Employee and Contractor Privacy
Employee and Contractor Privacy
Employee and Contractor Privacy Policy
Effective Date (Last Updated): June 11, 2025
Policy
Overview
This Employee and Contractor Privacy Policy (the “Privacy Policy”) contains the policies and procedures to be followed by Progressive Holdings, Inc., Progressive Leasing, LLC., and Approve.Me LLC., Vive Financial LLC, Four Technologies Inc., Prog Services, Inc., and PRGB, Inc., including their present or future affiliates and subsidiaries (the “PROG,” “Company,” “we,” “us,” or “our”), related to the collection and use of Personal Information of an applicant for employment, an Employee, a Company officer or director, or a Contractor in the United States (collectively referred to in this Privacy Policy as the “Employee/Contractor,” “you,” or “your”). Note: A “Contractor” is a non-employee who performs services for PROG and is not employed by PROG. Certain sections of this privacy policy do not apply to Contractors.
PROG wants you to understand how and why we collect “Personal Information,” which includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Employee/Contractor. Employees/Contractors should have no expectation of privacy when using technology provided by PROG or whenever accessing PROG technology resources or information.
PROG is committed to protecting the privacy of all of our Employees/Contractors, and we take administrative, technical, and physical safeguards to protect your Personal Information from unauthorized access, misuse, accidental loss, or alteration.
If you are a resident of California, please see the California Privacy Notice Addendum below for a full list of the disclosures and rights available to you under California law.
Notice of Employee/Contractor Monitoring
We may monitor telephonic and electronic conversations or transmissions, including e-mail, instant messaging or chat applications, as well as internet access, websites visited, and other activities by Employees/Contractors conducted using our systems or devices. This includes use of systems, computers, telephones, and other devices provided or maintained by the Company or by our service providers, as well as systems or applications you access using our system or devices, such as while using social media messaging and personal web-based email accounts. We may monitor these devices, services, activities, and communications to ensure safety, security, and efficiency, and to permit internal evaluations.
What Information Do We Collect?
The following chart identifies the categories of Personal Information that we may collect or process and the specific reasons for which we process each category of information. For more detailed information regarding why we process each category of information, please see the “Purposes of Collection” Section below.
Please note that we may not collect all categories of Personal Information about each Employee/Contractor. For example, if the collection of Personal Information relates to a specific benefit that is not generally available, we would only collect that Personal Information from the Employees/Contractors who are eligible for and enroll in the benefit. Additionally, when we collect a category of Personal Information, we may not collect each specific example listed.
Categories | Examples | Reasons for Collection |
|---|---|---|
A. Identifiers.
| A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. |
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B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
| A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories. |
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C. Protected classification characteristics under California or federal law.
| Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). |
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D. Commercial information.
| Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
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F. Internet or other similar network activity.
| Browsing history, search history, information on a Employee/Contractor’s interaction with a website, application, or advertisement.
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G. Geolocation data.
| Physical location or movements.
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H. Sensory data.
| Audio, electronic, visual, thermal, olfactory, or similar information.
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I. Professional or employment-related information.
| Current or past job history or performance evaluations.
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K. Inferences drawn of the Employee/Contractor.
| Inferences drawn from Personal Information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
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L. Sensitive Personal Information | Personal Information that reveals (a) Social Security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credential allowing access to an account; (c) precise geolocation; (d) racial or ethnic origin, religious or philosophical beliefs, or union membership; or (e) the contents of a Employee/Contractor’s mail, email, and text messages unless the business is the intended recipient of the communication. Biometric information processed for the purpose of uniquely identifying a Employee/Contractor, [JL1] Personal Information collected and analyzed concerning an Employee/Contractor’s health, sex life, or sexual orientation. Some Sensitive Personal Information included in this category may overlap with other categories. |
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Administering the Employee/Contractor Relationship
We collect, keep and process Personal Information for traditional employment/Contractor engagement purposes. We use this information for management and administrative uses and only disclose it with others who have a need-to-know such information. We keep and use it to enable us to run the business and manage our relationship with you effectively, lawfully, and appropriately, during the recruitment process, while you are working for us, and after your employment or contract has ended. This includes using Personal Information to enable us to comply with any legal requirements associated with an Employee or contractor relationship, to administer payroll, to provide you with benefits, ensure your safety, comply with an employment or service contract, and to demonstrate our commitment to equal employment opportunity and fair employment practices.
Comply with Legal Obligations
In certain situations, we may need to collect and process your Personal Information to comply with our legal obligations. This may include:
Tracking demographic information to confirm compliance with equal opportunity and non-discrimination policies and requirements;
Processing information relating to your health, which could include reasons for absence and doctor’s reports and notes, in order to comply with our obligations under applicable employment and safety and health laws;
Processing information regarding certifications and qualifications for your role or position;
Processing information regarding participation in employment related activities about which we are required to retain a record; and/or
Processing information relevant to any alleged violations of the Company policies to investigate allegations and institute disciplinary action as is required.
Facilitate Communications and Efficiency
The Company uses various tools and platforms that allow Employees/Contractors to communicate with each other more easily and to more efficiently access and disclose various types of work products and schedules. Some tools may also allow Employees to disclose information via social media or other channels, including information relating to job opportunities.
These tools and platforms may collect and disclose contact information and company profile pictures; log certain preferences and actions; collect your geolocation; and create user profiles that allow Employees and the Company to track their efficiency and performance. We may also have access to communications sent using Company systems and devices.
Provide Benefits
We offer Employees a variety of benefits, including benefits related to healthcare, retirement savings, and the ability to order goods and services directly from the Company. If Employees take advantage of other benefits, such as fitness-related benefits, we may also collect additional biometric and sensory information. When you participate in certain benefits programs, we may also generate a log of your activity, track internet and other network activity, and develop a user profile to provide those programs to you in a manner tailored to your preferences.
All benefits may not be available to all Employees, and the Company will only collect Personal Information to provide a benefit if the Employee is eligible for and enrolled in that benefit. Employees should take care to read the specific terms applicable to any mobile application or benefits program to understand the specific pieces of information collected.
Ensure the Safety of Employees, Contractors, Facilities, and Property
We collect various categories of information to ensure the safety of Employees/Contractors, facilities, and property. This information helps verify the identity of Employees/Contractors in specific facilities and ensure the security of facilities and Company vehicles. It may also include the collection of certain health, vaccination, or screening information when individuals enter our facilities.
Additionally, we may process certain categories of Personal Information to ensure the safety and security of our electronic systems and devices. This includes monitoring our systems for suspicious or fraudulent activity and other forms of illegal conduct. This monitoring is to ensure the safety and security of our systems and the confidential information that is entrusted to us.
Disposal of Personal Information
We take appropriate measures to ensure that your Personal Information is processed and disposed of in a manner that maintains its confidentiality. All Personal Information disposal procedures, including the disposal of computerized data storage devices, are designed to ensure the complete destruction of Personal Information and eliminate the risk of subsequent unauthorized access or disclosure.
Updates to the Privacy Policy
This Privacy Policy is subject to occasional revision, and if we make any material changes in the categories of information we collect or the reasons we collect that information, we will notify you by sending you an e-mail and/or by prominently posting notice of the changes. This Privacy Policy will also be posted to SharePoint. You can review or consult the Privacy Policy at any time.
The Company may be subject to certain laws and regulations relating to privacy and information security in more than one jurisdiction in which Employees/Contractors reside. If any term, covenant, condition, or provision of this Privacy Policy is held by a court of competent jurisdiction to be invalid, void, or unenforceable, it is the intent of this Privacy Policy that the scope of the rights and obligations of the Privacy Policy be reduced only for the affected jurisdiction and only to the extent deemed necessary under the laws of the local jurisdiction to render the provision reasonable and enforceable and the remainder of the provisions of the Privacy Policy statement will in no way be affected, impaired, or invalidated as a result.
We May Contact You Using Automated Means
During the course of our relationship, we may contact you via texting or calling using automated means such as an autodialer. Our communications with you using these methods will always directly relate to our relationship and will not include marketing or commercially promotional content.
Where Your Information is Held
We process Personal Information on our servers in the United States of America and may do so in other countries. If you use our services or otherwise provide us with information from outside of the United States, you expressly consent to the transfer of your data to the United States, the processing of your data in the United States, and the storage of your data in the United States.
Contact Us With Questions
If you have questions regarding this Privacy Policy, please contact us by email at privacy@progleasing.com, via phone at 877-898-1970, or by mail at the following address, 256 W Data Drive, Draper, UT 84020, ATTN: Privacy Office
California Privacy Notice Addendum
Last Updated: June 11, 2025
This California Privacy Notice Addendum (the “Notice”) addresses how we process the Personal Information of applicants for employment, Employees, and Contractors who are residents of California. This Notice supplements our underlying Employee and Contractor Privacy Policy to ensure compliance with the law.
If you are an Employee or Contractor residing in California, you have rights regarding how we collect and process your Personal Information under the California Consumer Privacy Act, as modified by the California Privacy Rights Act (collectively, the “CCPA”). This Addendum will provide you with a summary of the categories of information we collect, the reasons that we collect each category of information, information regarding how we may disclose your Personal Information with third parties, and information regarding your rights under the CCPA. If you have any questions, please contact us via the Contact Us section, below.
Information We Collect
In the preceding 12 months, we have collected the categories of Personal Information identified above in the “What Information Do We Collect? Section of the Employee and Contractor Privacy Policy for the purposes identified in the “Purposes of Collection” Section of the Employee and Contractor Privacy Policy.
Sources of Personal Information
We collect the majority of the information that we process about you directly from you, through the applications or forms you submit and the information you provide at the time of hiring. In addition, we may collect information about you from third parties, such as information from third parties that provide accreditation, educational institutions, benefits providers, and vendors that provide background checks or related information. Finally, we may automatically collect, store, or otherwise process information about you as you use our tools, systems, or resources.
How Your Personal Information Is Disclosed
In the preceding 12 months, we have disclosed the following categories of employment related information with service providers, who are necessary for facilitating the Employee/Contractor relationship and providing you with benefits: identifiers, personal information, protected classification commercial information, internet or similar network activity, professional or employment-related information, sensory data, inferences, and sensitive personal information. Further detail about these categories are identified above in the “What Information Do We Collect?” Section of the Employee and Contractor Privacy Policy.
We enter into written contracts with our service providers to ensure the privacy and security of your Personal Information. Under these contracts, we restrict the access to and processing of your Personal Information to that which is necessary for the purpose of the disclosure.
In certain circumstances, we may provide you with opportunities to sign up for certain benefits programs that involve the disclosure of your Personal Information to third party benefits providers. Any such program will be purely optional and based on your opt-in participation.
We process sensitive personal information as defined by California law, only for the purposes specifically authorized by California law and in a manner that is necessary and proportionate for those purposes. As such, we do not perform any processing for which a Right to Limit request is available. We also do not process any personal information related to employment regarding individuals under 16 years of age.
Individual Rights
The CCPA provides residents of California with a series of rights regarding the processing of their Personal Information. This section explains the scope of these rights and outlines how you may exercise them.
Employee/Contractor Right | Explanation |
|---|---|
Right to Know/Access | You may have the right to confirm whether we are processing your personal information, the right to know specific pieces of personal information we have collected about you, to know the categories of personal information we are processing or have processed, and the right to access that data. You also have the right to know the third parties to whom we have disclosed your personal information. |
Right of Correction | You may have the right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information. |
Right of Deletion | You may have the right to delete your personal information provided by you or obtained about you. |
Right to Restrict, Suspend, or Object | You may have the right to object to the processing of your personal information that is based on legitimate interests or your consent. |
Right of Portability | You may have the right to obtain your personal information in a portable and—to the extent technically feasible—readily usable format that allows you to transmit the data to another entity without hindrance. |
Right to Withdraw Your Consent | You may have the right to withdraw your consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal; |
Right to Opt Out | You may have the right to opt-out of the processing of your personal information for the purposes of:
At this time, we do not engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you. |
Right to Non-Discrimination | You may have the right not to receive discriminatory treatment for exercising the privacy rights conferred by law. We will not discriminate against you because you exercised any of your privacy rights. |
Submitting Requests
You may submit a request online at https://progleasing.truyo.com/, email us at privacy@progleasing.com, or call toll-free at 1-877-898-1970.
We will respond to these requests, if applicable, within 45 days of receipt of the request and without undue delay. If we need to extend this period, we will notify you of the delay and explain the reasonably necessary justifications for our delay.
We will provide responses to your requests free of charge unless exclusions apply, which we will identify in our response.
Verifying Requests
To ensure the protection of your Personal Information, we must verify that the individual submitting a request is the Employee/Contractor to whom the request relates prior to processing the request. To verify your identity, we may request up to three pieces of Personal Information about you to compare against our records.
You will not be required to create an account with us to submit a verifiable request. However, you may be required to access an existing account to the extent accessing the account is necessary.
We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request. We reserve the right to take additional steps as necessary to verify your identity where we have reason to believe a request is fraudulent.
Authorized Agents
California residents may submit rights requests through the use of an Authorized Agent to act on your behalf. If you choose to use an Authorized Agent, we require that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with us. Failure to do so may result in us denying your request.
Data Retention
We retain the information collected pursuant to the Privacy Policy during the period of active employment of the Employee or service relationship of the Contractor, as well as during the post-employment period only as long as the Personal Information is required to serve its original purpose in accordance with our internal retention standards and in compliance with applicable laws or contractual obligations. Personal Information that is no longer needed for its stated purpose will be destroyed, erased, or made anonymous.
We take appropriate measures intended to ensure that your Personal Information is processed and disposed of in a manner that maintains its confidentiality. All Personal Information disposal procedures, including the disposal of computerized data storage devices, are designed to ensure the complete destruction of Personal Information and eliminate the risk of subsequent unauthorized access or disclosure.
Contact Us
If you have questions regarding this Privacy Policy, please contact us by email at privacy@progleasing.com, via phone at 877-898-1970, or by mail at the following address, 256 W Data Drive, Draper, UT 84020, ATTN: Privacy Office