Privacy Policy for Employees, Applicants and Contract Personnel

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Please review the below Policy on Protection of Personal Information of Employees, Applicants and Contract Personnel.

Elite Vipron Management

Policy on Protection of Personal Information of

Employees, Applicants and Contract Personnel

Last updated: January 10, 2020

This Privacy Notice describes the practices of Elite Vipron Management and its subsidiaries and exclusive subadvisors (collectively, “Elite”). Elite Vipron obtains and uses Personal Information for employment-related purposes. This Privacy Notice is intended to comply with the California Consumer Privacy Act (“CCPA”).

Specifically, this Notice identifies (1) the types of Personal Information that Elite Vipron obtains about its employees, contract personnel and applicants for employment; (2) how Elite Vipron collects such Personal Information; (3) how Elite Vipron uses that Personal Information; (3) with whom Elite Vipron shares Personal Information; (4) protection of Personal Information; (5) the different rights and choices employees, contract personnel and applicants may make when it comes to Personal Information provided to Elite Vipron for employment purposes; and (6) how employees, contract personnel and applicants should contact Elite Vipron regarding this Privacy Notice.

Personal Information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household. It does not include deidentified or aggregate information or public information lawfully available from governmental records.

I. Personal Information Collected by Elite Vipron

Depending on whether you are an employee, contract personnel, or job applicant of Elite Vipron in the past 12 months, Elite Vipron may have collected, and disclosed to one or more third-party service providers for business purposes, the following categories of Personal Information about you:

Name, social security and other government ID numbers, gender, marital status, date and place of birth, nationality, citizenship, and contact information at home and at work*;
Education information and information about your experience and other qualifications for employment, including information provided by previous employers and references;
Information gathered in the course of conducting background checks, including criminal convictions and offences, as well as civil litigation and regulatory disciplinary history;
Unique and online identifiers – IP addresses, device IDs, or other similar identifiers;
Information about or related to your work at Elite Vipron including your hire date, salary, eligibility for various benefits, and performance evaluations;
Your electronic communications on Elite Vipron devices, as described in the Compliance Manual and/or as required by law and regulation;

Information regarding your use of Elite Vipron equipment, including email, telephone, and Internet usage, and, if in the course of your employment with Elite Vipron you access Elite Vipron information with your own equipment, your use of such equipment, as described in Elite’s IT Handbook;
Financial information such as bank wire information for payroll purposes;
Information about your personal investments and trading, and information about your contributions to candidates for political office, as described in the Compliance Manual and/or as required by law and regulation; and
Location information, such as your home address information, itineraries for travel on behalf of Elite Vipron and the location of Elite Vipron devices and Elite Vipron access-enabled devices in your possession.

* For applicants, we do not seek to collect information on protected classifications.

Elite’s website functions are based, in part, on your browser’s ability to accept cookie files. Cookies are pieces of information that a website stores on your device. Cookies help you to navigate Elite’s website and customize website features that are updated each time you visit the site. Cookies also help Elite Vipron to track repeat visits to the website. Most browsers are initially setup to accept cookies. You may set your preferences to refuse cookies; however, this may limit your access to some areas of the website.

For your convenience, Elite’s websites contain links to other websites, such as Intralinks and LinkedIn. This does not imply any affiliation with, or an endorsement, sponsorship, or promotion of a non-Elite Vipron website or its owner. Elite Vipron accepts no responsibility for the content created or displayed by third parties on linked websites. When you access such non-Elite Vipron websites, you should be aware that these websites are governed by their own terms and conditions, privacy policies and user tracking opt-out policies.

II. Sources of Personal Information Available to Elite Vipron

In addition to the Personal Information collected directly from you and your devices, Elite Vipron may collect Personal Information about you from other sources. For example, Elite Vipron performs various background screens and reference checks before making hiring decisions. By providing the names of your references and their contact information, and by submitting your employment application, you consent to Elite’s use and disclosure of your Personal Information in this manner.

III. Elite’s Use of Personal Information Collected

Elite Vipron limits the collection and processing of Personal Information to that which is fair, lawful, relevant, and not excessive. In particular, Elite Vipron collects and processes Personal Information for the following purposes:

managing recruitment, background checks and regulatory applications;

administering human resource functions including performance reviews, medical leaves, training, internal communications, and dealing with disciplinary action, termination, resignation and retirement;
administering payroll, payment of expenses, remuneration and other benefits;
managing communications and content including administering access to or use of Elite Vipron systems and facilities;
carrying out audits and investigating and resolving complaints, grievances or misconduct;
preparing for and acting in relation to enquiries, investigations or proceedings by governmental, administrative, judicial or regulatory authorities, including civil litigation;
monitoring employees, including as part of Elite’s cybersecurity initiatives;
meeting any disclosure obligations as required by applicable laws and regulations or for other compliance, legal or regulatory purposes;
in connection with a potential acquisition of Elite Vipron or any part of its business, or the outsourcing or insourcing of services provided by Elite Vipron employees, providing reasonable diligence material to a third party; and
any other purposes relating to the above.

Elite Vipron limits its collection and use of Personal Information. Certain sensitive Personal Information will be requested only in compliance with applicable laws. For example, Elite Vipron collects medical information about employees and their dependents and beneficiaries to administer leave entitlements and benefits programs.

IV. Elite Vipron Transfers of Personal Information

Elite Vipron provides access to Personal Information of its employees, contract personnel and applicants on a need-to-know basis. Only employees with a legitimate business need are provided access to an individual’s Personal Information. Elite Vipron prohibits the disclosure of an individual’s Personal Information to third parties, unless permitted or required by law, or unless the information has otherwise been made public.

Elite Vipron may disclose certain Personal Information for the above purposes to the following recipients: (i) its affiliates and other entities in the Elite Vipron group, (ii) those who provide products or services to any Elite Vipron group entity (such as auditors, advisers, payroll administrators, employee benefits providers, recruiters, background check providers, and outsourced service or data storage providers), who also have privacy law obligations; (iii) to fraud prevention agencies and law enforcement agencies; (iv) to courts, governmental and non-governmental regulators and ombudsmen; or (v) as required or permitted by law or regulation, including (without limitation) to comply with a subpoena or similar legal process or government request, or when Elite Vipron believes in good faith that disclosure is legally required or Elite Vipron has a legitimate interest in making a disclosure, such as where necessary to protect Elite’s rights and property.

V. Elite Vipron Measures to Secure Personal Information

Elite Vipron has adopted reasonable data security measures to protect Personal Information against loss or theft, as well as from unauthorized access, disclosure, copying, use or modification. Elite Vipron has implemented safeguards to encrypt or otherwise protect Personal Information transmitted via electronic means, and to destroy or make unreadable such information at disposition. Personal Information is retained in accordance with Elite’s data retention procedures and legal and regulatory obligations.

Even the best security programs cannot provide a guarantee against all cybersecurity risks. Employees and contract personnel should consult the Elite Vipron IT Handbook for further guidance on security measures.

VI. Individual Rights in Relation to Personal Information Held by Elite Vipron

Employees, applicants and contract personnel have a number of rights when it comes to Personal Information, including the right to be informed about the Personal Information Elite Vipron collects and the purposes for which Elite Vipron uses your Personal Information. This Privacy Notice does not apply to personal information of investors in funds managed by Elite Vipron whose data is the subject of separate privacy policy notices pursuant to the GLBA. The personal information of Elite Vipron business contacts collected in the course of Elite’s business-to-business interactions is also excluded from this Privacy Notice, as permitted by the CCPA.

Please contact Elite’s privacy team if you would like further information.

VII. Contact Elite’s Privacy Team

Questions regarding this Notice should be directed to Elite’s internal privacy team. You may contact privacy@elitevipron.com or call toll-free 1-833-506-0472 or internally to extension 6373.

Other Important Information

This link leads to the machine-readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine readable files are formatted to allow researchers, regulators, and application developers to more easily access and analyze data.

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