US Employees and Job applicants Privacy Notice

OFFICERND, Inc. (the “Company,” “us”, “we” or “OFFICERND”) is committed to protecting the privacy and security of the personal information you provide to us. Please read this Employee and Job Applicant Privacy Notice (the “Privacy Notice”) to learn how we collect and process your personal information when you apply for a job or other role with us. As a job applicant, you have the right to know and understand the categories of personal information we collect about you, and the purposes for which we use such personal information, pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”) and other relevant legislation. The Company does not sell or otherwise disclose this personal information for monetary or other consideration to any third parties.

1. Categories of Personal Information collected.

In each case as permitted by applicable law, we collect the following categories of personal information for the purposes described below:

Categories Personal Data	Types of personal data
Personal identifiers	Name, preferred name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, date of birth, and other similar identifiers.
Personal records	Signature, Social Security number, address, telephone number, education, employment or employment history.
Protected characteristics	Minority, veteran and disability status, through voluntary self-disclosure. Such information will only be collected as permitted by applicable law and will not be used to make hiring decisions.
Internet or other similar network activity information	IP address, log-in information or information regarding your interaction with a website, application or advertisement.
Geolocation data	IP addresses from which we can determine your general location.
Sensory data	Audio and visual information, for example if you use video interviewing as part of the application process.
Professional or employment-related information	Work history, references, information about skills and abilities, accomplishments and awards, training and development information, performance evaluation information, and employment termination information.
Education information	Education history, education records (such as grades, transcripts and class lists), and other information included in your resume or cover letter.
Inferences drawn from other personal information	A profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Other	Job interview notes, responses to screening questions, assessment results, and any other information you provide in connection with the recruitment process. We also collect legal and contractual information, such as information necessary to respond to law enforcement and governmental agency requests, comply with legal and contractual obligations, exercise legal and contractual rights, and initiate or respond to, or establish, exercise, and defend, legal and contractual rights claims.

2. Sources of Personal Information.

We collect personal information you voluntarily provide to us when you apply for a job or otherwise contact us in the recruitment context. If you are visiting our website or online job application, we may also automatically collect device information such as IP addresses and device identifiers.

We may also combine personal information collected from other sources with the personal information that you provide to us. For example, we may collect information from:

• Recruiters.
• Prior employers (e.g., for references).
• Professional references you provide to us.
• Educational institutions.
• Pre-employment screening services.
• Credentialing and licensing organizations.
• Publicly available sources such as your social media profile (e.g., LinkedIn, Twitter and Facebook).
• Other sources as directed by you.

3. Use of Personal Information.

We use the categories of personal information listed above for the following purposes:

• Process and manage your application: We use your personal information to process your job application, establish a job applicant profile for the recruitment process, assess your qualifications for a specific role with us, schedule and conduct interviews, communicate with you. We may collect audio and visual information of job applicants through photographs used for identification purposes. With your consent, we may record video of you in connection with the application process, for example through a third-party screening service. Additionally, if you are offered a position with us, we may use your personal information to carry out background and reference checks (see the following bullet point for additional information) and use the information in the employee on-boarding process.
• Conduct reference and background checks (as permitted by applicable law): We use personal information we collect to conduct reference checks and to evaluate your qualifications and experience. We may also conduct background checks (as authorized by you and permitted by applicable law).
• Provide immigration support: If applicable and as permitted by applicable law, we may collect your personal information to assist with immigration support, such as applying for visas or work permits.
• Analyze and improve our recruitment process and tools: For example, we analyze trends in our applicant pool, and use personal information to understand and improve our recruitment process and tools (including improving diversity and inclusion). If you use our online job application process, we collect personal information in this category, such as your interactions with our “Careers” page and our online application process. We collect IP address location information to better understand how candidates use our careers page and online application process.
• Record-keeping: We keep records of your personal information as required by law and in accordance with our record retention policies.
• Meeting legal requirements and enforcing legal terms: We collect and process your personal information for purposes of: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, us or another party; enforcing any agreements with you; responding to claims; and resolving disputes. Additionally, we may use information about protected characteristics to analyze and monitor the diversity of our job applicants in accordance with applicable laws.

4. Disclosure of Personal Information, no Sale.

We may share your personal information as necessary for the purposes described in this Privacy Notice, including internally with our personnel involved in the hiring process. For example, we share your personal information with the following parties:

• Affiliates: We may share your personal information with our affiliates.
• Service Providers: We use service providers to operate, host and facilitate our hiring and recruitment process. These include hosting, technology and communication providers; security and fraud prevention consultants; analytics providers; background and reference check screening services; and hiring process management tools.
• Government authorities and law enforcement: In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
• Business transfers: Your personal information may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
• Other: We may also share your personal information with third parties in conjunction with any of the activities set forth under “Meeting legal requirements and enforcing legal terms” in the “Use of Personal Information” section above.

5. Retention of Personal Information.

Personal information will not be kept for longer than is necessary for the Business Purpose for which it is collected and processed and will be retained in accordance with our internal document retention policies. In certain cases, laws or regulations require us to keep records for specific periods of time, including following termination of the employment relationship. In other cases, records are retained in order to administer the employment relationship or to resolve queries or disputes which arise from time to time.

6. Application for further positions.

Occasionally we also have an interest in and need for competent applicants in other areas and would be happy to consider your application for other vacancies. With your application you agree that other recruiters from OFFICERND may also view your applicant data, including any sensitive data contained therein, and take it into account when filling vacancies.

Should you appear to be suitable for the vacancy, we would approach you to inquire whether you would be interested in participating in the selection process for the position to be filled.

7. How to access and control your data.

You have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests, to the extent OFFICERND acts as a “business” (as opposed to a “service provider”) for purposes of handling personal information. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request).

7.1. Right to Opt-Out of the Sale of Your Personal Information.

We do not, and will not, sell your personal information.

7.2. Right to Request Deletion of Your Personal Information.

You may also request that we delete any personal information that we have collected directly from you, such as if you have been a business partner of ours (note that this is different from your right to “opt-out” of us selling your personal information, which is described above). However, we may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. If you ask us to delete it, you may no longer be able to apply at OFFICERND.

7.3. Right to Request Access to Your Personal Information.

You also have the right to request that we disclose what categories of your personal information we collect, use, or sell. You may request access to the specific pieces of personal information that we have collected from you. You may learn more how to exercise these rights of information access by sending an email to privacy(at)officernd.com.

However, we may withhold some personal information where the risk to you or our business is too great to disclose the information, or where we cannot verify your identity in relation to such personal information. Once we have verified your identity, we will respond to your request as appropriate:

Where you have requested the categories of personal information that we have collected about you, we will provide a list of those categories.
Where you have requested specific pieces of personal information, we will provide the information you have requested, to the extent required under the CCPA and other applicable legislation and provided we do not believe there is an overriding privacy or security concern by doing so.

If we are unable to complete your requests fully for any of the reasons above, we will provide you with additional information about the reasons why we could not comply with your request.

7.4. Right to non-discrimination.

We will not deny application or discriminate during applicants if you exercise your rights. However, if you refuse to provide your personal information to OFFICERND or ask us to delete your personal information and considering that personal information is necessary for OFFICERND to complete the recruiting process, OFFICERND may not be able to complete it.

7.5. Information About Persons Under 16 Years of Age.

We do not knowingly collect personal information from minors under 16 years of age unless we have received legal consent to do so.

7.6. Authorized Agents

You may also designate an agent to make requests to exercise your rights under CCPA and other applicable legislation as described above. We will take steps to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf by providing us with a signed written authorization or a copy of a power of attorney.

8. Contact information.

If you require any further information, please do not hesitate to contact the Human Capital Team or email us at [email protected]

9. Policy update.

This notice does not form part of any employment contract or other contract to provide services. We may update this notice at any time and changes will appear on this page.

Latest update: April 20, 2022