Last Updated December 1, 2023.

1. Introduction

This notice (“Notice”) describes how Qatalyst Group LP (“Company”, “we”, “us” and “our”) collects, uses, discloses, and otherwise processes personal information about California residents who apply or are recruited for a job with us or one of our affiliates (“candidates”).

For purposes of this Notice, “personal information” has the meaning given in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act, and any regulations promulgated thereunder (collectively, the “CCPA”) but excludes information exempted from the CCPA’s scope.

This Notice does not create or form part of any contract for employment or otherwise.

If you have questions about this Notice, please contact us at 1-877-642-7890 or 415-844-7710.

2. Information we collect and disclose about candidates

This section details which categories of your personal information we collect and process, as well as which categories of your personal information we may disclose to third parties for our operational business purposes, including within the preceding 12 months.

There may be limited occasions when we need to collect categories of personal data not covered above, or additional occasions when we collect information that is not described above. In those cases, we will treat the personal data we collect in accordance with this Privacy Policy.

3. How we use and disclose personal information about candidates

Providing personal information to us 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. Each of the categories of personal information described above may be used or disclosed for the following purposes:

• Recruitment management. Managing recruitment generally, such as:
  • operating the careers website we maintain at Sainoo.com, Handshake.com or Wearwiser.com or any other site to which this Notice is posted (“Careers Site”), as well as Qatalyst domiciled email addresses to which recruits deliver information;
  • recruiting, interviewing and evaluating job candidates;
  • conducting background checks and other pre-employment screening (where permitted by law);
  • analyzing and improving our application and recruitment processes;
  • accommodating disabilities or health conditions;
  • communicating with you regarding your candidacy, opportunities with the Company or about the Careers Site and any changes to applicable terms or policies;
  • onboarding successful candidates; and
  • other business operations.
• Compliance, safety and fraud prevention, such as:
  • complying with or monitoring compliance with legal and other requirements, such as reporting and equal opportunities monitoring requirements, where applicable;
  • complying with internal policies and procedures;
  • complying with lawful requests and legal process, such as to respond to subpoenas or requests from government authorities;
  • protecting our, your or others’ rights, safety and property;
  • investigating and deterring against fraudulent, harmful, unauthorized, unethical or illegal activity, or conduct in violation of our policies or procedures; and
  • sharing information with government authorities, law enforcement, courts or private parties where we have a good-faith belief it is necessary for the foregoing purposes.
• Analytics. Creating anonymous, aggregated or de-identified data that we use and share to analyze our application and recruitment activities, business and for other lawful business purposes.
  We do not sell your personal information (including your sensitive personal information), and we do not share your personal information (including your sensitive personal information) for purposes of cross-context behavioral advertising, as defined under the CCPA. We have not engaged in such activities in the preceding 12 months. For example, and without limiting the foregoing, we do not sell or share the personal information of minors under 16 years of age.
  Where we maintain or use de-identified data pursuant to the CCPA, we will continue to maintain and use the de-identified data only in a de-identified fashion and will not attempt to re-identify the data unless permitted under the CCPA.

4. Purposes for the collection, use, and disclosure of sensitive personal information

We collect, use, and disclose sensitive personal information for purposes of: performing services on behalf of our business; performing services as requested by you; ensuring the quality or safety of services we control or improving those services; ensuring the security and integrity of our infrastructure and the individuals we interact with; short-term transient use; 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 other collection and processing that is not for the purpose of inferring characteristics about an individual. We do not use or disclose sensitive personal information for additional purposes.

5. Sources of personal information

We collect personal information directly from you, as well as from prior employers, references, recruiters, job-related social media platforms, and third-party sources of demographic information.

6. Retention of personal information

We retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

• The duration of the application process;
• 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 or regulatory obligation to which we are subject (for example, certain laws or regulations may require us to keep your 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).

7. Privacy rights and requests

You may request that we:

• Disclose to you the following information:
  • The categories of personal information we collected about you and the categories of sources from which we collected such 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).
• Correct inaccuracies in your personal information.
• Delete your personal information that we collected from you.
• Provide specific pieces of personal information, we collected about you, including a copy of the personal information you provided to us in a portable format.

You have the right to be free from unlawful retaliation for exercising your rights under the CCPA. To make a request to know, access, correct, delete, or receive a copy of, your personal information, please contact us at pp.qatalyst.com, emailing us at [email protected] or calling us toll free at 1-877-642-7890. 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. We may need to request additional personal information from you, such as your name and email address, in order to verify your identity and protect against fraudulent requests. If you make a request to delete, we may ask you to confirm your request before we delete your personal information.

Authorized Agents: 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 above under “Privacy rights and requests.” As part of our verification process, we may request that the agent provide proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Privacy rights and requests” or confirm that you provided the agent permission to submit the request.

8. Other information about this Notice

8.1 Third parties

This Notice 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.

8.2. Changes to this Notice

We reserve the right to change this Notice at any time. The “Last Updated Date” heading at the top of this Notice indicates when it was last revised. Any changes will become effective when we post the revised notice on our Careers Site.

8.3. Public-Facing Privacy Policy

Additional information about our information practices may be found in our public-facing online privacy policy, available at http://qatalyst.com/index.php/privacypolicy. Please note, however, that the practices described in our public-facing privacy policy may not apply to the collection, use or other processing of personal information relating to candidates.

9. 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 the Company up to date and inform us of any significant changes to it.