This California Privacy Policy provides you with information regarding Sterling & Sterling LLC DBA Bolton Street Programs’ (“Bolton Street Programs,” “we,” “us,” and “our”) treatment of personal information relating to you as either an employee, director, officer, independent contractor, or part-time worker of Bolton Street Programs, or as an applicant for one of those positions (collectively, “Employee”).
Your Rights
Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”), California residents have the following rights:
- The right to know what personal information we’ve collected about you, including the categories of personal information; categories of sources from which we collected the personal information; the purpose for our collection, selling, or sharing of your personal information; the categories of parties to whom we disclose personal information; and the specific pieces of personal information we have collected about you;
- The right to delete personal information we have collected from you, subject to certain exceptions;
- The right to correct inaccurate personal information that we maintain about you; and
- The right to not receive discriminatory treatment for exercising your privacy rights.
How to Submit a Request to Know, Access, Correct, or Delete
If you are a California resident and you would like to submit a request to know, access, correct, or delete your personal information, you can email your request to Webmaster@BoltonSt.com, call us toll-free at 1-800-767-7837, or submit the webform available at www.boltonst.com/consumer-privacy-request/.
What Happens After You Submit a Request to Know, Access, Correct, or Delete?
Following receipt of a request to know, access, correct, or delete your personal information, we will take commercially reasonable steps to verify your identity, including verifying you via your existing password-protected account with us or asking you to provide us with information to confirm your identity (e.g., your zip code, email address, phone number, or dates of employment). If you are an agent authorized to make a request on a California resident’s behalf, please indicate that when submitting your request. Agents must generally provide a signed authorization evidencing their authority to act on behalf of another individual.
We will make good faith efforts to evaluate and act on your request, but there may be circumstances in which we do not grant your request. For example, we are not required to delete personal information needed (i) to provide a service we are contracted to provide, (ii) to detect fraudulent or illegal activity, (iii) for bookkeeping or tax purposes, or (iv) for legal purposes. Also, we are not required to provide access, correction, or deletion where your identity could not be verified, where the information would compromise others’ privacy or other legitimate rights, such as intellectual property rights, or where the information contains legally privileged material. If we determine that your request should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries.
Any requests that can be processed by us will be done so within 45 days from the date we receive your request, unless we notify you that an extension is required. In case of an extended completion period, we will process your request within 90 days from the date of your original request. Employees are limited to two requests to know or access within a 12-month period.
Personal Information Collected, Used, and Disclosed Within the Past 12 Months
Below you will find a chart that generally describes the categories of personal information we have collected, where that information came from, the purpose for the collection of that information, the categories of parties to whom that information was disclosed, and the purpose for that disclosure, all within the past 12 months from the effective date of this notice and as it relates to Employees. Please note that these are categories of personal information as they are set forth under California law. We did not necessarily collect all of the specific pieces of personal information listed for any given person.
We do not sell any of the personal information we obtain from Employees, nor do we use it to track you across websites and target advertising to you (known as “sharing” under California law). We only use your sensitive personal information as necessary to process your application to work with us and manage and administer that relationship (e.g., to verify your eligibility to work with us, administer your benefits, pay you, and/or comply with legal requirements), or as otherwise permitted by law. If you do not provide us with certain personal information when requested, we may not be able to perform certain functions, such as considering your application for employment, hiring you, or paying or providing a benefit to you.
Document Retention
We will not retain your personal information for longer than reasonably necessary for the purpose(s) we collected it. How long we retain your personal information depends on a number of criteria, including whether we hire you, your employment status with us, how long it’s been since we employed you, the nature of our relationship with you, and legal considerations.
Additional Information or Questions
If you have any questions about our privacy policy or exercising the rights described above, please visit www.boltonst.com/privacy-policy. You can also email us at Webmaster@BoltonSt.com or call us at 1-800-767-7837.
Effective Date
This California Privacy Policy is effective as of August 29, 2024, and was last updated on 08/29/2024.
