NOTICE TO CALIFORNIA RESIDENTS - CALIFORNIA CONSUMER PRIVACY PROTECTION ACT


Last Modified: January 20, 2020.

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Policy applies soley for and applicable to you if you are a natural person who is a resident of California (“California Consumer”) and uses our Services. If you are not a California Consumer (or a resident of California), this does not apply to you and you should not rely on it. This Addendum supplements the information in the Privacy Policy.

In the below tables and sections, we describe (as required by the CCPA):

  1. 1. Our Collection of Personal Information – the types of Personal Information (which the CCPA defines broadly) that we collect, the types of sources we collect it from,
  2. 2. Our Disclosure and Sale of Personal Information – the types of recipients to whom we disclose or sell Personal Information.
  3. 3. Our Business Purposes - our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same.
  4. 4. Your California Privacy Rights and Choices.

1. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

Depending on how you interact with us, we may collect about you the categories of information summarized in the table below from the categories of sources identified.

Category of Personal Information Categories of Sources
Identifiers, name; alias; postal address; online identifiers; telephone number; email address. From job boards, consumer goods retailers, informational and retail websites, public records and other publicly available sources, content publishers, business-to-business companies, consumer surveys and survey companies.
Categories of personal information described in Cal. Civ. Code § 1798.80(e).
Telephone number
 
Characteristics of protected classifications under California or US law
Sex/gender; age.
 
Professional or employment-related information
Current and past job history and job title.
 

2. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION

We will share the categories of personal information set forth above for various business purposes, with service providers and with third parties including our customers. The chart below sets forth with whom we share or disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.

Category of Personal Information Categories of Third Parties We Share With Whether We “Sold” This Category of Personal Information in the Last 12 Months
Identifiers , name; alias; postal address; online identifiers; telephone number; email address. Job boards, hiring companies, CRM companies, sales and marketing companies, consumer goods retailers, retail websites, education companies, anti-fraud companies and other business to business service companies. Yes
Categories of personal information described in Cal. Civ. Code § 1798.80(e). Telephone number. Job boards, hiring companies, CRM companies, sales and marketing companies, consumer goods retailers, retail websites, education companies, anti-fraud companies and other business to business service companies. Yes
Characteristics of protected classifications under California or US law
Sex/gender, age.
Job boards, hiring companies, CRM companies, sales and marketing companies, consumer goods retailers, retail websites, education companies, anti-fraud companies and other business to business service companies. Yes
Professional or employment-related information
Current and past job history and job title.
Job boards, hiring companies, CRM companies, sales and marketing companies, consumer goods retailers, retail websites, education companies, anti-fraud companies and other business to business service companies. Yes

We also may share any of the categories of personal information we collect as follows:

For Legal Purposes: We may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public. We likewise may provide nformation to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.

In Event of a Corporate Transaction: We may share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.

With Service Providers: We share personal information with vendors to perform business purposes on our behalf, including analytics, hosting, fraud prevention, and other services.

We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device ("Aggregate/De-Identified Information"). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

3. OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION

Generally speaking, we collect and share the Personal Information that we collect for the following purposes, as we also have described in our Privacy Policy, in the section titled "Personal Information That We Collect and Use":

Our Purposes for collecting, using and sharing Personal Information

Helping people get jobs, for example:

We work with many job boards, applicant tracking systems, recruiting companies, and other hiring companies who use our data to identify candidates they would like to hire.

Add additional information to the candidate profiles a recruiter has, to enable them to have a comprehensive picture of the candidate, to aid in the hiring process.

Fighting Fraud, for example:

Analyzing and optimizing our Clients’ (or their service providers’) proprietary databases, or helping Clients to identify and mitigate potential fraud. Identiftying fraudlent actors, transactions, and other fraud helps the world save money and protect identities.

Verifying that someone is who they say they are when signing up or checking out online, to prevent identity theft and other fraud.

Personalizing Education Experiences, for example:

Working with online education and traditional education institutions to provide additional information on each user, to enable our Client to personalize the learning experience to each individual. With a more personalized education experience, each user is able to learn more.

Personalizing Experiences, for example:

Generally, creating data marketing tools and products for our marketer clients, as more fully described in our Privacy Policy (and on our websites). This includes our provision of datasets, data “appends” (connecting data across datasets), data “scoring” (providing inferences about potential consumer behavior), data hygiene services (helping customers to evaluate, validate and correct personal information they hold), and security and anti- fraud services (helping customers to identify potentially fraudulent activity).

Helping our Clients identify and understand their consumers better, by providing insights about them and managing loyalty programs, as well as providing financial and other scoring products.

Assisting our Clients through our Services to provide their current and prospective customers with better service, improved offerings, and special promotions, for instance, advising on which current or prospective customers are most likely to be interested (or disinterested) in certain offers.

Online targeting, for example:

Creating or helping to create defined audience segments based on common demographics and/or shared (actual or inferred) interests or preferences (e.g., households with prospective students). When we do this, we work with a data partner that “matches” our or other Information through de-identification techniques (such as through coded data “hashing”) with online cookies and other identifiers, in order to target and measure ad campaigns online across various display, mobile and other media channels.

Operating our Services, for example:

Improving, testing, updating and verifying our own database.

Developing new products.

Operating, analyzing, improving, and securing our Services.

Other internal purposes, for example:

For internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance. We use the information collected from our own website for the above, as well as for our own marketing purposes.

4. YOUR CALIFORNIA RIGHTS AND CHOICES

If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

Please note that certain information may be exempt from such requests under California law. For example, for access requests, we may withhold some personal information where the risk to you or our business is too great to disclose the information. Where we act only as a “service provider” to our clients (for instance, if they provide information to us for analytics, processing or other data management services), requests must be made through that client; we will forward your requests to a named client, as feasible. In addition, following a deletion request, we may retain certain information subject to exemptions under the law such as for our legal compliance.

Verification: For security purposes (and as required under California law), we will verify your identity – in part by requesting certain information from you -- when you request to exercise your California privacy rights to match the information with our records. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

California residents may exercise their California privacy rights by submitting your request via online web form.

Right to Opt-out of the sale of your personal information.

California residents may opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale” – including in the definition making available a wide variety of information in exchange for “valuable consideration.”

Depending what information we have about you, and whether we have included any of it in our marketing products and services, we may have sold (as defined by California law) certain categories of information about you in the last 12 months, as described in the above table in Section 2 of this Addendum, titled "OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION".

If you would like to opt out, you may do so as outlined on the following page: Do Not Sell My Personal Information

Information About Persons Under 16 Years of Age

We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your access, deletion or sale opt out rights.

California “Shine the Light” Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. If you would like to opt out of such sharing, please use the sale opt out form noted above. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: PMC, 11175 Santa Monica Blvd., Los Angeles, CA 90025, Attn: Privacy Officer. In your request, please specify that you want a “PMC California Privacy Rights Notice.” Please allow at least 30 days for a response.











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