Privacy Notice for California Residents
Effective Date: January 1, 2020
Last Reviewed: December 15, 2025
This Privacy Notice for California Residents (“Notice”) supplements the information contained in our privacy policy. This Notice applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). Imagine adopts this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this Notice.
Definitions
- Personal Information: As used in this Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household. Personal Information includes Sensitive Personal Information.
- Sensitive Personal Information: As used in this Policy, “Sensitive Personal Information” includes Personal Information that reveals, among other things, social security number, driver’s license number, state identification card number, passport number, racial or ethnic origin, union membership, or the contents of a Consumer’s mail, email, and text messages, unless Imagine is the intended recipient of the communication. Sensitive Personal Information also includes information concerning the Applicant or Employee’s health, sex life, or sexual orientation.
- Other CCPA Definitions: As used in this Policy, the terms “Collect,” “Processing,” “Service Provider,” “Third Party,” “Sale,” “Share,” “Consumer,” and other terms defined in the CCPA and their conjugates have the meanings afforded to them in the CCPA, whether or not such terms are capitalized herein, unless contrary to the meaning thereof.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a specific consumer or household (“personal information”). We have collected the following categories of personal information from consumers within the last twelve (12) months.
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | YES |
| B. California Customer Records (Cal. Civ. Code § 1798.80(e)). | A 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, medical information, or health insurance information. | YES |
| C. Protected classification characteristics. | Age (40+), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex, sexual orientation, veteran or military status, genetic information. | YES |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information. | NO |
| F. Internet or similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
| G. Geolocation data. | Physical location or movements. | NO |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO |
| J. Non-public education information. | Education records directly related to a student maintained by an educational institution or party acting on its behalf. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
| L. Sensitive Personal Information. | Social security, driver’s license, or passport numbers; account log-in credentials; precise geolocation; racial or ethnic origin; contents of email and text messages; genetic data; biometric information; health, sex life, or sexual orientation data. | YES |
Personal information does not include publicly available information from government records, deidentified or aggregated consumer information, or information excluded from CCPA’s scope (such as HIPAA/CMIA-covered health information, FCRA, GLBA, FIPA, or DPPA-covered information).
Imagine obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete.
- Indirectly from you. For example, through information we collect in the course of providing services.
- Directly and indirectly from activity on any of our Websites.
- Directly from third parties, such as your employer, partners and service providers who work with us, and publicly available sources.
- Applicants and Employees when they complete recruiting and employment forms.
- Service Providers and Third Parties that help us screen and onboard individuals for hiring purposes.
- Joint marketing partners, public databases, providers of demographic data, publications, professional organizations, educational institutions, social media platforms.
Use of Personal Information
We may use or disclose the personal information for one or more of the following business purposes:
- Fulfill or meet the reason for which the information has been provided.
- Provide you with information, products, or services that you request from us.
- Provide you with email alerts and other notices concerning our products or services, or events or news that may be of interest to you.
- Carry out our obligations and enforce our rights arising from any contracts between you and us, including for billing and collections.
- Improve our website and present its contents to you.
- Testing, research, analysis, and product development.
- As necessary or appropriate to protect the rights, property, or safety of us, our clients, or others.
- Respond to law enforcement requests and as required for compliance with applicable law, court order, or governmental regulations.
- Engage in corporate transactions requiring review of employee records.
- Recruit and evaluate job applicants and candidates for employment.
- Manage your employment relationship with us.
- Manage and monitor employee access to company facilities, equipment, and systems.
- Conduct internal audits and workplace investigations.
- Maintain commercial insurance policies and coverages.
- Perform workforce analytics, data analytics, and benchmarking.
- Exercise or defend the legal rights of Imagine and its employees, affiliates, customers, contractors, and agents.
- Operate, manage, and maintain our business.
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.
Sharing Personal Information
Imagine may disclose your personal information to a third party for a business purpose, such as applicant selection and related hiring services, benefits and wellness services, and legal services.
When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
- Service providers
- Our affiliates
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you
In the preceding twelve (12) months, Imagine has disclosed the following categories of personal information for business purposes: Category A (Identifiers), Category B (California Customer Records), Category C (Protected classification characteristics), and Category I (Professional or employment-related information).
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information.
Access to Specific Information and Data Portability Rights
You have the right to request that Imagine disclose specific information to you about our collection and use of your personal information over the past 12 months, including:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (data portability request).
Deletion Request Rights
You have the right to request that Imagine delete any of your personal information that we collected from you and retained, subject to specific exceptions.
Right to Correction
You may request that we correct any inaccurate Personal Information we maintain about you.
Exercising Your Data Subject Rights
To exercise the access, data portability, deletion, and correction rights described above, please submit a verifiable consumer request to us by either of these methods:
- Calling us: 818-295-6100 (you may hear reference to “Midnight Oil” in the greeting, as “Midnight Oil” is a California-based subsidiary of The Imagine Group)
- Visiting theimaginegroup.com
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal information. You may make a verifiable consumer request for access or data portability only twice within a 12-month period.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing.
We do not Sell or Share Personal Information. Further, we do not use Sensitive Personal Information for purposes beyond those authorized by the CCPA.
Non-Discrimination
You have the right not to be discriminated against for exercising your data subject rights. We will not discriminate against you for exercising any of your data subject rights.
Retention of Personal Information
We retain each of the above-listed categories of Personal Information for the duration of your relationship with us, as applicable, and longer as may be required by applicable laws or necessary for our legitimate business purposes.
Changes to Our Privacy Notice
We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice on the Website and update the Notice’s effective date.
Contact Information
If you have any questions or comments about this Notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or if you wish to exercise your rights under California law, please contact us:
Phone: 818-295-6100
Website: theimaginegroup.com
If you have any questions about this Notice or need to access this Notice in an alternative format due to having a disability, please contact [email protected] or 818-295-6100.