California Privacy Notice for Employees and Job Applicants

Last updated on: December 12, 2023

Bold North America LLC and its parent and affiliates (collectively “Bold,” “we,” “us” or “Company”) are providing you with this Notice for California Employees (defined as Bold employees who have either initiated their employment with Company while residing in California and remain in California or subsequently became residents of California while employed with Company ) and Applicants (defined as individuals who have applied to Company positions while residents of California) (“Notice”) to inform you about the categories of Personal Information that the Company collects about employees and applicants who reside in California, the purposes for which the Company uses that Personal Information, and the retention period of the Personal Information.

“Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person that the Company collects about its employees and applicants, who reside in California, in their capacity as employees of the Company or applicants for positions with the Company.

This Notice sets out the Personal Information that we collect and process about you, the purposes of the processing and the rights that you have in connection with it. The California Consumer Privacy Act of 2018, including the California Privacy Rights Act of 2020 and any regulations promulgated thereunder (“CCPA”), provides California residents with specific rights regarding their Information. This Notice, which applies only to California residents, describes your rights under the CCPA, explains how you may exercise your rights, and provides an overview on the types of Personal Information we collect.

This Notice does not apply to any Personal Information that we may collect if you use Bold’s public websites and you should instead consult the applicable Consumer Privacy Policy for further information about our data practices in relation to Bold’s websites.

The categories of Personal information we collect from California applicants and employees are:

Descriptions of purposes for which we use the personal information described above:

• Recruitment management: Performing recruitment tasks including identifying potential candidates, considering suitability for a position (including qualifications, skills and experience), communicating with Applicants, verification of references, preparation of offers of employment, assistance in obtaining visa sponsorship, analyzing recruitment metrics, creating a talent pool for future job openings.
• Auditing, investigations, and compliance: Auditing, investigations, and compliance related to the recruitment process, including conducting background checks where permitted by law, creating and submitting reports required by law, ensuring that Applicants have the right to work in the country they have applied to work in, and complying with legal obligations (e.g., gathering and reporting information relevant to compliance with labor regulations related to diversity and equality).
• Security: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Quality/safety maintenance: Maintaining the quality and safety of our work environment, including undertaking activities to verify or maintain the quality or safety of a service or device and to improve, upgrade, or enhance the service or device.
• Employment Relationship Management: As an employee we may collect and use your Personal Information for the purpose of managing our employment or working relationship with you – for example, your employment records (so we can manage our employment relationship with you) , your bank account and salary details (so we can pay you and administer and maintain benefits, including group health insurance and your retirement account;), and details of your spouse and dependents (for emergency contact, tax and benefits purposes). We also collect and use your Personal Information such as: your social security, driver’s license, state ID, or passport number, your racial/ethnic origin and gender for equal employment opportunity reporting purposes (in accordance with applicable law) and to arrange business travel; or information about your physical or mental condition to provide work-related accommodations.
• Other legitimate business purposes: We may also collect and use Personal Information when it is necessary for other legitimate purposes, such as:
  • to help us conduct our business more effectively and efficiently – for example, for general HR resourcing, reporting or analytics, IT security/management, business continuity purposes, accounting purposes, or financial planning;
  • to engage in corporate transactions requiring review of employee records and information, such as for evaluating potential mergers and acquisitions;
  • to maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance;
  • to investigate violations of law or breaches of our own internal policies and more generally to protect the rights and interests of Company’s group, our employees, applicants and others. For instance, we may monitor your browsing or communications activity or location when using our devices or systems, if we suspect that you have been involved in phishing scams, fraudulent activity or activities in competition with or inconsistent with your work for the Company;
  • to help secure our networks and systems from unauthorized access, scams, and malicious code. For instance, we may monitor and review electronic mail communications sent or received using Company issued devices or accounts, or stored on or using such a device or account. We may also monitor and record each website visit, each chat session, newsgroup post, e-mail message, and each file transfer into and out of our systems and networks.Company may monitor this activity at any time, and, to the extent permitted by laws, users of our networks and systems should not expect privacy when using these systems and devices;
  • in accordance with any personal device policy in effect. For instance, we may deploy security software on your personal device that monitors URLs for phishing risks and other security threats; and
  • to foster diversity, inclusion, and a welcoming work culture.

In addition to the purposes identified above, Bold may use and disclose any and all personal information that we collect as necessary or appropriate to:

• Comply with laws and regulations, including (without limitation) applicable tax, health and safety, Equal Employment Opportunity Act, anti-discrimination, immigration, labor and employment, and social welfare laws.
• Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons.
• Exercise or defend Bold’s legal rights and those of its employees, affiliates, customers, contractors, and agents.

Retention Period:

We will store your personal data, in a form that permits us to identify you, for no longer than is necessary for the purpose for which the personal data is processed and in accordance with our internal Data Retention Policy. We store your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically and reasonably feasible to remove it. Otherwise, we will seek to delete your personal data within 45 days of your data deletion request.

Selling or Sharing of Information:

Bold does not sell or share, as those terms are defined under applicable law, the above categories of Employees or Applicants Personal Information. We do not use or disclose your Personal Information to third parties for purposes that, with limited exceptions, are not necessary for the application or employment related purpose for which we collect it or as reasonably expected by an average individual in this context or for other permitted purposes under the CCPA or as authorized by regulation.

To carry out the purposes outlined above, Bold may share Applicants or Employees Personal Information with service providers or third parties, such as background check vendors, third-party human resources and information technology vendors, cloud service providers, recruiting companies, outside legal counsel, and state or federal governmental agencies. When we disclose Personal Information to service providers, we enter into a binding contract that describes the purpose of sharing the information and requires the recipient to keep the Personal Information confidential and not use it for any purpose except performing the contract. Additionally, we may share your information to detect and mitigate potential fraud, respond to legal requests for information, and as required by applicable law, comply with a court order, or government regulation.

In addition, by submitting your application and to the extent permitted by law, you authorize Bold to conduct its own investigation of your references, employment history and education, and authorize designated references and prior employers to provide Bold information related to your employment history and qualifications for the position for which you are applying, without prior notice.

Your Privacy Rights

If you are a California employee, you have the following rights with respect to your Personal Information:

• Right to know. You have a right to request that we disclose the Personal Information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, sale, or sharing of Personal Information. Note that we have provided much of this information in this Notice.
• Right to request correction. You have the right to request the correction of inaccurate Personal Information.
• Right to request deletion. You also have a right to request that we delete your Personal Information, subject to certain exceptions.
• Right to opt-out from a sale. We do not sell personal data as defined by the CCPA and have not done so in the past 12 months.
• Right to opt-out of sharing of cross-context behavioral advertising. We do not share Personal Information for cross-contextual behavior advertising purposes.
• Right to limit use and disclosure of personal information. We do not use or disclose any personal information to infer individual characteristics or for purposes other than those permitted by CCPA.
• Right to notice. You have a right to receive notice of our Personal Information collection, use, retention, and disclosure practices at or before the collection of personal information as provided herein.
• Right to non-discrimination. You have a right not to be discriminated against for exercising these rights.
• Right to appeal. You have the right to appeal any decision made by Bold relating to these rights.

How to Exercise Your Rights

To exercise any of the rights described above, please contact HR-privacy@bold.com. We will need to verify your identity to the degree of certainty required by law. We will verify requests by asking you to send the request from the email address associated with your application or by requiring you to provide additional information reasonably necessary to verify your identity.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof that you have authorized them to act on your behalf. We may need you to verify your identity directly with us and confirm that you provided the authorized agent permission to submit the request.

Who should I contact with questions?

For further information regarding Bold’s collection, use, or disclosure of your personal information or questions related to Bold’s compliance with this Notice, please contact HR-privacy@bold.com.

Accessibility

We are committed to ensuring this Notice is accessible to individuals with disabilities. If you wish to access this Notice in an alternative format, please contact us at: HR-privacy@bold.com.