US Workforce Privacy Notice
Brilliant Gifts LLC d/b/a Brilliant
Effective Date: June 24, 2026
Brilliant Gifts LLC, doing business as Brilliant (“Brilliant,” “we,” “us,” or “our”), provides this Workforce Privacy Notice to explain how we collect, use, disclose, retain, and protect personal information about people in our workforce.
This Notice applies to U.S.-based job applicants, candidates, employees, former employees, contractors, consultants, temporary workers, interns, officers, directors, owners, emergency contacts, dependents, beneficiaries, references, and other people whose personal information we collect in connection with recruiting, employment, contractor, payroll, benefits, security, or human-resources activities.
This Notice is meant to be practical. We collect workforce information because we need it to recruit, hire, pay people, provide benefits, run the business, protect our systems and facilities, comply with the law, and manage our workforce.
Some states provide additional rights or require additional disclosures. The California section below applies to California residents. The biometric data section below applies more broadly, and is especially important for Illinois workforce members.
This Notice applies only to workforce-related personal information. Other personal information may be covered by our general Privacy Policy.
We may update this Notice from time to time to reflect changes in our practices, systems, legal obligations, or business operations.
If we make material changes, we will provide notice as required by applicable law. The effective date above shows when this Notice was last updated.
The personal information we collect depends on your relationship with Brilliant, your role, your location, the systems you use, and applicable legal requirements.
We may collect the following categories of information:
Identifiers
Name, alias, postal address, personal email address, work email address, phone number, Social Security number, driver’s license number, passport number, employee ID, account username, online identifier, IP address, emergency contact information, and similar identifiers.
Payroll, tax, and financial information
Bank account information, direct deposit information, tax forms, payroll records, compensation information, bonus or commission information, expense reimbursement information, garnishments, deductions, and related records.
HR, recruiting, and employment information
Job applications, resumes, CVs, cover letters, work history, references, background-check information where permitted, interview notes, offer information, employment or contractor agreements, job title, department, manager, compensation, performance reviews, disciplinary records, training records, promotions, transfers, work product, separation information, and related personnel records.
Protected classification information
Age, date of birth, sex, gender, pregnancy or related medical condition, marital status, military or veteran status, disability information, race, ethnicity, national origin, citizenship, and other information required or permitted for equal employment opportunity, benefits, accommodations, leave, or legal compliance.
Benefits, leave, health, and accommodation information
Benefits enrollment information, dependent or beneficiary information, leave records, disability or accommodation information, workers’ compensation information, health-related information provided for employment purposes, and similar records.
Education and credentials
Education history, degrees, transcripts, certifications, licenses, training records, professional credentials, and verification information.
Commercial or transaction information
Expense reports, corporate card activity, travel or event participation, equipment and asset records, work-related purchases, and reimbursement records.
Internet, device, and system activity
Device identifiers, IP addresses, log-in activity, access logs, browser information, usage of Brilliant systems, applications, email, messaging tools, collaboration tools, security tools, and other electronic resources.
Geolocation and work-location information
Approximate location inferred from IP address, work location, time-zone information, travel-related location information, and, where applicable, location information associated with company devices, applications, security tools, or timekeeping tools.
Audio, electronic, visual, and similar information
Photographs, video footage, call recordings, voicemail, meeting recordings, security camera footage, profile images, chat messages, emails, transcripts, summaries, and other electronic communications.
Call recording, transcription, and conversation analytics information
Audio and video recordings of sales calls, customer calls, demos, meetings, and other business communications; transcripts; summaries; call metadata; participant names and contact information; meeting information; CRM information; email and calendar information; coaching notes; and analytics generated from those communications.
Inferences and evaluations
Information derived from other workforce information to evaluate job fit, skills, performance, preferences, abilities, workplace needs, coaching opportunities, sales activity, customer interactions, or similar employment-related matters.
Sensitive personal information
Social Security number, driver’s license number, passport number, state ID number, account login credentials, financial account information, precise geolocation where applicable, racial or ethnic origin, religious beliefs where voluntarily provided or legally relevant, union membership where applicable, health information, disability or accommodation information, leave information, and other information treated as sensitive under applicable law.
Brilliant does not collect every category of information from every person.
We may collect personal information from:
We may collect, use, disclose, and otherwise process workforce personal information for the following purposes:
Recruiting and hiring
To identify candidates, evaluate applications, conduct interviews, verify qualifications, perform background checks where permitted, communicate with candidates, make hiring decisions, and onboard new team members.
Employment and contractor administration
To manage employment, contractor, consulting, internship, and temporary-worker relationships; maintain personnel records; administer policies; manage work assignments; and support day-to-day workforce operations.
Payroll, compensation, expenses, and taxes
To process payroll, wages, bonuses, commissions, incentive compensation, expense reimbursements, tax withholding, tax reporting, garnishments, deductions, and related financial administration.
Benefits and leave administration
To administer health, dental, vision, retirement, insurance, wellness, leave, disability, accommodation, workers’ compensation, and other benefit programs.
Performance, training, and workforce management
To conduct performance reviews, set goals, manage promotions, transfers, discipline, investigations, training, workforce planning, succession planning, restructuring, and separations.
Sales, customer, and account operations
To manage sales activity, customer relationships, account handoffs, demos, customer communications, pipeline reporting, forecasting, sales coaching, call review, quality assurance, and customer experience.
Call recording, transcription, and conversation analytics
To record, transcribe, summarize, analyze, and review business calls, demos, meetings, emails, and related communications for training, coaching, quality assurance, sales operations, customer support, recordkeeping, compliance, business analytics, and account management.
Legal and compliance purposes
To verify work authorization and comply with employment, labor, tax, immigration, occupational safety, benefits, privacy, security, anti-discrimination, wage-and-hour, accounting, audit, and regulatory obligations.
Security, fraud prevention, and asset protection
To protect Brilliant personnel, systems, facilities, equipment, accounts, confidential information, intellectual property, data, and assets; prevent fraud, misuse, security incidents, unauthorized access, and unlawful activity; and investigate potential violations.
IT, systems, and communications
To provide and manage access to email, messaging, collaboration tools, business systems, devices, networks, software, applications, security tools, and other electronic resources.
Remote work and distributed operations
To support remote work, manage equipment, coordinate time zones and work schedules, secure remote access, administer collaboration tools, and maintain business continuity.
Workplace communications and culture
To communicate with you, provide announcements, maintain internal directories and organizational charts, administer surveys and events, and support employee engagement.
Health, safety, and emergencies
To support workplace safety, respond to emergencies, maintain emergency contact information, manage illness, injury, accommodations, workplace incidents, travel safety, and business continuity.
Business operations and transactions
To manage Brilliant’s business operations, reporting, analytics, budgeting, forecasting, audits, insurance, corporate transactions, mergers, acquisitions, financings, restructurings, and legal claims.
We use sensitive personal information only for workforce-related and legally permitted purposes, including:
We do not use sensitive personal information to infer characteristics about workforce members except where permitted by law and necessary for legitimate workforce purposes.
Brilliant may use ordinary photographs, video footage, call recordings, meeting recordings, transcripts, summaries, and similar information for legitimate workforce purposes, including timekeeping, identity verification, security, facility safety, training, coaching, sales operations, customer support, account management, compliance, recordkeeping, and workplace operations.
For example, Brilliant may use timekeeping tools that capture a photograph when an employee clocks in or out. Brilliant may use security cameras in certain facilities. Brilliant may also use tools such as Gong to record, transcribe, summarize, analyze, and review sales calls, customer calls, demos, meetings, emails, and related business communications.
Brilliant does not use facial recognition, face matching, fingerprint scanning, hand-geometry scanning, iris scanning, voiceprint identification, speaker biometric identification, voice-based authentication, or other biometric identification tools for workforce members.
A photograph, ordinary security video, call recording, or meeting transcript is not, by itself, the same as a biometric template. The issue is whether a system uses an image, recording, or other physical characteristic to create or derive a biometric identifier, such as a faceprint, facial-geometry template, fingerprint template, iris scan, voiceprint, or similar identifier used to identify or verify a person.
If Brilliant ever decides to collect or use biometric identifiers or biometric information, we will first provide any legally required notice, obtain any legally required consent, and implement any required retention, destruction, security, and vendor controls.
No Brilliant employee or administrator should enable, test, purchase, install, or configure facial recognition, fingerprint, hand scan, iris scan, voiceprint, speaker biometric identification, voice-based authentication, face match, face verification, biometric timeclock, biometric access control, or similar features without Legal approval first.
This section applies to Illinois workforce members.
Illinois law regulates the collection, use, disclosure, retention, and destruction of biometric identifiers and biometric information. Biometric identifiers may include fingerprints, voiceprints, retina or iris scans, and scans of hand or face geometry. Photographs are not biometric identifiers by themselves.
Brilliant does not currently collect, capture, purchase, receive through trade, or otherwise obtain biometric identifiers or biometric information from Illinois workforce members.
Brilliant does not currently use biometric timekeeping, facial recognition, fingerprint scanning, hand-geometry scanning, iris scanning, voiceprint identification, speaker biometric identification, voice-based authentication, or other biometric identification tools for Illinois workforce members.
Brilliant may use non-biometric tools for ordinary workforce operations, including clock-in photos, security video, call recording, transcription, meeting summaries, conversation analytics, and similar tools. These tools are not used by Brilliant to create or use biometric identifiers or biometric templates to identify or verify Illinois workforce members.
If Brilliant ever decides to collect or use biometric identifiers or biometric information from Illinois workforce members, Brilliant will first:
This section is not permission to enable biometric features. Any proposed biometric tool or setting must be reviewed and approved by Legal before use.
We may disclose workforce personal information to the following categories of recipients:
We do not sell workforce personal information for money.
We also do not sell or share workforce personal information for cross-context behavioral advertising as those terms are used under the California Consumer Privacy Act.
We retain workforce personal information for as long as reasonably necessary for the purposes described in this Notice, unless a longer retention period is required or permitted by law.
How long we keep information depends on factors such as:
When personal information is no longer reasonably needed, we delete, de-identify, aggregate, or otherwise dispose of it in accordance with our policies and applicable law.
We use reasonable administrative, technical, and physical safeguards designed to protect workforce personal information from unauthorized access, disclosure, alteration, loss, misuse, or destruction.
No security measure is perfect, and we cannot guarantee absolute security.
This section applies to California residents.
Subject to legal limitations and exceptions, California workforce members may have the following rights under the California Consumer Privacy Act:
Right to know/access
You may request information about the personal information we collect, use, disclose, sell, or share about you.
Right to obtain a copy
You may request a copy of specific pieces of personal information we maintain about you.
Right to delete
You may request deletion of personal information we collected from you, subject to exceptions.
Right to correct
You may request correction of inaccurate personal information.
Right to opt out of sale or sharing
You may opt out of the sale or sharing of personal information. As stated above, we do not sell or share workforce personal information.
Right to limit use and disclosure of sensitive personal information
You may request that we limit use or disclosure of sensitive personal information where required by law. We use sensitive personal information only for legally permitted workforce purposes.
Right to non-discrimination and non-retaliation
We will not discriminate or retaliate against you for exercising privacy rights.
Depending on where you live, you may have additional privacy rights under applicable state law. If you submit a privacy request, we will evaluate and respond to it based on the law that applies to you.
To submit a privacy request, contact us at:
Please include “Workforce Privacy Request” in the subject line and describe the right you want to exercise.
If you are a California resident, please include “California Workforce Privacy Request” in the subject line if possible.
We may need to verify your identity before responding. Depending on the request, we may ask for your name, email address, relationship to Brilliant, or other information reasonably necessary to verify your identity.
You may designate an authorized agent to submit a request on your behalf where permitted by law. We may require proof that the agent is authorized to act for you and may require you to verify your identity directly with us, as permitted by law.
We will respond to privacy requests in accordance with applicable law.
If you have questions about this Notice or our workforce privacy practices, contact us at:
Brilliant Gifts LLC
Email: [email protected]
The business responsible for workforce personal information covered by this Notice is Brilliant Gifts LLC.