Proven Recruiting, Inc. California Applicant Privacy Notice

Effective Date: May 15, 2023

The purpose of this Applicant Privacy Notice (“Applicant Privacy Notice”) is to inform Proven Recruiting, Inc.’s (“Proven Recruiting,” “us,” “we,” or “our”) California job Applicants of our practices regarding the collection, use, and disclosure of their Personal Information, and the rights they have under the California Consumer Privacy Act, as amended (the “CCPA”). “Applicant” means California residents applying for jobs with Proven Recruiting.

Please read this Applicant Privacy Notice and our Terms of Use carefully before using our websites, applications, or services (“Services”). By using the Services or otherwise providing Personal Information to us, you agree to our Terms of Use and our privacy practices as described in this Applicant Privacy Notice.

Unless otherwise noted, the disclosures herein cover our activities in the twelve (12) months preceding the Effective Date, as well as our current practices.

• How and Why We Collect, Use, and Disclose Your Personal Information

As used in this Applicant Privacy Notice, the term “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 Proven Recruiting Applicants. 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 Applicant Privacy Notice applies only to information governed by the CCPA.

Proven Recruiting may collect, use, and disclose Personal Information for business purposes consistent with applicable laws as identified below. Where Proven Recruiting discloses 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 Personal Information	Business Purposes for Collection, Use, or Disclosure	Categories of Recipients to whom Personal Information is Disclosed for a Business Purpose
Identifiers such as name, alias, telephone number, email address, IP address, professional licenses, 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 •  Background check vendors
Personal information described in Cal. Civ. Code § 1798.80(e) such as name, telephone number, education, employment history	•  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 •  Background check vendors
Protected classification characteristics such as military or veteran status, disability status, race and ethnic origin, and sex	•  To comply with applicable laws and regulations •  For diversity, equity, and inclusion initiatives	•  Service providers •  Background check vendors
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	•  Service providers •  Background check vendors
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	•  Service providers •  Background check vendors
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 •  Background check vendors
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 background check information, drug and alcohol screening history, and languages spoken	•  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 •  Background check vendors

We may also collect 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 your CV, during your interview, or in other communications.

• Disclosing Personal Information

We may disclose each of the categories of 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 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 Personal Information described in this Applicant Privacy Notice, we may collect, use, and disclose 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 Personal Information to other parties in connection with the sale, assignment, merger, or reorganization.

• Sources of Personal Information

We may collect 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.
• From service providers that help us run our business. For example, background check vendors, 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.

• Sales and Sharing of Personal Information

We do not sell Applicant Personal Information or share it for cross-context behavioral advertising. We do not have actual knowledge that we sell or share the Personal Information of Applicants under sixteen (16) years of age.

• How Long We Keep Your Personal Information

We will store your Personal Information for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the 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 Personal Information from our systems and records or take appropriate steps to properly anonymize, deidentify, or aggregate it, where legally applicable.

• Submitting Requests Relating to Your 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 email us at hello@provenrecruiting.com or call us toll free at (858) 412 1111 Please note that if you submit a request, you will be asked to provide two-to-three (2-3) pieces of Personal Information that we will match against our records to verify your identity. 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 Personal Information we have collected about you, which includes:

• The categories of Personal Information we have collected about you, including:
  1. The categories of sources from which the Personal Information was collected;
  2. Our business or commercial purposes for collecting Personal Information;
  3. The categories of recipients to which we disclose Personal Information;
  4. The categories of 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 Personal Information.
• The specific pieces of Personal Information we have collected about you.

Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions.

Right to Correct Inaccurate Information. If you believe that 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 your 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 Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

Right to Access and Opt-Out of Automated Decision Making. We do not use automated decision making technology for purposes to which the right to access and opt-out 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.

California “Shine the Light.” We do not share Personal Information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. Californians may request information about our compliance with this law by contacting us via email at hello@provenrecruiting.com.

• Not for Children

Our Services are neither intended for, nor targeted to children. If you are a parent or guardian and you believe that your child has provided Personal Information to us, please contact us so that we can delete the information.

• Changes to this Applicant Privacy Notice

This Applicant Privacy Notice may be revised from time to time for any reason. If this Applicant Privacy Notice changes, the revised Applicant Privacy Notice will include a new effective date, and we will notify you of such changes by posting the revised Applicant Privacy Notice on this page. Any such changes will automatically apply on or after the effective date.

• How to Contact Us

If you have any questions about how Proven Recruiting handles your Personal Information, please contact us at:

Phone: 858-412-1111

Email: hello@provenrecruiting.com