Privacy Notice for California Residents

1. Categories of Personal Information Collected

Delphia collects (and in the past 12 months has collected) the following categories of personal information:

• Identifiers: Name, business name, postal address, email address, phone number, account login credentials, IP address, or similar identifiers.

• Professional or Employment Information: Job title, company, role, and employment history.

• Commercial Information: Records of products or services purchased, obtained, or considered.

• Internet or Network Activity: Browsing history, search history, and interactions with Delphia’s website, applications, or advertisements.

• Device/Technical Information: Device type, operating system, approximate geolocation, and metadata from use of Delphia applications.

• Inferences: Information drawn from other personal information to create a profile (e.g., product preferences).

• Sensitive Personal Information (depending on services provided):

  • Government identification data (such as Social Security numbers, driver’s license, or passport numbers for I-9 verification and other compliance).

  • Biometric data (such as fingerprint, facial recognition, or other data used in time clocks or secure system access).

  • Precise geolocation data (when employers or clients use geofencing technology in time and attendance systems).

  • Health and benefits information (such as data provided for health insurance enrollment, benefits elections, and related administration).

2. Sources of Personal Information

Delphia collects personal information from:

• Individuals directly (forms, registrations, transactions, communications).

• Devices when using Delphia websites and applications (cookies, analytics, geofencing).

• Employers and clients using Delphia’s HR, payroll, and benefits solutions.

• Service providers, partners, and public sources.

3. Purposes for Collection and Use

Delphia uses and discloses personal information for the following business or commercial purposes:

• To provide, support, and improve applications, products, and services.

• To process transactions and payments.

• To administer HR, payroll, timekeeping, and benefits services on behalf of clients.

• To verify employment eligibility (e.g., I-9 compliance).

• To provide location-based timekeeping services (e.g., geofencing clock-ins).

• To maintain security and prevent fraud.

• To perform analytics, benchmarking, and research.

• To comply with legal and regulatory obligations.

• To send marketing communications (with opt-out options).

4. Disclosure of Personal Information

In the past 12 months, Delphia has disclosed personal information to:

• Service providers and vendors (e.g., hosting, payment processors, analytics, HR/payroll integrations).

• Business partners and resellers who help deliver Delphia’s services.

• Regulators or law enforcement when required by law.

• Employers/clients (when individuals are employees or participants in their HR/payroll/benefits systems).

Delphia does not sell personal information for monetary consideration. However, under CPRA definitions, Delphia may “share” personal information with third parties for cross-context behavioral advertising.

California residents have the right to opt out of this sharing. To exercise this right, visit Delphia’s [“Do Not Sell or Share My Personal Information” link] (insert URL).

5. Retention of Personal Information

Delphia does not generally retain client employment or HR data after the termination of services. The legal obligation to preserve employment, payroll, I-9, or benefits records rests with Delphia’s clients (the employers), not with Delphia as the service provider.

When a client relationship ends, Delphia requires the client to extract and preserve their data. Delphia does not retain that data unless the client:

• Contracts with Delphia to store data on their behalf, or

• Engages Delphia to assist with data extraction.

Delphia may retain limited categories of personal information for its own business purposes, as follows:

• Customer account and transaction records: 7 years.

• Marketing contact information: until opt-out or request for deletion.

• Website analytics and technical logs: up to 24 months.

If a client elects to pay for data storage, Delphia retains the data only as specified in the service agreement.

6. Rights Under CPRA

California residents have the following rights (subject to verification and applicable exceptions):

• Right to Know the categories of personal information collected, the sources, purposes, and categories of third parties disclosed to.

• Right to Access the specific personal information held.

• Right to Delete personal information, subject to legal and contractual exceptions.

• Right to Correct inaccurate personal information.

• Right to Opt Out of Sale or Sharing of personal information.

• Right to Limit Use of Sensitive Personal Information to what is necessary for core services (e.g., verifying employment eligibility, processing payroll, administering benefits).

• Right to Non-Discrimination for exercising privacy rights.

7. Exercising Rights

California residents may exercise their rights by contacting Delphia through:

• Phone: 1-888-421-2004

• Email: privacy@delphiaconsulting.com

Delphia will confirm receipt of requests within 10 business days and respond within 45 calendar days (with extensions permitted by law). Additional information may be required to verify identity before fulfilling a request.

8. Changes to This Notice

Delphia may update this Notice from time to time. When updated, the “Last Updated” date above will be revised accordingly.

9. Contact Information

For questions about this Notice or Delphia’s privacy practices, please contact:

Delphia Consulting, LLC
1550 Old Henderson Road, Ste 227
Columbus, Ohio 43220
Email: privacy@delphiaconsulting.com
Phone: 1-888-421-2004