LAST UPDATED: September 29, 2023

EOLIAN CALIFORNIA JOB APPLICANT PRIVACY POLICY

Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, (the “CCPA”) Eolian Employee Holdings, LLC  (“Company,” “we,” or “us”) provide this privacy policy to California residents (“you”) about the processing of information that can reasonably be linked with them that we collect, use, retain or disclose in the context of their applications for employment with us (“Personal Information”).

Notice At Collection

Collection and Disclosure of Personal Information

The following chart details which categories of Personal Information we collect and process, as well as which categories of Personal Information we disclose to third parties for our operational business and hiring and recruitment purposes, including within the 12 months preceding the date this Policy was last updated.

Categories of Personal Information

Identifiers, such as name, alias, postal address, unique personal identifiers, email address, account name, online identifiers, and government-issued identifiers (e.g., Social Security number, driver’s license number)

Our affiliates; service providers that provide services such as recruiting, talent acquisition, employment screening and background checks, consulting, expense management, IT, and other services; professional advisors such as lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners

Personal information as defined in the California customer records law, such as name, contact information, signature, Social Security number, passport number, driver’s license number, state identification card number, financial, education, medical, and employment information, physical characteristics or description

Protected Class Information, such as characteristics of protected classifications under California or federal law, such as sex, age, gender, body size, race, disability, citizenship, military/veteran status, gender identity and expression, primary language, and immigration status

Our affiliates; service providers that provide services such as recruiting, talent acquisition, employment screening and background checks, consulting, IT, and other services; professional advisors such as lawyers; public and governmental authorities, such as regulatory authorities and law enforcement

Commercial Information, such as travel information and expenses

Disclosed to Which Categories of Third Parties for Operational Business Purposes

Our affiliates; service providers that provide services such as recruiting, talent acquisition, employment screening and background checks , expense management, IT, and other services; professional advisors such as lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners

Our affiliates; service providers that provide services such as travel arrangements and expense management, IT, and other services; public and governmental authorities, such as regulatory authorities and law enforcement

Education Information subject to the federal Family Educational Rights and Privacy Act such as confirmation of graduation

Our affiliates; service providers that provide services such as recruiting, talent acquisition, employment screening and background checks, consulting, IT, and other services; professional advisors, such as lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners

Employment Information. Professional or employment-related information, such as work history and prior employer, information from reference checks, work experience, qualifications, training and skills, work authorization, CV, résumé, cover letter, professional and other work-related licenses, permits and certifications held, and publicly accessible information posted on your professional social media accounts

Our affiliates; service providers that provide services such as recruiting, talent acquisition, employment screening and background checks, consulting, IT, and other services; professional advisors, such as lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners

Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences,  characteristics, predispositions, and abilities

Our affiliates; service providers that provide services such as recruiting, talent acquisition, employment screening and background checks, consulting, IT, and other services; professional advisors, such as lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; ad networks; social networks; business partners; marketing partners

Sensitive Personal Information.

Personal Information that reveals an individual’s Social Security, driver’s license, state identification card, or passport number; account log-in; racial or ethnic origin, citizenship, immigration status, or union membership.

Our affiliates; service providers that provide services such as recruiting, talent acquisition, employment screening and background checks, consulting, IT, and other services; professional advisors, such as lawyers; public and governmental authorities, such as regulatory authorities and law enforcement

We may also disclose the above categories of Personal Information to a third party in the context of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

We do not sell Personal Information, and we do not share or otherwise process Personal Information for purposes of cross-context behavioral advertising, as defined under the CCPA.  We have not engaged in such activities in the 12 months preceding the date this Policy was last updated.  Without limiting the foregoing, we do not sell or share the Personal Information of minors under 16 years of age.

Purposes for the Collection, Use and Disclosure of Personal Information

We may collect, disclose, or use Personal Information for the purposes of operating, managing, and maintaining our business, sourcing talent and recruiting employees, including, for example, using Personal Information to:

  • Receive and process job applications;

  • Manage the candidate selection process;

  • Evaluate your suitability for the position(s) you are applying for;

  • Communicate with you about your application, respond to your inquiries and notify you of applicable terms and policies;

  • Conduct reference checks;

  • Conduct background checks, consistent with applicable law;

  • Subject to our discretion, make an offer to enter into an employment contract;

  • Contact you about future career opportunities;

  • Fulfill administrative functions, such as aggregate management reporting, statistical analyses, internal training, and as generally required to conduct our business; and

  • Comply with law, legal process, requests from governmental or regulatory authorities, internal policies and other requirements such as record-keeping, equal employment opportunity laws, work permit and immigration regulations, reporting obligations, and the exercise or defense of legal claims.

  • Disclose Personal Information to our Service Providers and providers of employee benefits so they can provide their services to us and our personnel.

Use of Sensitive Personal Information

We may use Sensitive Personal Information for purposes of performing services for our business, providing services as requested by you, and ensuring the security and integrity of our business, infrastructure and the individuals we interact with.  This includes receiving and processing your job application, evaluating your suitability for the position(s) you are applying for, conducting background checks, analyzing and monitoring diversity, making you an offer (subject to our discretion), fulfilling administrative functions, complying with law, legal process or requests from governmental or regulatory authorities, and exercising or defending legal claims.  We do not use your Sensitive Personal Information for purposes beyond those described here or otherwise allowed by applicable law.

Retention Period

We retain Personal Information including, without limitation, Sensitive 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 job application process;

  • Whether your job application is successful and you become and employee;

  • Whether, if your application is not successful, you would like to be notified of future job opportunities with us or our affiliates;

  • 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 obligation to which we are subject (for example, certain laws may require us to keep your application 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). 

Sources of Personal Information

We collect this Personal Information from you and from our affiliates, references you provide, prior employers or schools, recruiting and consulting firms, background check providers, social media networks, publicly available databases, and cooperative databases.

Individual Requests

You may, subject to applicable law, make the following requests:

1.       You may request that we disclose to you the following information covering the 12 months preceding your request:

a.       The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;

b.       The business or commercial purpose for collecting Personal Information about you; and

c.       The categories of Personal Information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such Personal Information (if applicable).

2.       You may request to correct inaccuracies in your Personal Information.

3.       You may request that we delete your Personal Information that we have collected from you.

4.       You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including a copy of the Personal Information you provided to us in a portable format.

 We will not unlawfully retaliate against you for making a request under the CCPA. To make a privacy request, please contact us at hr@eolianenergy.com or 650-744-2100.  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 your date of birth, social security number, driver’s license number, and/or address, in order to verify your identity and protect against fraudulent requests.  If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information.  If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information. We will verify and respond to your request consistent with applicable law.

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 in the section entitled “Individual Requests”.  As part of our verification process, we may request that the agent provide, as applicable, proof concerning his or her status as an authorized agent.  In addition, we may require that you verify your identity as described in the section entitled “Individual Requests” or confirm that you provided the agent permission to submit the request.

Diversity

In certain cases, we will ask questions about race/ethnic origin, gender, and disability of our job applicants, for monitoring equal opportunity.  We may also inquire about criminal records, where permitted by applicable law.  Otherwise, we ask that you avoid submitting information that may qualify as sensitive information under applicable law, except where such information is legally required.  We are an equal opportunity employer, which means we offer equal treatment to all job applicants consistent with applicable law.  We do not unlawfully discriminate, either directly or indirectly, based on characteristics protected by applicable law, such as: race, ethnicity, sex, gender identity, sexual orientation, nationality, national origin, ethnic origin, religion, beliefs or creed, age, disability, marital status, veteran status or genetic information in any area of recruitment.

Applicant Obligations

Any information you submit to us must be true, complete and not misleading.  Submitting inaccurate, incomplete, or misleading information may lead to a rejection of your job application during the application process or disciplinary action including immediate termination of employment.  In addition, it is your responsibility to ensure that information you submit does not violate any third party’s rights.  If you provide us with Personal Information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.

Changes to this CCPA Applicant Privacy Policy

We may change or update this policy from time to time.  When we do, we will communicate changes and updated to this policy by posting the updated policy on this page with a new “Last Updated” date.  If we make a material change to this policy we may notify you directly or ask for your consent to the change.

Contact Us

Please contact hr@eolianenergy.com if you have any questions regarding this policy.