Employment Privacy Notice for California Residents

Effective January 31, 2022

The purpose of this Employment Privacy Notice for California Residents (this “Privacy Notice”) is to inform our personnel (including employees, temporary workers, job applicants, independent contractors and directors) who reside in the State of California (referred to herein as “you” or “individual”) about the categories of personal information that Worthington Armstrong Venture (“WAVE”, “we”, “us” or “our”) collects about you and the purposes for its use during and after your working relationship with us.

WAVE collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household (“personal information”).

Information We Collect

We may collect the following categories of personal information from individuals. Not all categories may be collected about every individual.


Category Types of Identifiers We Collect
Identifiers Examples include: real name, alias, postal address, unique personal identifier, email address, social security number, or other similar identifiers.
Personal information Similar identifiers as above, and other identifiers including: signature, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, beneficiary designations, birth certificate, date of birth, permanent resident card, and badge photos.
Characteristics of protected classifications under California or federal law Examples include: race, color, ancestry, national origin, religion or creed, age (40 years or older), mental or physical disability, citizenship, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, medical condition, genetic information (including familial genetic information), marital status, military or veteran status.
Commercial information Records of personal property or products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Biometric information Examples include: physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints or face recognition.
Internet or other electronic network activity information Examples include: browsing history, search history, online behavior, access logs, and interactions with websites, applications, advertisements and systems.
Geolocation data Examples include: physical location or movements (including vehicle tracking devices, cell phones), and information associated with the location of fobs and badges used for authentication for access to secure WAVE facilities.
Sensory data Audio, electronic, visual, thermal, olfactory, or similar information (including use of cameras). Examples include: activities and usage of our electronic devices and systems, call recordings, security camera footage and facility access.
Professional or employment-related information Current or past job history or performance evaluations.
Education information Information about an employee’s educational background, such as grades or transcripts, that are not publicly available.
Inferences drawn from other personal information A profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes and attitudes.
Health and medical information Examples include: medical information, health insurance information, family member information, emergency contact information, communicable disease (including COVID-19) medical and health information for you, family members, friends, co-workers and other associates related to symptoms, exposure, vaccination status, testing results, close contacts, doctor’s notes for absences or work restrictions, medical leave of absence records, requests for accommodation, leave correspondence and travel information.
Additional background screening and investigation information Examples include: motor vehicle records, credit, criminal history, and drug testing.


Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • 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 (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Use of Personal Information

We may use the personal information we collect for a range of standard employment-related and business purposes, including:

  • Workforce Planning and Recruitment, for example for business forecasting, employee assignment planning and budgeting, job advertising, interviewing, conducting background and criminal history checks, performing drug testing, considering individuals for employment opportunities, selecting and hiring and terminating staff.
  • General Human Resources Management and Administration, for example for career development, performance management, compensation and benefits management and benchmarking, administering payroll, reimbursing expenses, obtaining employee satisfaction feedback, leave programs, vacations, timekeeping, managing absences, general headcount reporting, disaster recovery and emergency response planning, equal opportunities monitoring, training employees, and carrying out disciplinary or grievance procedures.
  • Performance of our Business Operations, for example, to carry out day to day business activities, to allow us to work together and collaborate, to provide our products and services, to ensure business continuity, to enforce our rights and protect our operations and those of our affiliates, and to pursue available remedies and limit damages we may sustain.
  • Security Management, for example, to ensure the security of our premises, assets, systems, information, employees and other personnel; to prevent, detect and investigate security incidents and potentially illegal or prohibited activities; and to protect the rights, property or safety of you, us, or another party.
  • Legal and Regulatory Compliance, for example, to respond to law enforcement requests; to fulfill our legal obligations under applicable laws, court orders, governmental regulations or other legal processes; to exercise and defend against legal claims; to ensure compliance with health and safety requirements and other legal or fiscal obligations, or in connection with litigation or an internal investigation or audit and to ensure compliance with our policies.
  • As described to you when collecting your personal information.
  • Business transactions, for example, to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about you is among the assets transferred.
  • Avert a Serious Health or Safety Threat, for example, to help prevent a serious threat to your health and safety or the health and safety of another person or the public. This may require disclosure of information to help reduce the risk of exposure to and the spread of a communicable disease, such as COVID-19, including disclosure to individuals with whom you have been in close contact, public health agencies, and law enforcement.


Changes to this Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our career site with an updated effective date and email the updated notice to current employees, temporary workers, and independent contractors who reside in the State of California.

Contact Information

If you have any questions or comments about this notice, including the ways in which we collect and use your information, please do not hesitate to contact us at:

Phone: 610-722-1211

Email: [email protected]

Postal Address: 101 Lindenwood Drive, Suite 350, Malvern, PA 19355

Individuals with disabilities may access this Privacy Notice in an alternative format by visiting our website: https://worthingtonarmstrongventure.com/.