Clair Global

Privacy Notice for
California Job Residents

Clair Global Privacy Notice for California Resident Job Applicants

‍Effective Date: November 1, 2026

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Under the California Privacy Rights Act (“CCPA”), Clair Global Corporation and its subsidiaries and corporate affiliates (collectively, “Clair Global”, “we”, or “us”) is required to notify you that we collect certain personal information in connection with your application for employment.  In particular, we collect, use and disclose the following categories of personal information regarding job applicants:

Category Description Disclosed for a Business Purpose? Categories of Third Parties to whom the Personal Information is Disclosed
Identifiers Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, social security, driver’s license, state identification card, or passport number or other similar identifiers Yes
  • Third-party service providers who perform services on the Clair Global’s behalf including, but not limited to, those who help manage the recruitment and onboarding process, provide applicant tracking systems and recruiting software, conduct background checks and provide data storage or hosting services
  • Other members of our group of companies
  • Government agencies or law enforcement to comply with legal obligations or valid legal processes such as search warrants, subpoenas or court orders and to protect our rights and property or protect the rights, property or safety of others
  • Buyers/acquirors in the event of a corporate transaction, including but not limited to a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy
Categories listed in the California Customer Records statute Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history Yes
Protected classification characteristics under California or federal law Characteristics of protected classifications under California or federal law (race, color, national origin, religion, gender (including pregnancy), disability, age (at least 40 years old), citizenship status, sexual orientation, gender identity and gender expression) Yes
Internet or similar network activity Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding interaction with an internet web site used to submit an application Yes
Professional or employment-related information Professional or employment-related information, including employment status, employment history and relevant certifications Yes
Education Information Education information, including degrees held and educational institutions attended Yes

We collect, use and disclose the followingcategories of sensitive personal information regarding job applicants:

Categories of Sensitive Personal Information Collected Disclosed for a Business Purpose? Categories of Third Parties to whom the Sensitive Personal Information is Disclosed
Personal information that reveals social security, driver’s license, state identification card, or passport number Yes
  • Third-party service providers who perform services on the Clair Global’s behalf including, but not limited to, those who help manage the recruitment and onboarding process, provide applicant tracking systems and recruiting software, conduct background checks and provide data storage or hosting services
  • Other members of our group of companies
  • Government agencies or law enforcement to comply with legal obligations or valid legal processes such as search warrants, subpoenas or court orders and to protect our rights and property or protect the rights, property or safety of others
  • Buyers/acquirors in the event of a corporate transaction, including but not limited to a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy
Personal information that reveals racial or ethnic origin, religious or philosophical beliefs or union membership Yes

Clair Global does not use or disclose the above sensitive personal information for any purpose other than those permitted under the CCPA.

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The personal information, including the sensitive personal information, described above are collected directly from you when you apply for employment or from other sources such as third parties for reference checks (e.g., past employers), recruitment agencies, background check agencies, public agencies (e.g., tax authorities, the California Department of Fair Employment and Housing, the California Labor Commissioner, the California Occupational Safety Administration, and if applicable to the position, the California Department of Motor Vehicles), and law enforcement agencies. With the limited exception of internet or other network activity that may be collected and shared with our third party website analytics and digital advertising service providers if you visit our websites, such information is not sold or shared as such terms are defined under the CCPA. See the Section of this privacy notice, below, entitled “CCPA Rights” for more information about how to opt-out of the sale or sharing of personal information. Clair Global does not have actual knowledge that it sells or shares such information of children under 18 years of age.

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We use the personal information, including the sensitive personal information, described above for business purposes related to your application for employment.

Those purposes may include:

  • To  evaluate an applicant’s qualifications and suitability for employment  
  • To  administer pre-employment and post-employment tests and training activity
  • To  complete the onboarding process
  • To  conduct criminal and other background checks on applicants and employees
  • To  prepare and maintain legally required records, such as I-9 forms, EEO-1 forms and affirmative action plans
  • To  ensure compliance with company policies and regulatory and legal requirements
  • To  detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity
  • To  achieve other operational purposes for which the personal information was collected that are compatible with the context in which the personal information was collected and our employment relationship

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We will retain the personal information, including sensitive personal information, described above as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.

 

CCPA Rights

 

As a California resident, you have the following rights under the CCPA:

 

Right to Know: You have theright to request that we disclose certain information to you about ourcollection and use of certain personal information, including sensitivepersonal information, about you as described below:

  • The specific pieces of personal information collected;
  • The categories of personal information collected;
  • The categories of sources from whom the personal information is collected;
  • The purpose for collecting, selling or sharing the personal information;
  • The categories of third parties with whom we have disclosed the personal information;
  • The categories of personal information that we have sold or shared, and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each third party to whom the personal information was sold or shared;
  • The categories of personal information that we disclosed for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

 

Right to Delete: You have the right to request that we delete your personal information, subject to certain exceptions.

 

Right to Correct Inaccurate Personal Information: You have the right to request that we correct inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

 

Right to Opt-Out of Sale or Sharing: Clair Global does not sell personal information to third parties for monetary consideration. However, certain sharing of information with our third-party analytics and digital advertising vendors may qualify as a “sale” and is considered “sharing” under the CCPA. This data collection is not directly related to your relationship to Clair Global as an applicant but may be collected from any user of our websites generally. To opt-out of certain sharing of information with our third-party analytics and digital advertising service providers, you may set your preferences to reject analytics and advertising cookies by visiting our cookie preference center.

 

Right to Limit the Use and Disclosure of Sensitive Personal Information for Certain Purposes: As stated above, we do not use or disclose your sensitive personal information for any purpose other than those permitted under the CCPA.

 

Freedom from Discrimination: You have the right not to receive discriminatory treatment for exercising your rights above, including not to be retaliated against for exercising such rights.

 

To exercise the rights above, you must submit a verifiable request to us by calling us at (717) 626-4000 or submitting a request via email to hr@clairglobal.com. To submit a verifiable request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the personal data that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors.

 

You may designate an authorized agent to make a request on your behalf by providing the agent with signed written permission to do so.

 

If you have any questions regarding the information contained in this notice, please contact hr@clairglobal.com.

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