Numerator Job Applicant Privacy Notice
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California Job Applicant Privacy Notice
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:
Category of Personal Information
Categories of Third Parties [HAK15]
Identifiers
- Our affiliates and subsidiaries
- Vendors who provide services on our behalf
- Data brokers, such as credit bureaus, credit reporting service providers and background check services
Protected Classifications
- Our affiliates and subsidiaries
- Vendors who provide services on our behalf
Employment Information
- Our affiliates and subsidiaries
- Vendors who provide services on our behalf
- Customers or business partners
- ISPs and operating systems and platform
- Data brokers, such as credit bureaus, credit reporting service providers and background check services
- Talent and recruiting agencies
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.
GDPR Addendum to California Job Applicant Privacy Notice
Last Updated: March 31, 2025
This GDPR addendum (the “Addendum”) supplements the Numerator California Job Applicant Privacy Notice (the “Notice”) and describes the types of personal data we obtain about data subjects in the European Economic Area (EEA) and United Kingdom (UK), how we use the personal data, and with whom we may share it. This Addendum also describes the choices available to you, the measures we take to safeguard personal data, and how you can contact us about our privacy practices and your rights.
Market Track, LLC d/b/a Numerator, with an address at 24 E. Washington St., Suite 1200 Chicago, IL 60602 (“Numerator”, “us”, “we”) will act as a “controller” in respect of your personal data, and will process personal data in accordance with this Addendum.
This Addendum uses certain terms that have the meaning given to them in the General Data Protection Regulation or UK General Data Protection Regulation, as appropriate (collectively, the “GDPR”).
Personal Data We Obtain
Where permitted by applicable law, we may obtain certain personal data in connection with processing job applications, evaluating candidates for employment, and carrying out and supporting HR functions and activities, which are listed under the Notice of Collection and Use of Personal Information section of the Notice. Our personal data collection includes the personal data we collect automatically listed under the Information We Obtain section of our Privacy Policy, and described in our Cookie Notice.
We may, where permitted by applicable law, collect personal data deemed “sensitive” or a “special category” of personal data such as racial or ethnic origin, religion or philosophical beliefs, trade union membership, health data (including with regards to disability), data concerning your sexual orientation, or criminal offences data.
With respect to “Employment Information” as listed under the Notice of Collection and Use of Personal Information section of the Notice, we will only perform pre-employment and background screening checks where permitted by, and in accordance with, applicable law.
How We Obtain Information About You
We will obtain personal data directly from you when you apply for a job and throughout the recruitment process, such as during interviews and discussions. We may also obtain personal data from recruitment agencies, if assisting with your application, and from previous employers or other referees. If permitted by applicable law, we may also obtain personal data from other third parties such as background check providers.
Where we collect personal data directly from you, we will indicate if provision of the personal data is necessary for our compliance with a legal obligation, or to perform a contract with you.
How We Use The Personal Data We Obtain
We rely on the following lawful bases to process your personal data for the following purposes, where permitted by applicable law:
- Our legitimate interests in recruiting new and appropriate personnel, expanding our workforce, and in ensuring the recruitment process is efficient, effective and secure:
- Making travel arrangements;
- Complying with internal policies and procedures;
- Providing access to facilities and monitoring access through the use of CCTV;
- Maintaining or servicing accounts used for the recruitment process;
- Retention and storage of information collected through the recruitment process;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- Monitoring of diversity and equal opportunities;
- Providing technical support, including debugging any recruitment services/applications to identify and repair errors that impair existing intended functionality;
- Conducting investigations, and managing grievances, complaints or claims;
- Pursuing legal rights and remedies, defending litigation, and managing complaints or claims; and
- Undertaking internal research for technological development and demonstration with regards recruitment services/applications.
- For the performance of a contract to which you are a party or to take steps at your request to enter into a contract with you:
- Recruiting – processing job applications, determining suitability for employment, reviewing and evaluating applications, conducting interviews, reviewing hiring decisions;
- Performing background checks (where permitted by applicable law);
- Verifying your identity and other information required by applicable law to make you an offer of employment and to enter into a contract with you;
- Reimbursing expenses incurred during the recruitment process, if accrued in accordance with our policies; and
- If it has been determined that an offer will be made, determining salary and other forms of compensation.
- With your consent:
- Depending on applicable law, certain processing activities may require your consent such as pre-employment and background screening; and
- With your consent we may store your details in order to contact you about future opportunities with Numerator.
- To comply with applicable legal and regulatory requirements:
- Determining physical and/or mental fitness for work to allow for necessary adjustments;
- Complying with requests from government or other public authorities; and
- Responding to legal process such as subpoenas and court orders.
We also may use the information in other ways for which we provide specific notice at the time of collection.
As stated above, we may process certain “sensitive” data or “special category” data during the recruitment process. We may do so for the following purposes:
- Determining physical and/or mental fitness for work to allow for necessary adjustments;
- Monitoring of diversity and equal opportunities; and
- Pursuant to pre-employment and background checks, we may process criminal offences data.
How We Share The Information We Obtain
We may share the personal data we obtain about you with our affiliates and the third parties listed in the Disclosure of Personal Information section of the Notice, for any of the purposes described above to the extent necessary in each case. We also may share the information we obtain about you with our professional advisors (e.g., auditors, accountants, law firms, and other consultants).
International Transfers
We may share your personal data for the purposes described in the Disclosure of Personal Information section of the Notice. Your personal data may be transferred to recipients located outside the EEA and UK.
Whenever we transfer your personal data to recipients located outside the EEA and UK, we will ensure that:
- The country to which the personal data will be transferred has been granted an adequacy decision by the European Commission and/or appropriate regulatory or government authority;
- We have put in place appropriate safeguards in respect of the transfer, for example, the EU Standard Contractual Clauses; or
- One or more of the derogations for specific situations provided by law applies, for example, because the transfer of personal data is necessary for us to establish, exercise, or defend against legal claims.
Please contact us using the details provided below if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA and UK.
Your Rights and Choices
In accordance with applicable law, you may have certain rights in relation to your personal data. These rights will, in accordance with applicable law, apply only in certain circumstances and are subject to certain exemptions that may apply, and they are as follows:
- Request access to personal data we maintain about you.
- Request correction of incomplete or inaccurate personal data that we hold about you. To help ensure your personal data is accurate and current, we ask that you please keep us informed if your personal data changes during your relationship with us.
- Request erasure of personal data we maintain about you. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request the restriction of processing of your personal data in certain situations, for example, if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to you or another party.
- Withdraw your consent where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legal basis for doing so.
If you want to exercise any of these rights, please contact us via email at privacy@numerator.com. To help protect your privacy and maintain security, we may request information from you to verify your identity before granting you access to your personal data or complying with your request.
You generally will not have to pay a fee to exercise any of your rights. However, where the relevant law permits, we may charge a reasonable fee if your request for access is clearly unfounded or excessive (for example, for repeat copies). Alternatively, we may deny your request in such circumstances.
You have the right to make a complaint at any time to a data protection authority in the EEA or UK, as appropriate. We would, however, appreciate the chance to deal with your concerns before you approach the data protection authority, so please contact us in the first instance.
How We Protect Personal Data
We maintain administrative, technical and physical safeguards designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.
Retention
We will retain your personal data for the time period necessary to achieve the purposes outlined in this Addendum and the Notice, taking into account applicable statute of limitation periods and records retention requirements under applicable law.
Updates To The Addendum
This Addendum may be updated periodically and to reflect changes in our personal data practices. We will post a notice on our website and/or mobile application to notify you of significant changes to the Addendum and indicate at the top of the Addendum when it was most recently updated.
How To Contact Us
If you have any questions about this Addendum, please contact us at privacy@numerator.com.