Last Updated: June 27, 2023
Sources of Personal Information
We collect this Personal Information from you and from our affiliates, references you provide, prior employers or schools, recruiting and consulting firms, background check providers, social media networks, and publicly available databases.
Disclosure of Personal Information
We disclose Personal Information for the purposes described below in this Policy to the following categories of third parties:
- Our affiliates
- Our third-party service providers that provide services such as recruiting, talent acquisition, employment screening and background checks, consulting, information technology, and professional advisory services, such as lawyers
- Public and governmental authorities, such as regulatory authorities and law enforcement
NOTICE AT COLLECTION
Collection and Disclosure of Personal Information
The following chart details which categories of Personal Information we collect and process, as well as which categories of Personal Information we disclose to third parties for our operational business and hiring and recruitment purposes, including within the 12 months preceding the date this Policy was last updated.
|Categories of Personal Information||Disclosed to Which Categories of Third Parties for Operational Business Purposes|
|Identifiers, such as name, alias, postal address, unique personal identifiers, IP address that can reasonably be linked or associated with a particular consumer or household, email address, account name, online identifiers, and government-issued identifiers (e.g., Social Security number, driver’s license, passport)||Our affiliates; service providers; public and governmental authorities|
|Personal information as defined in the California customer records law, such as name, contact information, signature, passport number; education and employment information, physical characteristics or description||Our affiliates; service providers; public and governmental authorities|
|Protected Class Information, such as characteristics of protected classifications under California or federal law, such as sex, age, gender, race, disability, citizenship, military/veteran status, gender identity and expression, and immigration status||Our affiliates; service providers; public and governmental authorities|
|Commercial Information, such as travel information and expenses||Our affiliates; service providers; public and governmental authorities|
|Internet or network activity information, such as access and usage information regarding our website or online application portal, timestamp information, IP address and access and activity logs||Our affiliates; service providers; public and governmental authorities|
|Geolocation Data, such as approximate location of devices used to access our website or online application portal, derived from IP address||Our affiliates; service providers; public and governmental authorities|
|Audio/Video Data. Audio, electronic, visual and similar information, such as voicemail recordings and photographs, for example, where included on resumes||Our affiliates; service providers; public and governmental authorities|
|Education Information subject to the federal Family Educational Rights and Privacy Act such as student transcripts, grade point average, grades, academic standing and confirmation of graduation||Our affiliates; service providers; public and governmental authorities|
|Employment Information. Professional or employment-related information, such as work history and prior employer, information from reference checks, work experience, qualifications, training and skills, work authorization, CV, résumé, cover letter, professional and other work-related licenses, permits and certifications held, and publicly accessible information posted on your professional social media accounts||Our affiliates; service providers; public and governmental authorities|
|Inferences drawn from any of the Personal Information listed above||Our affiliates; service providers; public and governmental authorities|
|Sensitive Personal Information.
||Our affiliates; service providers; public and governmental authorities|
We may also disclose the above categories of Personal Information to a third party in the context of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
We do not “sell” Personal Information (including Sensitive Personal Information) and we do not “share” Personal Information (including Sensitive Personal Information) for purposes of cross-context behavioral advertising, as defined under the CCPA. We have not engaged in such activities in the 12 months preceding the date this Policy was last updated. Without limiting the foregoing, we do not “sell” or “share” Personal Information (including Sensitive Personal Information) of minors under 16 years of age.
Purposes for the Collection, Use, and Disclosure of Personal Information
We collect, use, and disclose Personal Information for the purposes of operating, managing, and maintaining our business, sourcing talent and recruiting employees, and accomplishing our business purposes and objectives, including, for example, using Personal Information to:
- Receive and process job applications;
- Manage the candidate selection process;
- Evaluate your suitability for the position(s) you are applying for;
- Communicate with you about your application, respond to your inquiries and notify you of applicable terms and policies;
- Conduct reference checks;
- Conduct background checks, consistent with applicable law;
- Analyze and monitor the diversity of job applicants, in accordance with applicable law;
- Subject to our discretion, make an offer to enter into an employment contract;
- Contact you about future career opportunities;
- Fulfill administrative functions, such as aggregate management reporting, statistical analyses, internal training, and as generally required to conduct our business; and
- Comply with law, legal process, requests from governmental or regulatory authorities, internal policies and other requirements such as record-keeping, equal employment opportunity laws, work permit and immigration regulations, reporting obligations, and the exercise or defense of legal claims.
Purposes for the Collection, Use, and Disclosure of Sensitive Personal Information
We collect, use, and disclose Sensitive Personal Information for purposes of performing and improving services for our business, providing services as requested by you, and ensuring the security and integrity of our business, services, infrastructure and the individuals we interact with. This includes, without limitation, receiving and processing your job application, evaluating your suitability for the position(s) you are applying for, conducting background checks, analyzing and monitoring diversity, making you an offer (subject to our discretion), fulfilling administrative functions, complying with legal obligations, legal process, or requests from governmental or regulatory authorities, exercising or defending legal claims, securing the access to, and use of, our facilities, equipment, systems, networks, applications, and infrastructure, preventing, detecting, and investigating security incidents, resisting and responding to fraud or illegal activities, and ensuring the physical safety of individuals. We do not use or disclose Sensitive Personal Information for additional purposes.
We retain each category of Personal Information (including Sensitive Personal Information) for as long as needed or permitted considering the purpose(s) for which it was collected. The criteria used to determine our retention periods include:
- The duration of the job application process;
- Whether your job application is successful and you become and employee;
- Whether, if your application is not successful, you would like to be notified of future job opportunities with us or our affiliates;
- The length of time we have an ongoing relationship with you and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
- Whether there is a legal obligation to which we are subject (for example, certain laws may require us to keep your application records for a certain period of time); and
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Individual Rights and Requests
- You may, subject to applicable law, make the following requests:
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- The specific pieces of your Personal Information;
- The business or commercial purpose for collecting Personal Information about you; and
- The categories of Personal Information about you that we disclosed, and the categories of third parties to whom we disclosed such Personal Information (if applicable).
- You may request to correct inaccuracies in your Personal Information.
- You may request that we delete your Personal Information that we have collected from you.
We will not unlawfully retaliate against you for making a request under the CCPA To make a privacy request, please contact us at firstname.lastname@example.org, 646-569-2300 or toll free at 1-833-358-2395, or by mail at ORIX USA, 280 Park Avenue, 40th Floor, New York, NY 10169, Attn: Chief Compliance Officer. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. In order to verify your identity and protect against fraudulent request, we may need to request additional Personal Information from you, such as the email address or phone number provided on the application. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.
If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted in the section entitled “Individual Rights and Requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning his or her status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Individual Rights and Requests” or confirm that you provided the agent permission to submit the request.
In certain cases we will ask questions about race/ethnic origin, gender, and disability of our job applicants, for monitoring equal opportunity. We may also inquire about criminal records, where permitted by applicable law. Otherwise, we ask that you avoid submitting information that may qualify as sensitive information under applicable law, except where such information is legally required. We are an equal opportunity employer, which means we offer equal treatment to all job applicants consistent with applicable law. We do not unlawfully discriminate, either directly or indirectly, based on characteristics protected by applicable law, such as: race, ethnicity, sex, gender identity, sexual orientation, nationality, national origin, ethnic origin, religion, beliefs or creed, age, disability, marital status, veteran status or genetic information in any area of recruitment.
Any information you submit to us must be true, complete and not misleading. Submitting inaccurate, incomplete, or misleading information may lead to a rejection of your job application during the application process or disciplinary action including immediate termination of employment. In addition, it is your responsibility to ensure that information you submit does not violate any third party’s rights. If you provide us with Personal Information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.
Changes to this Policy
We may change or update this Policy from time to time. When we do, we will communicate changes and updated to this Policy by posting the updated Policy on this page with a new “Last Updated” date.
Please contact email@example.com if you have any questions regarding this policy.