Sequoia
Sequoia

Privacy Notice to Sequoia Employees and Independent Contractors

Updated June 17, 2025

  1. Notice. Sequoia Benefits and Insurance Services, LLC and its affiliates (collectively, “Sequoia”, “we” “us” or “our”) is required by certain state laws, including California Civil Code Sec. 1798.100 et seq. and Sec. 1798.145(m)(3), to provide employees and independent contractors (“Sequoia Personnel”, “you”, “yours” or “your”) you with notice (this “Notice”) about how we collect and use your personal information (“PI”). This includes how the information collected during your employment or engagement at Sequoia, is used and how you can access and correct certain information that we may collect. This Notice applies to information obtained or disclosed in connection with your employment or independent consulting engagement with Sequoia. Please note that this Notice does not apply to information publicly available from any government agency, deidentified or aggregated information, or information covered by another state or federal law such as the Gramm-Leach-Bliley Act.
  2. Alternative Format. This Notice can be provided in audio format by contacting contactus@sequoia.com.
  3. Categories of PI We Collect. We collect the following categories of information on Sequoia Personnel:
    Identifiers Including your first name, middle name, and surname, former names, and aliases, social security number, passport number, driver’s license number, or other similar identifiers
    Contact Information Including address, phone numbers, and email
    Records Information Including signatures, identification card numbers, employment status, bank account information, salary expectation information, insurance information, medical and health information
    Protected Classifications Including age over 40 years, race, ancestry, national origin, citizenship, religion, disability or other physical or mental conditions, gender, veteran status, and requests for family medical, parental, disability, or sick leave
    Biometric Information Including physical or biological characteristics, faceprints, or related data
    Internet and Electronic Activity Including browsing history, cookies, caches, searches, use of websites, applications, logins, credentials, ISP, and geolocations associated with Sequoia systems, applications, and devices, and your access to Sequoia physical locations, such as badging data, and Sequoia Workplace data
    Job Application Data Including resume, cover letter, references, prior employment history, prior employer obligations, educational background, licensures, credentials and certifications, professional credentials and qualifications, job skills, and other job-related information
    Professional Qualifications Including educational background, licensures, credentials and certifications, professional credentials and qualifications, job skills, and other job-related information;
    Biographical Information Including date of birth, nationality, gender, and professional qualifications, including where you make such information available on social networking profiles such as LinkedIn
    Employment History Including positions held, companies, salary, role, job description, and locations, performance evaluations, photos, payroll history, company device usage, and any information captured on company video, audio, or device monitoring, history, or logs
    Background Check Information Such as criminal background and credit information, where permissible by law
    Sensory Data Audio records, including voicemails, thermal scans at office locations utilizing Sequoia Workplace, and related data
    Other Information Such as other PI collected during employment including personal preferences, characteristics, behaviors, attitudes, abilities, and aptitudes
  4. Sources of PI. We collect PI from you during the application process, along with other sources available to us. This may include the following sources of information such as the following: (i) pre-employment screening and recruiting services, such as recruiters or placement agencies; (ii) prior employers that provide employment verification or history; (iii) references that you authorize us to contact on your behalf; (iv) third-party job posting and recruiting websites; (v) your university or other educational institution; (vi) publicly available online information about you such as on social media or the internet; (vii) your online activity on the www.sequoia.com website; and (viii) Sequoia personnel that you may communicate with during the recruiting process; (ix) your activity on any Sequoia website or device; (x) from Sequoia employees, consultants, vendors, or customers that you may interact with; (xi) your work product; (xii) your performance evaluations, reviews, feedback, evaluations, and similar processes; (xiii) your communications with and the information you provide to Sequoia third-party vendors.
  5. Purposes of Data Collection. We collect data on Sequoia Personnel for the following purposes: (i) employment, including in the hiring, interaction, and management of employees, and promotion of employee retention, health and safety; (ii) provision of benefits services to Sequoia Personnel, including providing employee benefits services such as health, vision, or dental insurance, 401(k) and other retirement benefits, paid time off, absence or other leave; (iii) reimbursement of Sequoia Personnel expenses; (iv) accommodating disabilities and health status of Sequoia Personnel; (v) in related human resources and employment business operations; (vi) in connection with recruiting, hiring, evaluation, performance review, promotion, and termination of employees; (vii) compliance with state and federal employment laws related to employment, recruiting, hiring, evaluation, performance review, promotion, and termination of employees, and compliance with local, state, and federal employment laws, rules, and obligations; (viii) compliance with internal company policies and priorities, including promotion of the company’s culture, priorities, and values; (ix) compliance with requests and legal obligations from government agencies, including the company and any individual Sequoia Personnel’s licensure, maintenance of licensure requirements, or other government requirement for the performance of the company’s services, or right to work in the United States or other country; and (x) protecting the rights, safety, privacy, and security of the Sequoia Personnel, the company, the company’s business activities, its vendors, and customers.
  6. Disclosure of PI. We may share your PI with the following: (i) Company subsidiaries and affiliates, including those under common control or operations; (ii) Service providers, including those that provide services to Sequoia and on behalf of Sequoia to Sequoia Personnel, such as employee health and wellness benefits service providers, in our recruiting and interviewing processes such as third party recruiters, interviewers, testing companies, pre-employment screening providers, relocation companies, travel providers, providers of other recruitment related services, professional services providers such as accounting firms, immigration advisors, and law firms, and artificial intelligence (“AI”) providers; (iii) government agencies for purposes of compliance with regulatory or legal obligations; and (iv) In the event of business transactions, such as mergers or acquisitions, divestiture, sale of assets, acquisition, dissolution, bankruptcy or change of control event.
  7. How We Share Your Data. In the past twelve (12) months, Sequoia has collected and shared the above PI for the aforementioned purposes the following categories of information: Identifiers, Contact Information, Record Information, Protected Classifications, Biometric Information, Internet and Electronic Activity, Job Application Data, Professional Qualifications, Biographical Information, Employment History, Background Check Information, Sensory Data, and Other Information. Such information has been shared with our affiliates, vendors, and service providers, third parties who provide professional services such as accounting firms, immigration providers, and law firms, third parties to who you advise us to disclose on your behalf, such as health and wellness providers, and government agencies to comply, maintain, or otherwise conduct with Sequoia’s business activities.
  8. De-identified Data. We may also aggregate, anonymize, or otherwise de-identify your data to use and disclose for our business operations. Where we use, disclose or process de-identified data we will maintain and use the data in de-identified form and not to attempt to re-identify the data, except as permitted by applicable privacy laws.
  9. Sequoia Personnel Privacy Rights. We provide Sequoia Personnel with the privacy rights described in this section. You have the right to exercise these rights via an authorized agent who meets the agency requirements of under applicable state law and related regulations, and any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”) via email, phone number or address listed below. This process may consist of, but is not limited to, our verifying your identity through established protocols, or our asking you to confirm information previously submitted to Sequoia. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the person about whom we collected PI. If we cannot comply with a request, we will explain the reasons in our response. You are not required to create an account with us to make a Verifiable Consumer Request. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses unless you also gave it to us for another purpose.
  10. Response to Requests. We will make commercially reasonable efforts to identify PI that we collect, process, store, disclose and otherwise use and to respond to your requests. We reserve the right to direct you to where you may access and copy responsive PI yourself. If your request is excessive, repetitive, unfounded, or overly burdensome, we may determine that the request warrants a fee, or we may refuse it, and we will give you notice explaining why we made that decision. In such case, you will be provided with a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.
  11. Your Rights. Your rights include the right to send us a request, no more than twice in a twelve (12) month period, for any of the following:
    1. The Right to Know. You have the right to know the following: (i) the categories of PI we have collected about you; (ii) the categories of sources from which we collected your PI; (iii) the business or commercial purposes for our collecting or selling your PI; (iv) the categories of third parties to whom we have shared your PI; (v) the specific pieces of PI we have collected about you; (vi) the right to make or obtain a transportable copy; (vii) a list of the categories of PI disclosed for business purposes, or that no disclosure occurred; and (viii) list of the categories of PI sold about you, or that no sale occurred.
    2. Right to Correct Information. Except to the extent, we have a basis for retention under the law, you may request that we correct your PI that we have collected directly from you and are maintaining.
    3. Right to Delete Information. Except to the extent, we have a basis for retention under the law, you may request that we delete your PI that we have collected directly from you and are maintaining. Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. Note also that we are not required to delete your PI that we did not collect directly from you.
    4. Right to Non-Discrimination. You have the right to non-discrimination based on your exercise of privacy rights. We will not discriminate against you in a manner prohibited by law because you exercise your privacy rights.
    5. Right to Notice of Additional Disclosures. You may also request information regarding additional disclosure of your PI, including as defined by certain state laws such as California Civil Code Sec. 1798.83, (California’s “Shine the Light” law), to a third party for that party’s direct marketing purposes. We do not disclose Candidate information to third parties for direct marketing purposes.
    6. Right to Opt Out. You have the right to opt out of sale of your PI. We do not sell your PI. Accordingly, we do not offer an opt-out of the sale of PI.
  12. Exclusions. Notwithstanding anything to the contrary, we may collect, use, and disclose your PI as required or permitted by applicable law and this may override your privacy rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.
  13. Systems Monitoring. Sequoia may monitor its systems for any lawful purpose, including but not limited to cybersecurity, workplace and business management, and systems operations and maintenance, subject to local law. For more information please review Sequoia’s Acceptable Use and Systems Monitoring Policy which is incorporated by reference and can be found in ADP.
  14. Use of Artificial Intelligence. Sequoia may use AI technologies, including tools provided by third-party AI service providers, to support employment-related activities, improve business operations, systems monitoring, and to provide a better experience to Sequoia Personnel. These tools may process your PI to provide their services and any PI processed by these tools is handled in accordance with applicable labor, anti-discrimination, and data protection laws. Sequoia maintains safeguards to ensure transparency, accuracy, and fairness. Sequoia does not use AI for decisions that produce legal or similarly significant effects without human oversight. You have the right to request information about how AI may be used in connection with your employment and to contest any decisions made through automated means.
  15. Changes to Notice. Sequoia reserves the right to change the contents of this Notice at any time. The date at the top of this Notice indicates the date when it was last revised. You should check this site to confirm any changes.
  16. Contact Information and Making Requests. Sequoia welcomes questions and comments about this Notice and your California privacy rights. Questions, comments, and requests should be directed to Sequoia’s privacy policy compliance department as follows:
    Via email: dataprivacy@sequoia.com
    Via phone:  1-650-369-0200
    Via U.S. Mail:
    Sequoia Benefits and Insurances Services, LLC
    1850 Gateway Drive
    Suite 700
    San Mateo, CA 94404