Privacy Notice to California Job Applicants

Best Formulations LLC. and/or any affiliated entities (collectively, the “Company” or “we”) provide this California Privacy Notice (“Notice”) to describe our privacy practices with respect to our collection of Personal Information as required under the California Consumer Privacy Act and the California Privacy Rights Act as amended (Cal. Civ. Code §§ 1798.100 to 1798.199), and any related regulations or guidance provided by the California Attorney General and/or the California Privacy Protection Agency (“CCPA”). This Notice “Personal Information” and “Sensitive Personal Information” as defined in the CCPA. We provide you this Notice because under the CCPA, California residents who are job applicants qualify as Consumers. For purposes of this Notice, when we refer to Consumers, we mean you only to the extent you are a job applicant of the Company who resides in California.

1. Information We Collect From or About Job Applicants

We may collect Personal Information and Sensitive Personal Information from or about you in a variety of different situations and using a variety of different methods, including, but not limited to, on our website, your mobile device, through email, in physical locations, through written applications, through the mail, and/or over the telephone. Generally, we may at various times collect, receive, maintain, and use the following categories of Personal Information and Sensitive Personal Information for any of the Business Purposes listed below in this

CATEGORY
(Personal Information) 		EXAMPLES
Personal Identifiers Name, alias, Social Security Number, Date of Birth, driver’s license or state identification card number, passport number, application ID number, username and password for Company accounts and systems.
Contact Information Home, postal or mailing address, email address, home phone number, cell phone number.
Protected Classifications Race, ethnicity, national origin, sex, gender, sexual orientation, gender identity, religion or philosophical beliefs, age, disability, medical or mental condition, military status, familial status, language, or union membership.
Physical Characteristics or Description Information on your Driver’s License, Passport, Student ID card with photo or Identification card (such as eye color, hair color, height, weight)
Pre-Hire Information Information provided in your job application or resume, information gathered as part of background screening and reference checks, pre-hire drug test results, information recorded in job interview notes by persons conducting job interviews for the Company, information contained in candidate evaluation records and assessments, information in work product samples you provided, voluntary disclosures by you, and Wage Opportunity Tax Credit (WOTC) information.
Employment History Information regarding prior job experience, positions held, names of prior supervisors, and when permitted by applicable law your salary history or expectations.
Education Information Information contained in your resume regarding educational history and information in transcripts or records of degrees and vocational certifications obtained.
Travel Information Information regarding business travel, vacation and personal travel plans, and for infectious disease contact tracing purposes the locations travelled to within the applicable infectious period prior to coming to the workplace and the dates spent in those locations.
Mobile Device Security Information Data identifying job applicant devices accessing Company networks and systems, including cell phone make, model, cell phone number, and cell phone provider.
Online Portal and Mobile App Access and Usage Information Username and password, account history, usage history, file access logs, and security clearance level.
Visual, Audio or Video Recordings in the Workplace Your image when recorded or captured in surveillance camera footage or pictures of job applicants taken in the workplace or at a Company function or event, or in pictures or video of job applicants posted on social media to which the Company or its managers have access or that are submitted to the Company by a third party.
Contents of Personal Communications where the Company is not the intended recipient Job applicants have no expectation of privacy with respect to any communications or data they send, receive, access or store on any company computer or system, including any personal communications. The Company may monitor, access, review and use all such communications and data for lawful business purposes detailed below, including to manage and evaluate employee performance and make employment decisions.

Of the above categories of Personal Information, the following are categories of Sensitive Personal Information the Company may collect:

  1. Personal Identifiers (social security number, driver’s license or state identification card number, passport number)
  2. Account Information (your Company account log-in, in combination with any required security or access code, password, or credentials allowing access to the account)
  3. Protected Classifications (racial or ethnic origin, religious or philosophical beliefs, or union membership)
  4. Biometric Information (used for the purpose of uniquely identifying you)
  5. Medical and Health Information
  6. Geolocation Data (IP address and/or GPS location, latitude & longitude)
  7. Contents of Personal Communications (contents of mail, email, and text messages where the Company is not the intended recipient)

Personal information does not include:

  • Publicly available information from government records.
  • Information that a business has a reasonable basis to believe is lawfully made available to the general public by the job applicant or from widely distributed media.
  • Information made available by a person to whom the job applicant has disclosed the information if the job applicant has not restricted the information to a specific audience.
  • De-identified or aggregated information.

2. How We Use Personal Information and Sensitive Personal Information

The Personal Information and Sensitive Personal Information we collect, and our use of Personal Information and Sensitive Personal Information, may vary depending on the circumstances. This Notice is intended to provide an overall description of our collection and use of Personal Information and Sensitive Personal Information. Generally, we may use or disclose Personal Information and Sensitive Personal Information we collect from you or about you for one or more of the following purposes:

  1. To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to apply for a job with the Company, we will use that Personal Information in connection with your candidacy for employment.
  2. To comply with local, state, and federal law and regulations requiring employers to maintain certain records (such as immigration compliance records, travel records, personnel files, wage and hour records, payroll records, accident or safety records, and tax records), as well as local, state, and federal law, regulations, ordinances, guidelines, and orders relating to COVID-19.
  3. To maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance.
  4. To engage in lawful monitoring of job applicant activities and communications when they are on Company premises, or utilizing Company internet and WiFi connections, computers, networks, devices, software applications or systems.
  5. To evaluate job applicants and candidates for employment or promotions.
  6. To obtain and verify background checks on job applicants and to verify employment references.
  7. To evaluate, make, and communicate decisions regarding your job application and candidacy for employment, including decisions to hire.
  8. To communicate with you regarding your candidacy for employment.
  9. To engage in corporate transactions requiring review or disclosure of job applicant records subject to non-disclosure agreements, such as for evaluating potential mergers and acquisitions of the Company.
  10. To promote and foster diversity, equity, and inclusion in the workplace.
  11. To evaluate and improve our recruiting methods and strategies.
  12. COVID-19 RELATED PURPOSES
    • To reduce the risk of spreading the disease in or through the workplace.
    • To protect job applicants and visitors from exposure to COVID-19.
    • To comply with local, state, and federal law, regulations, ordinances, guidelines, and orders relating to COVID-19, including applicable reporting requirements.
    • To facilitate and coordinate pandemic-related initiatives and activities (whether Company-sponsored or through the U.S. Center for Disease Control and Prevention, other federal, state and local governmental authorities, and/or public and private entities or establishments, including vaccination initiatives).
    • To identify potential symptoms linked to COVID-19 (including through temperature checks, antibody testing, or COVID-19 questionnaire).
    • To permit contact tracing relating to any potential exposure.
    • To communicate with job applicants and visitors regarding potential exposure to COVID-19 and properly warn others who have had close contact with an infected or symptomatic individual so that they may take precautionary measures, help prevent further spread of the virus, and obtain treatment, if necessary.
  13. To evaluate, assess, and manage the Company’s business relationship with vendors, service providers, and contractors that provide services to the Company.
  14. To improve user experience on Company computers, networks, devices, software applications or systems, and to debug, identify, and repair errors that impair existing intended functionality of our systems.
  15. To detect security incidents involving potentially unauthorized access to and/or disclosure of Personal Information or other confidential information, including proprietary or trade secret information and third-party information that the Company receives under conditions of confidentiality or subject to privacy rights.
  16. To protect against malicious or illegal activity and prosecute those responsible.
  17. To prevent identity theft.
  18. To verify and respond to consumer requests under applicable consumer privacy laws.

3. Retention of Personal Information

The Company will retain each category of Personal Information in accordance with our data retention schedule, which you can access here. In deciding how long to retain each category of Personal Information that we collect, we consider many criteria, including, but not limited to: the business purposes for which the Personal Information was collected; relevant federal, state and local recordkeeping laws; applicable statute of limitations for claims to which the information may be relevant; and legal preservation of evidence obligations.

We apply our data retention procedures on an annual basis to determine if the business purposes for collecting the personal information, and legal reasons for retaining the personal information, have both expired. If so, we will purge the information in a secure manner.

4. Sale/Sharing of Information to Third Parties

The Company does not and will not sell your Personal Information or Sensitive Personal Information for any monetary or other valuable consideration. The Company does not and will not share your Personal Information or Sensitive Personal Information for cross-context behavioral advertising.

5. Access to Privacy Policy

For more information, please review the Company’s Privacy Policy at https://www.bestformulations.com/privacy.