Privacy Notice for California Job Applicant

Last updated: January 23, 2023

Centerline Communications, LLC and its Affiliate Companies* (“Centerline Communications,” “we,” or “us”) understands the importance of privacy to our job applicants and takes our responsibility to protect their information seriously. Pursuant to the California Consumer Privacy Act, as may be amended from time to time (“CCPA”), this privacy notice (the “Notice”) explains our online and offline practices regarding the collection, use, and disclosure of “personal information” of job applicants who reside in California. Some of the personal information we collect may be exempt from some or all of the requirements under the CCPA. Please read this Notice carefully so you understand our practices regarding your information.

For more information about the types of information we collect and use in connection with your general access and use of our website, please review our general Privacy Policy located here and website Privacy Notice for California Residents located here.

Information We Collect and Disclose

As defined by the CCPA, “personal information” includes any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include information that is:

• Lawfully made available from government records;
• We have a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media, or by the consumer;
• Made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience;
• Lawfully obtained, truthful information that is a matter of public concern;
• Deidentified or aggregate consumer information; or
• Information excluded from the CCPA’s scope, including personal information covered by certain sector-specific privacy laws such as the Fair Credit Reporting Act.

In the past 12 months, Centerline Communications has collected the following categories of personal information from consumers acting as a job applicant of Centerline Communications and disclosed such information to the following categories of third parties for business purposes.

Centerline Communications is an equal employment opportunity employer and does not discriminate against job applicants based on gender, race, race, color, creed, religion, sex, pregnancy, national origin, marital status, disability, age, sexual orientation, disability, genetic information or testing, HIV-positive status, veteran’s status or military status, or any other status protected by applicable federal, state or local law.

Collection of Personal Information

Centerline Communications collects the above-identified categories of personal information from the following sources:

• Direct collection: We collect information directly from you when you choose to provide it to us by filling out forms, participating in an interview or other applicant process, or otherwise directly providing the information to us.
• Third-Parties: We collect information about you from third parties who support our Human Resources and job application process, including recruitment agencies, background check vendors, and other hiring technologies.
• Indirect and technology-based collection: We also collect certain information from you indirectly when you access our websites, job application portals, or mobile applications. Centerline Communications collects certain identifiers (such as IP addresses) and internet and similar network activity (such as website usage data) from you indirectly using cookie, pixels, and passive tracking technologies.

Sale or Sharing of Personal Information

In the past 12 months, Centerline Communications has not “sold” any categories of personal information, or “shared” any such information for the purposes of cross-context behavioral advertising. Likewise, Centerline Communications does not have actual knowledge of any sales or sharing of personal information regarding minors under 16 years of age.

Use of Personal Information

We use the personal information that we collect from job applicants for the following business or commercial purposes, consistent with and only as permitted by applicable law:

• Considering job applicants for current and potential future employment opportunities and assess their skills, qualifications, and interests against our career opportunities.
• Evaluating job applicants’ employment application, corroborating the information contained in the application and any supporting documents, and (where applicable) conducting employment related screening and background checks. (Please note, we only use background information as permitted by applicable law.)
• Scheduling job applicants for interviews and communicate with them about their application and employment opportunities.
• Complying with state and federal laws and regulations and maintaining records pursuant to such laws and regulations.
• Communicating with job applicants about their candidacy.
• Keeping records of our interactions and communications with job applicants.
• Protecting our operations, rights, privacy, safety or property, or that of our affiliates, job applicants, or other parties.
• For any other purposes that we disclose to you at the time of collection.

Disclosure of Personal Information

As indicated above, we may share some of the personal information with third-party vendors as necessary for our business purposes. For example, such vendors could include the agencies we use to conduct pre-employment screening (such as background checks and drug screening). From time to time, Centerline Communications may also be required to disclose your information to governmental authorities for the purpose of complying with applicable laws and regulations or in response to legal process.

Applicable Retention Periods

For each category of personal information identified above, we will retain your personal information only for as long as necessary to fulfill your requests or the purposes for which it was obtained, as set forth in this Notice. The criteria used to determine our retention periods include (i) to fulfill the purpose for which the information was collected, (ii) for as long as we have an ongoing relationship with you, and (iii) as required by a legal obligation to which we are subject.

Sensitive Personal Information

Centerline Communications does not collect “sensitive personal information” (as defined by the CCPA) for the purposes of inferring characteristics about California consumers. Accordingly, Centerline Communications treats such information as “personal information” consistent with applicable provisions of the CCPA.

Your Rights Under the CCPA

The CCPA provides California residents with the rights discussed below. For convenience, and as required by the CCPA, we explain how you can exercise those rights, to the extent they are applicable.

1. Right to Request Information. You have the right to request that we disclose certain information about our collection and use of your personal information during the past twelve (12) months. Specifically, you may request that we disclose:
   • The categories of personal information we collected about you;
   • The categories of sources for the personal information we collected about you;
   • The business and commercial purposes for collecting your personal information;
   • The categories of third parties to whom we disclose your personal information;
   • The specific pieces of personal information we collected about you; and
   • If we disclosed your personal information for a business purpose, the categories of personal information received by each category of third party.
2. Right to Data Portability. You have the right to request that we provide copies of the specific pieces of personal information we collected about you. If a verifiable consumer request is made, and subject to any exceptions or limitations under the CCPA, we will take steps to deliver the personal information to you either by mail or electronically. If we provide the information to you electronically, it will be in a portable and readily useable format, to the extent technically feasible. Consistent with the CCPA and our interest in the security of your personal information, we will describe but may not provide copies of certain personal information we may receive from you (e.g., driver’s license number, other government-issued identification number, financial account number, health or medical identification number, account password, or security questions or answers) in response to a CCPA request, to the extent any of those items are in our possession.
3. Right to Request Deletion. You have the right to request that we delete personal information we collected from you, subject to any exceptions or limitations under the CCPA.
4. Right to Correct Inaccurate Information. If we maintain inaccurate personal information about you, you have the right to request that we correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
5. Right to Opt-Out. Consumers in California have the right to opt-out of (a) the sale of personal information, or (b) the sharing of their personal information for the purposes of cross-context behavioral advertising (as defined in the CCPA). Because Centerline Communications does not “sell” or “share” personal information, these rights are not available.

Exercising Your Rights

To exercise the rights described above, you—or someone authorized to act on your behalf—must submit a verifiable consumer request to us by sending an e-mail to: legal@clinellc.com with the subject line: “CCPA Request” or calling us at (844) 748-8878. Your request must include your name, e-mail address, mailing address, phone number, the nature of your inquiry and the context in which we may have received your information. If you are an agent submitting a request on behalf of a consumer, we may request that you submit a signed permission from the consumer authorizing you to make the request. In order to protect the privacy and data security of consumers, the verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such consumer; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

As indicated above, please be aware that the CCPA provides certain limitations and exceptions to the foregoing rights, which may result in us denying or limiting our response to your request.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We may also request that you provide additional information if needed to verify your identity or authority to make the request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you or the consumer on whose behalf you are making the request.

Response Timing and Format

The CCPA requires us to respond to a verifiable consumer request within forty-five (45) days of its receipt; however, we may extend that period by an additional 45 days. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response via e-mail. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request, provided that you may request disclosure beyond the 12-month period as permitted by the CCPA. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select the format of our response; the format will be readily useable and should allow you to transmit the information from one entity to another. We will not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing the request.

Our Commitment Not to Discriminate

We will not discriminate or retaliate against a job applicant for exercising their rights under the CCPA, including by denying you benefits or services that we make available, charging you different prices or rates for services or benefits, providing a different level or quality of services or benefits, or suggesting that you may receive a different price or level of quality of services or benefits.

Changes to this Notice

We reserve the right to amend this Notice at our discretion and at any time. If there are changes to this Notice, we will post them here and update the “Last Updated” date at the top of this document. Continued use of this website after any changes is deemed to be acceptance of those changes. Please check this page periodically for updates.

Contact Information

Questions regarding this privacy Notice, our use and disclosure your information, or the employment process should be directed to:

Phone: (844) 748-8878

Email: hr@clinellc.com

Centerline Communications, LLC

Attn: Chief Human Resources Officer

750 W. Center Street, #301 West Bridgewater, MA 02379