Job Applicant Privacy Notice

Last Updated: April 2024

This Privacy Notice (“Privacy Notice” or “Notice”) explains how Stephen Gould Corporation (“company,” “we,” or “us,” or “our”) collects personal information from job applicants (“applicant personal information”), to the extent the personal information is collected and used by us solely within the context of their status as a job applicant. This Notice supplements other privacy notices you may receive in connection with your relationship with us.

Please note that the job application portal, including job information webpages and the application form, are managed by a third-party vendor. When you navigate to a job information webpage or apply for one of our open positions, you will be interacting with the third-party vendor’s website.

Notice at Collection: Applicant Personal Information We Collect

The categories of personal information we collected from these sources during the 12 months preceding the date of this Notice, and will continue to collect, includes the following:

• Personal identifiers: email address, postal address, and government-issued identification documents.
• Protected class information: race, ethnicity, gender, gender identification, and veteran status.
• Professional information: records of your work and education history.
• Educational information: education history, trade school records, and certificates obtained.
• Sensitive personal information: race, ethnicity and other diversity data

We have collected the same categories of applicant personal information in the 12 months prior to the date of this Privacy Notice.

Notice of Collection: Purposes for Collection of Personal Information

We use your personal information to evaluate your application for employment, to conduct job interviews, to improve our promotional and recruitment efforts, and to comply with applicable law.

Notice at Collection: Categories of Personal Information We Sell or Share

We do not sell or share for cross-context behavioral advertising the personal information of our employees or contractors.

Notice at Collection: Retention Periods

We retain the categories of applicant personal information for the length of time necessary to evaluate applicants, comply with legal obligations and to protect our legal rights.

Sources From Which We Collect Personal Information

We collect your applicant personal information when you applied for a position with us or otherwise voluntarily provided information to us. We will continue to collect personal information from the same sources.

Use or Disclosure of Sensitive Personal Information

We do not use or disclose sensitive applicant personal information to infer characteristics about applicants or for any purposes other than to identify applicants to comply with applicable laws or to operate our business, including by evaluating applicants.

Disclosure of Personal Information For Business Purposes in the Past 12 Months

The following chart describes the categories of personal information that we disclosed to third parties for a business purpose in the 12 months prior to the date of this Notice:

Additional Information About How We May Disclose Personal Information

We may also share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share your personal information with third parties to help detect and protect against fraud or data security vulnerabilities. And we may share or transfer your personal information to a third party in the event of an actual or potential sale, merger, reorganization of our entity or other restructuring.

Rights Related to Personal Information Held by Us

California law provides certain rights to California residents. If you are a California resident, you have the following rights.

Your Right To Access Information We Collect and Share About You

You can ask us for the following information from us with respect to the employment personal information that we have collected about you since January 1, 2022:

• Specific pieces of personal information we have collected about you;
• Categories of personal information we have collected about you;
• Categories of sources from which such personal information was collected;
• Categories of personal information that the business sold or disclosed for a business purpose about you;
• Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
• The business or commercial purpose for collecting or selling your personal information.

Your Right To Request Deletion of Personal Information We Have Collected From You

Upon your request and subject to exceptions in the law, we will delete applicant personal information we have collected about you.

Your Right to Request to Correct Applicant Personal Information We Hold About You

You have the right to request that we correct applicant personal information we hold that you believe is not accurate. We will take steps to determine the accuracy of the personal information that is the subject of your request to correct, and in doing so will consider the totality of the circumstances relating to the personal information you have identified as being incorrect. We may ask that you provide documentation regarding your request to correct in order to assist us in evaluating the request.

Our Commitment to Honoring Your Rights

If you exercise any of the rights explained in this Privacy Notice, we will continue to treat you fairly.

Exercising Your Rights and How We Will Respond

To exercise your access, deletion, or correction rights, or to ask a question about your data subject rights, submit your request through the webform,
https://privacyform.stephengould.com, or contact us at 833-527-2436.

We will first acknowledge receipt of your request within 10 business days of receipt of your request.  We will then provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances.

You can direct us not to sell your personal information or share it for purposes of cross-context behavioral advertising here. For such requests, we will comply no later than 15 business days after receipt of your request.

We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations.

In some cases, the law may allow us to refuse to act on certain requests.  When this is the case, we will endeavor to provide you with an explanation as to why.

Verification of Identity – Access, Deletion, or Correction Requests

We will ask you for two or three pieces of personal information and attempt to match those to information that we maintain about you.

If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request.  We will notify you to explain the basis of the denial.

Authorized Agents

You may designate an agent to submit requests on your behalf.  The agent can be a natural person or an entity that is registered with the California Secretary of State.

If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our verification process. Specifically, if the agent submits requests to access, know or delete your personal information, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.

Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney.  Any such requests will be processed in accordance with California law pertaining to powers of attorney.

Personal Information of Minors

We do not advertise our positions to minors under 16, and we do not knowingly collect or sell the personal information of minors, including minors under 16 years of age.

Third Party Websites and Social Media Buttons

Our site may contain links to third party websites, including social media buttons that link to social media platforms. This Notice does not govern how those third parties or social media platforms collect or use personal information and we do not endorse or have control over their practices. The privacy policies and terms of use for those third parties’ websites/apps or social media platforms govern those companies’ privacy practices. We are not responsible for the content or privacy practices of any third-party websites or platforms.

How We Keep Your Personal Information Secure

We maintain reasonable security measures appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process. Those measures include administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security.

Changes to This Notice

We will review and update this Notice as required to keep current with rules and regulations, new technologies and security standards. We will post those changes on the website or update the Privacy Notice modification date above. In certain cases and if the changes are material, you will be notified via email or a notice on our website.

Accessibility

We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact our Human Resources department at the number set forth below.

Contact Us

If there are any questions regarding this Privacy Notice or to request a copy of this Privacy Notice in another format you may contact our Human Resources department at meheyert@stephengould.com or 973-463-3908.