California Applicant Privacy Disclosures

Effective Date: January 1, 2023

This California Applicant Privacy Disclosures (“CA Applicant Disclosures”) informs California residents applying for or interested in applying for a role at eMoney Advisor, LLC. or one of its affiliates, (collectively “eMoney” or the “Company” or “we” or “us” or “our”) of our practices regarding the collection, use, sale, sharing, and retention of your personal information (“Information Practices”) as a job applicant through our Careers website (the “Site”), including through a recruiter, to facilitate your job application (“Applicant Personal Information”). This CA Applicant Disclosures should be read in association with all other Company policies that may be provided to you as part of the application process.

I. COLLECTION AND USE OF APPLICANT PERSONAL INFORMATION

We may collect, store, use, and disclose Applicant Personal Information for business purposes consistent with applicable laws. Where we transfer Applicant Personal Information to service providers or contractors, it is for the same business purposes described below and, where appropriate, requires that such parties maintain its confidentiality and maintain appropriate systems and processes to ensure its security and protection.

We may Collect and use the categories of Applicant Personal Information about you to manage your application below.

Categories of Applicant Personal Information	Business Purpose(s) for Collection and Disclosure
Personal Identifiers such as your name, home address, telephone/cellphone numbers, email address, and/or other similar identifiers.	We will use this information to open and maintain your application records; communicate with you regarding your application; confirm eligibility, qualification, and background checks; maintain business records to meet our retention policy; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws.
Personal Information Described in Subdivision (e) of Section 1798.80 such as name, signature, address, telephone number, national identification number (i.e., Social Security Number, Driver’s License), education, employment, and employment history.	We will use this information to open and maintain your application records; communicate with you regarding your application; confirm eligibility, qualification, and background checks; maintain business records to meet our retention policy; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws.
Characteristics of protected classifications such as age and date of birth, race, ancestry, ethnic origin, sex, gender, gender identity, military or veteran status, medical condition, disability.	We will use this information to open and maintain your application records; maintain business records to meet our retention policy; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws. We will also use any information relating to any disability or medical condition to address our legal obligations to you, make any adjustments required to assist you in the application process and whether you are fit to undertake tasks required by your job role. We will also use this to comply with U.S. Equal Employment Opportunity Commission (“EEOC”) and California Civil Rights Agency (“CCRA”) requirements, and other equal opportunity initiatives.
Internet or other electronic network activity information such as browser type and language, operating system, website access time, duration of visit, referring website address, browsing and search history on our websites, webpages viewed immediately before and after our websites, and information related to your interactions with our websites.	We will use this information as needed to operate our Site and systems.
Geolocation data such as your geographic location inferred from your device IP address or otherwise provided by you.	We will use this information to give you the most relevant jobs and opportunities in your area.
Sensory information such as security camera recordings, videos, and photos, including job interview recordings.	We will use this information to monitor your compliance with our internal policies and procedures, to investigate security breaches and misuse of computer equipment and systems, to protect the safety of employees and third parties, and to protect our property from theft, vandalism, and damage.
Professional or employment-related information such as skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, application form, or cover letter; Answers to behavioral or other screening questions in an application or interview; Information contained in any websites or documents you choose to share with us; Information relating to professional licenses, training, disciplinary actions, and membership in professional organizations; Information relating to membership in civic organizations.	We will use this information to open and maintain your application records; communicate with you regarding your application; confirm eligibility, qualification, and background checks; maintain business records to meet our retention policy; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws. We will also use this information to assess and consider other job positions that may be recommended to you based on your qualifications.
Non-public education information such as school(s) attended, grades, transcripts, records of attendance, disciplinary records, and other information relating to your secondary and post-secondary education, including any graduate or professional degrees.	We will use this information to open and maintain your application records; communicate with you regarding your application; confirm eligibility, qualification, and background checks; maintain business records to meet our retention policy; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws. We will also use this information to assess and consider other job positions that may be recommended to you based on your qualifications.
Inferences drawn from the Applicant Personal Information above, except from characteristics of protected classifications, such as preferences, characteristics, predispositions, behavior, or attitudes.	We will only use this information for recruitment efforts and will not impact your current application or future employment with us.
Sensitive Personal Information such as national identification number (i.e., social security number, driver’s license); race or ethnic origin; precise geolocation; and information relating to any disability or medical condition that is relevant to your role, including the results of any pre-employment physical or screening examination, if any.	We will use this information to open and maintain your application records; communicate with you regarding your application; confirm eligibility, qualification, and background checks; maintain business records to meet our retention policy; and comply with applicable state, federal labor, employment, equal employment opportunity, and related laws.

II. ADDITIONAL PURPOSES FOR USING APPLICANT PERSONAL INFORMATION

In addition to the business purposes set forth above, we may use and disclose the categories of Applicant Personal Information identified:

To comply with applicable legal and regulatory requests and obligations (including investigations).
To establish or defend legal claims and allegations.
For security or the prevention, detection, or investigation of fraud, suspected or actual illegal activity, violations of company policy or rules, or other misconduct.
To seek advice from lawyers, auditors, and other professional advisers.

III. RETENTION PERIOD CRITERIA FOR APPLICANT PERSONAL INFORMATION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Applicant Personal Information (which includes the categories of PI set forth in the chart above) for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, obligations, or as necessary to resolve disputes.

To determine the appropriate retention period for Applicant Personal Information, we consider applicable legal requirements, the amount, nature, and sensitivity of the Applicant Personal Information, the potential risk of harm from unauthorized use or disclosure of your Applicant Personal Information, the purposes we process your Applicant Personal Information for, and whether we can achieve those purposes through other means.

For example, we will retain your Applicant Personal Information, during the entire application process to fulfill the purposes described above, including but not limited to: opening and maintaining your application records; communicate with you regarding your application; and confirm eligibility, qualification, and background checks. At the conclusion of the application process, we may retain your Applicant Personal Information for as long as two (2) years or as required by applicable laws, including but not limited to: Title VII of the Civil Rights Act of 1964; the Age Discrimination in Employment Act of 1967; American Disabilities Act of 1990; and for California Applicants, California Government Code Section 12946.

IV. CATEGORIES OF RECIPIENTS TO WHOM APPLICANT PERSONAL INFORMATION MAY BE DISCLOSED FOR BUSINESS PURPOSE

To carry out the purposes described above, we may disclose your Applicant Personal Information to the following recipients: include data analytics providers, security providers, background check vendors, human resources and information technology vendors, outside legal counsel, and state or federal governmental agencies.

V. CATEGORIES OF SOURCES FROM WHICH APPLICANT PERSONAL INFORMATION MAY BE COLLECTED

We may collect Applicant Personal InformationSHARE OR SELL OF APPLICANT PERSONAL INFORMATION on this Site, including through a recruiter, from a variety of sources to facilitate your job application, operate the Site, comply with applicable laws, and other permitted purposes.

(1) Directly From You. For example, we collect your name, home address, telephone/cellphone numbers, email address, and other employment-related information when you apply for a job through our Site.

(2) Automatically When Using Our Electronic Systems. For example, our Site automatically collects your internet and network activity information when you apply for a job.

(3) Service Providers and Contractors. For example, background check vendors and credit agencies and bureaus, recruitment and staffing agencies.

(4) Affiliates.

VI. OR SELL OF APPLICANT PERSONAL INFORMATION

We will not share or sell your Applicant Personal Information to third parties.

VII. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and other tracking technologies (such as web beacons) to collect and store information about your interactions with our Site, including information about your browsing behavior.

Cookies are small files that a website transfers to your device through a web browser that enable the Site’s systems to recognize your device and to capture and remember certain information. Web beacons (also known as tracking pixels) are tiny graphics embedded invisibly on a webpage or in an email that may be used to deliver or communicate with cookies, to count users who have visited certain pages, and to understand usage patterns. In general, our website use cookies and other tracking technologies as follows:

(1) Where necessary to run our Site;

(2) To optimize the functionality of our Site, including by personalizing content for you, greeting you by name and remembering your preferences (e.g., your choice of language or region);

(3) For analytics purposes—for example, to help us understand how our Site is used.

Our Site uses analytics technology, including Google Analytics, to understand how users interact with the Site, improve our web experience, and better market our products. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

VIII. CALIFORNIA PRIVACY RIGHTS

If you are a resident of California, you have the right to submit certain requests relating to your Applicant Personal Information as described below.

Right to Opt-Out of Share and Sale of Applicant Personal Information.

As stated above, we will not share or sell your Applicant Personal Information. For this reason, we do not treat Applicant Personal Information collected by us as subject to a “Do Not Share or Sell My Applicant Personal Information” request and, therefore, we do not offer a way for you to submit such a request.

Right to Limit Use and Disclosure of Sensitive Personal Information.

We will not use Sensitive Personal Information for the purpose of inferring characteristics about you, or for any other reasons besides the permitted purposes including: to provide our goods and services, or as needed: to ensure security and integrity; to prevent fraud or illegal activity; for physical safety; for short-term, transient use, including for non-personalized advertising; to perform services on behalf of the business; and to verify or maintain the quality or safety of a service or device owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance such services or devices. For this reason, we do not treat the Sensitive Personal Information we collect as subject to a Limit the Use of My Sensitive Personal Information request and, therefore, we do not offer a way for you to submit such a request.

Right to Know, Delete, and Correct Applicant Personal Information.

Any Request to Know, Request to Delete, and Request to Correct you submit to us is subject to an identification and residency verification process (“Verifiable Applicant Request”). We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the Applicant about whom we collected Applicant Personal Information.

If you are unable to provide us with certain information about yourself, we will be unable to verify your identity to fulfill a request to know, delete, or correct. For your specific pieces of information, as required by the California Consumer Privacy Act (“CCPA”), we will apply heightened verification standards, and reserve the right to request further information from you, in addition to the information mentioned above. Under the CCPA they are exceptions to your request rights. If we do not comply fully with a request, we will explain the reasons in our response.

We will make commercially reasonable efforts to identify Applicant Personal Information that we collect, process, store, disclose, and otherwise use and to respond to your requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

You may use an authorized agent to submit your request. If you use an authorized agent to submit a request, we may require proof that the agent has been authorized by you to do so, and take other steps permissible under the CCPA, to ensure it is a proper request by an authorized agent.

Right to Know. You have the right to send us a request, no more than twice in a twelve-month period, for any of the following:

(1) The categories of Applicant Personal Information we have collected about you, including:

The categories of sources from which the Applicant Personal Information was collected
Our business or commercial purposes for collecting, selling, or sharing Applicant Personal Information
The categories of third parties to which we disclose Applicant Personal Information
The categories of Applicant Personal Information that we disclosed for a business purpose, and for each category identified, the categories of third parties to which we disclosed that particular category of Applicant Personal Information.

(2) The specific pieces of Applicant Personal Information we have collected about you.

Right to Delete. You may request that we delete your Applicant Personal Information that we have collected directly from you and are maintaining. Exceptions do apply, including, without limitation, where we need to retain your Applicant Personal Information as permitted by applicable law, such as for legal retention requirements, regulatory reasons, to complete a warranty or other contract with you, or other internal uses of the information that are compatible with the context in which you provided it. Note also that we are not required to delete your Applicant Personal Information that we did not collect directly from you.

Right to Correct. If you believe that any of your Applicant Personal Information, we maintain about you is inaccurate, you have the right to request that we correct that information.

To exercise the right to know, right to delete, or right to correct, you may submit a request by clicking here, or by emailing us at privacy-px@emoneyadvisor.com or calling us at 1-888-362-8482 and including your name, address, email address, and phone number. Do not send other information via e-mail. We will contact you for further information if necessary. In order to complete your request, you will be required to respond to any follow up inquires we may make, and we may deny your request if you do not do so.

Right to Non-Discrimination for the Exercise of Your Privacy Rights.

If you choose to exercise any of your privacy rights under the CCPA, we will not discriminate against you.

IX. COMMUNICATIONS

You can elect to unsubscribe from certain promotional communications (emails or text messaging) from Company at any time either by following the instructions provided in a Company email to click on the unsubscribe link or by changing the marketing communication preferences settings in your account. Please note that if you enrolled in the Site using more than one email address or telephone number, you will need to submit a separate unsubscribe request for each. Even if you unsubscribe from receiving certain types of communications, Company may, subject to applicable law, continue to send you non-promotional communications, such as those about the position for which you applied or may be interested in applying, similar job opportunities at Company, or communications relevant to your use of the Site. If you would like to completely deactivate your account, please opt-out of receiving any future communications from Company by changing your marketing communication preferences in your Site account or by contacting us at unsubscribe@emoneyadvisor.com.

X. CHANGE IN STATEMENT

We reserve the right to amend this CA Applicant Disclosures at any time in order to address future developments of Company, the Site or changes in industry or legal trends. We will post the revised Notice on the Site. Any changes will become effective upon the posting of the revised CA Applicant Disclosures on the Site. By continuing to use the Site following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Notice, in whole or part, you can choose to not continue to use the Site.

XI. CONTACT US

Please contact Human Resources with any questions.

Contact: eMoney Advisor, LLC.

Email: privacy-px@emoneyadvisor.com

Address: Four Radnor Corporate Center, 100 Matsonford Rd Suite 220, Radnor, PA 19087

Phone: 1-888-362-8482