CCPA HR Notice

California Consumer Privacy Act Applicant Notice

Last Updated: January 1, 2023

Mainsail Management Company, LLC (the “Company”) is providing you with this California Consumer Privacy Act Applicant Notice (“Notice”) to inform you about the categories of Personal Information that the Company collects about applicants who reside in California; and the purposes for which the Company uses that Personal Information.

For purposes of this Notice, “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person that the Company collects about its applicants, who reside in California, in their capacity as applicants for positions with the Company.

Assistance for Disabled Applicants

Alternative formats of this Notice are available to individuals with a disability.  Please contact [email protected] for assistance.

Categories of Personal Information We Collect and Purposes for Collecting Personal Information

1. Identifiers and Professional or Employment-Related Information

1.1   Personal Information Collected: The Company collects identifiers and professional or employment-related information, including the following: (i) Identifiers: real name, nickname or alias, postal address, telephone number, e-mail address, signature, online identifier, and Internet Protocol address, and (ii) Professional or Employment-Related Information: evaluations, membership in professional organizations, professional certifications, and employment history (including that displayed on publicly available social media profiles).

1.2   Purposes of Use:

2. Commercial Information

2.1   Personal Information Collected: The Company collects commercial information, including the following: products or services purchased or obtained; or other purchasing or consuming histories or tendencies.

2.2   Purposes of Use: Reimbursement of travel expenses.

3. Internet or Other Similar Network Activity

3.1   Personal Information Collected: To the extent candidates visit the Company’s website, the Company collects information about applicants’ use of the Internet or other similar network activity, including the following activities conducted on the Company’s website: browsing history, information regarding an applicant’s interaction with the website and publicly available social media activity.

3.2   Purposes of Use: To monitor use of the Company’s information systems and other electronic resources or information systems, to conduct internal audits, to conduct internal investigations, and to protect the safety and security of the Company’s facilities.

4. Preferences

4.1   Personal Information Collected: The Company collects applicant preferences information, including preferred meals, seating and other travel preferences, desired working hours, and desired working conditions.

4.2   Purposes of Use: To evaluate the application for employment, reimbursement of travel expenses and for travel and event planning.

5. Purposes Potentially Applicable to Any of The Categories of Personal Information Listed Above

5.1 The Company also may use applicants’ Personal Information to facilitate administrative functions and information technology operations and for legal reasons and corporate transactions. These functions include, but are not limited to the following:

(a) to manage and operate information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, strategic planning;
(b) to manage litigation involving the Company, and other legal disputes and inquiries and to meet legal and regulatory requirements;
(c) in connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of the Company or any of its subsidiaries or affiliates; and
(d) to manage licenses, permits and authorizations applicable to the Company’s business operations.

6. Sensitive Personal Information

6.1   We do not collect or use sensitive personal information other than:

(a) to perform services, or provide goods, as would reasonably be expected by an average person who requests those goods or services;
(b) as reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
(c) as reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
(d) as reasonably necessary and proportionate to ensure the physical safety of natural person;
(e) for short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
(f) to perform services on behalf of our business;
(g) to verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
(h) to collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about you.

Retention of Personal Information
We retain the categories of personal information set forth above only as long as is reasonably necessary for those purposes set forth above, except as may be required under applicable law, court order or government regulations.

Disclosure of Personal Information
We do not share for the purpose of cross-context behavioral advertising or sell any of the personal information we collect about you to third parties.
Within the last twelve (12) months, we may have disclosed personal information collected from you for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Your Rights Under the California Consumer Privacy Act

1.   Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations.
2.  Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you. Such information includes:

2.1           the categories of personal information we collected about you;
2.2           the categories of sources from which the personal information is collected;
2.3           our business or commercial purpose for collecting such personal information;
2.4           the categories of third parties with whom we disclose the personal information;
2.5           the specific pieces of personal information we have collected about you; and
2.6           whether we disclosed your personal information to a third party, and, if so, the categories of personal information that each recipient obtained.

3.  Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations.

4.  No Discrimination: We are an equal opportunity employer and are committed to complying with all federal, state, and local equal employment opportunity laws. We will not discriminate against you for exercising your rights as an applicant under the CCPA.

5.  How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.

Contact us

For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.

Call us using the following toll-free number: 866-855-0897.

Email us at the following email address: [email protected].

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request.  We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information, if applicable, in order to verify your request.  You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.

Please contact the Chief Compliance Officer of Mainsail Management Company, LLC at [email protected] with any questions or concerns about this Privacy Notice.