This Privacy Notice for California Residents (“Notice”) supplements the information contained in Savista’s (the “Company”) general Privacy Policy (available on our website) and applies solely to individuals who seek employment with the Company and reside in the State of California (“consumers” or “you”).  This policy is intended to describe our online and offline information practices as they relate to your personal information and also to describe your rights related to your personal information.  We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and its implementing regulations and any terms defined in the CCPA/CPRA have the same meaning when used in this notice.

 

This Notice does not include information practices related to employee onboarding or employment with the Company.  For California residents who receive an offer of employment, please refer to our Privacy Policy & Notice for California Colleagues.

 

Information we collect

 

The Company collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (personal information).  The Company collects and uses personal information for recruiting activities, business-related purposes and to be in legal compliance.

 

We collect the following categories of personal information in association with your application for employment with us:

 

Identifiers: such as your name, email address, phone numbers, username, online identifier, device identifier, IP address, social media handle, physical address, and government-issued identifiers.

 

Demographics: such as your date and place of birth; age; gender; nationality; native language; family and marital status; veteran status; details of family members and dependents (name, date of birth, relationship to applicant or candidate); and emergency contact name, address, and telephone number.

 

Information regarding eligibility to work, such as passport or visa information.

 

Work history: such as position/title; location; work address; start and end-dates of employment; contact information for former employer(s) or other persons or entities for which work was performed; business unit; function; organizational unit; dates and reasons for hire, promotion, transfer, status change and termination; employment status (full-time or part-time); employment type; job performance and related evaluative information; information relating to awards, certifications, and professional associations and volunteer activities; language proficiency; skills.

 

Education information: such as education level, training, development, professional degrees, and certificates.

 

Inferences and other characteristics: such as any observations we may make based on your application or interview, and information provided by your references. We use the information we collect for the following purposes:

 

- Processing your application

- Evaluating your qualifications

- Administering and managing our recruitment processes

- Managing payroll and compensation

- Developing financial and employment metrics

- Budgeting, forecasting, and reporting

- Monitoring and complying with legal requirements

- Responding to internal or external audits and inquiries, law enforcement requests, or requests from administrative or judicial authorities

- Monitoring and promoting compliance with our policies and procedures

- Security

 

If you provide us with personal information about members of your family and/or other dependents (e.g., for emergency contact), it is your responsibility to provide them with the information contained in this section.

 

Personal information does not include:

 

- Publicly available information from government records.

- Deidentified or aggregated consumer information.

- Information excluded from the CCPA/CPRA’s scope, like:

• • - health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • - personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994 (DPPA).

 

Participants in video interviews

 

Please note when you use Company provided technology (such as Zoom or Teams) to participate in an online video interview, you consent and agree to the use of your personal information for this purpose; such technology providers may maintain their own terms of use and privacy policies for your use of those platforms, for which the Company disclaims any responsibility.

 

The Company does not require a video interview and does not record video interviews.  Therefore, the Company does not collect or store your voice or image as the result of a video interview. Information learned about you through online interviews may include information about your personality, behavior, and suitability for a particular position. Sensitive personal information may be revealed in a video interview such as racial or ethnic origin, religion or philosophical beliefs, sexual orientation, membership in a trade union, political affiliation, physical or mental health or condition, commission or alleged commission of an offense or related proceedings or job evaluations or educational records. The Company does not require and asks that you do not provide such information as part of these interviews.

 

Sources of personal information

 

The Company obtains the categories of personal information listed above from the following categories of sources:

 

- Directly from you. For example, information you provide in online profiles, including social media or career sites, job applications, recruiting events, e-mail correspondence, voicemails, or phone screens or interviews.

 

Use of personal information

 

We may use or disclose the personal information we collect for one or more of the following purposes:

 

• - To recruit and evaluate your job application and/or candidacy for employment. For example, if you share your name, job history and other personal information on an employment application, the Company will use that information to process your application for employment.  In addition, the Company may also save your information to contact you about future openings or for legal record-keeping purposes.
• - To facilitate the creation, maintenance and security of your online applicant account(s) or profiles and enable your use of those accounts/profiles.
• - To conduct interviews for a job position for which you have applied or generally for future open positions.
• - To provide you with support, to communicate with you, and to respond to your inquiries, including to address your concerns.
• - To monitor our operations and improve our recruitment processes or responses.
• - To conduct audits or workplace investigations, including investigation of potential breaches of Company policies, procedures or compliance requirements.
• - To defend the interests of the Company or colleagues in threatened or actual legal proceedings, investigations or inquiries.
• - To comply with all applicable federal, state or local laws and regulations.

 

The Company will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

The Company only collects or processes your sensitive personal information for the purposes expressly permitted by the CCPA/CPRA and its implementing regulations.  The Company does not collect or process sensitive personal information for the purpose of inferring characteristics about you.

 

 

Disclosure of personal information

 

The Company may disclose your personal information to external parties for a business purpose, including those purposes noted above. When we disclose personal information for a business purpose to a Service Provider or Contractor, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

 

We also may disclose your personal information to other third parties when required by law or to meet a legal or compliance obligation.

 

We disclose your personal information to the following categories of external parties:

 

• - Service providers who are providing a service for, or on behalf of, the Company such as our HR/recruiting information systems providers, website providers, recruiters, or auditors.
• - Other external parties such as government authorities, law enforcement or state and federal investigative agencies where we may be required to disclose your information to meet a legal or compliance obligation.

Sale or Sharing of Personal Information

 

The Company does not sell personal information or share personal information for cross-context behavioral advertising.

 

Retention of Personal Information

 

In broad terms, we will only retain your Information for as long as is necessary for the purposes described in this Notice. This means that the retention periods will vary according to the type of Information and the reason that we have collected the Information in the first place. For example, some Information we collect will be kept for a number of years in order to comply with various finance and tax related legal obligations. We have detailed internal retention policies that set out the various retention periods for different categories of information, depending on our legal obligations and whether there is a commercial need to retain the Information. After a retention period has lapsed, the information is securely deleted, unless it is necessary for the establishment, exercise or defense of legal claims. For further information regarding applicable retention periods, you should contact us using the contact methods set out below.

 

Your rights and choices

 

The CCPA, as amended by the CPRA, provides you (California residents) with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights.

 

Your Right to Know and Access Specific Pieces of Personal Information (Data Portability Rights)

 

You have the right to request that the Company disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Deletion, and Correction Rights), we will disclose to you:

 

• - The categories of personal information we collected about you.
• - The categories of sources for the personal information we collected about you.
• - Our business or commercial purpose for collecting, selling, or sharing that personal information.
• - The categories of third parties with whom we disclose that personal information.
• - The specific pieces of personal information we collected about you (if requested, also called a data portability request).
• - If we sold or shared your personal information, or disclosed it for a business purpose, two separate lists disclosing:
  • - the categories of personal information sold or shared about you and the categories of third parties to whom the information was sold or shared (by category of personal information for each category of third party); and
  • - the categories of personal information disclosed about you for a business purpose and the categories of persons to whom it was disclosed.

 

Your Right to Delete Personal Information

 

You have the right to request that the Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Deletion, and Correction Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

 

• - Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• - Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for
  such activities.
• - Debug products to identify and repair errors that impair existing intended functionality.
• - Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• - Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• - Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• - Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• - Comply with a legal obligation.
• - Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Your Right to Correction Inaccurate Personal Information

 

You have the right to request that the Company correct inaccurate personal information that we maintain about you.  Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Deletion, and Correction Rights), we will use commercially reasonable efforts to correct (and direct our service providers to correct) your inaccurate personal information in our records.

 

 

Exercising access, data portability, deletion and correction rights

 

To exercise the access, data portability, deletion and correction rights described above, please submit a verifiable consumer request via email to [email protected] or by calling 1-833-770-3100.

 

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.  Your request for access or data portability will apply to personal information collected on or after January 1, 2022, that is still maintained by the Company at the time of the request.  You may specify a shorter time-period for your request at your option.

 

The verifiable consumer request must:

 

• - Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. For example, we may need to verify your home address or other information to validate against our system information.  Authorized representatives may be asked to provide documentation to support their role.
• - Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

 

Making a verifiable consumer request does not require you to create an account with us.

 

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

For instructions on exercising sale opt-out rights, see Your Right to Opt-Out of Personal Information Sale or Sharing.

 

Response timing and format

 

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

 

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

 

The response we provide will explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Your Right to Opt-Out of Personal Information Sale or Sharing

 

The Company does not sell or share personal information described in this Notice.  However, if you are 16 years of age or older, you have the right to direct us to not sell or share your personal information at any time (the “right to opt-out”).  We will maintain your preference on file to prevent any future sale or sharing.

 

We do not sell or share the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

 

To exercise the right to opt-out, you (or your authorized representative) may submit a request via email to [email protected] or via phone by calling 1-833-770-3100.

 

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by submitting a request to [email protected] or by calling 1-833-770-3100.

 

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

 

Your Right to Limit the Use and Disclosure of Sensitive Personal Information

 

You have the right to request that the Company limit its use of your sensitive personal information when used for purposes other than those permitted by the CCPA/CPRA and its implementing regulations.  Sensitive personal information that is collected or processed as permitted is not subject to this “Right to Limit” and is treated as personal information (and thus subject to other rights listed above).  The Company only collects or processes your sensitive personal information for the purposes expressly permitted by the CCPA/CPRA and its implementing regulations.

 

 

Your Right to No Retaliation

 

You have the right to exercise your rights without retaliation.  We will not discriminate against you for exercising any of your CCPA/CPRA rights. Unless permitted by the law, we will not:

 

• - Deny you goods or services
• - Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
• - Provide you a different level or quality of goods or services
• - Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services

 

If you feel you have experienced retaliation, you are encouraged to call the 1-844-606-1748 or https://savista.ethicspoint.com/, Organization Name: Savista. Callers can report concerns anonymously and confidentially.

 

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

 

Other California privacy rights

 

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, submit your request to [email protected].

 

Changes to our privacy notice

 

The Company reserves the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice on our website at the point of collection and update the “Last Updated” date.

 

Contact information

 

If you would like information about how colleagues with disabilities may access this privacy notice in an alternative format, or if you have any questions or comments about this notice, the ways in which the Company collects and uses your information described in this notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at [email protected].