Effective Date: March 30, 2023

Market Track, LLC d/b/a Numerator and its affiliates and subsidiaries (“Numerator”) respect your concerns about privacy.  This California Job Applicant Privacy Notice describes the types of personal information we collect about California residents who apply for jobs with Numerator (“Job Applicants”).  Certain terms used in this Notice have the meanings given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”). 

Notice of Collection and Use of Personal Information 

Numerator may collect (and may have collected during the 12-month period prior to the Effective Date of this Notice) the following categories of personal information about Job Applicants:

• Identifiers: identifiers, such as a real name, alias, postal address, unique personal identifier (e.g., a device identifier, employee number, unique pseudonym, or user alias/ID), telephone number, online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, date of birth,  and other similar identifiers
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
• Employment Information: professional or employment-related information, such as compensation, benefits and payroll information (e.g., salary-related information, tax-related information, benefits elections and details regarding leaves of absence), information relating to your position (e.g., job title and job description), performance-related information (e.g., evaluations and training), talent management information (e.g., résumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, and pre-employment screening and background check information, including criminal records information), and emergency contact information

We may use (and may have used during the 12-month period prior to the Effective Date of this Notice)  personal information for the purpose of processing job applications, evaluating candidates for employment, and carrying out and supporting HR functions and activities, including as described below.  In addition to general HR purposes, the purposes listed below also include relevant “business purposes” as they are described in the CCPA. 

• Recruiting; processing job applications; performing background checks; determining suitability for employment; determining physical and/or mental fitness for work; reviewing and evaluating applications; determining salary and other forms of compensation; providing references; reimbursing expenses; making travel arrangements; securing immigration statuses; reviewing hiring decisions; and providing access to facilities.
• Complying with legal requirements, such as tax, record-keeping and reporting obligations; conducting audits, management and resolution of health and safety matters; complying with requests from government or other public authorities; responding to legal process such as subpoenas and court orders; pursuing legal rights and remedies; defending litigation and managing complaints or claims; conducting investigations; and complying with internal policies and procedures.
• Performing services, including: including: maintaining or servicing accounts; providing services to Job Applicants; verifying Job Applicants’ information; providing analytics services; providing storage; or providing similar services
• Auditing related to a current interaction with you and concurrent transactions.
• Certain short-term, transient uses.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Debugging to identify and repair errors that impair existing intended functionality.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

To the extent Numerator processes deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Retention of Personal Information

We retain personal information about Job Applicants for the time period reasonably necessary to achieve the purposes described in this Notice, or any other notice provided at the time of collection, unless a longer retention period is required or permitted by applicable law, taking into account applicable statutes of limitation and our records retention requirements and policies.

Sources of Personal Information

During the 12-month period prior to the Effective Date of this Notice, we may have obtained personal information about Job Applicants from the following categories of sources[HAK13] :

• Directly from Job Applicants

Disclosure of Personal Information

During the 12-month period prior to the Effective Date of this Notice, we may have disclosed the following categories of personal information about Job Applicants for a business purpose to the following categories of third parties:

In addition to the categories of third parties identified above, during the 12-month period prior to the Effective Date of this Notice, we may have disclosed personal information about Job Applicants to government entities and third parties in connection with corporate transactions, such as mergers, acquisitions or divestitures.

Numerator does not sell or share (for cross-context behavioral advertising purposes) personal information about Job Applicants. 

California Privacy Rights

If you are a Job Applicant, you have certain choices regarding your personal information, as described below.

• Access: You have the right to request, twice in a 12-month period, that we disclose to you the categories of personal information we have collected about you, the categories of sources from which the information was collected, the business or commercial purposes for collecting the information, the categories of third parties to whom we disclosed your personal information, and the specific pieces of personal information we have collected about you.
• Deletion: You have the right to request that we delete certain personal information we have collected from you.
• Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.

How  to Submit a Request. To submit an access, deletion, or correction request, please email us at privacy@numerator.com. To submit a request as an authorized agent on behalf of a Job Applicant, please email us at privacy@numerator.com.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may verify your identity by requiring you to sign in to your Hirebridge account. If you do not have a Hirebridge account and you request access to, correction of or deletion of your personal information, we may require you to provide us with the following data elements for verification purposes: your email address, the date of your application and some other identifying data provided when you submitted your application. In addition, if you do not have a Hirebridge account and you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the Job Applicant whose personal information is the subject of the request.

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

How To Contact Us

If you have any questions regarding this California Job Applicant Privacy Notice or our privacy practices, please contact us at [privacy@numerator.com].