CCPA Job Applicant Privacy Notice
This California Employee and Job Applicant Privacy Notice (“Notice”) applies to individuals who are applying for employment with Yendo Inc. (“Company,” “we,” “us,” or “our”) and are considered “job applicants” under the California Consumer Privacy Act (“CCPA”), as well as California Employees of the Company and referred to as “you” and “your.” This Notice outlines Yendo’s online and offline information practices, including the categories of personal information (“PI”) we collect, the purposes for which we use the information, and the rights you have under the CCPA.
In the event of a conflict between this Notice and any other Company policy or statement, this Notice will take precedence, unless stated otherwise. You may print a copy of this Notice for your records.
NOTICE OF DATA PRACTICES
This Notice applies to our data collection practices, including when you submit personal data for purpose of applying for and/or becoming a valued employee at the Company, and in the course of your employment with the Company. In accordance with the CCPA and our data collection practices, we may revise this Notice from time to time for any reason.
PI Sources, Use and Disclosure
We may collect your PI directly from you during the job application process and as an employee of the Company. See PI Collection – by Category below.
Generally, we use and disclose your PI for HR Business Purposes, such as:
- Evaluating your qualifications for the position you applied for;
- Communicating with you regarding your application and the hiring process;
- Conducting background checks and verifying your information;
- Complying with legal and regulatory requirements, such as equal employment opportunity laws;
- Analyzing our recruitment process and improving our hiring procedures;
- Ensuring compliance with internal HR policies;
- Facilitating the employment relationship, including processing of payroll and benefits, and other internal business needs;
- Maintaining internal employment records;
- Meeting and monitoring government reporting regulations;
- Protecting our legal rights and interests;
We may also use and disclose PI for additional business purposes under the CCPA, such as:
- to consultants, vendors, service providers, and contractors that we use to support our business and operations who have agreed to keep the information confidential and use it only to provide the applicable service(s);
- to outside parties (including, without limitation, governmental agencies) if required to do so by law, legal process, regulation, or court order, including to respond to governmental and/or law enforcement requests or to protect or enforce legal rights or obligations or prevent harm;
- as required or permitted by applicable law;
- to investigate, prevent, or take action if we think someone might be using information for illegal activities, fraud, or in ways that may threaten someone’s safety or violate our policies or legal obligations; and
- to non-parties in connection with the sale, assignment, or other transfer of the business of our website or the sale, assignment, merger, reorganization or other transfer of our brand or company such as assignees as part of an acquisition, merger, asset sale, or other transaction where another party assumes control over all or part of our business (“Corporate Transaction”).
PI Collection - By Category
In the past 12 months, we have collected, disclosed, and retained the following categories of PI as follows:
- Identifiers, such as your name, contact information, and government-issued identification numbers.
- Personal information, such as your name, job title, date of birth, gender, marital status, relationships of dependents, emergency contact information, credit check, background check, beneficiary designations, garnishment notices from tax agencies, proof of identification, and health information.
- Professional or employment-related information, including your resume with professional, employment and educational background, language proficiency, CV, cover letter, work history.
- Diversity information and Equal Employment Opportunity data collection including protected classification characteristics under California or federal law, such as race, ethnicity, disability, and veteran status (if voluntarily provided).
- IP address, device ID, browser type, domain names, access times and dates, pages viewed, one or more cookies that may uniquely identify your browser, referring website addresses, what applications are run on your company issued device, files downloaded, opened, and created using company managed equipment, geolocation of laptops and mobile devices which contain company data, and any personal information entered into any company controlled system, including company email.
- Internet or other electronic network activity information, such as IP address, browser type, and browsing history if you visit our website.
- Inferences drawn from other personal information, such as your potential job performance based on your application and interview responses.
There may be additional information we collect that meets the definition of PI under the CCPA but is not reflected by a category above, in which case we will treat it as PI as required but will not include it when we describe our practices by PI category.
We do not sell and have not sold or shared California job applicants’ or California Employees’ personal information in the preceding 12 months. We do not collect PI of individuals under 16 years of age.
As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information, and may elect not to treat publicly available information as PI. We will not attempt to reidentify data that we maintain as deidentified.
Retention of PI
Because there are numerous types of PI in each category, and various uses for each PI type, actual retention periods vary. We retain specific PI pieces based on how long we have a legitimate purpose for the retention, including as mandated by applicable laws.
YOUR RIGHTS AND HOW TO EXERCISE THEM
You have certain rights under the CCPA, including:
- Right to Know: You have the right to request information about the categories of personal information we collect and the purposes for which we use it.
- Right to Access: You have the right to request access to the specific pieces of personal information we have collected about you.
- Right to Correct: You have the right to request that we correct inaccurate information about you.
- Right to Deletion: You have the right to request the deletion of your personal information, subject to certain exceptions.
- Right to Non-Discrimination: We will not discriminate or retaliate against you in a manner prohibited by the CCPA for your exercise of your privacy rights.
We collect and use your Sensitive Personal Information as allowed by law. We do not collect or process sensitive personal information for the purpose of inferring characteristics or for any purpose other than those specified in 11 CCR § 7027(m).
You may designate an authorized agent to make a request on your behalf under the CCPA.
However, there are several exceptions that may apply to your rights. These exceptions to the right to request to access, correct, amend, and/or delete your personal information may include our right to maintain personal information of employees for business purposes and solely internal uses reasonably aligned with the expectations of the employee, as well as to comply with any legal obligations, including maintaining proper employee records, or maintaining privilege or confidentiality of certain records, in compliance with applicable U.S. and California labor laws and legal rights.
NOTICE OF FINANCIAL INCENTIVE PROGRAMS
We do not offer programs requiring you to limit any of your Consumer rights, or otherwise require you to limit your Consumer rights in connection with charging a different price or rate, or offering a different level or quality of good or service, or that would otherwise be considered a financial incentive or price or service difference related to the collection of PI.
REQUESTS—EXERCISING YOUR RIGHTS
To exercise your rights, please submit or have your authorized agent submit a verifiable request (“Request”) at email@example.com. The Request must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. Once we receive your initial Request, we will need to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. Subject to certain limitations, we will honor your privacy rights request within 45 calendar days of receipt of your request, unless we request an extension as permitted by the CCPA.
GOVERNING LAW and OUR RIGHTS AND THE RIGHTS OF OTHERS
This Notice along with our privacy practices will be subject exclusively to the laws of the State of California, United States of America. 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 rights under the CCPA. In addition, we are not required to honor your requests to the extent that doing so would infringe upon our or another person’s or party’s rights or conflict with applicable law.
If you have any questions or concerns regarding this Notice or our privacy practices, please contact us at firstname.lastname@example.org.
Effective Date: August 15, 2023