1619 Broadway, 8th Floor, New York, NY 10019

1 (917) 421-5400

California Applicant Privacy Notice

Privacy Notice to California Job Applicants Regarding The Collection of Personal Information

Effective Date: December 2022

The John Gore Organization, Inc., and its operating groups, subsidiaries and affiliates, (collectively, “Our”, “Us” or “We”) are committed to protecting the privacy and security of the personal information You provide to Us. Please read this Job Applicant Privacy Notice for California Job Applicants (the “California 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”). This California Privacy Notice only applies to job applicants who are residents of the State of California. We do 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:
    1. Personal identifiers, such as Your 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.

    2. Personal Records, such as Your signature, Social Security number, address, telephone number, education, employment or employment history.

    3. Protected characteristics, such as 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.

    4. Internet or other similar network activity information, such as Your IP address, log-in information or information regarding Your interaction with a website, application or advertisement.

    5. Geolocation Data, such as IP addresses from which We can determine Your general location.

    6. Sensory data, such as audio and visual information, for example if You use video interviewing as part of the application process. If You visit Our facilities, Your entry and exit may be monitored by CCTV.

    7. Professional or employment-related information, such as Your work history, references, information about skills and abilities, accomplishments and awards, training and development information, performance evaluation information, and employment termination information.

    8. Education information, such as Your education history, education records (such as grades, transcripts and class lists), and other information included in Your resume or cover letter.

    9. Inferences drawn from other personal information, such as a profile reflecting Your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

    10. 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 (a) recruiters; (b) prior employers (e.g., for references); (c) professional references You provide to us; (d) educational institutions; (e) re-employment screening services; (f) credentialing and licensing organizations; (g) publicly available sources such as Your social media profile (e.g., LinkedIn, Twitter and Facebook); and (h) other sources as directed by You.

  3. Use of Personal Information. We use the categories of personal information listed above for the following purposes:

    1. 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, and carry out background and reference checks (see the following bullet point for additional information). 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 in the employee on-boarding process.

    2. 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).

    3. 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.

    4. 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.

    5. Record-keeping: We keep records of Your personal information as required by law and in accordance with Our record retention policies.

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

    1. Affiliates: We may share Your personal information with Our affiliates.

    2. Service Providers: We use service providers, including Workda,y 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.

    3. Government authorities and law enforcement: In certain situations, We may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

    4. 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).

    5. Professional advisors: We may share Your personal information with Our professional advisors.

    6. With Your consent. We may disclose Your personal information for any purpose with Your consent.

    7. Referrals. Upon request, to Our employee who referred You to inform them about the limited, general status of the referral.

    8. 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. Opt-Outs. The CCPA provides California residents with specific rights regarding their personal information. This section describes the rights that You have under CCPA if You are a California resident and explains how You can exercise those rights.

    1. Right to Know About Personal Information Collected, Disclosed or Sold. You have the right to request that We disclose certain information to You about Our collection, use, disclosure or sale of Your personal information over the past 12 months. Once We receive and confirm Your verifiable request (see Exercising Access, and Deletion Rights), and subject to certain limitations that We describe below, We will disclose such information to You. You have the right to request any or all of the following:

      • The categories of personal information We collected about You.
      • The categories of sources from which the personal information is collected.
      • Our business or commercial purpose for collecting that personal information.
      • The categories of third parties with whom We share that personal information.
      • The specific pieces of personal information We collected about You
      • The categories of personal information about You that We have sold or disclosed for a business purpose.
    2. Right to Request Deletion. You have the right to request that We delete any of Your personal information that We have collected from You and retained, subject to certain exceptions. Once We receive and confirm Your verifiable request (see Exercising Access, and Deletion Rights), We will delete (and direct Our service providers to delete) Your personal information from Our records. However, We may retain personal information that has been de-identified or aggregated. Furthermore, We may deny Your deletion request if retaining the information is necessary for Us or Our service provider(s) in order to perform certain actions set forth under CCPA, such as detecting security incidents and protecting as illegal activity.

    3. Exercising Access and Deletion Right. To exercise the access and deletion rights described above, please submit a request to Us by emailing Us at hrprivacy@johngore.com.

      Only You, or a person or business entity registered with the California Secretary of State that You authorize to act on Your behalf (an “authorized agent”), may make the requests set forth above. If You use an authorized agent to make a request, You must provide the authorized agent written permission to do so, and We may require that You verify Your identity directly with Us. You may also make a request on behalf of Your minor child.

      The request should include Your contact information and describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it. In addition, We may ask You to provide additional information that allows Us to reasonably verify that You are the person about whom We collected the personal information or an authorized representative.

      For more information about verification, see Response Timing and Format. For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

    4. Response Timing and Format. We will respond to your requests in a reasonably timely manner. If We require extra time to respond, We will inform You of the reason and extension period in writing. In order to protect the security of Your personal information, We will not honor a request if We cannot verify Your identity or authority to make the request and confirm the personal information relates to You. The method used to verify Your identity will vary depending on the nature of the request. Generally speaking, verification will be performed by matching the identifying information provided by You to the personal information that We already have. Any disclosures We provide will only cover the 12-month period preceding Our receipt of Your request. We are not obligated to provide the information set forth above under “Right to Know About Personal Information Collected, Disclosed or Sold” more than twice in a 12-month period. We do not charge a fee to process or respond to Your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If We determine that the request warrants a fee, We will tell You why We made that decision and provide You with a cost estimate before completing Your request.

    5. Non-Discrimination. We will not discriminate against You for exercising any of Your CCPA rights, including, but not limited to, by:

      • Withdrawing or not providing an offer of employment.
      • Denying You goods or services.
      • Charging You different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
      • Providing You a different level or quality of goods or services.
      • Suggesting that You may receive a different price or rate for goods or services or a different level or quality of goods or services.
  6. Contact for Questions. If You have any questions or concerns regarding this California Privacy Notice or the collection of Your personal information, please contact: hrprivacy@johngore.com. Job applicants with disabilities may access this notice in an alternative format by contacting hrprivacy@johngore.com.