Habemco, LLC (“Habemco”), or any of its affiliated entities including ULPS, LLC (collectively “Habemco,” “we,” “our,” or “us”) is the company that is recruiting for the job vacancy for which you are applying. We are providing you with this Privacy Notice for Job Applicants (the “Notice”) to describe how Habemco collects, processes, transfers, and safeguards your Personal Data when you, the job applicant, apply for a job with Habemco or ULPS. Personal Data, sometimes referred to as Personal Information or Personally Identifiable Information, means any data or information that relates to an identified or identifiable individual or that Habemco can link to an identified or identifiable individual. Personal Data may be in any form, including paper, electronic, audio, or video.

Thank you for your interest in working with us. By participating in the application process you acknowledge receipt of this Notice and agree to its terms. This Notice and all activities described herein is subject to the laws of the Habematolel Pomo of Upper Lake, a federally recognized Indian tribe (the “Tribe”).

Personal Data We Collect

When you apply for a job with us, we will ask you to provide us with Personal Data about you so that we may evaluate your application. This is voluntary, but if you do not provide this information then our ability to consider you as a candidate may be limited. We may collect Personal Data from you or from third parties, through various means (such as emails, text messages, phone calls, video calls, and in-person interviews). We may also collect some of this information from time to time during your relationship with us, if we hire you. 

We may collect Personal Data about you in the following categories:

a. Identity and contact details, such as your full name, address, email address, photo, phone number, and contact preferences;

b. Application information, such as position applied for, salary expectations, eligibility to work, and willingness to relocate;

c. Employment details, such as your employment background, including position, work experience, and employment references;

d. Background information, such as your educational background, credit history, and (where legally permitted) criminal background information and drug screen results;

e. Photographs, and images/audio/footage which may be captured on CCTV or other video systems when visiting Habemco offices or captured during recruitment events or video interviews;

f. Immigration and Citizenship information and documentation, as applicable and where legally permitted;

g. Diversity information, where legally permitted and voluntarily provided, such as gender, ethnicity, veteran status, and disability status;

h. Assessment data, generated by your participation in psychological, technical or behavioral assessments in connection with your application. You will receive more information about the nature of such assessments before your participation in any of them;

i. Habemco Website Visit Information, such as certain technical information from you about your visit to our website using “cookies” and other similar technologies; and

j. Any other information in your application or interviews that you choose to share with us - such as personal preferences, hobbies, and other information about you.

How We Use Your Personal Data

We use your Personal Data to:

a. Evaluate your application for current or future positions;

b. Communicate with you about your application;

c. Conduct interviews and assessments;

d. Perform pre-employment screening and background checks;

e. Analyze and improve our recruitment process;

f. Comply with legal and regulatory requirements; and

g. Maintain records for future opportunities.

Legal Bases for Processing

We use your Personal Data as described above and as stated or agreed to at the point of collection, or as is obvious by the context and nature of the collection. Our legal bases for processing your information vary, but may include processing that is: necessary for our performance of the employment relationship with you, if you are hired; in connection with our legitimate business interests; for the purposes of carrying out our legal and regulatory rights and obligations; for reasons of substantial public interest; and for any other legal purpose or reason.

Use of an Automated Decision-Making Technology

If we, in connection with your application for a job with us, make use of an Automated Decision-Making Technology (a tool or technology that processes personal information and uses computation to make a significant decision, without human intervention, in connection with your application with us, such as whether or not to proceed with that

application or a final hiring or contracting decision), then we will provide notice to you of that use before you submit your information to us, pursuant to Tribal law.

Sharing and Transferring Your Personal Data

We may share your Personal Data in the following circumstances:

a. Internally, to our employees who are involved in the recruitment, evaluation, and hiring processes. All employees are required to comply with our privacy and information security policies.

b. Externally, to certain third-party service providers or suppliers (“Service Providers”) that include, without limitation, data storage providers, website or mobile application hosting providers, background check or drug screen providers, and email service providers. We take steps to ensure appropriate protections are in place before we share Personal Data with any Service Provider.

c. To our professional advisors, such as our attorneys, in their capacity as advisors.

d. In connection with the evaluation of a change of control, or an actual change of control, such as a merger, acquisition, or sale of assets.

e. In connection with a legal requirement, such as cooperating with law enforcement and other government agencies. This disclosure may occur if we believe in good faith that we are required to disclose that Personal Data; if we are advised to disclose Personal Data by our legal counsel; when necessary to identify, contact, or bring a legal action against someone who may cause or be causing harm to us, or interfering with our legal rights or those of any other party; to protect our rights or property, or the health and safety of any party; or to detect and investigate fraud or illegal activity.

Data Security

We implement appropriate technical, organizational, and physical safeguards designed to protect your Personal Data from unauthorized access, disclosure, alteration, and destruction.

You are responsible for safeguarding the security of any password, user ID, or other form of authentication involved in obtaining access to password-protected or secure areas of any of our platforms, and to use the appropriate level of care when interacting with us.

If you have reason to believe that an interaction with us is no longer secure, you should notify us immediately. If a breach of applicant Personal Data occurs, we will notify impacted individuals of the breach if and as required under applicable law.

Retention of Personal Data

We retain applicant Personal Data subject to our record retention policy and applicable law. Generally, this means that your Personal Data will be retained through the application process plus a reasonable period of time thereafter to respond to application-related inquiries or any legal matters related to an application process. If you are hired, your Personal Data will become part of your employee record which may be subject to different retention requirements. Personal information which is no longer needed to be retained will be securely and effectively destroyed or permanently erased from our systems, and we will also require third parties to destroy or erase such Personal Data where applicable.

Your Responsibilities

You are responsible for the information you provide to us and ensuring that it is honest, truthful, accurate, and not misleading. If you provide information about another person, such as a reference, you are responsible for ensuring that they are aware of such and that they consent to us collecting and processing that information as described herein.

Updates

We may update this Notice periodically. Changes will be communicated via our website.

Minors

We do not knowingly collect information from individuals under age 18. If you believe we have done so, please contact us so we can delete that information.

Communication

Your submission of Personal Data to us and your participation in the recruitment and application process constitutes consent for us or our Service Providers to contact you at any phone number or email address you provide to us. This specifically includes contacting you via SMS, possibly by use of an automatic telephone dialing system, if you provide us with a mobile phone number.

If you have questions about this Notice or our privacy practices as relate to applicants, you may contact our Human Resources department via email at hr@habemco.com.