CPRA Notice at Collection for California Employees and Applicants

Last Updated: May 6, 2024

Nylas, Inc. (“We” or “Nylas”) collects and uses Personal Information from or about you (“you” or “employee”) for human resources, employment, benefits administration, health and safety, and business-related purposes and to be in legal compliance with the California Consumer Privacy Act of 2020, as amended by the California Privacy Rights Act (“CPRA”). This policy applies only to personal information we collect about you in the employment or application context; for information on our other privacy practices, please see our Privacy Policy. As used herein, “Personal Information” has the meaning given to it in the CPRA.

Personal Information We Collect

Below are the categories of Personal Information we collect and the purposes for which we intend to use this information:

• Identifying Information, such as your full name, gender, date of birth.
• Demographic data, such as race, ethnic origin, marital status, disability, and veteran or military status, if you choose to provide it.
• Contact Information, such as your home address, telephone numbers, email addresses, and emergency contact information.
• Dependent’s or other individual’s information, such as full name, address, date of birth, and Social Security numbers.
• Educational and professional background, such as your work history, academic and professional qualifications, educational records, references, if you choose to provide it in your application, along with interview notes.
• Employment details, such as your job title, position, hire dates, compensation, performance and disciplinary records, and vacation and sick leave records.
• Financial information, such as retirement account details, tax information, payroll information, and withholdings.
• Health and Safety information, such as health conditions (if relevant to your employment), job restrictions, benefits information, workplace illness and injury information, and health insurance policy information.
• Location Information, for field reporting and remote work purposes.
• Inferences, generated from any other information you voluntarily disclose to us in the course of your employment, including without limitation photographs, chats, emails, your employee profile, and other work product in any form whatsoever.

How We Collect Personal Information

We generally collect Personal Information directly from you when you apply for a position at Nylas, during the employee onboarding process, and during your employment. 

Service Providers also collect Personal Information on you on our behalf, for example:

• When you sign up for benefits, our third-party Service Providers collect health and safety information, dependent’s information, employment details, and demographic data if you choose to provide it.
• When you apply for employment, we collect background check information on you from a third-party Service Provider.
• During your employment, we use a number of third parties to help administer your benefits, payroll, and health insurance. 
• During employment, third party tools that you use will collect Personal Information. For example, our employee communications tools collect and process your messages and emails; communications services collect and process your business calls and emails; and security services may see your credentials, work product, and communications.

These Service Providers are contractually bound to only process your Personal Information as we direct them, in accordance with the CPRA. For more information on Service Providers that collect Personal Information on our behalf, see Appendix A. 

Why We Collect Personal Information

In general, Nylas collects Personal Information to use or disclose as appropriate to:

• Comply with all applicable laws and regulations.
• Recruit and evaluate job applicants and candidates for employment.
• Conduct background checks.
• Manage your employment relationship with us, including for:
  • onboarding processes;
  • timekeeping, payroll, and expense report administration;
  • employee benefits administration;
  • employee training and development requirements;
  • the creation, maintenance, and security of your online employee accounts;
  • reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill;
  • workers’ compensation claims management; and
  • employee job performance, including goals and performance reviews, promotions, discipline, and termination.
• Assist with employee productivity, such as monitoring code committed.
• Secure our systems and services.
• Manage and monitor employee access to company facilities, equipment, and systems.
• Conduct internal audits and workplace investigations.
• Investigate and enforce compliance with and potential breaches of Company policies and procedures.
• Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance.
• Perform workforce analytics, data analytics, and benchmarking.
• Administer and maintain Nylas’s operations, including for safety purposes.
• Exercise or defend the legal rights of Nylas and its employees, customers, contractors, and agents. 

How We Share Your Personal Information

We share your Personal Information with third parties as set forth in the below chart. We do not sell or share your Personal Information for value and have not done so in the previous 12 months.

Category of Personal Information Collected	Sold or Shared?	Disclosed for a Business Purpose?	Retention Period*
Identifying information	No	Yes, to database hosting, benefits, recruiting, and human resource Service Providers	4 years from date of rejection of application, upon request, or 8 years from termination date unless a different period is prescribed by applicable state law
Demographic Data	No	Yes, to database hosting, benefits, recruiting, and human resource Service Providers	For 8 years after termination
Contact Information	No	Yes, to database hosting, benefits, recruiting, and human resource Service Providers	4 years from date of rejection of application, upon request, or 8 years from termination date unless a different period is prescribed by applicable state law
Background Check Information	No	Yes, to database hosting and human resource Service Providers	6 years from the date of background check
Sensitive Personal Information, such as Government ID, Dependent’s information	No	Yes, to database hosting, benefits, and human resource Service Providers	For 8 years after termination
Financial Information	No	Yes, to database hosting and human resource Service Providers	For 8 years after termination
Professional or Education Information, Employment Details	No	Yes, to database hosting, recruiting, and IT Service Providers	For 8 years after termination
Health and Safety Information	No	Yes, to benefits, and human resource Service Providers	For 8 years after termination
Inferences	No	Yes, to human resource Service Providers	As needed or for 12 months after termination

*May differ depending on applicable state or federal law.

Your Rights and Choices

Depending on where you live, you may have the below rights with respect to your Personal Information.

• Right to Know: The right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices.
• Right to Access: The right to access the Personal Information held about you by us or on our behalf.
• Right to Request Correction: The right to request that we correct inaccurate Personal Information that we maintain about you.
• Right to Request Deletion: The right to request that we delete your Personal Information that we have collected from or about you, subject to exceptions in the CPRA and under prevailing law.
• Right to Non-Discrimination and Non-Retaliation: The right not to receive discriminatory treatment for exercising your privacy rights under the CPRA.

• Right of Portability: The right to have your Personal Information delivered to you in a standard portable form.

• Right to Opt Out of Automated Decision-Making Technologies: The right to have decisions made by automated technologies made by a human. We do not currently employ these decision making technologies for any decisions relevant to employees, but if we do, you may exercise this right.

• Right to Limit Processing of Sensitive Personal Information, as defined by the CPRA: The right to limit Nylas’s processing of your Sensitive Personal Information (e.g. your social security number, email content, health information), to the purposes authorized by the CPRA. For clarity, we only collect and use your Sensitive Personal Information to perform services for you related to your employment.

Depending on your request, we may fully or partially comply given our legal obligations or exceptions to your rights under the CPRA. For example, we cannot delete all financial information we have about you during the term of your employment because that would make it impossible to pay you; we cannot delete your social security number or email during the term of your employment for tax and recordkeeping purposes. If you are involved in a legal action with or against Nylas, we will retain Personal Information to assist us in protecting our legal rights.

If you have any questions about this Notice, want to exercise your rights, or need to access this Notice in an alternative format due to having a disability, please contact Samantha Cowan, [email protected], 608-385-2225.

Appendix A

Service Provider Collection of Personal Information

To support in the completion of their duties, Nylas uses Service Providers that may store and process personal information (ex. name, Nylas email, etc). This appendix provides important information about their identities, locations, and roles.

Subprocessor	Subject Matter	Purpose	Location(s)
Adobe	Name, work email	Document and Design Software	United States
Amazon Web Services	Name, work email, IP address	Cloud hosting	United States, EU, Canada
Apollo	Name, work email	Lead Generation	United States
Atlassian Pty Ltd	Name, work email	JIRA Ticketing	United States, Germany, Ireland, Singapore, and Australia
ChurnZero	Name, work email	Customer Support Automation	United States, United Kingdom, and Ireland
ClassMarker	Name, work email	Training	United States
Cloudflare	Name, work email, IP address	Web Application Firewall and DDoS Prevention	North America, EU
Coralogix	Name, Work email	Logging, Alerting	Switzerland, United Kingdom
Dell Financial Services LLC (Jamf)	Name, work email, IP address,	Endpoint Management	United States, Germany, United Kingdom, Australia, Japan
Docusign	Name, work email, telephone number	Electronic Document Signing	United States, EU
Drata	Name, work email	Compliance Management	United States
Emburse Inc.	Name, work email, bank account	Expense Reimbursement	United States
Eshares Inc.	Name, personal email	Options Management / Excercising	United States
Ethena	Name, work email	Training	United States
Figma	Name, work email	Product Design	United States
FirstBase	Name, work email, address	Inventory Management	United States
Fivetran	United States (US), Canada, European Union (EU), United Kingdom (UK), and Asia-Pacific (APAC) regions	Data Movement	United States (US), Canada, European Union (EU), United Kingdom (UK), and Asia-Pacific (APAC) regions
Gong.io	Name, work email	Video Call Recording	United States
Goodhire	Name, email, background check information	Background Checks	United States
Gravitational Inc.	Name, work email, IP	Access Control	United States
Greenhouse	Name, personal email, hiring information, IP address	Recruiting	United States
Guideline	Name, personal email	401k Management	United States
Google	Name, work email, IP address	Email API	United States, EU, Canada
Google Cloud Platform	Name, work email, IP address	Cloud hosting	United States, EU, Canada
Google Workspaces	Name, work email, IP address	Email, Documents, Spreadsheets, Slides, Drive	United States
HackerOne	Name, work email, IP address	Application Testing	United States
Harness	Name, work email	Access Controls	United States
Heroku	Name, work email	Backups	United States
Honeycomb.io	Name, work email	Observability / Logging	United States
Hubspot	Name, work email	Communication	United States
Jellyfish	Name, work email, github account	JIRA / Github Productivity	United States
Ketch	Name, work email, IP	Cookie Consent Management	United States
KnowBe4, Inc.	Work email	Phishing Simulation	United States
Kong Inc.	Name, work email, IP	API Gateway	United States, EU
Lattice	Name, work email	Collaboration	United States
Looker	Name, work email	Analytics	United States
Loom	Name, work email	Internal Video Hosting and Sharing	United States
Mailgun	Name, work email	Transactional Email	United States, EU
Microsoft	Name, work email	MS Office / Email API	United States, Ireland
New Relic	Name, work email	Observability, Logging	United States
PagerDuty	Name, work email, phone numbers	Calls, Paging	United States
Pave	Name, work email, compensation information	Compensation Platform	United States
Pipedrive	Name, work email	Pipeline CRM Tool	United States, EU
Postman	Name, work email	API Testing Utility	United States
ProductBoard, Inc.	Name, work email	Project Management and Customer Request Management	United States
Recurly Inc.	Name, work email	Billing and Subscriptions	United States, EU
Retool Inc	Name, work email	Low-code internal app generator	United States, EU
Rewatch	Name, work email	Video Knowledge Base	United States
Rippling	Name, work email, personal email, banking, telephone numbers	Human Resources-related Functions and Payroll Processing	United States
Rootly, Inc.	Name, work email	Incident Management via Slack	United States
Salesforce	Name, work email	Customer Relationship Management	United States
Salesloft	Name, work email, telephone number	Sales Engagement Platform	United States, EU
SeekOut	Name, work email	Talent Aquisition and Management	United States
Slack	Name, work email, telephone number	Messaging	United States
Snyk	Name, work email	Real-time security & compliance monitoring	United States
Sora	Name, work email, personal email	Onboarding and Questionnaires	Switzerland
Stripe	Name, work email	Credit Card Processing	United States
Tropic	Name, work email	Procurement Platform	United States
Twilio Segment	Name, work email	Customer Data Platform	United States
Whimsical	Name, work email	Flowchart Tooling	United States
Woopra	Name, work email	Usage Analytics	United States
Zendesk	Name, work email	Ticketing Platform	United States, EU
Zesty	Name, work email	Reserved Instance Management	United States, Ireland
ZoomInfo – REMOVE APRIL 1	Name, work email	B2B Lead Generation	United States