CA APPLICANT PRIVACY NOTICE
Effective Date: January 1, 2023
The purpose of this California Privacy Notice (“Notice“) is to inform job applicants of ITG Brands, LLC (“ITGB,” “we,” or “us“) who are residents of the State of California (“Applicants” or “you“) of the categories of Personal Information we may collect about them and how we may use or disclose their Personal Information. This Notice is provided pursuant to the California Consumer Privacy Act, as amended (the “CCPA“), and should be read in conjunction with all other policies that govern your relationship with us.
As used in this Notice, the term “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with Applicants. Personal Information does not include information that is publicly available, de-identified, or aggregated, and the CCPA exempts certain additional categories of information from its purview, such as information subject to other laws and regulations. This Notice applies only to information governed by the CCPA.
Unless otherwise noted, the disclosures herein cover our activities in the twelve (12) months preceding the Effective Date, as well as our current practices
I. Collection, Use, and Disclosure of Personal Information
ITGB may collect, use, and disclose Personal Information for valid business purposes consistent with applicable laws as identified below. Where we transfer applicable Personal Information to recipients, such as our service providers, we do so for the same business purposes described below. These examples may vary depending on the nature of your interactions with us.
Category of Personal Information
Identifiers including name, alias, postal address, IP address, email address, or other similar identifiers
Personal Information described in Cal. Civ. Code § 1798.80(e), including your name, address, telephone number, education, employment, and employment history
Characteristics of protected classifications under California or federal law, including age, race, gender, military or veteran status, medical condition, or disability status
Professional or employment-related information, including: Skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, application form, or cover letter;
Answers to behavioral or other screening questions in an interview;
Information contained in any personal webpages or documents you choose to share with us;
Information relating to professional licenses, training, disciplinary actions, and membership in professional organizations;
Information relating to membership in civic organizations you may provide to us.
Non-public education information, including school(s) attended, grades, transcripts, records of attendance, disciplinary records, and other information relating to your secondary and post-secondary education
Inferences used to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
Other Categories of Personal Information, including national identification information (citizenship, immigration, visa status, and work authorization information), criminal records information (such as results of background checks), languages spoken, and drug screening results
Purposes for Collection, Use, or Disclosure
Identifiers
• To process job applications and maintain records
• To assess qualifications for a particular job or task
• To complete activities related to recruiting, onboarding, and employment referrals
• To enable you to register an account with us
• To recommend potential jobs for you
• To verify your identity and stated credentials
• To undertake activities to verify or maintain the quality or safety of our systems and services, and to improve, upgrade, or enhance our systems and services
Personal Information described in Cal. Civ. Code § 1798.80(e)
• To process job applications and maintain records
• To assess qualifications for a particular job or task
• To complete activities related to recruiting, onboarding, and employment referrals
• To enable you to register an account with us
• To recommend potential jobs for you
• To verify your identity and stated credentials
• To undertake activities to verify or maintain the quality or safety of our systems and services, and to improve, upgrade, or enhance our systems and services
Characteristics of protected classifications
• To process job applications and maintain records
• To complete activities related to recruiting and onboarding
• To verify your identity and stated credentials
• To comply with applicable laws and regulations
Professional or employment-related information
• To open and maintain your application records
• To assess your eligibility for employment
• To assess qualifications for a particular job or task
• To comply with applicable laws and regulations
• To manage the workplace safety and security
• To verify your identity and stated credentials
Non-public education information
• To open and maintain your application records
• To assess your eligibility for employment
• To assess qualifications for a particular job or task
• To comply with applicable laws and regulations
• To manage workplace safety and security
• To verify your identity and stated credentials
Inferences
• We will only use this information for recruitment efforts and will not impact your current application or future employment with us.
Other Categories of Personal Information
• To open and maintain your application records
• To assess your eligibility for employment
• To assess qualifications for a particular job or task
• To comply with applicable laws and regulations
• To manage the workplace safety and security
• To verify your identity and stated credentials
Categories of Recipients to whom Personal Information is Disclosed for a Business Purpose
Identifiers
• Data analytics providers
• Background check vendors
• Information technology vendors
• Service providers
Personal Information described in Cal. Civ. Code § 1798.80(e)
• Data analytics providers
• Background check vendors
• Information technology vendors
• Service providers
Characteristics of protected classifications
• Service providers
• Data analytics providers
• Background check vendors
• Information technology vendors
Professional or employment-related information
• Background check providers
• Service providers
• Information technology vendors
Non-public education information
• Background check providers
• Information technology vendors
Inferences
• Service providers
Other Categories of Personal Information
• Background check providers
• State or federal government agencies’ related to confirmation of national identification information and criminal records information
II. Sensitive Personal Information
ITGB may collect, use, and disclose sensitive Personal Information for valid business purposes consistent with applicable laws as identified below. Where ITGB transfers applicable sensitive Personal Information to recipients, such as our service providers, it does so for the same business purposes described below. These examples may vary depending on the nature of your interactions with us.
Category of Sensitive Personal Information
1. Social security, driver’s license, state identification card, or passport number(s)
2. Personal Information that reveals an Applicant’s racial or ethnic origin.
3. Personal Information collected and analyzed concerning an Applicant’s health
Purposes for Collection, Use, or Disclosure
1. Social security, driver’s license, state identification card, or passport number(s)
• To assess your eligibility for employment
• To comply with applicable laws and regulations
2. Personal Information that reveals an Applicant’s racial or ethnic origin.
• To process job applications and maintain records
• To complete activities related to recruiting and onboarding
• To verify your identity and stated credentials
• To comply with applicable laws and regulations
3. Personal Information collected and analyzed concerning an Applicant’s health
• To assess your eligibility for employment
• To comply with applicable laws and regulations
Categories of Recipients to whom Personal Information is Disclosed for a Business Purpose
1. Social security, driver’s license, state identification card, or passport number(s)
• Background check providers
• State or federal government agencies’ related to confirmation of national identification information and criminal records information
2. Personal Information that reveals an Applicant’s racial or ethnic origin.
• Government agencies
• Service providers
• Data analytics providers
• Background check vendors
3. Personal Information collected and analyzed concerning an Applicant’s health
• Service providers
III. Disclosing Your Personal Information
We may disclose each of the categories of Personal Information identified above to the respectively identified categories of recipients for operational or business purposes consistent with the purposes for collection or use designated, as is reasonably necessary and proportionate to achieve those purposes, or for another purpose that is compatible with the context in which the Personal Information was collected including, but not limited to:
• Helping to ensure security and integrity;
• Debugging, repairing, and improving functionality;
• Short-term, transient use;
• Performing services on our behalf;
• Internal research for technological development; and
• Verifying quality and/or safety.
In addition to the other purposes for collection, use, and disclosure of Personal Information described in this Notice, we may collect, use, and disclose Personal Information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a threatened or pending case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may use and disclose Personal Information to other parties in connection with the sale, assignment, merger, or reorganization of the company or its affiliates.
IV. Sources of Personal Information
We may collect the Personal Information and Sensitive Personal Information identified above from the following sources:
• Directly from you. For example, during the application process and throughout your interactions with us, including through our IT systems, company forms, and other processes where you submit information to us.
• Automatically when using our electronic systems. For example, we may collect your usage history when you use our websites, systems, and applications.
• Automatically when you visit our facilities. For example, security camera footage.
• Service providers. For example, from third-party human resources and information technology vendors, background check agencies, and other service providers.
V. Selling or Sharing of Your Personal Information
We do not sell Applicant Personal Information or share it for cross-context behavioral advertising.
VI. How Long We Keep Your Personal Information
The information below shows how long we retain Personal Information. For each category of Personal Information, our retention period is determined by the purposes for which we use the information and any legal obligations that require or authorize us to retain it.
Personal Information
Identifiers
Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Personal Information described in Cal. Civ. Code § 1798.80(e)
Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Characteristics of protected classifications
Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Internet or other electronic network activity information
Short-term, transitory use only
Professional or employment-related information
Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Non-public education information
Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Inferences
Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Other categories of information
Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Sensitive Personal Information
Social security, driver’s license, state identification card, or passport number
Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Personal Information that reveals an Applicant’s racial or ethnic origin
Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Personal Information collected and analyzed concerning an Applicant’s health Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.
VII. California Privacy Rights
If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please submit a request by emailing us at privacy@ITGBrands.com, or calling us at (888) 342-6567.
If you make a privacy request, we may take steps to verify your identity before responding to your request. You may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. As permitted by law, we may take steps to verify your own identity in response to a request even if you choose to use an agent.
Right to Opt-Out of the Sale and Sharing of Your Personal Information. We do not sell Applicant Personal Information or share it for cross-context behavioral advertising.
Right to Limit Use and Disclosure of Your Sensitive Personal Information. We do not use or disclose sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.
Right to Know. You have the right to know what Personal Information we have collected about you, which includes:
(1) The categories of Personal Information we have collected about you, including:
a. The categories of sources from which the Personal Information was collected;
b. Our business purposes for collecting or disclosing Personal Information;
c. The categories of recipients to which we disclose Personal Information;
d. The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information.
(2) The specific pieces of Personal Information we have collected about you.
Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions.
Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.
VIII. How to Contact Us
If you have any questions about how ITGB handles your Personal Information or if you need to access this notice in an alternative format or language, please contact us at:
Phone: (888) 342-6567
Email: privacy@ITGBrands.com