Effective Date: October 18, 2024

1. Introduction

This Privacy Policy describes how Sellers International LLC (“Quimbee,” “we,” “our,” or “us”) collects, uses, discloses, and otherwise processes the personal information of job applicants in compliance with the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), and other applicable laws and regulations. “Personal information” is information that is linked or is reasonably linkable to you and includes “personal data” as defined in applicable privacy law. 

By applying for any job with Quimbee, you represent and warrant that you have read and understood this Job Applicant Privacy Policy and agree to it.

Please read this Job Applicant Privacy Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. If you do not agree with our policies and practices, you may choose not to apply for any job with Quimbee. By submitting your application for any role at Quimbee, you affirm that you have read, understood, and agreed to this Job Applicant Privacy Policy.

This Job Applicant Privacy Policy may change from time to time. We will indicate the date of the last update by changing the “Effective Date” date at the top of this Job Applicant Privacy Policy. You agree to keep abreast of these changes. Your application for any role at Quimbee after we make changes is deemed to be acceptance of those changes.

Please note that this privacy policy is specific to job candidates. If you are a Quimbee website user or subscriber, please see our general Privacy Policy and Terms of Service.

2. Personal Information Collection

We and our vendors may collect the following types of personal information through our Services:

• Identifiers, such as: first and last name, postal address, unique personal identifier, online identifier, IP address, email address.

• Personal Records, such as: telephone number, education (law school), employment, employment history and disciplinary action, professional memberships, employee reference checks, credit card number, debit card number, or any other financial information.

• Protected Classification Characteristics Under State or Federal Law, such as: age, nationality, racial or ethnic origin, marital status, sex (including gender, gender identity, gender expression), sexual orientation, disability status (if voluntarily disclosed). Please note that Quimbee does not actively solicit this information, but it may be shared as part of your application package.

• Internet or Other Similar Network Activity, such as: browsing history, search history, information on a consumer's interaction with a website, application logs, device data and registration, social media account information or advertisement.

• Geolocation Data, such as: your physical location based on information you provide directly or inferred from your IP address.

• Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information, such as: audio data collected when you call our customer service numbers.

• Professional or Employment-Related Information, such as: current or past job history or performance evaluations; resume or curriculum vitae (CV); disciplinary action, professional memberships, employee reference checks, employment history; education history; references; certifications and licenses; and trade union membership.

• Inferences drawn from other personal information, such as: profile reflecting a consumer’s preferences, behavior, and attitudes.

• Other information, such as background check results (once an offer has been made and you authorize us to perform a background check); interview notes; work authorization status; and the like.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you or your agents.

• Indirectly from you or your agents. For example, through information shared with us by your recruiting service or agency.

• Directly and indirectly from activity on our Services. For example, from website usage details that are collected automatically. 

• From our vendors, partners, and third parties that assist us in providing certain transactions and services.
  

3. Personal Information Use

We may use the personal information we collect about you through the application process for various purposes, including but not limited to:

• Recruitment and hiring, such as assessing your qualifications for employment, determining whether you meet the job requirements for a particular role, scheduling and conducting interviews, making hiring decisions, verifying information you provide, conducting background checks (once an offer is made and permission is granted), and the like.

• Communication and scheduling, such as contacting you about your application status, administering skills tests, arranging and scheduling interviews, reaching out about additional roles you may be a fit for, seeking permission for a background check (once an offer is made) etc.

• Compliance, including abiding by all applicable laws and regulations.

• Process improvement, such as analyzing our recruitment process, improving key metrics like time to hire and number of qualified candidates, and the like.
  

4. Personal Information Disclosure

We may disclose your personal information for any purposes not inconsistent with this Job Applicant Privacy Policy, our written statements at the point of collection, or applicable law. In general, we share personal information as follows:

• Disclosure in Connection with the Recruiting and Hiring. Quimbee discloses personal information to those who help us recruit and hire, including without limitation those who perform technical, administrative, and data-processing tasks such as hosting, billing, fulfillment, data storage, and security, as well as those who create or administer skills tests or similar hiring assessments or those who arrange or schedule interviews.

• By Law or to Protect Rights. Quimbee discloses personal information when required to do so by law, in response to a subpoena or court order, or when Quimbee believes in its sole discretion that disclosure is reasonably necessary to protect the property or rights of Quimbee, third parties, or the public.

• Business Transfers; Bankruptcy. Quimbee reserves the right to transfer all personal information in its possession to a successor organization in the event of a merger, acquisition, or bankruptcy or other sale of all or a portion of Quimbee’s assets.
  

5. Security of Personal Information

Quimbee maintains commercially reasonable administrative, technical and physical safeguards designed to protect your personal information from accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. 

Although we take reasonable steps designed to protect your personal information, please be advised that no security system or means of transmitting data over the internet can be guaranteed to be entirely secure. We cannot and do not guarantee or warrant the security of your personal information or any information you disclose or transmit to us. 

For your own privacy protection, we urge you to keep all passwords confidential. We also recommend that you do not include sensitive information such as passwords, social security numbers, or payment information, in any emails that you send to us.

6. Third Party Websites and Other Features

a. Third Party Websites

Quimbee's website and job applicant portal may contain links to third party websites for your convenience. Quimbee neither owns nor controls such third party websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Before visiting or providing personal information to third party websites, you should inform yourself of their privacy policies and practices.

b. Other Features

Interactive Features. We may engage vendors to provide certain interactive features on our job applicant portal. Your use of these interactive features is voluntary, and we may retain the personal information that you submit through these features. For example, we may offer an interactive chat feature to answer questions and for other recruiting and hiring purposes. When you participate in the interactive chat, either with a virtual or live agent, the contents of the chat may be captured and kept as a transcript. By using these features, you understand that our vendors may process the personal information obtained through the feature to provide the service on our behalf.

Third Party Features. Certain functionalities on the Services permit interactions that you initiate between the Services and certain third party Services, such as social networks (“Third Party Features”). Examples of Third Party Features include applying for a job using your third party account. If you use Third Party Features, information you post or provide access to may be publicly displayed by the third party services that you use. Similarly, if you post information on a third party service that references Quimbee, your post may be used on or in connection with recruiting and hiring. Both Quimbee and the third party may have access to certain information about you and your use of Quimbee and any third party service.

7. Storage and Transfer of Personal Information

We may, directly or indirectly through third party entities around the world, process, store, and transfer all of the personal information you provide, including your personal information, as described in this Job Applicant Privacy Policy. Specifically, the personal information that we collect from you may be transferred to, and stored in a country with laws which are different, and potentially not as protective, as the laws of your own country. In some of these countries, the privacy and data-protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. If you do not agree to the transfer, storage, and use of your personal information in the United States, and any other country where we operate, please do not use the job applicant portal.

By submitting your personal information and using the job applicant portal, you acknowledge this transfer, storing, or processing.

8. Children’s Privacy.

Quimbee does not solicit or knowingly collect personal information from children under the age of 16. If Quimbee becomes aware that we have received personal information from a child under the age of 16, Quimbee will use reasonable efforts to remove that personal information from its database.

9. Additional Notices for California Residents

This section applies to California residents and supplements our Privacy Policy. Unless otherwise noted, this section covers our activities in the 12 months prior to the Privacy Policy’s effective date as well as our current practices.

a. Personal Information We Collect

We may obtain the personal information listed in the “Personal Information Collection ” section from California residents through the job applicant portal and in other contexts, including offline.

b. Privacy Rights

Under the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (CPRA), California residents have specific rights regarding their personal information. This section describes Californians’ rights and explains how California residents can exercise those rights.

Below we outline specific rights which California residents may have under the CCPA and CPRA.

Right to Access Your Data. You have the right to know what personal information we have collected about you, which includes:

• The categories of personal information we have collected about you, including:

• The categories of sources from which the personal information was collected;

• Our business or commercial purposes for collecting, selling, sharing, or disclosing personal information;

• The categories of recipients to which we disclose personal information;

• The categories of personal information that we sold or shared, and for each category identified, the categories of third parties to which we sold or shared that particular category of personal information; and

• The categories of personal information that we disclosed for a business purpose, and for each category identified, the categories of recipients to whom we disclosed that particular category of personal information.

• The specific pieces of personal information we have collected about you.

Right to Delete Your Data. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Right to Correct Your Data. You have the right to request that we correct any personal information we maintain about you that you believe is inaccurate.

Right to Opt Out of Sales and Sharing of Personal Information. Quimbee does not sell or share job applicant personal information.

Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA. For this reason, we do not offer a way for you to submit such a request.

Rights Related to Automated Decision-Making. You have the right to opt out of automated decision-making, including profiling, that we use to evaluate certain personal aspects relating to your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

We will not discriminate against you for exercising your privacy rights conferred by the CCPA/CPRA.

c. Exercising Your Rights

If you are a California resident who chooses to exercise your rights, you can submit a request via email to [email protected]. Please note that if you submit a request to know, delete, or correct, you may be asked to log into your account or to verify your identity. You may also designate an agent to exercise your privacy rights on your behalf; however, you will still need to verify your identity with us before your request can be processed. 

d. California “Shine the Light” Law.

California Civil Code Section § 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for the third parties’ direct marketing purposes. If you are a California resident, then you may request information about our compliance with Shine the Light by contacting us using the contact information in the “How To Contact Us” section. Any such request must include “California Privacy Rights Request – Shine the Light” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per consumer each year, and we are not required to respond to requests made by means other than through this email address. 

 10. How to Contact Us

If you have any specific questions about this Privacy Policy, you can contact us via email at: [email protected].