CCPA Employee Privacy Policy

This CCPA Employee Privacy Policy (“Policy”) sets forth our privacy practices as required by the California Consumer Privacy Act (“CCPA”). This Policy applies only to A.K.A. Brands and its subsidiaries regarding employment-related individuals residing in the State of California who are considered “consumers” as defined by the CCPA – namely, job applicants, employees, and contractors of A.K.A. Brands. Pursuant to the CCPA, A.K.A. Brands (“we” or “us”) must deliver this Policy at or before the point we collect your personal information and identify the categories of personal information that we collect and why we collect such information.
As defined in the CCPA, “personal information” is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California resident.
For Applicants: We only ask and collect personal information that we require to enable us to decide about whether to offer you employment. If you do not provide particular information to us, then we will have to make a decision on whether or not to offer you a role without that information, which in some cases could result in us deciding not to pursue your recruitment. In addition, some of the personal information you provide to us is required by law, such as documentation we need to check your right to work. If you choose not to provide us with such required personal information, we will be unable to proceed with considering you for employment, and we will inform you of this decision accordingly.
1. Updates
This Notice will be updated at least once every twelve (12) months to reflect changes in our business, legal or regulatory obligations, so please check this Notice periodically for changes by December 31 of every year. A.K.A. Brands will not collect additional categories of your personal information or use your personal information already collected for additional purposes without providing you with a notice of our intent to do so. Any changes to this Notice will be effective from the date they are communicated to you. If we make any material changes to this Notice, we will notify you by email before such changes are effective at the email address you have provided to us.
2. Definitions
2.1 “Personal information” has the meaning as defined in the CCPA, and includes information that is collected by A.K.A. Brands about you in the course of employment for employment related purposes and encompasses any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.
2.2 “Process”, “processed” or “processing” means any operation or set of operations which is performed on personal information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal information.
2.3 “Employees”, “employee” or “you” means an identified or identifiable natural person who is a California resident and who is acting as a A.K.A. Brands job applicant, employee, or contractor. In this context “job applicant” refers to any person who has submitted his or her candidacy with A.K.A. Brands; “employee” refers to any person who is employed at A.K.A. Brands as a full-or part-time employee or temporary worker, and “contractor” means a natural person who provides any service to a business pursuant to a written contract.
3. Personal Information We Collect About You
Listed below are the categories of personal information that A.K.A. Brands may process about employees:
Within the last twelve (12) months, A.K.A. has collected the following categories of personal information about its job applicants, employees, and contractors (some example elements overlap with multiple categories):
CATEGORY EXAMPLES
A. Identifiers A real name, alias, postal address, unique personal identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
B. Records Information A name, signature, Social Security number, 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, temperature or health insurance information, and temperature checks and vaccine status per COVID rules and regulations.
C. Protected Classification Characteristics under California or Federal Law 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, veteran or military status, genetic information (including familial genetic information), and requests for parental, pregnancy, disability or sick leave.
E. Biometric Information 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, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or Other Electronic Activity Information Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
G. Geolocation Data Physical location or movements, such as tracking building and office entry.
H. Sensory Data Audio, electronic, visual, thermal, olfactory, or similar information, such as voicemail greetings and messages.
I. Professional or Employment-Related Information Job related data, maintained as part of the employment relationship that could be contained in a job application or resume; an employment contract; a contractor agreement; a performance review; a disciplinary record; photos; information from employee expenses; browsing and search history; payroll and benefits related data; internal and external contact information; or information captured from video, audio, systems, or other forms of monitoring or surveillance.
J. Non-public Education Information (Family Educational Rights and Privacy Act (FERPA)) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades or transcripts.
K. Inferences Drawn from Other Personal Information Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
4. Purposes for Collecting Your Personal Information

A.K.A. Brands collects the personal information identified in Section 3 above for the reasons listed below.

4.1 To Recruit Employees, including to conduct employment related background screening and checks.

4.2 To Administer Benefits, such as medical, dental, optical, commuter, and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, insurance and accident management and provision of online total reward information and statements.

4.3 To Pay and Reimburse for Expenses, including salary administration, payroll management, payment of expenses, to administer other compensation related payments, including assigning amounts of bonus payments to individuals, administration of departmental bonus pools and administration of stock option payments.

4.4 To Conduct Performance-Related Reviews, including performance appraisals, career planning, skills monitoring, job moves, promotions and staff re-structuring.

4.5 To Monitor Work-Related Licenses and Credentials, including provisioning software licenses for use in the course of an employee’s work related responsibilities, ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies.

4.6 To Provide Our Employees with Human Resources Management Services, including providing employee data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of employee claims, and travel administration.

4.7 To Administer International Assignments, including relocation services, documenting assignment terms and conditions, obtaining relevant immigration documents, initiating vendor services, fulfilling home/host country tax administration and filing obligations, addressing health requirements and populating the International Mobility global system.

4.8 To Maintain Your Contact Information, including altering your details across relevant entities within the A.K.A. Brands group of companies (for example personal, other employment and transferring roles).

4.9 To Assist You in Case of Emergency, including maintenance of contact details for you, and your dependents in case of personal or business emergency.

4.10 To Monitor Eligibility to Work in the U.S., which means monitoring and ensuring compliance of employees’ ability to work in the U.S.

4.11 To Conduct Healthcare-Related Services, including conducting pre-employment and employment-related medical screenings for return to work processes and medical case management needs; determining medical suitability for particular tasks; identifying health needs of employees to plan and provide appropriate services, including operation of sickness policies and procedures; and providing guidance on fitness for travel and fitness for expatriation.

4.12 To Facilitate Better Working Environment, which includes conducting staff surveys, providing senior management information about other employees, and conducting training.

4.13 To Ensure a Safe and Efficient Working Environment, which includes A.K.A. Brands actions relating to disciplinary actions, and code of conduct processes and investigations.

4.14 To Maintain Security on A.K.A. Brands Websites and Internet Connected Assets, which includes hosting and maintenance of computer systems and infrastructure; management of A.K.A. Brands’s software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; and monitoring email and Internet access.

4.15 To Comply with Applicable Law or Regulatory Requirements, such as legal (state and federal) and internal company reporting obligations, including headcount, management information, demographic and Health, Safety, Security and Environmental reporting.

5. How Information Is Shared

When disclosing your personal information to a third party for a business purpose, A.K.A. enters into a contract with the third party describing the purpose of such disclosure and requiring that such personal information be kept confidential and not used for any purpose except to perform the services under the contract or respond to regulatory or law enforcement requests.

In the preceding twelve (12) months, A.K.A. has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers

Category B: California Customer Records personal information categories

Category C: Protected classification characteristics under California or federal law

Category E: Biometric Information

Category F: Internet or other similar network activity

Category I: Professional or employment-related information

We disclose your personal information to the following categories of third parties:

  •   Our vendors and service providers (e.g., website hosting, information technology and security, cloud storage, etc.).
  •   Third parties who provide professional services such as attorneys, auditors, etc.
  •   Third parties to whom you or your representatives authorize us to disclose personal information in connection with products or services we or they provide to you.
  •   Government agencies as required by laws and regulations or otherwise to comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal information necessary for the specific purpose and circumstances.

A.K.A. Brands has not in the last twelve months and has no intention of selling your personal information.

Further Information

We reserve the right to amend this Policy at our discretion and at any time. When we make changes, we will notify employees through an email notice and reflect the date it was updated. 

If you have any questions about this statement, please contact a.k.a. Brands Human Resources at [email protected].