Privacy Policy – California

California Personnel Privacy Notice


Last Updated: January 1, 2020

We at Gava Talent Solutions, LLC (“we,” “us,” or “our”) have created this California Personnel Privacy Notice (this “Privacy Notice”) because we know that you value how the information and data you provide to us is collected, used and shared. Gava Talent Solutions is the Controller for purposes of this Privacy Notice.


Our Commitment to Privacy

We provide this Privacy Notice to make you aware of our privacy practices and describes what information we may collect about you; how we use your information; how we protect it; and what choices you have about how that information is used.

We may revise any portion of this Privacy Notice from time to time at (the “Site”) to keep up with technical innovation, post new Site content, and for other reasons. All revisions to this Privacy Notice will be effective upon notice given by means of posting the revised Privacy Notice on the Site, with a new effective date posted at the top. If this Privacy Notice changes in a way that materially affects how we handle personal information, we will not use the personal information we previously gathered in the manner described in the new policy without providing notice and/or obtaining your consent, as appropriate. Your continued use of the Site after any revision(s) to this Privacy Notice will constitute your acceptance of the revised Privacy Notice. We encourage you to refer to this Privacy Notice frequently, and to regularly check the effective date shown at the top.

This California Personnel Privacy Notice (“Notice”) applies solely to current, former, or prospective employees, owners, directors, officers, and contractors (collectively “Personnel,” and each individually a “Staff Member”) of Global Upside Corporation and its subsidiaries (“Global Upside”) who reside in the State of California. This Notice is provided to Personnel pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), and any terms defined in the CCPA have the same meaning in this Notice.


  1. Personal Information We Collect About You

Listed below are the categories of personal information that Gava Talent Solutions collects from Personnel:

  • Identifiers, including real name, alias, postal address, unique personal identifiers, email, account name, social security number, driver’s license number, passport number or other similar identifiers. In this context, a “unique personal identifier” means a persistent identifier that can be used to recognize a Staff Member, or a device that is linked to a Staff Member, over time and across different services, including, but not limited to, a device identifier, an Internet Protocol address, cookies, beacons, pixel tags, or similar technology, unique pseudonym, or user alias, telephone numbers, or other forms of persistent or probabilistic identifiers.
  • Characteristics of Protected Classifications Under California or Federal Law, including the following: race, skin color, national origin, religion (includes religious dress and grooming practices), sex/gender (includes pregnancy, childbirth, breastfeeding, and/or related medical conditions), gender identity, gender expression, sexual orientation, marital status, medical condition (such as genetic characteristics, cancer, or history of cancer), disability (mental or physical), military or veteran status, request for family care leave, request for leave for a Staff Member’s own serious health condition, request for pregnancy disability leave, and age.
  • Internet or Other Electronic Network Activity Information, including browsing history, search history, application access location, and information regarding a Staff Member’s interaction with an internet website, application, or advertisement, time and geolocation data related to use of an internet website or application, or physical access to a Gava Talent Solutions office location.
  • Professional or Employment-Related Information, including job related data maintained as part of the employment relationship that is present in: a job application or resume; an employment contract; a contractor agreement; a performance review; a disciplinary record; photos; biometric data, including imagery of your fingerprint, face, and voice recordings; information from a Staff Member’s expenses; browsing and search history; payroll and benefits-related data; internal and external contact information; or information captured from video or audio systems, or other forms of monitoring or surveillance.
  • Education Information, including information about a Staff Member’s educational background that is not publicly available, such as education records, report cards, and transcripts.
  • Inferences, including any information drawn from any of the personal information categories referenced above to create a profile about a Staff Member reflecting the Staff Member’s characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.


  1. Use of Your Personal Information

Gava Talent Solutions uses your personal information to:

  • Recruit Personnel, including to conduct employment-related background screening and checks.
  • 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.
  • Pay and Reimburse for Expenses, including salary administration, payroll management, payment of expenses, and administer other compensation related payments, including assigning amounts of bonus payments to individuals, administration of departmental bonus pools, and administration of stock option payments.
  • Conduct Performance-Related Reviews, including performance appraisals, career planning, skills monitoring, job moves, promotions, and staff restructuring.
  • Monitor Work-Related Licenses and Credentials, including provisioning software licenses for use in the course of a Staff Member’s work related responsibilities, ensuring compliance, training, examination, and other requirements are met with applicable regulatory bodies.
  • Provide Our Personnel with Human Resources Management Services, including providing Staff Member data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of Staff Member claims, and travel administration.
  • 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.
  • Maintain Your Contact Information, including altering your details across relevant entities within the Global Upside group of companies so that we can facilitate role transfers or assist you in case of a business or personal emergency.
  • Monitor Eligibility to Work in the U.S., which means monitoring and ensuring each Staff Member’s legal ability to work in the U.S.
  • 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 Personnel to plan and provide appropriate services, including operation of sickness policies and procedures; and providing guidance on fitness for travel and fitness for expatriation.
  • Facilitate Better Working Environment, which includes conducting Personnel surveys, providing senior management information about Staff Members, and conducting training.
  • Ensure a Safe and Efficient Working Environment, which includes code of conduct processes and investigations and disciplinary actions.
  • Maintain Security on Gava Talent Solutions Websites and Internet Connected Assets, which includes hosting and maintenance of computer systems and infrastructure; management of Gava Talent Solutions’ 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.
  • Comply with Applicable Laws 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.