HIRING PRIVACY POLICY

If you are applying to work for The Mid-Atlantic Wolf Pack, LLC, The Mid-Atlantic Wolf Pack 2, LLC, or our affiliates (“Company”, “we”, “us”, “our”), this notice describes how and why we collect and process your personal data as a candidate (“you” or “candidate”), along with how it will be used in connection with our recruitment and hiring activities. It also describes the rights and options available to you with respect to your personal data.

This notice does not apply to information that we collect outside the recruitment and hiring context. If you are engaged for a position, then the processing of your personal information will become subject to our employee privacy notice. Please note that this notice is provided only for transparency purposes. If you have any questions related to your personal data, you should contact the Company directly.

We are the responsible party for the candidate’s personal data when provided to the Us in the context of your candidacy. We determine the means and purposes for the processing of your personal data.

1. Personal data processed

We receive personal data about you as a candidate for one or more positions at the Company at various stages throughout the recruitment process, including personal data collected directly from you, such as when you complete a paper or online application (including on a third party platform), communicate with us in connection with your application, or provide references. If you submit your candidacy by email or online or other digital platform, then you are the main source of the personal data. Your personal data can also originate from other sources, such as social media profiles such as LinkedIn, recruitment agencies, headhunters, prior employers (e.g. for reference), and third party sources that may include data brokers arising out of background, screening, reference checks. 

This data varies among candidates but may include: 

  • Identification      and contact information, such as name, copies of governmental      identification documents, such as driver’s license, passport, social      security number, residency and work permit status, postal and electronic      address, phone number, and other contact details, including emergency      contacts.
  • Professional      qualifications or employment-related information, including a Curriculum      Vitae (“CV”) or resume and information such as work experience, education,      academic qualifications, professional qualifications, professional      licenses, professional areas of interests, performance and skills      information, information about your candidacy and employment options (such      as availability to be hired and salary expectations), and employment      contract details (if applicable). We may also collect and process      information about you generated during or after interviews and related      activities, such as interview notes and recordings, assessment feedback,      test results, and, where permitted by law, background check information. 
  • Demographic      data, which may include protected classifications under applicable law,      such as age, gender, military or veteran status, race, ethnicity, national      origin or nationality, if you choose to provide it.
  • Technology      and internet activity information, such as sign-in, account, and device      information, including online and device identifiers, information about      how you use the website(s) where you provide candidate information,      non-precise geolocation data as derived from your IP address, audio,      electronic, visual, or other sensory information, such as photographs,      audio, or footage collected in the course of video interviews, and      information about your interactions with the Firm’s websites or social      media pages.
  • Other      information we collect or process in connection with our recruitment      process, including information you choose to provide about your hobbies,      social preferences, and answers to feedback surveys.

Some of the above categories of personal data may be considered sensitive personal data or special category data under applicable law. Some sensitive personal data such as racial or ethnic origin information, or health information, is collected on a purely voluntary basis and only used in accordance with applicable law. 

We may combine personal data that we receive from the sources described in this Notice, including third party sources and public sources, and use or disclose it for the purposes described below.

2. Use and disclosure of your information

The Company uses the personal data identified above primarily to evaluate and consider you as a candidate for positions in accordance with its processes and policies for evaluating employment candidates, including the verification of qualifications and administration of background checks, to contact you for your candidacy status and interviews, and to schedule meetings and interviews, among others.

We may also process your personal data for the following business purposes to the extent permitted by applicable law, such as:

  • Ensuring      the safety and security of the Company’s workplace, workers, data, and      Systems, including by managing, monitoring, protecting, and improving our      Systems, administering background checks as permitted by applicable law,      protecting against other malicious or illegal activity, and prosecuting      those responsible. We also may need to process your information in      connection with preventative and occupational medicine and emergency      situations, such as to administer first aid, or contact your emergency contact      in the event of an emergency.
  • For      other legal and compliance purposes, including those relating to tax and      anti-discrimination laws, to exercise and defend against legal claims, and      to comply with our other legal obligations.

We may share a candidate’s personal data among our various offices or our affiliated entities (entities controlled by, under common control with, or controlling us, directly or indirectly) as required by our business needs. In addition to uses and disclosure of your personal data within the Company, we may disclose your personal data with certain third parties including, but not limited to, insurers, service providers or public bodies. For example, your personal data may be disclosed to the following categories of recipients for the following reasons:

· Authorized Third Parties and Service Providers. We may share your personal data with our service providers and vendors who assist us to collect, process, and store your personal data, including Indeed, in the context of your candidacy. These companies are authorized to use your personal data as necessary to provide these services or as otherwise authorized by us. We may share your general recruitment status with third parties who submitted your candidacy to us.

  • Other      Parties for Legal, Contractual, or Compliance Purposes. We may make personal data      available to third parties to comply with our legal obligations,      government clearances, or contracts or respond to a court order,      administrative or judicial process, such as in the event of a subpoena,      government audit or search warrant, lawful request by public authorities,      or to seek legal or professional advice from external professionals. 
  • Other      Parties in Connection with Business Transactions. If, in the future, we sell or      transfer, or we consider selling or transferring, some or all of our      business, shares or assets to a third party, we will disclose your      personal data to such third party (whether actual or potential) in      connection with the foregoing events. In the event that we are acquired      by, or merged with, a third party entity, or in the event of bankruptcy or      a comparable event, we reserve the right to transfer, disclose or assign      your personal data in connection with the foregoing events, including, in      connection with, or during negotiations of, any merger, sale of company      assets, consolidation or restructuring, financing, or acquisition of all      or a portion of our business by or to another company.

3. Security and data retention

We will retain your personal data collected as part of recruitment and hiring, including sensitive personal data, for only as long as necessary to fulfil the business purposes described in this notice, and only in compliance with applicable law. If hired, this data becomes part of your permanent personnel file.

To determine the appropriate retention period for your personal data, we will consider the following criteria: (i) the amount, nature, and sensitivity of the personal data, (ii) the potential risk of harm from unauthorized use or disclosure, (iii) the purposes for which we process your data and whether we can achieve those purposes through other means, and (iv) any applicable legal requirements.

4. Your rights; federal and state-specific disclosures

Your rights may vary, depending on the applicable law. These rights may not be available in certain jurisdictions and/or may be subject to certain derogations or limitations. You may have the following rights:

  • To ask us to      receive a copy of your personal data that is stored on our servers;
  • to update,      correct and/or delete your personal data; 
  • to request the      restriction of processing concerning your personal data or to object the      processing of your personal data;
  • to request to      obtain a copy of your personal data in a structured, commonly used and      machine-readable format;
  • If we rely on      consent, please note that you have the right to withdraw consent at any      time; 
  • to lodge a      complaint with a supervisory authority; and/or
  • to withdraw your      consent, such as where we have relied upon your voluntarily consent to      process your personal data.

Our processing of your personal data is governed by several key federal mandates:

· Fair Credit Reporting Act (FCRA): We may use third-party consumer reporting agencies for background checks. We provide a separate disclosure and obtain your written authorization before pulling these reports.

· Equal Employment Opportunity (EEO): Per Title VII of the Civil Rights Act, we may collect demographic data to monitor our diversity and inclusion efforts. This data is kept separate from the hiring decision.

· Immigration Reform and Control Act (IRCA): We collect identity and work authorization documents to complete Form I-9 within three days of hire.

Our processing of your personal data may be governed by certain specific state laws, depending on the applicable jurisdiction, including, without limitation:

California (CCPA/CPRA)

  • Notice at      Collection:      Candidates must be informed at or before the point of collection.
  • Sensitive PI: We do not use or disclose SPI      (like your SSN or precise geolocation) for purposes other than those      permitted under Cal. Civ. Code § 1798.121.
  • No      Sale/Sharing: We      do not "sell" applicant data for monetary value or      "share" it for cross-contextual behavioral advertising.

New York City (Local Law 144)

  • Automated      Employment Decision Tools (AEDT):      If we use AI to screen your resume or score your interview, we conduct an      annual independent bias audit and publish the results on our website.      Candidates may request an alternative evaluation process.

Texas (Data Privacy and Security Act - TDPSA)

  • Texas residents      have the right to opt-out of the processing of their personal data for      profiling in furtherance of decisions that produce legal or similarly      significant effects.

Other States with Privacy Regulations

· Virginia, Colorado, Connecticut, Utah, Illinois, Iowa, Indiana, Montana, Tennessee, Florida, Delaware, New Hampshire, New Jersey, Kentucky, Nebraska, Oregon, Rhode Island, Maryland, and Minnesota.

If you wish to exercise any of these rights, please contact us at the resources described in paragraph 7 below. If you choose to exercise any of your rights, we will handle these requests in accordance with applicable law, but please note that the exercise of some of those rights may affect your ability to proceed with the application as a candidate.

5. Use of AI technologies

We may also use AI-driven tools to assist in the recruitment process.

· Candidate Matching: Algorithms may suggest roles based on your resume.

· Analysis: We may use tools to remove "bias identifiers" (like names or graduation dates) during initial screening to ensure objective evaluation.

· Human-in-the-Loop: All final hiring decisions are made by human recruiters, not exclusively by automated systems.

6. Changes to this privacy notice

The Company may make changes to this notice from time to time, without prejudice to your rights under applicable laws. The new version will be effective from the date indicated in that updated notice, ensuring that individuals receive sufficient advance notice and draw their attention to any significant changes.

7. Contact us

If you have any requests, responses, or questions regarding this privacy notice, please email us at lisa@mawolfpack.com.