California Consumer Privacy Notice to California Employees and Job Applicants

This California Employee Privacy Notice (the “California Employee Privacy Notice”) supplements the Ad.net Privacy Notice and California Consumer Privacy Notice and applies to the personal information of California employees, interns, contractors, volunteers and applicants for roles at Ad.net, Inc., (“Ad.net” or the “Company”). This California Employee Privacy Notice also applies to information provided to us about employees’ relatives or others that is used for emergency contact or benefits administration purposes.

 

Please read this California Employee Privacy Notice to learn how we collect and process your personal information when you are employed by Ad.net, engaged to provide services to Ad.net or apply for a job with Ad.net. Under the California Consumer Privacy Act of 2018, Cal. Civ. Code § 1798.100 et seq. and its implementing regulations (the “CCPA”), as modified by the California Privacy Rights Act (the “CPRA”), 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. Certain terms used in this California Privacy Notice have the meaning given to them in the CCPA or CPRA and their implementing regulations. This California Employee Privacy Notice only applies to employees, contractors and job applicants who are residents of the State of California. The Company does not sell or otherwise disclose this personal information for monetary or other consideration to any third parties.

Categories of Personal Information We Collect

In each case as permitted by applicable law, we may collect, and within the last 12 months have collected the following categories of personal information for the purposes described below:

Category

Examples

Collected

A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, marital status, physical or mental disability, sex, veteran or military status,

YES

D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO

E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

YES

G. Geolocation data. Physical location or movements in company vehicles.

YES

H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information. Current or past job history or performance evaluations.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records to the extent necessary for purposes of tuition reimbursement.

YES

K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

 

We also may collect personal information included in job interview notes, responses to screening questions, assessment results and any other information you provide in connection with the recruitment process.

Sources of Personal Information

We collect personal information you voluntarily provide to us during the application process or when you otherwise contact us. Ad.net uses a third party service to manage payroll, benefits and other services once an applicant is offered employment. These third parties ( ex., Trinet) with collect your information on our behalf and will share may share the information with us. We also collect personal information from third parties as permitted by law, such as our service providers, background check providers, Employment Eligibility Verification Services (U.S. Citizenship and Immigration Services), certification or licensure governing bodies, and motor vehicle record providers.

We may combine personal information you voluntarily provide to us with information we collect from other sources, such as:

  • Recruiters;
  • Prior employers and professional references;
  • Educational institutions;
  • Pre-employment screening and background check services;
  • Credentialing and licensing organizations;
  • Publicly available sources, such as public social media profiles on LinkedIn, Twitter or Facebook; and
  • Other sources as directed by you.

Business Purposes for Collecting Personal Information

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

  • Recruitment of Employees and Processing and Managing Job Applications: We use your personal information to process your job application, evaluate your qualifications, schedule and conduct interviews and communicate with you.
  • Conducting Pre-Employment Screening and Background Checks: In accordance with applicable law, we may use your personal information to conduct employment screening and background checks.
  • Compensation and Expense Management: We use your personal information to conduct payroll processing, salary administration, expense reimbursement, manage the Company’s compensation programs such as determining bonuses, equity and other forms of employee compensation.
  • Benefits Administration: We use your personal information we collect to administer benefits we provide, such as medical, dental, vision, retirement benefits and other employee benefit programs.
  • General Human Resources Management: We use your personal information we collect to provide general HR management services, including managing employee on-boarding, termination and separation, travel administration and return-to-work screening (including any medical screening as required or permitted by applicable law).
  • Training and Professional Development: We use your personal information to provide employment-related training, assisting with professional licensing and development.
  • Internal Employment Purposes: We use your personal information to conduct internal investigations, conduct surveys, resolve disputes, prevent or detect fraud or security incidents, conduct employee performance reviews, enforce our policies and code of conduct, protect the rights and safety of employees or others and manage whistleblower programs.
  • Compliance with Legal Requirements and Enforcement of Our Legal Rights: We use your personal information to comply with applicable laws, regulations and legal processes (such as responding to subpoenas or court orders), and to respond to legal claims, resolve disputes, enforce our legal rights contained in employment or other contracts and comply with legal or regulatory recordkeeping requirements.

Disclosure of Personal Information

We may share your personal information for the business purposes described in this California Employee Privacy Notice with the following parties:

  • Affiliates and Subsidiaries: We may share your personal information with our affiliates and subsidiaries.
  • Service Providers: We may share your personal information with service providers, such as recruiters, pre-employment screening services, third-party benefits administrators, payroll processors, background check providers and others.
  • Governmental Authorities: As required by law or legal process, we may share your personal information with federal or state regulatory agencies, law enforcement, courts and other governmental authorities.
  • Professional Advisors: We may share your personal information with our professional advisors, such as auditors and law firms.
  • Parties Involved with Business Transfers: We may share your personal information to third parties in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).

In accordance with our policies and procedures, we will not discriminate or retaliate against you if you choose to exercise any of your rights under the CCPA or CPRA.

How to Contact Us

If you have any questions or concerns regarding this California Employee Privacy Notice or the collection of your personal information, please contact: [email protected].

10100 Santa Monica Blvd. Suite 110, Los Angeles, CA 90067

Attention: Privacy Officer

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.