California Applicant Privacy Notice

Last Updated: January 10, 2023

This California Applicant Privacy Notice (“Applicant Notice”) describes our information practices relating to applicants and candidates for employment with James R. Glidewell, Dental Ceramics, Inc. DBA Glidewell Laboratories, or our affiliates or subsidiaries (“Glidewell,” “we,” “our,” “us,” or the “Company”) who are California residents (each an “Applicant” or “you”). This Applicant Notice is intended to satisfy the requirements of the California Consumer Privacy Act (as amended by the California Privacy Rights Act of 2020) (collectively “CCPA”).

1. Scope and Relation to Other Policies

This Applicant Notice applies to the Personal Information we collect about our Applicants. This Policy supplements other agreements, including any Non-Disclosure Agreement(s), if applicable. This Applicant Notice applies to any information that identifies, relates to, describes, is reasonably capable of being associated, or could reasonably be linked, directly or indirectly, with you (subject to some exemptions under the CCPA) (“Personal Information”). Note, our information practices may vary depending upon the circumstances, such as the location or role for which you are applying.

This Applicant Notice does not address or apply to our information practices that are not subject to the CCPA, such as:

Business Information Company or business information that constitutes trade secrets, proprietary information, intellectual property, company property, information that includes or affects the rights of other employees, privileged or investigative materials, or information that helps ensure security and integrity of company assets.
Publicly Available Information. Information that is lawfully made available from government records, information we have a reasonable basis to believe is lawfully made available to the general public by you or by widely distributed media, or by a person to whom you have disclosed the information and not restricted it to a specific audience.
Deidentified Information. Information that is deidentified in accordance with applicable laws.
Aggregated Information. Information that relates to a group from which individual identities have been removed.
Protected Health Information. Information governed by the Health Insurance Portability and Accountability Act or California Confidentiality of Medical Information Act.
Activities Covered by the Fair Credit Reporting Act. This includes information we receive from consumer reporting agencies that are subject to the Fair Credit Reporting Act, e.g., information contained in background check reports we obtain as part of our vetting process.

This Notice also does not apply to the Personal Information we collect from our customers, contractors, employees, or our Applicants in the context of their personal use of our products and services, which are subject to different notices. For additional information on our general privacy practices, please visit our Online Privacy Policy.

We may provide Applicants additional notices about our information practices that are covered by other laws (e.g., if we conduct a background check).

2. Personal Information We Collect

The following identifies the categories and types of Personal Information we may collect about Applicants (and may have collected in the prior 12 months):

Identifiers. This includes name, alias, postal address, telephone number, signature, email address, or other similar identifiers.
Characteristics of Protected Classifications. This includes your date of birth, gender, race, or marital status, if you provide this information as part of your application.
Internet or Other Electric Network Activity Information. This includes browsing history, and search history, as well as applicants’ interactions with our portals, websites, applications, or advertisements.
Employment-Related Information. This includes employment history, qualifications, or any other related information. We will not request or collect your salary history information.
Education Information. This includes your educational history or background, or any other related information you provided.
Sensitive Personal Information. To the extent required by law and/or voluntarily provided by you, we may collect your social security number, driver’s license number, passport number, date of birth, racial or ethnic origin, medical condition, or physical or mental disability.
Inferences and Preferences. This includes inferences reflecting an Applicant’s preferences, characteristics, attitudes, behaviors, and abilities.

3. Where We Get Your Personal Information

We generally collect the categories of Personal Information identified above from the following categories of sources:

Directly from you;
Recruiters and recruiting platforms;
Publicly available information and sources;
Former employers (with your prior permission);
Our service providers, representatives, and agents; and
Any references you provide.

4. Why We Collect Personal Information

We generally collect Personal Information as reasonably necessary for the following business or commercial purposes, as permitted by applicable laws:

Recruiting and Hiring. We use Personal Information from your application and through the interview process to evaluate your qualifications and eligibility for employment. This includes identifying Applicants, scheduling interviews, conducting background checks, evaluating qualifications, extending offers, communicating with Applicants, maintaining Applicant information for future consideration, and supporting our equal opportunity employment practices.
Defending and Protecting Rights. We use Personal Information to protect and defend our rights and interests and those of third parties, including to manage and respond to Applicant and other legal disputes, to respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, including without limitation, Glidewell’s trade secrets and other intellectual property, and protecting the rights, property, and reputation of Glidewell and its workforce, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.
Compliance with Legal Obligations. We use Personal Information to comply with applicable legal obligations (such as determining hiring eligibility or responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, Social Security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions and guidance.
Use of Sensitive Personal Information. Our collection, use, and disclosure of sensitive personal information is limited to what is reasonable and proportionate to employ you for example, complying with our legal, regulatory and reporting obligations.
Securing Our Premises. We also may use Personal Information to secure our offices, premises, and physical assets, including using electronic access systems if Applicants visit a Glidewell location for interviews and screening.

5. Disclosure of Personal Information

A. Purposes for Disclosing Personal Information

We may disclose the categories of Personal Information identified in Section 2 for the following business purposes.

Evaluate Candidacy. We may disclose Personal Information when it is necessary to provide services you request and where it is necessary to identify Applicants, schedule interviews, and otherwise evaluate your qualifications and eligibility for employment.
Protection of Us and Others. We may disclose Personal Information if required to do so by law, to protect rights, property, or safety of our employees, contractors, owners, members, and guests, ourselves or others; or where we have a legitimate interest in doing so.

B. Categories of Recipients

We may disclose Personal Information to the following categories of recipients:

Affiliates and Business Partners. We may disclose Personal Information to our affiliates and business partners where necessary to evaluate your candidacy for employment or for business operations purposes.
Service Providers. We may disclose Personal Information to our service providers who perform services on our behalf, such as recruiters or recruitment platform providers. Our service providers are required to take appropriate security measures to protect your Personal Information in line with our policies and are not permitted to use Personal Information for their own purposes.
Government Entities and Agencies. To comply with our legal obligations and where otherwise required by law, we may disclose the following categories of Personal Information to applicable regulatory and government entities: identifiers, characteristics of a protected classifications, and employment-related information.
Third-Party Websites. If you apply for a job with Glidewell through LinkedIn or another third-party website, these websites may collect your Personal Information. These third-party websites may also send their own cookies and other tracking devices to you, log your IP address, otherwise collect data regarding your use of the Website, or solicit Personal Information from you. Please be aware that this Policy does not apply to those websites. Glidewell does not control and is not responsible for what third parties do in connection with their websites or how they handle your Personal Information. Please exercise caution and consult the privacy policies posted on each third-party website for further information.

6. How Long We Retain Personal Information

We store your Personal Information for as long as needed, or permitted, based on the reason we obtained it (consistent with applicable law). When deciding how long to keep your Personal Information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period of time before we can delete them) or whether we have taken any legal positions that require data retention (e.g., issued any legal holds or otherwise need to preserve data). From time to time, we may also deidentify your Personal Information, retain it and use it for a business purpose in compliance with CCPA.

7. Your California Privacy Rights

A. Applicant Privacy Rights

If you are a resident of California, starting January 1, 2023, you may have additional rights regarding your Personal Information under the CCPA. These rights include:

Right to Know/Access. You have the right to request (subject to certain exemptions):
- The categories of Personal Information we collected about you;
- The sources from which we have collected that Personal Information;
- Our business or commercial purpose for collecting, selling, or sharing that Personal Information;
- The categories of third parties to whom we have disclosed that Personal Information; and
- A copy of the specific pieces of Personal Information we have collected, to the extent sourcing these specific pieces of Personal Information does not involve disproportionate effort.
Right to Correct. You have the right to request that we correct inaccuracies in your Personal Information. Applicants seeking to update their information may do so at any time by using our recruitment platform.
Right to Delete. Subject to certain exceptions, you have the right to request deletion of Personal Information we have collected from you. Please note, Glidewell is not obligated to delete Personal Information that is required to comply with applicable laws.
Right to Opt-Out. Under the CCPA, California residents may have the right to opt-out of the “sale,” or “sharing,” of Personal Information. California CCPA defines a "sale" as disclosing or making available to a third-party Personal Information in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available Personal Information to a third party for purposes of cross-context behavioral advertising. While we do not disclose Personal Information to third parties in exchange for monetary compensation, if you apply to an open position on our website, we may “sell” or “share” (as defined by the CCPA) Identifiers and Internet or Other Electric Network Activity Information to third-party advertising networks, analytics providers, and social networks for purposes of marketing and advertising. We do not sell or share sensitive personal information, nor do we sell or share any Personal Information about individuals who we know are under sixteen (16) years old. To opt out from the sharing or sale of Personal Information, please click on the “Do Not Sell or Share My Personal Information” link on the bottom of the website homepage. We do not use or disclose Applicant Sensitive Personal Information for purposes except as described herein (and as permitted pursuant to Cal. Code Regs. tit. 11, § 7027(l) (2022)).
Right to Limit Use and Disclosure. Subject to certain conditions and exceptions, you may have the right to limit the use and disclosure of “Sensitive Personal Information,” as defined under the CPRA. However, we do not engage in activities triggering this right.
Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.

B. Exercising Your California Privacy Rights

To exercise any of these CCPA rights, please use one of the following methods:

Submit a data privacy request online.
Phone: 1-888-530-1066

Please indicate you are exercising your “CCPA rights” as an applicant of Glidewell. Glidewell will need to confirm your identity before fulfilling the request, so please provide us with your full name, the email address you used to communicate with us, your address, and any applicant number you were assigned]. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

You may designate someone to submit requests and act on your behalf (an “Authorized Agent”). To do so, the Authorized Agent must submit a data privacy request using this form and provide us with written consent signed by you to act on your behalf. We may also ask you directly to verify that you have authorized your authorized agent to act on your behalf.

8. Contact Us

If you have questions or concerns regarding your information or your rights, please contact us at 1-888-530-1066 or submit a data privacy request online.