CCPA Job Applicant Privacy Notice

This California Job Applicant Privacy Notice (this “Applicant Notice”) explains how Cadent LLC and its subsidiaries and affiliates (collectively, “Cadent,” “we,” “us,” or “our”) processes personal information about our California-based job applicants under the California Consumer Privacy Act (CCPA) (collectively, “applicants,” “you,” or “your”). For purposes of this Applicant Notice, “personal information” has the meaning given to it in the CCPA.

This Applicant Notice applies with respect to Cadent’s processing of your personal information as a job applicant and does not cover your use of Cadent’s products and services outside of that capacity (e.g., as an actual employee or contractor, use of the cadent.tv website outside of what you provide to us on Careers pages, collection of data via advertising/analytics vendors on cadent.tv or general logging on our site). In the case of any conflict between this Applicant Notice and the rest of our Website Privacy Policy, this Applicant Notice controls with respect to the processing of personal information of job applicants.

1. Collection of Job Applicant Personal Information

‍Categories of personal information

Categories of Personal Information Collected	Examples
Identifiers	Name, Email address Home address Phone number Social Security Number
California Customer Records (Cal. Civ. Code § 1798.80(e))	Home address Phone number
Protected classification information	Age Disability information Disability information Veteran or military status Race/ethnic origin Sex – Female/Male/I don’t wish to answer Citizenship
Professional/employment related information (for example, resumes, references, background checks)	Resumes/CVs Security Clearances References Background Checks Education Employment eligibility information, such as visa information
Inferences drawn from personal information	Job application or candidacy vetting

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Note on “Sensitive” Personal Information

‍Certain “sensitive” information may be revealed by virtue of submission of your job applicant materials or correspondence with our team (e.g., information contained within a resume/CV), such as race/ethnic origin, religious/philosophical beliefs, or data concerning health. Pursuant to the CCPA, we will process such data only for purposes that do not require an opt-out under the CCPA (i.e., the “right to limit”) or otherwise without the purpose of inferring characteristics about you.

‍Sources of personal information

‍We collect personal information directly from you when you apply for a job and throughout the job application or recruitment process. We also collect your personal information from other sources and may use it in conjunction with the personal information you provide us. For example, we may collect your personal information from:

Job board websites you may use to apply for a job with us;
Prior employers that provide us with employment references;
Professional references that you authorize us to contact;
Pre-employment screening services, such as background check providers (where permitted by law);
Employment agencies and recruiters;
Your educational institutions;
Your public social media profile or other publicly-available sources (e.g., LinkedIn);
Other Company personnel.

2. How We Use and Disclose Personal Information

Purposes for which we collect personal information

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

Carry out the job application process. Evaluate job applications to determine suitability and to carry out any related next steps (e.g., interviews, background checks, onboarding);
Compliance/audits, safety and security (including cybersecurity), potential or actual dispute resolution, and fraud protection (or protection against other deceptive, illegal, or harmful activity);
Comply with applicable laws, rules, regulations, legal proceedings (e.g., exercise or defend legal claims, government investigations) or subpoena or summons;
Business transfers (see section below);
Analytics. Creating data that we use and share to analyze our application and recruitment activities, business, and for other lawful business purposes; and
As otherwise with your consent or as notified to you.

Disclosure of personal informationWe may share your personal information with other parties as necessary for the purposes described above. For example, we may disclose your personal information with:

Affiliates. Our subsidiaries and affiliates for purposes consistent with this Applicant Notice or to operate shared infrastructure, systems, or technology.
Company service providers. Companies or persons that provide us with services that help us manage the recruiting process and operate other aspects of our business.
Government authorities, law enforcement, and others. Government authorities, law enforcement, courts, and other such entities.
Business transfers. Parties to transactions and potential transactions whereby we sell, transfer, or otherwise share some or all of our business or assets, including your personal information, such as a corporate divestiture, merger, consolidation, acquisition, reorganization, or sale of assets, or in the event of bankruptcy or dissolution.
Professional advisors. Lawyers, immigration advisors, and other outside professional advisors.
Otherwise with consent or notice. To certain other entities or persons or publicly with your consent or where notice has been provided to you.

3. Retention

We retain the categories of personal information listed above as reasonably necessary to fulfill the purposes outlined in this Applicant Notice, unless a longer retention period is required or permitted by law. In many situations, we must retain all, or a portion, of your personal information to comply with legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, illegal, or otherwise harmful activity, or for another one of our business purposes.

Relatedly, note that we may retain application information for unsuccessful applicants beyond consideration of the immediate position for which the application is submitted as a reference in case future positions become available and are of interest. Application information for successful applicants may become part of the applicant’s employment file and is treated accordingly.

4. Your CCPA Rights

As a California resident, you may be able to exercise the following rights, subject to certain limitations (e.g., where exercise of the rights involves disproportionate efforts, reveals confidential company information, adversely affects the rights and freedoms of other persons, is related to the exercise or defense of legal claims or similar potential or actual dispute, or as otherwise explained in further guidance from California regulators):

The Right to Know	Subject to certain exceptions (such as where such requests involve disproportionate effort or where a request was made more than twice in a 12-month period), the right to request that we disclose information about our collection and use of your personal information, including: The categories of personal information we collect about you; The categories of sources of the personal information we collect about you; The business or commercial purpose for collecting, the personal information; The categories of third parties to whom the business discloses personal information; and The specific pieces of personal information we’ve collected about you
The Right to Correction	The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data
The Right to Deletion	The right to have us delete the personal data we maintain about you, subject to certain exceptions.

Note: We do not “sell” or “share” your personal information as a job applicant and, in the last 12 months, we have not “sold” your personal information or “shared” your personal information as a job applicant. However, as part of your visit to our website generally, we disclose personal information to adtech and analytics companies for advertising/analytics-related purposes. This activity is not covered under this Applicant Notice; instead, please go to our main Website Privacy Policy to learn more about how to opt-out of these “sales/ shares.” We do not have actual knowledge of “selling” or “sharing” any personal information of anyone under sixteen (16) years of age.

Further, as stated above, we do not process your “sensitive” personal information for any purpose that requires a corresponding opt-out right under the CCPA (i.e., the “right to limit”).

Submitting Privacy Rights Requests

To submit a request to exercise one of the privacy rights identified above, please:

Email HR@cadent.com and specifying (i) what type of request you are making (I.e., access, correction, or deletion) and (ii) that you are making such request pursuant to this Job Applicant Privacy Notice specifically.

Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. We may at times need to request additional personal information from you, taking into consideration our relationship with you and the sensitivity of your request.

In certain circumstances, we may decline a privacy rights request, particularly where you are not a resident of the State of California or where we are unable to verify your identity.

Pursuant to the CCPA, you have the right to not receive discriminatory adverse treatment for exercising any of
your CCPA rights.

Submitting Authorized Agent Requests

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above, where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. We may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

5. Changes to this Applicant Notice

Any change to this Applicant Notice shall be effective once the modified Applicant Notice is made available on this website, and we will update the “Effective Date” accordingly.

6. Contact Us

If you have any questions or requests in connection with this Applicant Notice, please send an email to privacy@cadent.tv with the subject line, “Applicant Privacy Notice”.

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