At-Bay, Inc. California Applicant Privacy Notice
Effective Date: April 11, 2023
The purpose of this Applicant Privacy Notice (“Applicant Privacy Notice”) is to inform At-Bay, Inc., and its affiliates’ (collectively referred to as “At-Bay,” “Company,” “us,” “we,” or “our”) California workforce Applicants of our practices regarding the collection, use, and disclosure of their personal information (“Applicant Personal Information”), and the rights they have under the California Consumer Privacy Act, as amended (the “CCPA”). “Applicant” means California residents applying for workforce jobs with At-Bay.
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. How and Why We Collect, Use, and Disclose Your Applicant Personal Information
As used in this Applicant Privacy Notice, the term “Applicant 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 At-Bay Applicants. Applicant 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.
At-Bay may collect, use, and disclose Applicant Personal Information for business purposes consistent with applicable laws as identified below. Where At-Bay discloses applicable Applicant 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 Applicant Personal Information | Business Purposes for Collection, Use, or Disclosure | Categories of Recipients to whom Applicant Personal Information is Disclosed for a Business Purpose |
| Identifiers such as name, alias, telephone number, signature, email address, mailing address, IP address, professional licenses, driver’s license number, or other similar identifiers | • To open and maintain your application records
• To assess your eligibility to work with us • To communicate with you regarding your application • To comply with applicable laws and regulations • To detect and prevent fraud against you and/or us |
• Service providers
• Information technology vendors
|
| Personal information described in Cal. Civ. Code § 1798.80(e) such as name, physical and electronic signature, address, telephone number, education, employment history
Some of these pieces of information may overlap with other categories. |
• To open and maintain your application records
• To assess your eligibility to work with us • To communicate with you regarding your application • To comply with applicable laws and regulations • To detect and prevent fraud against you and/or us |
• Service providers
• Information technology vendors
|
| Protected classification characteristics such as age and date of birth, marital status, military or veteran status, disability status, race and ethnic origin, gender and/or gender identity | • To comply with applicable laws and regulations
• To assess your eligibility to work with us
|
• Service providers |
| Internet or other electronic network activity information such as browser type and language, operating system, website usage, emails, or text message communications | • To communicate with you
• To improve our website • To protect the security of our website • To detect and prevent fraud against you and/or us |
• Service providers
• Information technology vendors
|
| Sensory information, such as photographs to the extent contained on documents you provide | • To open and maintain your application records
• To detect and prevent fraud against you and/or us • For safety and security |
• Service providers
|
| Professional or employment-related information such as skills, qualifications, work experience, references, licenses and/or certifications, recommendations, and other information included in a resume, CV, or application form;
Answers to behavioral or other screening questions in an application or interview; Information contained in any websites or documents you choose to share with us; Information relating to professional licenses, training, or disciplinary actions.
|
• To open and maintain your application records
• To assess your eligibility to work with us • To comply with applicable laws and regulations • To detect and prevent fraud against you and/or us • For safety and security |
• Service providers
|
| Non-public education information such as school(s) attended, area of study, dates attended, and other information relating to your education, including any graduate or professional degrees | • To open and maintain your application records
• To assess your eligibility to work with us • To comply with applicable laws and regulations |
• Service providers
|
| Inferences drawn from other personal information such as preferences, characteristics, predispositions, behavior, or attitudes based on other personal information collected about you | • To assess your eligibility to work with us
|
• Service providers
|
| Personal Information that does not fall directly within the categories listed in the CCPA such as driving record, criminal records, background check information, drug and alcohol screening history, languages spoken, immigration, visa status, and work authorization information | • To open and maintain your application records
• To assess your eligibility to work with us • To comply with applicable laws and regulations • To detect and prevent fraud against you and/or us • For safety and security |
• Service providers
|
We may also collect Applicant Personal Information that you provide to us on a voluntary basis which we would not regularly request or collect. For example, if you provide us with additional categories of information in emails or other communications.
II. Disclosing Your Applicant Personal Information
We may disclose each of the categories of Applicant 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 Applicant 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 Applicant Personal Information described in this Applicant Notice, we may collect, use, and disclose Applicant 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 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 Applicant Personal Information to other parties in connection with the sale, assignment, merger, or reorganization.
III. Sources of Applicant Personal Information
We may collect Applicant Personal Information from the following sources:
- Directly from you. For example, throughout the application process 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.
- From service providers that help us run our business. For example, information technology vendors, and other service providers.
We may also collect publicly available information about you, including information that is lawfully made available to the general public from federal, state, or local government records.
IV. Sales and Sharing of Applicant Personal Information
We do not sell Applicant Personal Information or share it for cross-context behavioral advertising. If you also interact with us as a consumer, please review our California Consumer Privacy Notice [link] for more information about our practices in that context. We do not have actual knowledge that we sell or share the Applicant Personal Information of consumers under sixteen (16) years of age.
V. How Long We Keep Your Applicant Personal Information
We will store your Applicant Personal Information for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the Applicant Personal Information was collected, or as may be required or permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove Applicant Personal Information from our systems and records or take appropriate steps to properly anonymize, deidentify, or aggregate it, where legally applicable.
VI. Submitting Requests Relating to Your Applicant Personal Information
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 contact us at privacy@at-bay.com or call us toll free at (888) 320-4041. Please note that, if you submit a request to know, request to delete or request to correct, you will be asked to verify your identity in accordance with the law. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed.
Right to Know. You have the right to know what Applicant Personal Information we have collected about you, which includes:
- The categories of Applicant Personal Information we have collected about you, including:
- The categories of sources from which the Applicant Personal Information was collected;
- Our business purposes for collecting Applicant Personal Information;
- The categories of recipients to which we disclose Applicant Personal Information;
- The categories of Applicant 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 Applicant Personal Information.
- The specific pieces of Applicant Personal Information we have collected about you.
Right to Delete Your Personal Information. You have the right to request that we delete Applicant Personal Information we collected from you, subject to certain exceptions.
Right to Correct Inaccurate Information. If you believe that Applicant Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.
Right to Opt Out of Sales and Sharing of Personal Information. We do not sell Applicant Personal Information or share it for cross-context behavioral advertising.
Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose sensitive Applicant Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.
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, including retaliation against you as a job applicant.
VII. How to Contact Us
If you have any questions about how At-Bay handles your Applicant Personal Information or if you need to access this notice in an alternative format or language, please contact us at:
Phone: (888) 320-4041
Email: privacy@at-bay.com