Applicant Privacy Notice

California Applicant Privacy Notice

Last Updated: January 1, 2023

This California Applicant Privacy Notice (“Applicant Notice”) describes our information practices relating to applicants and candidates for employment with EmployBridge Holding Company, or our affiliates or subsidiaries (“EmployBridge,” “we,” “our,” “us,” or the “Company”) who are California residents (each an “Applicant” or “you”). This Applicant Notice is intended to satisfy the requirements of the California Consumer Privacy Act (as amended by the California Privacy Rights Act of 2020) (collectively “CCPA”).

1. Scope and Relation to Other Policies

This Applicant Notice applies to the Personal Information we collect about our Applicants. This Policy supplements other agreements, including any Non-Disclosure Agreement(s), if applicable. This Applicant Notice applies to any information that identifies, relates to, describes, is reasonably capable of being associated, or could reasonably be linked, directly or indirectly, with you (subject to some exemptions under the CCPA) (“Personal Information”). Note, our information practices may vary depending upon the circumstances, such as the location or role for which you are applying.

This Applicant Notice does not address or apply to our information practices that are not subject to the CCPA, such as:

• Business Information. Company or business information that constitutes trade secrets, proprietary information, intellectual property, company property, information that includes or affects the rights of other employees, privileged or investigative materials, or information that helps ensure security and integrity of company assets.
• Publicly Available Information. Information that is lawfully made available from government records, information we have a reasonable basis to believe is lawfully made available to the general public by you or by widely distributed media, or by a person to whom you have disclosed the information and not restricted it to a specific audience.
• Deidentified Information. Information that is deidentified in accordance with applicable laws.
• Aggregated Information. Information that relates to a group from which individual identities have been removed.
• Protected Health Information. Information governed by the Health Insurance Portability and Accountability Act or California Confidentiality of Medical Information Act.
• Activities Covered by the Fair Credit Reporting Act. This includes information we receive from consumer reporting agencies that are subject to the Fair Credit Reporting Act, e.g., information contained in background check reports we obtain as part of our vetting process.

This Notice also does not apply to the Personal Information we collect from our clients, associates, colleagues, or our Applicants in the context of their personal use of our products and services, which are subject to different notices. For additional information on our general privacy practices, please visit our website Privacy Policy.
Our information practices may vary depending upon the circumstances, such as the location or the role for which you are applying. Also in some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain Personal Information. We may also provide Applicants additional notices about our information practices covered by other laws (e.g., if we conduct a background check).

2. Personal Information We Collect

The following identifies the categories and types of Personal Information we may collect about Applicants (and may have collected in the last 12 months).

• Identifiers. Such as name, date of birth, mailing address, personal email address and personal phone number.
• Protected Classifications. Such as age, race, ancestry, national origin, citizenship, marital status, pregnancy, medical condition, physical or mental disability, sex, veteran or military status and other characteristics of protected classifications under California or federal law. This information is generally collected on a voluntary basis and is used in support of our equal opportunity and diversity and inclusion efforts, as well as any reporting obligations where otherwise required by law.
• Professional or Employment-Related Information. Such as employment history, including job title, qualifications so we can place you in a job that you are qualified to do. We may also collect licensing, disciplinary record, assessment records, resumes, cover letters, conduct information (including disciplinary and grievance records, and termination data.
• Education Information. Such as your education records, including grades, transcripts, student disciplinary records, or any other information about education history or background that is not publicly available personally identifiable information you choose to provide.
• Internet or Other Electronic Network Activity Information. Such as network activity information or usage data including, browsing history, search history, clickstream data, as well as interactions with our portals, websites, applications, and platforms, and other network activity information related to your interactions with us.
• Geolocation Data. In some circumstances, we may collect general location data derived from a device.

3. Where We Get Your Personal Information

We generally collect the categories of Personal Information identified above from the following categories of sources:

• Directly from you;
• Recruiters and recruiting platforms;
• Former employers (with your prior permission);
• Our service providers, representatives, and agents; and
• Any references you provide.

4. Why We Collect Personal Information

We generally collect Personal Information as reasonably necessary for the following business or commercial purposes, as permitted by applicable laws:

• Recruiting and Hiring. We use Personal Information from your application and through the interview process to evaluate your qualifications and eligibility for employment. This includes identifying Applicants, scheduling interviews, conducting background checks, evaluating qualifications, extending offers, communicating with Applicants, maintaining Applicant information for future consideration, and supporting our equal opportunity employment practices.
• Defending and Protecting Rights. To protect and defend our rights and interests and those of third parties, including to manage and respond to Applicant and other legal disputes, to respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, including without limitation, EmployBridge’s trade secrets and other intellectual property, and protecting the rights, property, and reputation of EmployBridge and its workforce, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.
• Compliance with Legal Obligations. Related to our compliance with applicable legal obligations (such as determining hiring eligibility or responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, Social Security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions and guidance.
• Use of Sensitive Personal Information. Our collection, use, and disclosure of sensitive personal information is limited to what is reasonable and proportionate to employ you for example, complying with our legal, regulatory and reporting obligations.
• Securing our Premises. We may also use Personal Information to secure our offices, premises, and physical assets, including electronic access systems if Applicants visit a EmployBridge location for interviews and screening.

5. Disclosure of Personal Information

A. Purposes for Disclosing Personal Information

We may disclose the categories of Personal Information we collect for the purposes described above and for the following business purposes.

• Evaluate Candidacy. We may disclose Personal Information when it is necessary to provide services you request and where it is necessary to identify Applicants, schedule interviews, and otherwise evaluate your qualifications and eligibility for employment.
• Protection of Us and Others. We may disclose Personal Information if required to do so by law, to protect rights, property, or safety of our other associates, workers and contractors, our owners, members, and guests, ourselves or others; or where we have a legitimate interest in doing so.
• Compliance and Legal Obligations. If required to do so by law or subpoena, or if we reasonably believe such action is necessary to comply with the law, judicial proceeding, court order, or the reasonable requests of regulators, law enforcement or other public authorities.
• Other Disclosures. We may disclose Personal Information to others and in ways not described above if we give you notice and/or obtain your consent.

B. Categories of Recipients

We may disclose Personal Information to the following categories of recipients:

• Affiliates, Subsidiaries and Business Partners. We may disclose Personal Information to our corporate affiliates, subsidiaries and business partners where necessary to administer the working relationship, conduct our business, or for business operations purposes.
• Service Providers. We may disclose Personal Information to our service providers who perform services on our behalf, such as recruiters or recruitment platform providers. Our service providers are required to take appropriate security measures to protect your Personal Information in line with our policies and are not permitted to use Personal Information for their own purposes.
• Regulatory and Government Entities. To comply with our legal obligations and where otherwise required by law, we may disclose the following categories of Personal Information to applicable regulatory and government entities: identifiers, characteristics of a protected classifications, and employment-related information.
• Clients and Prospective Clients. Clients and prospective clients may request professional and employment-related information for purposes of evaluating an Applicant’s credentials, skills and experience.
• Social Networks. If you sign into social media such as LinkedIn to apply for a position with us, we may disclose the following categories of Personal Information to LinkedIn: identifiers and internet and network activity information.
• Internet Providers, Operating Systems, and Platforms. If you sign in to or access Company platforms in connection with your application, we may disclose the following categories of Personal Information to Internet service providers, operating, systems and platforms for security and integrity purposes: identifiers and Internet and network activity information.

6. Retention of Personal Information

We store your Personal Information for as long as needed, or permitted, based on the reason we obtained it (consistent with applicable law). When deciding how long to keep your Personal Information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period of time before we can delete them) or whether we have taken any legal positions that require data retention (e.g., issued any legal holds or otherwise need to preserve data). From time to time, we may also deidentify your Personal Information, retain it and use in compliance with CCPA.

7. How You Can Update Your Personal Information

It is important that the information contained in our records is both accurate and current. We offer self-help functions within our recruitment platform that will allow you to update your Personal Information. If your Personal Information changes during the interview process, you can use these self-help tools to update your Personal Information.

8. Your California Privacy Rights

A. Applicant Privacy Rights

The CCPA provides California residents with specific rights regarding Personal Information. This section describes your rights under the CCPA and explains how to exercise those rights. Subject to certain conditions and exceptions, Applicants have the right to make the following requests:

• Right to Know/Access. You have the right to request (subject to certain exemptions):
o The categories of Personal Information we collected about you;
o The categories of sources from which the Personal Information is collected;
o Our business or commercial purposes for collecting, selling, or sharing Personal Information;
o The categories of third parties to whom we disclosed Personal Information; and
o A copy of the specific pieces of Personal Information we have collected, about you.
• Right to Correct. You have the right to request that we correct inaccuracies in your Personal Information. Applicants seeking to update their information may do so at any time by using our recruitment platform.
• Right to Delete. You have the right to request we delete your Personal Information. Please note, EmployBridge is not obligated to delete Personal Information that is necessary to provide services you request or to comply with applicable laws.
• Right to Opt-Out. You have the right to opt-out of “sales” and “sharing” of your Personal Information, as those terms are defined under the CCPA. While we do not “sell” Personal Information, our use of certain third-party analytics and advertising cookies may constitute “sharing” under the CCPA. To exercise your right to opt-out of the “sharing” of your Personal Information, please use the Do Not Sell or Share My Personal Information link at the bottom of our website. We do not sell or share “sensitive personal information,” nor do we sell or share the Personal Information of individuals under who we know are under sixteen (16) years old.

You also have the right to opt-out of “sales” and “sharing” of your Personal Information through the use of an opt-out preference signal. If we detect that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control”—or GPC—signal, we will opt that browser or device out of cookies that result in a “sale” or “sharing” of your Personal Information. If you visit our website from a different device or from a different browser on the same device, you will need to opt-out, or use an opt-out preference signal, for that browser and/or device as well.

• Right to Limit Use and Disclosure. We do not use or disclose “sensitive personal information” for purposes except as described in this Applicant Notice or as otherwise authorized by the CCPA.
• Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.

B. Exercising Your California Privacy Rights

To exercise any of these CCPA rights, please use one of the following methods:

• Email: CCPA_Applicants@employbridge.com
• Phone: (800)-605-8304

EmployBridge may require additional information to confirm your identity before fulfilling the request, such as your full name, the email address you used to communicate with us, and your address. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.
You may designate someone as an authorized agent to submit requests and act on your behalf. To do so, you must provide us with written permission to allow the authorized agent to act on your behalf. We may also ask you directly to verify that you have authorized your authorized agent to act on your behalf.

9. Contact Us

If you have questions or concerns regarding this Applicant Notice or the handling of your Personal Information, please contact us at:

EmployBridge Holding Company
1845 Satellite Blvd., Suite 300
Duluth, GA 30097
privacy@employbridge.com
800-605-8304