Applicant Privacy Notice and Policy

Last Updated: December 31, 2022

This Applicant Privacy Notice and Policy (this “Policy”) applies to all of the information collected on this website (the “Site”) and otherwise by Lendmark Financial Services (“Company”), including information submitted by you to facilitate your job application (“Applicant Personal Information”). This Policy only applies to applicants that are California residents.

The Site is operated by Company in part to support its recruitment efforts. The Site is not intended for distribution or use in any jurisdiction or country where such distribution or use would be contrary to local law or regulation. Also, this Site does not extend binding offers or terms or conditions of employment. Any employment offer that may result from your submitting information in response to a job opening listed on this Site is in accordance with the specific terms of that offer and is not based in any way on the description of the job on this Site. Except as otherwise prohibited by law, nothing on this Site shall be construed as a contract of employment or as a guarantee of continued employment or employment for any specific duration. Employment with Company is "at will" and that generally cannot be modified by an employee or representative of Company. This means if you are hired, either you or Company can separate your employment at any time without notice or cause.

Company operates in different locations across the United States. You understand and agree that, by applying through this Site for a particular position(s), your application also may be considered for other positions or other positions may be recommended to you based on your qualifications.

Personal Information We Collect. The chart below describes the categories of Applicant Personal Information that may be collected in connection with the application and below that a list of the purposes for which such information was collected and may be used.

Category of Personal Information Collected	Purposes Personal Information, Including Sensitive Personal Information, is Used
Identifiers and Contact information. This category includes names, addresses, telephone numbers, mobile numbers, email addresses, signature, account name, dates of birth, bank account information, and other similar contact information and identifiers.	Collect and process employment applications, including confirming eligibility for employment, background and related checks, onboarding, and related recruiting efforts. To maintain physician records and occupational health programs. Maintaining personnel records and record retention requirements. Communicate with you about your application. Complying with applicable state and federal health, labor, employment, disability, equal employment opportunity, and related laws, guidance, or recommendations. Preventing unauthorized access to, use, or disclosure/removal of the Company’s property, including the Company’s information systems, electronic devices, network, and data. Investigating complaints, grievances, and suspected violations of Company policy. Protect the legal rights, privacy, safety or property of Company or its employees, agents, contractors, customers or the public. Protect against fraud or other illegal activity or for risk management purposes. Enforce the Company’s website’s terms of use. Design, implement, and promote the Company’s diversity and inclusion programs. Facilitate the efficient and secure use of the Company’s information systems. Improve safety of employees, customers and the public with regard to use of Company property and equipment. Evaluate an individual’s appropriateness for a participation position at the Company, or promotion to a new position. To respond to and manage any legal claims against the Company and/or its personnel, including civil discovery in litigation. To facilitate other business administrative functions and strategic activities, such as risk management, information technology and communications, financial management and reporting, workforce and succession planning; and maintenance of licenses, permits and authorization applicable to Company operations. Carry out a license, sale or transfer of all or a portion of the business or assets (including in connection with any bankruptcy or similar proceedings); or manage or arrange for acquisitions, mergers and re-organizations.
Protected classification information. category includes characteristics of protected classifications under California or federal law.	Purposes listed above
Internet or other electronic network activity information. This category includes without limitation: all activity on the Company’s information systems, such as internet browsing history, search history, email communications, usernames and passwords, and all activity on communications systems including phone calls, call logs, voice mails, text messages, chat logs, and app use.	Purposes listed above
Geolocation data. This category includes GPS location data from the Company’s information systems including company-issued mobile devices and laptop computers.	Purposes listed above
Audio, electronic, visual, thermal, olfactory, or similar information. This category includes, for example, information collected from camera, microphones, and similar devices.	Purposes listed above
Professional and employment-related information. This category includes without limitation: data submitted with employment applications including employment history, recommendations, etc., background check and criminal history; work authorization and fitness for duty.	Purposes listed above
Education information. This category includes education history.	Purposes listed above
Sensitive Personal Information. This category includes sensitive information such as social security, driver’s license, state identification card, or passport number, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, or union membership, biometric information for the purpose of uniquely identifying a consumer, and information concerning health and sex life or sexual orientation.	Purposes listed above

Sources of Personal Information We Collect.

• You. We collect information when you are an applicant for employment with us and employed by us. We may collect personal information that you provide during your interactions with us, such as through our Site, by email, or when you communicate with our associates online, by phone, or at one of our locations. We may also collect information when you attend an event or program we sponsor. We also collect information through certain online tracking tools, such as browser cookies, flash cookies, and web beacons.
• Related Entities and Affiliates. We may collect information about you from our related parties and affiliates, including joint ventures.
• Social media and related services.
• Service providers and contractors. We may collect your PI from service providers and contractors who collected information about you that is needed as part of our recruiting efforts.
• News outlets, social media, surveys, and certain third parties. In the course of performing our recruiting activities, we or third parties on our behalf may conduct research and other activities resulting in the collection of PI about you.
• Information Collected Automatically. As you navigate through and interact with our Site, we may compile statistical information concerning your usage of the Site through analytics services, such as those provided by Google Analytics. To do so, we may collect certain information about your equipment, browsing actions and patterns, including:
  • Details of your visits to our Site, such as traffic data, location data, logs and other communication data and the resources that you access and use on the Site
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.
  • Information about the type of device you are using, mobile ad identifiers, the time and length of your visit, and the website that referred you to our Site.
  • Information about your preferences to make your use of the Site more productive, via the use of Cookies. For more information on Cookies, please see the Cookies and Other Tracking Technologies section. While all of this information can be associated with the IP address your computer had while you visited the Site, it will not be associated with you as an individual or with any other information you may submit through the Site or that we may store about you for any other purposes. We may use this information to generate aggregate statistics about visitors to our Site. Please check your web browser if you want to learn what information your browser sends or how to change your settings.

We do not require, but you may also voluntarily choose to provide, other relevant information as part of your application. We would prefer that you avoid submitting sensitive information, except where such information is legally required, or needed for us to comply with our legal obligations and internal policies relating to diversity and anti-discrimination.

Any information you submit must be true, complete, not misleading and you must have the lawful right to provide it. If not, this may lead to a rejection of your application during the application process or disciplinary action including immediate dismissal if you have been employed. If you intend to provide us with details of a reference or any other third party as part of your CV/résumé, it is your responsibility to obtain consent from that third party prior to passing the personal information to us. If you become an employee, any personal information that you submit may become part of your employment file and may be used for other employment/work-related purposes as permitted by local law.

To carry out the purposes outlined above, the Company may disclose personal information to third-party service providers, such as background check vendors, third-party human resources and information technology vendors, outside legal counsel, and state or federal governmental agencies. The Company may add to the categories of personal information it collects and the purposes it uses personal information. In that case, the Company will inform you.

We may also disclose your personal information if necessary to: (1) courts and government agencies to comply with federal, state, or local laws, as well as in connection with civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (2) law firms and their service providers to defend legal claims, (3) potential buyers or sellers of portions of our business in connection with due diligence related to organizational transactions.

The Company does not sell or share, as those terms are defined under applicable law, the above categories of personal information of applicants. We also do not use or disclose your sensitive personal information for purposes that, with limited exceptions, are not necessary to evaluate your application for employment. The Company may add to the categories of personal information it collects and the purposes it uses personal information. In that case, the Company will use reasonable efforts to inform you.

Data Retention. We are required to temporarily retain certain information relating to candidates applying for jobs. If there is no activity in relation to Applicant Personal Information, Company may remove it from its database, subject to Company’s data retention obligations and policies and any applicable legal or regulatory obligations or for the period of time permitted by local laws, for the purpose of considering whether your skills are suitable for other opportunities. Note that Company may delete personal information about you at any time (including your CV/résumé), without any reason, subject to applicable law and the Company’s policies and procedures. Therefore, please retain your own copy of the personal information provided to us.

California Resident Individual Rights Requests. Individuals who are residents of the State of California have certain individual rights as outlined below.

Upon receipt of a verifiable request (see below), and as required by applicable law, we will provide a response to such requests.

Right To Know About Personal Information Collected or Disclosed. In addition to what is described above, as a California resident, you also have the right to request more information regarding the following topics, to the extent applicable:

• the categories of personal information,
• the categories of sources from which the personal information is collected,
• the business or commercial purpose for collecting, selling, or sharing personal information, if applicable,
• the categories of third parties to whom the business discloses personal information, and
• the specific pieces of personal information the business has collected about you.

Right To Request Deletion Of Your Personal Information. You have the right to request that we delete the personal information we collected or maintained about you. Once we receive your request, we will let you know what, if any, personal information we can delete from our records, and we will direct any service providers and contractors with whom we disclosed your personal information to also delete your personal information from their records. There may be circumstances where we cannot delete your personal information or direct service providers or contractors to delete your personal information from their records. Such instances include, but are not limited to, enabling solely internal uses that are reasonably aligned with your expectations based on your relationship with the Company and compatible with the context in which you provided the information or to comply with a legal obligation.

Right to Request Correction. You have the right to request that the Company correct any inaccurate personal information we maintain about you, taking into account the nature of that information and purpose for processing it.

Right to Non-Discrimination for the Exercise of Your Privacy Rights. We will not discriminate or retaliate against you for exercising any of your rights as described above.

Submitting Consumer Rights Requests. To submit a verifiable request as outlined above, please contact the Company’s Human Resources Department by calling us at 1-866-413-8340 or emailing us at HRInfo@lendmarkfinancial.com. We reserve the right to only respond to verifiable requests to know, delete, or correct.

A verifiable request is one made by any individual who is:

• the applicant who is the subject of the request,
• the authorized agent of the applicant.

What to submit. If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of the applicant. In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive PI to verify your identity. We may not be able to respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. However, making a verifiable request does not require you to create an account with us.

Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. We will not use the PI we collect from an individual to determine a verifiable request for any other purpose, except as required or permitted by law.

Our response. We will endeavor to respond to a verifiable request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. To the extent permitted by the CCPA, we will respond to no more than two requests during any 12-month period.

Authorized Agent. You may authorize a natural person or a business (the Agent) to act on your behalf with respect to the rights under this section. When you submit a Request to Know, Correct, or Delete, the Agent must provide proof that you gave the Agent signed permission to submit the request, and you either must (i) verify you own identity with the business or (ii) directly confirm with us that you provide permission to the Agent. However, these steps are not required when you have provided the authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.

Consent The provision of personal information, including on the Site, is voluntary. Please note however that the failure to provide sufficient information may result in Company being unable to consider you for employment, promotion, transfer, or relocation. Please read this Policy carefully and indicate your acceptance of our collection, retention, use, transfer and disclosure of Applicant Personal Information and the other provisions concerning your application as described in this Policy by clicking the “I Accept” button at the end of this Policy. If you do not accept the terms you will not be allowed access to apply for a position online.

Changes to Policy. We reserve the right to amend this Policy at any time without advance notice in order to address future developments of Company, the Site or changes in industry or legal trends. We will post the revised Policy on the Site or announce the change on the home page of the Site. You can determine when the Policy was revised by referring to the "Last Updated" legend on the top of this Policy. Any changes will become effective upon the posting of the revised Policy on the Site. By continuing to use the Site following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Policy, in whole or part, you can choose to not continue to use the Site.