CCPA Notice for Employees and Job Applicants at BuzzRx

Last Revised Date: January 1, 2023

California law requires that We provide you this notice about the collection and use of your personal information. We encourage you to read it carefully. Upon request, this notice can be made available in alternative formats, such as large print or audio. Please contact privacy@buzzrx.com and an alternative format will be provided to you so you can access the information in this notice.

Click here to opt out of selling or sharing your Personal Information. Click here to make other data rights requests.

1. Introduction

This notice (“Notice”) describes the categories of personal information that Water Tree Ventures LLC, d/b/a BuzzRx (“BuzzRx”, “We”, “Us” and “Our”) collects about California residents who work for BuzzRx (“Employees”) or apply for a job at BuzzRx (“Job Applicants”), and the purposes for which We use that information.

For purposes of this Notice, “personal information” has the meaning set forth in the California Consumer Privacy Act of 2018, including all amendments thereto (the “CCPA”).

This Notice does not create or form part of any contract for employment or otherwise.

If you have questions about this Notice, please contact Our Legal Department:

Email: privacy@buzzrx.com

BuzzRx
Attn: Data Privacy
1 E Broward Blvd., Suite 205W
Ft. Lauderdale, FL 33301

2. Information We collect about Job Applicants and Employees

2.1.1 Categories of Personal Information of Job Applicants

The categories of personal information We may collect and process during the application and recruitment process include:

- Contact information, such as home address, telephone number, and email address;
- Information from job application materials or recruiters, such as your job application, resume or CV, cover letter, references, education history, work history, whether you are subject to prior employer obligations, and information that referrers provide about you;
- Professional qualifications, such as licenses, permits, memberships, and certifications;
- Information from the application process, such as any phone-screens, interviews, evaluations and outcomes of take home tests and other recruiting exercises;
- Immigration status and other information that would allow Us to verify your employment eligibility;
- Biographical information, such as name, gender, date of birth, professional history, references, language proficiencies, education details, and information you make publicly available through job search or career networking sites;
- Job preferences, such as desired position and compensation, location preferences and willingness to relocate;
- Employment history;
- Background check information, such as information necessary to complete background, credit, and/or other checks when permitted by law, and information received during these checks;
- Information needed to understand and assess accommodation requests regarding potential disabilities or other health conditions; and
- Other information you provide to Us.

Providing personal information to Us is voluntary. However, if you do not provide sufficient information, We may be unable to consider your application or, if you are hired, your subsequent promotion, transfer or relocation.

In certain cases We may ask you for additional information for purposes of complying with applicable laws. We may also inquire about criminal records. We will do so only where permitted by applicable law.

2.1.2 Categories of Personal Information of Employees

The categories of personal information We may collect and process during the course of your employment with Us include:

- Gender, marital status, military or veteran status,
- Sensitive personal information, including, but not limited to: social security number, race, ethnicity, and health and medical information.
- All other information described in Section 2.1.1 above.

2.2 Sources of Personal Information

We collect personal information from you when you apply for a job, throughout the job application or recruitment process, and when you are employed by Us. We may also collect your personal information from other sources and combine it with the personal information you provide Us. For example, We may collect your personal information from:

- Job board websites you may use to apply for a job with Us;
- Prior employers that provide Us with employment references;
- Professional references that you authorize Us to contact;
- Pre-employment screening services, such as background check providers (where permitted by law);
- Employment agencies and recruiters;
- Your educational institutions;
- Your public social media profile or other publicly-available sources;
- Online activity information that We and Our service providers collect using server logs, “cookies” and similar technologies on any careers sites. Please see Our Privacy Policy for more information.
- Other BuzzRx personnel.

3. How We use Personal Information about Job Applicants and Employees

3.1 Purposes for which We Use Personal Information

We may use the categories of personal information above for the following purposes:

- To administer employment benefits, establish work authorization, manage payroll, and report tax information.
- Managing recruitment generally, such as:
  - operating the careers section of Our Website;
  - recruiting, interviewing and evaluating Job Applicants;
  - conducting background checks and other pre-employment screening (where permitted by law);
  - analyzing and improving Our Website, App and recruitment processes;
  - accommodating disabilities or health conditions; and
  - communicating with you regarding your candidacy, or opportunities with BuzzRx.
- Compliance, safety and fraud prevention, such as:
  - complying with or monitoring compliance with legal and other requirements, such as reporting and equal opportunities monitoring requirements, where applicable;
  - complying with internal policies and procedures;
  - complying with lawful requests and legal process, such as responding to subpoenas or requests from government authorities;
  - protecting Our, your or others’ rights, safety and property;
  - investigating and deterring against fraudulent, harmful, unauthorized, unethical or illegal activity, or conduct in violation of Our policies or procedures; and
  - sharing information with government authorities, law enforcement, courts or private parties where We have a good-faith belief it is necessary for the foregoing purposes.
- For Analytics Purposes. Creating anonymous, aggregated or de-identified data that We use and share to analyze Our Website, employment and recruitment activities, business and for other lawful business purposes.

3.2 Sharing Personal Information

We may share your personal information with third parties as necessary for the purposes described above. For example, We may share your personal information with:

- Affiliates: Our corporate parent, subsidiaries, and other affiliates under the control of Our corporate parent, for purposes consistent with this Notice or to operate shared infrastructure, systems and technology.
- BuzzRx’s service providers: Companies that provide Us with services that help Us manage the recruiting process and operate Our business, such as job boards, recruiters, interviewing and testing, pre-employment screening, interview travel booking and expense reimbursement (where applicable), relocation (where applicable), payroll processors, insurance companies and other employment benefit administrators.
- Government authorities, law enforcement and others: Government authorities, law enforcement, courts, and others as described in the compliance, safety and fraud prevention section above.
- Business transfers: Parties to transactions and potential transactions whereby We sell, transfer or otherwise share some or all of Our business or assets, including your personal information, such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
- Professional advisors: Lawyers, immigration advisors, HR and other employment benefit consultants and other outside professional advisors.
- Customers and business partners: Customers, other companies and individuals with whom BuzzRx does business or is exploring a business relationship.

4. Your Right to Access, Delete, Correct, or Port the Personal
Information We Collect about You

As a California resident, you are entitled to the rights described in the State Consumer Data Privacy Policy Addendum. For a full description of your rights, please visit the State Consumer Data Privacy Policy Addendum

5. How Long We Will Retain Your Personal Information

We will retain your personal information for the period of time that is required to comply with federal, state or local laws. We may retain employee personal information for a longer period of time to comply with Internal Revenue Service tax reporting requirements.

6. Other information about this Notice

6.1 Third Parties

This Notice does not address, and We are not responsible for, the practices of any third parties, which have their own rules for how they collect and use your personal information. Our links to third party websites or services are not endorsements.

6.2 Changes to this Notice

We reserve the right to change this Notice at any time. The “Last Revised Date” heading at the top of this Notice indicates when it was last revised. Any changes will become effective when We post the revised notice on Our Website.

7. Your Obligations

Among other obligations, including without limitation the obligation to provide complete and accurate information in recruiting documents and processes, it is your responsibility to ensure that information you submit does not violate any third party’s rights.

You should keep your personal information on file with BuzzRx up to date and inform Us of any significant changes to it.