personal information is the subject of the request.

Additional Information. You have the right not to be retaliated against if you choose to exercise any of your rights under the CCPA. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

How To Contact Us 

If you have any questions regarding this HR Privacy Notice or our privacy practices, please contact us at
humanresources@deltastar.com.