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: 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: Includes Personal Information that reveals 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. Also includes information concerning health, sex life, or sexual orientation.
- Other CCPA Definitions: The terms “Collect,” “Processing,” “Service Provider,” “Third Party,” “Sale,” “Share,” “Consumer,” and other terms defined in the CCPA have the meanings afforded to them in the CCPA.
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 | Name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, SSN, driver’s license number, passport number, or similar identifiers. | YES |
| B. California Customer Records (Cal. Civ. Code § 1798.80(e)) | Name, signature, SSN, physical characteristics, address, telephone number, passport number, driver’s license, insurance policy number, education, employment history, bank account number, credit/debit card number, financial information, medical or health insurance information. | YES |
| C. Protected Classification Characteristics | Age (40+), race, color, ancestry, national origin, citizenship, religion, marital status, medical condition, disability, sex, sexual orientation, veteran or military status, genetic information. | YES |
| D. Commercial Information | Records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies. | NO |
| E. Biometric Information | Fingerprints, faceprints, voiceprints, iris or retina scans, keystroke patterns, sleep/health/exercise data. | 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. | NO |
| K. Inferences Drawn from Other Personal Information | Profile reflecting preferences, characteristics, psychological trends, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
| L. Sensitive Personal Information | SSN, driver’s license, financial account numbers with security codes, precise geolocation, racial/ethnic origin, religious/philosophical beliefs, union membership, contents of email/text messages, genetic data, biometric data, health data, 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, FCRA, GLBA, FIPA, or DPPA-covered data).
Sources of Personal Information
- Directly from you (forms you complete)
- Indirectly from you (through our services)
- From activity on our Websites (submissions, usage details)
- From third parties (employers, partners, service providers, publicly available sources)
- From applicants and employees (recruiting and employment forms)
- From service providers and third parties (screening and onboarding)
- From joint marketing partners, public databases, social media platforms, professional and educational organizations
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.
- Carry out our obligations and enforce our rights arising from any contracts between you and us.
- Improve our website and present its contents to you.
- Testing, research, analysis, and product development.
- Protect the rights, property, or safety of us, our clients, or others.
- Respond to law enforcement requests and comply with applicable law.
- Engage in corporate transactions requiring review of records.
- Recruit and evaluate job applicants.
- Manage employment relationships (onboarding, payroll, benefits, performance, training, security, workers’ compensation, investigations, and other HR purposes).
- Manage and monitor employee access to company facilities, equipment, and systems.
- Conduct internal audits and workplace investigations.
- Investigate and enforce compliance with Imagine policies and procedures.
- Maintain commercial insurance policies and coverages.
- Perform workforce and data analytics and benchmarking.
- Administer and maintain our operations, including for safety purposes.
- For client marketing purposes.
- Exercise or defend legal rights.
- Operate, manage, and maintain our business.
- Perform accounting, audit, and other internal functions.
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, benefits and wellness services, or legal services. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep that personal information confidential.
We share your personal information with the following categories of third parties:
- Service providers
- Our affiliates
- Third parties you or your agents authorize
- Government authorities, as reasonably necessary for our business purposes or as required by law
In the preceding twelve (12) months, Imagine has disclosed Categories A, B, C, and I for business purposes. In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides 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 about our collection and use of your personal information over the past 12 months, including the categories and specific pieces collected, the categories of sources, our business purposes, and the categories of third parties with whom we share that information.
Right to Receive Information on Privacy Practices
You have the right to receive, at or before the point of collection, the categories and purposes of personal information collected, whether it is sold or shared, and the intended retention period.
Right to Receive Information About Onward Disclosures
You may request information about the categories of personal information collected, sold, shared, or disclosed for a business purpose, and the categories of recipients.
Deletion Request Rights
You have the right to request that Imagine delete any of your personal information that we collected and retained, subject to specific exceptions (completing transactions, detecting security incidents, debugging, exercising free speech, complying with legal obligations, and other lawful internal uses).
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, right to receive information, deletion, and correction rights described above, please submit a verifiable consumer request by either:
- 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. You may make a 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 charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded.
We do not Sell or Share Personal Information. Further, we do not use Sensitive Personal Information for purposes beyond those authorized by the CCPA. We do not have actual knowledge that we Sell or Share Personal Information of California Consumers under 16 years of age.
Non-Discrimination
You have the right not to be discriminated against for exercising your data subject rights. We will not deny you goods or services, charge different prices, or provide a different level of quality for exercising any of your rights. Under California law, we do not provide financial incentives to California Consumers who allow us to Collect, retain, Sell, or Share their Personal Information.
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, we will post the updated notice on the Website and update the effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
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 wish to exercise your rights under California law, please contact us:
- Phone: 818-295-6100
- Website: theimaginegroup.com
- Email: [email protected]
If you need to access this Notice in an alternative format due to having a disability, please contact [email protected] or 818-295-6100.