We collected and disclosed the following categories of personal information about our employees, contractors, and applicants in the past 12 months, and we may also collect and disclose these categories of personal information going forward:

• Personal and online identifiers: Includes real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, social security number, driver’s license number, passport number, United States immigration or work permit identifiers, or other similar identifiers. Some of this information is also “sensitive personal information” under the CCPA.
• Recordkeeping information: Includes insurance policy number and bank account number.
• Characteristics of protected classifications under California or federal law: Includes age, race or ethnicity, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, pregnancy or childbirth and related medical conditions), sexual orientation, religion, union membership, veteran, or military status. Some of this information is also “sensitive personal information” under the CCPA.
• Commercial or transactions information: Includes expense records and information and records of products or services purchased using a corporate credit card.
• Internet or other electronic network activity information: Includes browsing history, search history, and information on interactions with websites, email, social media, applications, or advertisements on company owned devices or using company VPN (virtual private networks) connections or software.
• Geolocation information: Includes physical location or movements of company fleet vehicles and drivers while in service. Precise geolocation data is also “sensitive personal information” under the CCPA.
• Audio, electronic, visual, or similar information: Includes photographs or videos, work meeting and work-related recordings, or security videos.
• Professional or employment-related information: Includes records relating to your employment with Brightspeed, current or past job history, performance evaluations, compensation data, resumes, work applications, and professional certifications.
• Education information: Includes academic records, professional training records, or other education information included on your resume.
• Sensitive personal information: Access credentials relating to company services, as well as other information described above including racial or ethnic origins, religious beliefs, health information (such as for disability accommodations or benefits), sexual orientation, citizenship or immigration status, precise geolocation data, and social security numbers and other government identification numbers.
• Inferences drawn from other personal information: Such as a profile reflecting a person’s preferences, characteristics, behavior, or attitudes.
• Other information about you that is linked to the personal information above: Includes date of birth.

We collect personal information about our employees, contractors, and applicants from the following categories of sources:

• You: We may collect personal information that you provide during your relationship with Brightspeed. We may also collect personal information about you automatically, such as by monitoring your activities in accordance with our policies and procedures.
• Internal sources: We collect personal information from internal sources, such as a manager, supervisor, or colleagues. When you are an emergency contact or beneficiary of a Brightspeed employee or contractor, we may collect personal information about you from that employee or contractor.
• Brightspeed users: We may collect personal information about you from users of our services, such as when users provide feedback about you.
• Our service providers: We may collect personal information about you from our service providers, like those who administer payroll and employee benefits.
• Reference and background sources: We may collect personal information from reference and background sources such as current or former employers, references, recruiters, social media companies, government agencies, educational institutions, background check providers, and consumer reporting agencies.

We use and disclose the personal information we collect about our employees, contractors, and applicants for our commercial and business purposes. These commercial and business purposes include, for example:

• Human resources administration: For human resource functions such as recruiting, hiring, payroll processing and auto deposit, employment eligibility and visa status verification, garnishments, drug testing.
• Business operations: To run the business, financial services, tax reporting, business continuity, emergency preparedness, security, and safety programs, and for operations like employee expense reimbursement.
• Verifying applicant information: For determining applicant qualifications, employment eligibility, and background such as verifying past job performance, degrees, certification, licensing, and criminal background checks.
• Information technology and information security administration: For information technology and information security administration, and for monitoring use of Brightspeed devices, computer systems and network.
• Legal requirements: To comply with applicable laws and regulations such as IRS (Internal Revenue Service) or DOL (Department of Labor) reporting, or employment/labor contracts.
• Benefits: For administering benefits such as a deferred compensation plan, health or life insurance, or employee benefits program.

To run our business, we may share each category of personal information we collect with the categories of recipients listed below.

• Service providers: We disclose personal information to our service providers, such as those that help us manage the application process, maintain our records, administer employee benefits or payroll, or assist with human resources functions. These service providers are under contract to protect your information, to use it only as permitted by their contracts with Brightspeed, and to access only the personal information needed to provide the services.
• Recruiters: We may disclose personal information to recruiters, such as to convey the status of your application.
• Employment references: We may disclose personal information to references, such as to confirm the information you provided to us.
• Background check providers: As legally permitted, we may disclose personal information to background check providers to obtain a background check.
• Government entities: We may provide personal information to government entities, such as for reporting purposes or other purposes as legally required.
• To third parties for legal or safety reasons: We may also provide personal information to other third parties in response to a law enforcement request or legal process, for example, in response to a court order or a subpoena, or when necessary to protect the safety, security, or rights of Brightspeed or others.

Brightspeed does not sell employee, contractor, or applicant personal information or share it for purposes of cross-context behavioral advertising. 

As a California resident, you have certain rights related to personal information Brightspeed collects. Subject to certain exceptions and limitations, you may have the following rights:

• Request to know (a) the categories of personal information we collect, use, disclose for a business purpose, and share about you; (b) the categories of sources from which we collected personal information about you; (c) our purposes for collecting or sharing personal information; and (d) the categories of third parties to which we have shared personal information or disclosed it for a business purpose.
• Request to access the specific pieces of personal information we have collected about you.
• Request to delete the personal information we have collected from you.
• Request the correction of inaccurate personal information.
• Not receive discriminatory treatment for exercising your privacy rights.

While the CCPA provides an opt-out opportunity for certain uses or disclosures of “sensitive personal information” (as defined by the CCPA), Brightspeed uses and discloses such information only for purposes that do not require an opt-out opportunity under the CCPA.

California residents that work for or apply to work for our company can exercise these rights by submitting a Data Subject Request using the form at the link, by emailing the Privacy Office at privacy@brightspeed.com, by calling 833-MYBRSPD, or by mail to: Chief Privacy Officer, Brightspeed Legal Department, P.O. Box 1330, 717 McGilvary Street, Fayetteville, NC 28301.

In some cases, we may need to request additional information from you to verify your identity or understand the scope of your request. Generally, we verify your identity by matching the information provided in your request with the information we maintain in our records.

You may designate an authorized agent to submit data subject requests on your behalf. Your agent will need a valid power of attorney or written permission signed by you. We may contact you directly to confirm the permission. Your authorized agent can submit your Data Subject Request or other written request to Brightspeed’s Privacy Office at the contact details listed above.

We keep personal information for different lengths of time depending on the following criteria: how long federal and state laws require us to keep it and what is required to comply with our contracts, run our business, preserve data relevant to ongoing litigation, and comply with government orders or investigations.

We will update this notice when necessary to reflect changes in the law, regulations, or our information practices, to reflect feedback we receive, and to keep it accurate and complete. Please check this page for updates.

If you have questions about this privacy policy or about how your personal information is processed, please contact us:

• By email to privacy@brightspeed.com.
• By mail to the Chief Privacy Officer, Brightspeed Legal Department, P.O. Box 1330, 717 McGilvary Street, Fayetteville, NC 28301.
• By calling 833-MYBRSPD.