Version 2.0 – Effective Date 10/9/2020

Populus Financial Group, Inc.
CALIFORNIA EMPLOYEE PRIVACY POLICY

The State of California requires that we provide privacy information for individuals that are residents of California. If you are not a resident of California, you can disregard this document.

For California residents, here is a summary of what you will learn from this privacy policy:

  1. Personal Information We Collect
    1. Personal Information Does Not Include
    2. Categories of Personal Information Collected
    3. How We Obtain Your Personal Information
    4. How We Use Your Personal Information
    5. Who We Share Your Personal Information With
    6. Sale of Personal Information
  2. Changes to this California Privacy Policy
  3. How to Contact Us

Below is the legal information we are required to share:

This California Employee Privacy Policy supplements the employment-related policies and procedures of Populus Financial Group, Inc., and our family of brands including ACE Cash Express and PORTE Banking ("we," "us," or "our") included in MyHR and applies to our job applicants, employees, owners, directors, officers, and contractors who are acting in such a capacity ("personnel position") and who reside in the State of California ("consumers" or "you"). We provide these disclosures to comply with the California Consumer Privacy Act of 2018 ("CCPA"). Any terms defined in the CCPA have the same meaning when used in this California Employee Privacy Policy.

  1. PERSONAL INFORMATION WE COLLECT

    We collect information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular consumer ("personal information").

    1. Personal Information Does Not Include

      Personal information does not include:

      • Publicly available information from government records
      • De-identified or aggregated consumer information
      • Information excluded from the CCPA, including:
        • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 ("HIPAA") and the California Confidentiality of Medical Information Act ("CMIA") or clinical trial data;
        • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act ("FCRA"), the Gramm-Leach-Bliley Act ("GLBA") or California Financial Information Privacy Act ("FIPA"), and the Driver's Privacy Protection Act of 1994 ("DPPA").
    2. Categories of Personal Information Collected

      In the last 12 months, we collected the following categories of personal information:

      • "Identifiers" such as name, alias, address, unique identifier, internet protocol address, email address, account number, Social Security Number, or government identification number;
      • "Other Personal Information" such as 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, or medical information. Some personal information included in this category may overlap with other categories;
      • "Protected Characteristics" under California or federal law for classifications such as 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, or veteran or military status;
      • "Biometric Information" such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, or gait;
      • "Internet or Network Activity" such as browsing history, search history, information on a consumer's interaction with a website, application, or advertisement;
      • "Geolocation Data" such as physical location or movements;
      • "Sensory Data" such as audio, electronic, or visual information;
      • "Professional or Employment Related Information" such as current or past job history or performance evaluations; and
      • "Non-public education information" (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) such as education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
    3. How We Obtain Your Personal Information:
      Directly from you

      You enter or provide us with information in person, online, by email, by phone, by document upload, during COVID-19 return to work procedures

      For example, when you apply for a job or update your information on file

      Directly and indirectly from you based on activity on our website or network For example, from internet browsing or network usage details collected automatically
      From vendors that interact with us in connection with your personnel position For example, credit reporting agencies from which we check your credit in connection with a submitted employment application, vendors that provide background search results, or vendors that assist in protecting you and us from fraud and identity theft
    4. How We Use Your Personal Information:

      We may use or disclose the personal information we collect for one or more of the following purposes:

      1. Performing services on our behalf, including but not limited to:
        1. To fulfill or meet the reason for which the information is provided;
        2. To provide you with a decision on an employment application;
        3. To provide you with employment benefits; and
        4. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
      2. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
      3. Auditing related to a current interaction with you;
      4. Undertaking activities to verify or maintain the quality of a service or device controlled by us, and to improve, upgrade, or enhance our services;
      5. For short-term, transient uses; and
      6. To reduce the risk of spreading COVID-19 or other diseases in the workplace, including contract tracing as needed or required by law.

      We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

    5. Who We Share Your Personal Information With:

      We may disclose your personal information to a service provider or third party for a business or commercial purpose. When we disclose personal information to a service provider, we enter into a contract that describes the purpose and requires the service provider to both keep personal information confidential and not use it for any purpose except performing the services described in the contract or as allowed under the CCPA. Examples of who we share with include:

      • Service providers, including but not limited to payroll processors, insurance providers, human capital management software companies, expense and travel management systems, retirement providers and consultants, employment verification companies, staffing agencies, and human resource consultants.
      • Third parties including:
        • With attorneys we share Identifiers, Other Personal Information, Protected Characteristics, Biometric Information, Internet or Network Activity, Geolocation Data, Sensory Data, Professional or Employment Related Information, and Non-public education information;
        • With government and regulatory agencies we share Identifiers, Other Personal Information, Protected Characteristics, Biometric Information, Internet or Network Activity, Geolocation Data, Sensory Data, Professional or Employment Related Information, and Non-public education information, and when such sharing involves health information, we maintain an employee’s anonymity whenever possible; and
        • With third parties as required by subpoena, court order, or other legal process we share Identifiers, Other Personal Information, Protected Characteristics, Biometric Information, Internet or Network Activity, Geolocation Data, Sensory Data, Professional or Employment Related Information, and Non-public education information.
    6. Sale of Personal Information:

      We do not sell your personal information. We do not sell the personal information of minors under 16 years of age without affirmative authorization.

  2. CHANGES TO THIS CALIFORNIA EMPLOYEE PRIVACY POLICY

    We reserve the right to amend this privacy policy at our discretion and at any time. If we make material changes to this privacy policy, we will notify you by email, through MyHR or through a notice on our website homepages, www.acecashexpress.com and www.populusfinancial.com.

  3. HOW TO CONTACT US

    If you have any questions or comments about this privacy policy, the ways in which we collect and use your personal information, or your rights regarding such use, please do not hesitate to contact us at:

    Privacy Support E-Mail: CAprivacy@populusfinancial.com
    Postal Address: Populus Financial Group, Inc. d/b/a ACE Cash Express
    Attn: Compliance
    300 E John Carpenter Freeway, Suite 900
    Irving, TX 75062

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