Privacy Policy

for Californial Job Applicants

Last Updated: April 22, 2024

This Privacy Policy (“Privacy Policy”) describes how Path2Response, LLC and its subsidiaries and affiliates (collectively, “Path2Response”, “we”, “us,” and “our”) may collect, use, retain, and disclose personal information about California residents who apply or are recruited for a job with us or one of our affiliates (“candidates”), and their rights with respect to their personal information.
This Privacy Policy does not govern the general collection and privacy practices of any job boards or websites or online services where our job openings may be posted, including any third-party job search, recruiting, or career networking websites or online services. For example, when you visit the “Careers” section of the Path2Response website and click to see our open positions, you will be redirected to a third-party recruiting platform. Path2Response does not control how third-party websites or online services collect, use, or share your personal information when you visit those services. We encourage you to read the privacy policies of any websites and online services you engage with to understand how your personal information collected through such website or online service may be processed.
For purposes of this Privacy Policy, “personal information” has the meaning given in the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”) but excludes information exempted from the CCPA’s scope.
This Privacy Policy does not create or form part of any employment contract.
If you have questions about this Privacy Policy or to exercise your privacy rights under the CCPA, please contact

1. Personal Information We Collect About Candidates

Categories of personal information

The categories of personal information we may collect, or have collected in the 12 months preceding the “Last Updated” date of this Privacy Policy, and process before, during and after the application or recruitment process include:
Providing personal information is voluntary. However, if you do not provide sufficient information, we may be unable to consider your application or, if you are hired, your subsequent promotion, transfer, or relocation.
In certain cases we may ask you for additional information for purposes of monitoring equal opportunity or complying with applicable laws. We may also inquire about criminal records. We will do so only where permitted by applicable law.
To the extent that we collect sensitive personal information (as defined under the CCPA), we only use or disclose it for purposes permitted under the CCPA (e.g., to perform HR activities such as payroll and benefits, monitor for security incidents, and for compliance and safety purposes). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California employees.

Sources of personal information

We collect personal information directly from you when you apply for a job and throughout the job application or recruitment process.
We may also collect your personal information from various other sources and combine it with the personal information you provide to us. For example, we may collect your personal information from:

2. Purposes of the Collection and Use of Personal Information

We may use the categories of personal information described in this privacy policy for the following business purposes or as otherwise described at the point of collection:

3. Disclosure of Personal Information

We may disclose, and during the 12 months preceding the “Last Updated” date of this Privacy Policy may have disclosed, each of the categories of personal information described in Section 1 with other parties as necessary for the business purposes described above or as described at the time of collection, including the following persons or entities:
We do not and, during the 12 months preceding the “Last Updated” date of this Privacy Policy, have not “sold” or “shared” personal information about candidates. Further, we do not knowingly “sell” or “share” the personal information of California residents under 16 years of age.

4. Retention of Personal Information

We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

5. Your California Privacy Rights

California employees may exercise the rights listed below by contacting us as described at the beginning of this Privacy Policy. However, these rights are not absolute, and in certain cases we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.
To submit a request, please contact us using the contact information at the top of this Privacy Policy.
We may need to confirm your identity to process your requests to know/access, delete, or correct. In addition, consistent with California law, you may designate an authorized agent to make a request on your behalf. If you do so, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

6. Third Party Services

This Privacy Policy does not address, and we are not responsible for, the practices of any third parties, which have their own rules for how they collect and use your personal information. Our links to third party websites or services are not endorsements.

7. Changes to this Privacy Policy

We reserve the right to change this Privacy Policy at any time. The “Last Updated” date at the top of this Privacy Policy indicates when it was last revised. Any changes will become effective when we post the revised Privacy Policy in the respective job posting.

8. Your Obligations

Among other obligations, including without limitation the obligation to provide complete and accurate information in recruiting documents and processes, it is your responsibility to ensure that information you submit does not violate any third party’s rights.
You should keep your personal information on file with Path2Response up to date and inform us of any significant changes to it.

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