Notice of Collection of Personal Information for California Job Applicants
Effective Date: October 1, 2023
The purpose of this Applicant Privacy Notice (“Applicant Privacy Notice”) is to inform California job applicants (“Applicants” or “you”) of Empire Today, LLC, and its wholly-owned subsidiaries (collectively, “Empire,” “we,” “us,” or “our”), of the categories of Applicant Personal Information we collect, use, and disclose, and the rights you have relating to your Applicant Personal Information under the California Consumer Privacy Act, as amended (the “CCPA”).
Unless otherwise noted, the disclosures herein cover our activities in the twelve (12) months preceding the Effective Date, as well as our current practices.
I. Collection, Use, and Disclosure of Applicant Personal Information
As used in this Applicant Privacy Notice, the term “Applicant 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 Empire Applicants. Applicant 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.
We may collect, use, and disclose Applicant Personal Information for business purposes consistent with applicable laws as identified below. Where Empire discloses applicable Applicant 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 Applicant Personal Information
|Business Purposes for Collection, Use, or Disclosure
|Categories of Recipients to whom Applicant Personal Information is Disclosed for a Business Purpose
Identifiers, such as name, alias, title, username and password for our careers website, telephone number, email address, mailing address, IP address, signature, social media usernames, and professional license numbers
Personal information described in Cal. Civ. Code § 1798.80(e), such as name, physical and electronic signature, address, telephone number, education, employment, employment history
Protected classification characteristics under California or federal law, such as age and date of birth, marital status, race, ancestry, ethnic origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, genetic information, disability, marital status
Internet or other electronic network activity information, such as browser type and language, operating system, website access time, duration of visit, referring website address, browsing and search history on our websites, webpages viewed immediately before and after our websites, information related to your interactions with our websites, social media pages, emails, online chat, text message communications, and advertisements
Geolocation data, such as your geographic location inferred from your device IP address
Audio, electronic, visual, thermal, olfactory, or similar information, such as photographs on documents you may provide during the application process
Professional or employment-related information, such as skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, application form, or cover letter;
Non-public education information, including school(s) attended, degrees obtained, and other information relating to your education
Inferences drawn from other personal information, such as preferences, characteristics, predispositions, behavior, or attitudes based on other personal information collected about you
Other Applicant Personal Information, such as citizenship, visa status, work authorization information, languages spoken, willingness to relocate, driving record, criminal records, and drug and alcohol screening
Sensitive Applicant Personal Information, including social security, driver’s license, state identification card, or passport number; racial or ethnic origin; and information concerning your health (e.g., drug-screening information)
In addition to the categories above, we may collect and maintain Applicant Personal Information you provide to us on a voluntary basis that we do not regularly request. For example, information you volunteer in communications with us, information on your CV, or information in your cover letter.
II. How We Disclose Applicant Personal Information
We may disclose each of the categories of Applicant 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 Applicant Personal Information was collected including, but not limited to:
- Auditing related to ads;
- Helping to ensure security and integrity;
- Debugging, repairing, and improving functionality;
- Short-term, transient use;
- Performing services on our behalf;
- Providing advertising and marketing services, as applicable;
- Internal research for technological development; and
- Verifying quality and/or safety.
In addition to the other purposes for collection, use, and disclosure of Applicant Personal Information described in this Applicant Privacy Notice, we may collect, use, and disclose Applicant 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 Applicant Personal Information to other parties in connection with the sale, assignment, merger, or reorganization.
III. Sources of Applicant Personal Information
We may collect the Applicant Personal Information identified above from the following sources:
- Directly from you. For example, during the application process and throughout your interactions 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.
- Automatically when you visit our facilities. For example, security camera footage.
- From service providers that help us run our business. For example, from human resources and information technology vendors, background check agencies, 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.
IV. Tracking Technologies
We may use tracking technologies, such as cookies, including tracking technologies managed by vendors or external parties.
Tracking technologies can generally be categorized as follows:
- Necessary or essential. These tracking technologies are used for core functionality, for example for security and to enforce your privacy preferences. Without these cookies, some functionality on our websites and apps may fail.
- Functional or analytics. These tracking technologies help to improve our websites and apps by allowing us to understand how they are used and how they perform. We may also use location-aware technologies for purposes such as verifying your location and delivering or restricting content based on your location.
- Advertising. These tracking technologies help personalize ads that are shown to you on our websites and apps. If enabled, these tracking technologies will allow other parties to engage in advertising based on your use of online services
We may use Google Analytics or other providers for analytics services. We may also implement Google Analytics Advertising Features such as remarketing with analytics and interest-based ads. We may use first-party cookies or other first-party identifiers as well as third-party cookies or other third-party identifiers to, e.g., deliver advertisements, measure your interests, and/or personalize content. For more information on how Google Analytics uses data collected through our services, visit https://www.google.com/policies/privacy/partners. To opt out of Google Analytics cookies, visit https://tools.google.com/dlpage/gaoptout or download the Google Analytics Opt-Out Browser Add-On.
Depending on your device settings, you may also opt out of certain interest-based advertising through the device’s "Limit Ad Tracking" or equivalent feature. Refer to your device for more information on what this opt out affects. For instance, you can adjust or reset the advertising identifiers on your mobile device in the device settings. iOS users can visit Settings > Privacy > Advertising > Reset Advertising Identifier. Android users can visit Google settings > Ads > Reset advertising ID.
V. Selling or Sharing of Applicant Personal Information
We may sell or share the following categories of Applicant Personal Information with third parties for the purposes of cross-context behavioral advertising:
- Internet or other electronic network activity
- Geolocation data
We sell and/or share this Applicant Personal Information with third parties for advertising purposes. The third parties to whom this Applicant Personal Information was sold and/or shared are advertisers and analytics vendors. When we use the terms sell, sold, or sale, we mean for valuable consideration and not monetary value.
We offer you the ability to opt out of sales and sharing of your Applicant Personal Information as set forth in the “Right to Opt Out of Sales and Sharing of Personal Information” section below.
We do not have actual knowledge that we sell or share the Applicant Personal Information of consumers under sixteen (16) years of age.
VI. How Long We Keep Your Applicant Personal Information
We generally maintain Applicant Personal Information according to our retention obligations and policies, operational business purposes, and other legal and regulatory requirements. For example, the Applicant Personal Information you provide may be retained and used to consider whether your skills are suitable for other opportunities with Empire or our affiliated entities. We discard this Applicant Personal Information when reasonably practicable.
We keep the categories of Applicant Personal Information described above for as long as is necessary for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:
- Your Applicant Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
- Your Applicant Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which it was collected;
- Your Applicant Personal Information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
- We are otherwise required or permitted to keep your Applicant Personal Information by applicable laws or regulations.
Where your Applicant Personal Information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.
VII. California Privacy Rights
California residents have the right to submit certain requests relating to their Applicant Personal Information as described below. Please note that when submitting a request, you may be asked to provide information to verify your identity before action is taken. You may designate an authorized agent to make the requests below on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you will still need to verify your identity directly with us before we can process the request.
To submit a request, please use our California Applicant Rights Request Form or contact us as provided below.
A. The Right to Know
If you are a California resident, you have the right to request more information regarding the following, to the extent applicable:
- The categories of Applicant Personal Information we have collected about you, including:
- The categories of sources from which the Applicant Personal Information was collected;
- Our business or commercial purposes for collecting, selling, or sharing your Applicant Personal Information;
- The categories of recipients with which we shared your Applicant Personal Information;
- The categories of Applicant Personal Information about you that we sold in the preceding twelve (12) months, and for each category identified, the categories of recipients to which we sold that particular category of Applicant Personal Information;
- The categories of Applicant Personal Information that we disclosed for a business purpose in the preceding twelve (12) months, and for each category identified, the categories of recipients to which we disclosed that particular category of Applicant Personal Information.
- The specific pieces of Applicant Personal Information we have collected about you.
B. Right to Opt Out of Sales and Sharing of Applicant Personal Information
You have the right to opt out of the sale of your Applicant Personal Information and to request that we do not share your Applicant Personal Information for cross-context behavioral advertising in the context of cookies and other tracking technologies. To opt out of the sale or sharing of your Applicant Personal Information via cookies and other tracking technologies, please click on the “Do Not Sell or Share my Personal Information” link in the footer of our website. You may also opt out of the sale or sharing of your Applicant Personal Information through an opt-out preference signal. In order to process your request through an opt-out preference signal, you must use a browser supporting the preference signal.
C. Right to Delete
You have the right to request that we delete Applicant Personal Information we collected from you, subject to certain exceptions.
D. Right to Correct Inaccurate Information
If you believe that Applicant Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.
E. Right to Limit Use and Disclosure of Sensitive Applicant Personal Information
We do not use or disclose sensitive Applicant Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.
F. 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.
VIII. California “Shine the Light”
Separate from your CCPA rights, you may obtain a list of the recipients to which we have disclosed personal information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding calendar year for direct marketing purposes, as applicable. To submit a request, please email us at HR@empiretoday.com send a letter to us at 333 Northwest Ave., Northlake, IL 60164. Requests must include “California Privacy Rights Request” in the first line of the description, and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided email address or mail address. Because these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.
IX. Contact Information
Please contact us with any questions:
Attn: Human Resources
333 Northwest Avenue
Northlake, IL 60164