Privacy Notice for Employment-Related Personal Data

Last Updated December 22, 2022

Welcome to ThriftBooks! This Privacy Notice for Employment-Related Personal Data (or "Notice") explains how Thrift Books Global, LLC ("ThriftBooks," "we," or "us") collects and processes your information as an employee, contractor, or job candidate in an employment context.

Please read this Notice carefully to ensure you are fully informed of our practices. You can learn more by visiting our Careers page or by contacting Human Resources at HR@ThriftBooks.com.

     1. Acceptance

By applying for or accepting a position with ThriftBooks, or otherwise providing us with Personal Data in an employment context, you confirm your receipt of this Notice and consent to our collection and use of your Personal Data as described below. If you do not agree with this Notice, you may withhold consent. However, withholding your consent or refusing to provide necessary Personal Data might mean that we cannot consider you for a position or employ you.

     2. Personal Data

As used in this Notice, "Personal Data" means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular employee, job candidate, or contractor or with their household. Different types of Personal Data is often described as falling within one or more categories. For example: identifiers; sensitive information; protected classifications; biometrics; education- or employment-related information; commercial information; financial information; online activity; or inferences drawn from Personal Data to create a profile and anticipate employee behaviors.
Please note that information that is publicly available, aggregated, or deidentified so that it cannot be easily linked back to the individual is not considered Personal Data for the purposes of this Notice.

     3. Collection of Personal Data for Employment-Related Purposes

ThriftBooks collects employment-related Personal Data to recruit talent, fill open positions, facilitate the employment of our team members, and to comply with our obligations under applicable laws. We collect Personal Data during the recruitment, onboarding, and employment processes from the sources listed below.

     A. Directly from job candidates

ThriftBooks accepts inquiries from job candidates through the ThriftBooks Careers and Jobs page, third-party job posting platforms, and from recruiting agencies. We collect the following Personal Data from applications, resume submissions, and other recruitment materials:

• Identifiers like full name, email address, phone number, mailing address, and other contact information.
• Employment and education history and related information, which may include nonpublic education information, that you include in your resume or other submitted materials.
• Recruitment profile elements like social security number, date of birth, and other sensitive information.
• Protected classification characteristics, such as veteran’s status, disability status, gender, or ethnicity. Providing these details is optional, and any Personal Data of this nature that a candidate submits is voluntary and provided with consent.
• Information we direct candidates to submit information to our background check vendor. Candidates receive details from the background check vendor of its processes and policies. ThriftBooks will receive the background check results.

Information submitted to ThriftBooks for candidate consideration is parsed into our Applicant Tracking System. We collect this information with consent. We use it to consider you for employment and for our internal business purposes and, if you are hired, to facilitate your onboarding.

     B. Directly from employees and contractors

ThriftBooks collects Personal Data from employees and contractors via Human Resources forms and other internal forms. For example, ThriftBooks may collect:

• Financial information like bank account and routing numbers for payroll purposes.
• Information about dependents, including full name, address, birthday, social security number, gender, and relationship status, to provide healthcare and other employment benefits. Personal Data collected for healthcare benefit purposes will be processed subject to our carrier’s privacy policies and protocols.
• Protected classification characteristics like medical information, collected as needed to administer leave of absences, workers’ compensation, fitness for duty, and reasonable accommodation programs and policies.
• Protected classification characteristics such as veteran’s status, disability status, gender, and ethnicity to meet our employment law reporting obligations. Answering these questions is optional, and any Personal Data provided in response to these questions is voluntary and provided with your consent.
• Sensitive Personal Data such as legally protected information for internal company census and employee engagement surveys. We use this information to track the progress of company programs. Participation in these surveys is optional.

We collect this information with consent, and we disclose the purpose of collecting the Personal Data at the time it is collected.

     C. Employee online activity

ThriftBooks reserves the right to collect information related to your use of our information systems, networks, and devices, including any Personal Data contained in that information. We collect this information to achieve our legitimate interests of protecting ThriftBooks from risks associated with employees, contractors, and others using the internet in ways that may violate federal, state, or local laws or statutes, or put ThriftBooks at risk from the misuse of technology resources. We use this information to make decisions related to resource allocation and information technology management and to enforce company polices.

     4. How ThriftBooks Uses Employment Personal Data

Once collected, ThriftBooks will process the Personal Data as needed to consider your candidacy for a position, administer your employment, meet our legal obligations, offer fringe benefits, or for performance management or other business purposes.

Personal Data is entered into the software programs we use to manage and facilitate recruiting, human resources, payroll administration, expense reporting, healthcare and benefits administration, training, and project management. ThriftBooks uses this software to create and maintain records related to your employment.

ThriftBooks reserves the right to use your Personal Data in a deidentified form or in the aggregate to related to recruitment and employment metrics or generate internal reports about company employment, training, and employee engagement.

     5. Disclosures of Personal Data

ThriftBooks will only disclose employment-related Personal Data to trusted service providers as needed to perform their contractual obligations to us. For example, our benefits broker, health and dental plan carriers, retirement plan provider, and other employee benefits plan providers have access to employee information as necessary to provide ThriftBooks employee benefits. We also use credit reporting services and electronic verification platforms for candidate and employment verification purposes. ThriftBooks contractually limits service providers to only process Personal Data for specified purposes and in accordance with our instructions.

ThriftBooks does not sell employee Personal Data, nor do we allow our service providers to sell your Personal Data or use it for their own purposes. All ThriftBooks service providers are required to protect your Personal Data in alignment with our policies.

     6. Personal Data Retention

ThriftBooks will retain employee and contractor Personal Data on our information systems for the duration of your employment or contract with ThriftBooks and for a period of 6 years after your termination date. We retain job applicant Personal Data for 1 year following the close of the recruitment period of the role for which you applied. We reserve the right to retain your Personal Data for longer periods as necessary to comply with applicable law or a litigation hold. At the end of the retention period, we will securely destroy your Personal Data in accordance with ThriftBooks’s records retention and destruction policies.

     7. Data Security

ThriftBooks has implemented and maintains reasonable security measures to secure employment-related Personal Data from accidental loss and unauthorized access, use, alteration, and disclosure. Our security measures are appropriate to the volume, scope, and nature of the Personal Data processed and designed to meet our duty of care with respect to Personal Data. Please bear in mind that you are responsible for keeping access to your device and your login information confidential.

We have put in place procedures to respond to suspected security incidents. We will notify you and any applicable regulator of a suspected security incident as legally required.

     8. Applicable Laws

The laws and regulations that apply to your privacy in an employment context may vary amongst locations where ThriftBooks has operations or our employees, contractors, or applicants are located. It is ThriftBooks company policy to comply with all applicable laws, including requirements in certain states to give notice and, in some cases, obtain consent for certain collection or use of Personal Data. If the laws applicable to a given location are stricter than the practices described in this Notice, ThriftBooks will comply with the stricter standard where legally necessary.

     9. Your Privacy Rights

Privacy laws applicable in California, Colorado, Connecticut, Nevada, Utah, Virginia, and other states provide residents with specific rights to access and control their Personal Data in an employment context. This section gives you informational notice of the various rights that may be available by law and explains how you can exercise those rights to the extent they apply to you.

     A. Right to Correct. The right to correct allows you to request that we correct inaccurate Personal Data about you on our systems. If you become aware that the Personal Data that we hold about you is incorrect, or if your information changes, please inform us and we will update our records.

     B. Right to Deletion. You may request that we delete your Personal Data that we have collected and retained, with certain exceptions. ThriftBooks may permanently delete, deidentify, or aggregate the Personal Data in response to a request for deletion.

     C. Right to Access. The right to access allows you to request confirmation that we have collected Personal Data about you and that we provide you with access to that Personal Data. If you submit an access request, we will provide you with copies of the requested pieces of Personal Data in a portable and usable format. Please note that we may be legally prohibited from disclosing certain Personal Data, and we there may be legal limits to the number or frequency of requests we must fulfill.

     D. Right to Disclosure. Some privacy laws provide the right to receive details about our collection and use of your Personal Data, such as: (a) the categories of Personal Data we have collected about you; (b) the categories of sources for the Personal Data we have collected about you; (c) our business purpose for collecting, using, processing, sharing or selling that Personal Data, as applicable; (d) the categories of third parties to whom we disclose that Personal Data; and (e) if we sold or shared your Personal Data under California law, two separate lists stating: (i) sales or sharing, identifying the Personal Data categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained. Certain laws may limit the number or frequency of requests that we must fulfill.

     E. No Selling or Sharing. Some states entitle individuals to opt-out of the sale or sharing of Personal Data or targeted advertising practices. ThriftBooks does not sell Personal Data or share Personal Data with third parties for cross-contextual behavioral advertising purposes. If this changes in the future, we will update this Privacy Policy and provide a method to opt-out.

     F. Limited Use and Disclosure of Sensitive Personal Data. You may have the right to opt-out or limit our use of your sensitive information. Note that we do not disclose any sensitive information collected in an employment context for the purpose of inferring characteristics or otherwise use sensitive information without consent. If this changes in the future, we will provide methods to opt-out or limit our use and disclosure of sensitive Personal Data.

     G. No Profiling. Some state laws entitle individuals the right to opt-out of automated profiling. We do not process your employment-related Personal Data to evaluate, analyze, or predict your interests and preferences or otherwise use automated profiling to produce significant effects that concern you. If this changes in the future, we will provide you with a method to opt-out.

     H. Right to Nondiscrimination. ThriftBooks will not discriminate against you for exercising your legally available privacy rights. For example, unless permitted by law we will not: (a) deny you goods or services; (b) charge you different prices or rates for goods or services; (c) provide you a different level or quality of goods or services; (d) retaliate against you as an employee, job applicant, or contractor for exercising your privacy rights; or (e) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under applicable privacy laws.

     I. Right to Disclosure of Marketing Information. California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California residents to request certain disclosures regarding Personal Data sharing with affiliates and/or third parties for marketing purposes.

Some of these laws may not apply to you or your interactions with ThriftBooks, in which case these notices are offered as a courtesy only.

     10. Privacy Requests

If you have questions about your job application, please visit our Careers page for guidance.

To exercise your privacy rights, please contact HR@ThriftBooks.com. Only you or someone legally authorized to act on your behalf may make a verifiable Privacy Request related to your Personal Data. You may also make a verifiable privacy request on behalf of your dependent if they are a minor.

Please note that we can only assist with or fulfill a privacy request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Data, and to properly understand, evaluate, and respond to the request. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We endeavor to respond to privacy requests in accordance with the requirements of the law applicable to your jurisdiction.

If you want to express concerns, revoke your consent, lodge a complaint, or request information, or if we do not fulfill your request within the legally required timeline, you can appeal our response by contacting Human Resources.