Job Applicant and Website Privacy Notice and Policy

Job Applicant and Website Privacy Notice and Policy

1. Scope of this Policy

2. What Personal Information Do We Collect and How Do We Collect It?

  • Information You Voluntarily Give Us

  • Information Collected Automatically

  • Information We Create or Generate

  • Information Obtained from Third Parties

3. How Do We Use the Personal Information We Collect?

  • Evaluate Your Application

  • Background Checks

  • Personalization

  • Improve Our Site and Do Analysis

  • General Operations and Administration

  • Aggregate or De-Identify Personal Information

4. To Whom do We Disclose the Personal Information We Collect?

  • Our Affiliates

  • Our Service Providers

  • Other Third Parties

5. What Rights and Choices Do You Have Regarding Your Personal Information?

6. Third-Party Websites and Services

7. How Do We Protect Your Personal Information?

8. How Long do We Retain Your Personal Information?

9. Collection of Personal Information of Children

10. Changes

11. Contact Us

Scope of this Policy

Please read this privacy notice and policy (“Policy”) carefully to understand our policies and practices regarding your personal information. This Policy applies to individuals who interact with BlueTriton Brands, Inc. (“BlueTriton”, “We”, Us”) through our BlueTriton Careers site and/or apply for a position with Us. It also tells you how you can access and update your personal information, exercise certain rights, and make certain choices about how your personal information is used. 

Please note that We might combine personal information from different sources (website, offline event), including by combining personal information that were originally collected by different BlueTriton entities or BlueTriton partners. We also may combine data from third parties with data We already have. 

This Privacy Notice does not form or constitute an offer of or any part of any contract of employment or other contract to provide services, nor does it imply or create any employment relationship, contract of employment, relationship to provide services, or contract to provide services.

What Personal Information Do We Collect?

"personal information" is generally considered any information that can identify you or that relates specifically to you. The personal information that We collect about you through this site and your related interactions with Us are provided below.

Information You Give Us 

When you interact with Us or the site or as part of the application process, you may provide certain personal information to Us, including:

  • Identifiers, including certain data defined as personal information under the California Customer Records statute or as a protected classifications under California or federal law. This data includes:

    • Identification, Personal History and Contact Data. Any data that specifically identifies you or allows us to contact you, such as your first name, middle name or initial, last name, nickname or alias, social security number, government-issued ID, postal address, e-mail address, social media network details, signature, education history, employment information, medical history or information, or phone number.

    • Account Login Data.  Any data that is required to give you access to your specific account profile. Examples include your login ID/email address, screen name, password, and/or security question and answer.

  • Demographic Data.  Any data that describes or identifies your demographic or behavioral characteristics, including your date of birth, age or age range, gender, gender identity, or geographic location.

  • Professional, Education and Employment-Related Information.  Employment history and information regarding your work performance provided by references; education information, such as schools attended, degrees, GPA; references; attendance records; and information relating to any suspected disciplinary matter.

  • Audio, Electronic, Visual and Similar Information. Any content that you create and share with Us on third-party social media networks or the site. Examples include photos, videos, personal stories, or other similar media or content. We may also record and collect information from you during conversations with Customer Service. 

  • Sensitive Personal Information. Certain personal information that you provide might also be considered sensitive personal information under certain laws, including governmental IDs, social security number, account log-in information, medical and health information, disability information, sexual orientation, ethnic origin, financial account information, precise geolocation data, and certain demographic information. 

Information Collected Automatically

When you interact with Us or the site, certain information is automatically collected by the systems We use, including:

  • Data from Your Computer/Mobile Device/Browser. Data about the computer or device that you use to access the site, such as the Internet protocol (IP) address, and device and browser type, as well as other online identifiers. If you access the site via a mobile device such as a smartphone, the collected data will also include, where permitted, your phone’s unique device ID, advertising ID, and other similar mobile device data.

  • Internet or Other Similar Network Activity. As you navigate through and interact with the site or emails, We use automatic data collection technologies to collect certain data about your device(s) and your actions. This includes data such as which links you click on, which pages or content you view and for how long, and other similar data and statistics about your interactions, such as content response times, download errors, and length of visits to certain pages, as well as operating system type and web browser type and version. This data is captured using automated technologies such as cookies and web beacons and is also collected through the use of third-party tracking for analytics and advertising purposes (see Do Not Track/Opt-Out of Targeted Advertising").

  • Audio, Electronic, Visual and Similar Information. We may visually record your interactions with the site, including your mouse clicks, movement, scrolling, and navigation through the site, including through the creation of heat maps. 

  • Geolocation Data. Our systems record IP addresses, and that often provides your general location.

Information We Create or Generate

We may use certain personal information we collect to create or generate other information, including:

  • Inferences. We may draw inferences from the data We collect from and about you to create a profile reflecting your preferences, characteristics, and behavior, including assessments and interview notes. We may also obtain inferences from background and employment verification providers. We use this data for personalization and other employment and operational purposes, including to help evaluate attitudes, abilities and aptitudes.

Information Obtained from Third Parties

We get personal information about you from other sources, including our affiliates and business partners. We may obtain data from companies who compile information about individuals and job applicants, and we may also get information from parties who we use for verification and fraud prevention. Social media platforms may also give Us data about you. We may get data about your interactions with our ads on third-party sites.  The information that we obtain from third parties may be in any of the above categories.

How Do We Use the Personal Information We Collect?

Evaluate Your Application 

As part of our review and evaluation of your application, We may use any or all of the categories of information that we collect. This includes assessing your qualifications and/or capability for a particular job, role, or task; processing background checks and drug screening where appropriate; analyzing and supporting our belonging initiatives; and complying with applicable labor or employment laws or obligations, our commitment to equal opportunities, and complying with applicable local, state, or federal law.

Background Checks

As part of our application process, We may have third parties conduct background checks and We, or parties contracted by Us, may contact the references that you provide or otherwise verify the information that you provided.

If We learn (from any source) that you have been convicted of a criminal offense, We will process that information only in limited circumstances (see the "Disclosure Regarding Background Investigation " or similar document provided to you separately after an offer, if any, is made) For example, we may use it as permitted by applicable law in certain employment decisions in situations when it is job-related and consistent with business necessity to do so. 

Personalization 

We may use certain personal information, including Identification, Account, Demographic Data, Data From Your Device, Electronic and Similar Information, Internet Activity, Geolocation Data and Inferences  to (i) analyze your use of the site and preferences , (ii) anticipate your needs based on our analysis of your profile, (iii) improve and personalize your experience with the site, (iv) ensure that content from the site is optimized for you and for your computer or device, (v) provide you with targeted content, and (vi) allow you to participate with certain  features, when you choose to do so. For example, We remember your login ID/email address or screen name so that you can quickly login the next time you visit the site you may be able to pick up where you left off. 

Improve Our Site and Do Analysis

We constantly strive to improve our offerings, and in order to do so, We analyze interactions with the site and user behavior.  The information we use to do this may include any or all of the categories of information that we collect.

The models we use to analyze this information include the range of tools available to us from spreadsheets and databases to algorithmic models, and technologies like artificial intelligence and machine learning. 

General Operations and Administration 

In accordance with applicable laws, We use your personal information for other general business purposes, such as maintaining your account, conducting audits, financial calculations and tax reporting, administering our business and operations, evaluating performance, evaluating and maintaining our systems, security and fraud prevention and monitoring.  When and as appropriate, We may also use personal information to exercise Our legal rights or perform our obligations under applicable laws.  The information we use to do this may include any or all of the categories of information that we collect.

Aggregate or De-Identify Personal Information 

We may also use certain information that we have de-identified or aggregated (as defined under applicable law) with other information so that it can no longer identify, or be associated with, you.  Under applicable law, this information is no longer personal information, and we can use and disclose the information for any purposes, unless prohibited by applicable law.  The information we use to do this may include any or all of the categories of information that we collect.

To Whom do We Disclose the Personal Information We Collect?

Our Affiliates

We may provide your personal information to our affiliates who process that information for the delivery of our services, provision of the site, or for our business purposes as described in this Policy. 

Our Service Providers 

We disclose your personal information to service providers who We engage to help Us run our business (e.g., application management/onboarding, fraud detection and identity verification, information technology and computing support, operations, and similar activities). For the purposes of fraud prevention, we may share your personal information with Forter, Inc., our third-party provider of fraud screening services; please see Forter's privacy policy.

Other Third Parties

We may also disclose personal information to certain other parties, including:

  • Background check service providers.

  • Other parties in connection with a corporate transaction, including a merger, acquisition, restructuring, or bankruptcy. Personal information may be disclosed in the context of due diligence relating to the transaction and/or to the successors to Our business or the applicable parts of it.

  • To law enforcement, governmental authorities or third parties when and as required by law; in response to legal proceedings; in response to a required from law enforcement; to protect Our rights, security, safety, or property, or those of other parties or the public; to enforce the terms of any agreement, including the terms of the site.

What Rights and Choices Do You Have Regarding Your Personal Information?

You may have certain rights with respect to your personal information under various privacy and data protection laws. The rights that you may have under your state law (or that we might determine to provide to you, even if not required under your applicable state law), and the process to exercise those rights, are as follows:

Notice at Collection

At or before the time of collection of your personal information, you may have a right to notice of our privacy practices, as provided above in this Policy, including the categories of personal information and sensitive information that we collect, the purposes for which We collect and use that information, how long the information is retained, and whether that information is sold or shared.

Right to Know/Access

If applicable, this allows you to request that we tell you certain of the information we have collected, used, sold, or shared about you, as well as categories of personal information or categories of sources from which your personal information was collected, the purposes for which Personal Information was collected, and/or the specific pieces of personal information collected about you during a particular time period, as defined under appliable law.  You may also have a right to request a transportable copy of certain personal information.

Right of Correction

You may have the right request the correction of any incomplete or inaccurate personal information that we hold about you. 

Right of Deletion (Erasure)

When applicable, this enables you to ask us to delete all or certain elements of your personal information where there is no valid business reason for us to continue to process it or where we are required to erase your personal information to comply with applicable law. Note, however, that there are exceptions to this right, and we may not always be able to comply with your request of erasure for specific reasons which will be notified to you, if applicable, once we review and process your request. In addition, once deleted from our active systems, certain information may remain in our archiving or backup systems until deleted in accordance with our standard practices.

Do Not Track/Opt-Out of Targeted Advertising

The site uses several common tracking tools. These may include browser cookies, web beacons, flash cookies, and similar technologies. Service providers also use these tools on the site. and elsewhere on our behalf.  We also share information about your use of the site with our social media, advertising and analytics partners. 

If the site detects a Global Privacy Control (GPC) opt-out preference signal, it will generally recognize and honor it. Because there is no standard process to interpret other opt-out preference signals, the site may not recognize them. 

You may also disable or block cookies and certain other tracking technologies through certain software and browsers.  If you block or reject all cookies through your browser some of the functionality of the site may not work properly.

For more information on cookies and tracking technologies, and to control those uses, click on the Your Privacy Rights at the bottom of this page. 

Do Not Sell or Share My Personal Information

If you are a California resident, you have a right to opt-out from the “sale” or “sharing” (as those terms are defined under the California Consumer Privacy Act (CCPA)) of your personal information with third parties. To exercise this right, click on Your Privacy Rights here or at the bottom of the page, or in the "About" section in our app.

We do not knowingly “sell” or “share” the personal information of minors under 16 years old.

Right to Limit the Use and Disclosure of Sensitive Personal Information.

You may have a right to limit Our use of sensitive personal information for any purposes other than to provide the services (including processing your application) that you request or as otherwise permitted by law. To exercise this right, see "How to Exercise Your Rights".

“Shine the Light” Law Rights

Under the California “Shine the Light” law, California residents may opt out of Our sharing their personal information with certain parties for their direct marketing purposes. In order to exercise this right, see "How to Exercise Your Rights" and include the subject line “Shine the Light Opt-Out” in the subject line and your name and in the body of the message.

Non-Discrimination

We will not unlawfully discriminate nor retaliate against you for exercising the rights under this section. 

Authorized Agents

In certain instances, you may designate an authorized agent to exercise your rights under this section. The agent may submit the requests as in this section.  We have verification processes that we will need to follow, and as part of our verification process, we may request that the agent provide proof concerning their status as an authorized agent and that you verify your identity and confirm that you provided the agent permission to submit the request. 

Right to Appeal

Under the laws of certain jurisdictions, you have the right to appeal our decision not to act on your request to exercise certain of the rights described above.  To appeal our decision if you are in an eligible jurisdiction, please email us at:  dataprivacy@bluetriton.com the subject line "Individual Rights Request Appeal."

How to Exercise Your Rights 

To exercise most of these rights, or if you have any questions or concerns, you may submit this form with your request, or you may contact us at 844-887-3758 or at dataprivacy@bluetriton.com.  For any personal information that is automatically collected and is associated with your browser or device, you can exercise your rights through Your Privacy Rights at the bottom of this page. You are limited in the number of times that you can exercise specific rights in any 12-month period.

For verification purposes, we may request any or all of the following: your first and last name, account number, email address and any email address you may have used when registering with BlueTriton, phone number associated with your account, and a physical mailing/delivery address. 

We will generally respond to your access or deletion request within 45 days of receipt of your request, after proper verification, unless we need additional time, in which case we will let you know.   The response we provide will also explain the reasons we cannot comply with a request, if applicable. 

Third-Party Websites and Services 

The Site may include links to third-party websites or apps, including social media platforms. Those third-party websites and services are not operated or controlled by Us. This Policy does not apply to, and We do not control and are not responsible for, the privacy practices of those third-party websites or services. Please read their privacy policies carefully, since they have their own practices and policies, and they may collect and use your personal information in very different ways that We do.

The site may also include third-party content that collects data. This includes data collected by cookies, pixels, or other tracking tools, as further described above under "Do Not Track/Opt-Out of Targeted Advertising".

How Do We Protect Your Personal Information?

We use reasonable and appropriate security measures to protect your personal information.  No method of transmitting or storing data is completely secure, and despite our efforts to protect your personal information, We cannot guarantee the security of your personal information.

It is important that you also play a role in keeping your personal information safe and secure. When creating an account/profile, please be sure to choose a password that would be difficult for others to guess – generally meaning a unique, long and complex password -- and never reveal your password to anyone else. You are responsible for keeping this password confidential and for any use of your account. If you use a shared or public computer or other device, never choose to have your login ID/email address or password remembered and make sure to log out of your account every time you leave the computer or device. You should also make use of any privacy settings or controls We provide you through the site. 

How Long do We Retain Your Personal Information?

We keep personal information as long as it is necessary, relevant, or permitted for the purposes described in this Policy. We also keep personal information when and as otherwise required by law.  In the event you accept an opportunity with Us, our applicable personnel privacy policies will also apply with respect to the personal information collected under this Policy.

This might mean that We keep some or all of your personal information even if you are not chosen for, or do not accept, a particular position or opportunity,  or you otherwise end your relationship with Us, even if you exercise your deletion rights. When determining how long to retain your personal information, we take into account a number of factors, including the length and nature of our business relationship and the nature of your inaction with Us, the applicable statute(s) of limitation, and whether We are subject to any legal obligations relating to your personal information.  We also might de-identify certain personal information rather than deleting it. 

Collection of Personal Information of Children

We do not accept job applications from children, and this site is not targeted towards, and applications are not available to, those under the age of eighteen.

Changes to this Policy 

We are always improving our operations and we may change how we collect, use or disclose your personal information. In addition, the laws regarding personal information and privacy change frequently. Because of these changes in our practices and applicable laws, we periodically update this Privacy Policy.

When we make changes to this Policy, we will post any changes on this page so please check back frequently.  If we make material changes, if we have your contact information, we will notify you prior to the changes taking effect, and we will also post a notice through the site.

Any use of this site after we post the updated Policy will be subject to that updated Policy. 

Contact Us

To contact us about this Policy and/or our privacy practices, please contact Us at dataprivacy@bluetriton.com, 900 Long Ridge Road, Building 2, Stamford, CT 06902, or 844-887-3758. 

Last Updated:  September  29th, 2023