PRIVACY NOTICE FOR
CALIFORNIA EMPLOYEES AND INDEPENDENT CONTRACTORS
This
Privacy Notice describes how Valiant Capital Management, L.P., Valiant
Peregrine Managememt, L.L.C. and their affiliates
(collectively, “Valiant,” “we,” “us” or “our”) collect, use, store and disclose,
during and after your working relationship with us, personal information we
obtain from job applicants, current and former employees, owners of Valiant and
contractors, who reside in California, in accordance with the California
Consumer Privacy Act (“CCPA”). More
information about our privacy practices is available at our Privacy Policy at https://www.valiantcapital.com/ValiantCCPAPrivacyPolicy.htm.
Personal
Information We Collect
We may collect the following types of personal information:
· Identifiers, such as your name, email address, physical address,
telephone number, business contact information, and device identifiers;
· Records about you, such as financial information (including
financial account number used for payroll), background check information (where
permitted or required by law), and your physical characteristics or a
description of you;
· Protected class and demographic information, such as age
(including birthdates), gender and veteran or military status;
· Commercial information, such as records of business transactions,
salary and wage information, and payroll and benefits data;
· Internet or other electronic network activity information, such as
information relating to your use of or interactions with our networks, systems,
devices, email, applications, and platforms, including your browsing history,
search history, and other interactions;
· Non-precise geolocation data, such as your location as derived
from your IP address;
· Audio, visual, or other sensory information, such as photographs,
security camera footage in the public areas of our facilities, and recordings
of calls and video conferences;
· Professional or employment-related information, such as job title,
organization, professional licenses, credentials, specialty, professional affiliations,
professional experience, references, performance and other evaluation
information, disciplinary information, resumes, interview notes, human resource
records, payroll or other professional information;
· Physical security and biometric information, including badge
identifiers to enter the building and access certain parts of the premises and
health checks, as may be recommended by public health authorities;
· Education information;
· Inferences drawn from any of the information we collect about your
preferences and behavior; and
·
Sensitive Personal Information, such as social security
number, driver’s license number, or passport number; account log-in information;
racial or ethnic origin (if you voluntarily provide it); content of mail,
email, and text messages where we are not the intended recipient (such as
messages that we monitor for compliance and security purposes); political
contribution information (as required for our compliance with applicable law);
information about your health; medical or health insurance information,
including insurance policy number (and information about your beneficiaries);
and information relating to sexual orientation, if you voluntarily provide it.
Sources of Personal Information
We collect personal
information about you through job applications and the
recruitment process, either
directly from you, or from
our employees, agents or third parties (e.g., employment agencies, background
check agencies, credit reference agencies).
We
also collect personal information automatically when you use our technology
infrastructure, and through other interactions
with us and our service provider prior to, during, or after your engagement
with us (such as if you register for benefits for you and your family
members).
Use
of Your Personal Information.
We use your
personal information as otherwise described in this Privacy Notice and as
follows:
·
In
connection with an employment or contractor application, such as assessing your
application, interview, and test results for suitability for positions or projects; communicating with you
concerning position openings or your application; conducting pre-engagement
verification and screening; offering you the position, in
our discretion; notifying you of engagement opportunities (including from our
affiliates); and dealing with any inquiry, challenge, or request for feedback
received in relation to our recruitment and engagement decisions;
·
For human resources management, such as administering payroll
and benefits (including leaves of absence and government-related programs);
logistics; planning and managing travel and other reimbursable expenses;
development and training; absence monitoring; timekeeping; performance
appraisals; disciplinary and grievance processes; administration of termination
of employment or engagement; assessing qualifications and eligibility for
a particular role or project; equal employment opportunity monitoring;
background checks and reference checks; and compliance programs;
·
For our internal business purposes, such as managing operations
and workforce engagement; enforcing our policies and rules; managing our
business assets (including with respect to office locations and emergency
planning); maintaining records of our operations; IT administration of our
technologies, network, and intranet; analyzing and managing meeting or
conferencing information (including, but not limited to, recording content,
which may include your voice and/or images); and providing insights into
interactions with people you network with;
·
For our internal research and business improvement purposes;
·
For
legal, safety or security reasons, such as complying with legal, reporting, and
similar requirements; investigating and responding to claims against us, our
affiliates, personnel, and customers; for the establishment, exercise or
defense of legal claims; protecting personnel safety (including managing spread
of communicable diseases), property or rights; detecting, preventing, and
responding to security incidents; and protecting against malicious, deceptive,
fraudulent, or illegal activity;
·
In
connection with a corporate transaction, such as if we acquire, some or all of our assets are acquired by another entity; and
·
For
marketing or promotional purposes, including externally promoting our business.
For example, we may publicly disclose the names and work contact information of
certain of our representatives or post pictures of current or past personnel
who attend our events.
We only process information about criminal convictions if legally required
or permitted to do so, which includes, but is not limited to, the performance of any applicable
background checks. We may use
anonymized, de-identified, or aggregated information for any purpose
permitted by law.
If
you fail to provide certain
personal information when requested, we may not be able to provide
essential benefits to you (such as paying you or providing other employee benefits)
or we may be prevented from complying with our
legal obligations (such as to ensure the health and safety of our workers).
Information
We Disclose
We
do not sell or share your personal information for cross-context behavioral
advertising. We may disclose your
personal information described above as permitted by law or for the purposes
otherwise described in this Privacy Notice to the following types of parties: affiliates and
subsidiaries; service providers that administer our benefits, compensation
processes and physical and technical security; professional consultants to our
business (such as lawyers, brokers and accountants); vendors necessary to
complete transactions you request; law enforcement, government agencies, and
other recipients for legal, security, and safety purposes; other entities in
connection with a corporate transaction; and any party to which you have
consented to the disclosure of your personal information.
Personal Information Retention
Except
as otherwise permitted or required by applicable law or regulation, we will
only retain your personal information for as long as necessary to fulfill the
purposes we collected it for, as required to satisfy any legal, accounting, or
reporting obligations, or as necessary to resolve disputes. To determine the
appropriate retention period for personal information, we consider applicable
legal requirements, the amount, nature, and sensitivity of the personal
information, the potential risk of harm from unauthorized use or disclosure of
your personal information, the purposes for which we process your personal
information, and whether we can achieve those purposes through other means. We
specify the retention periods for our records, including your personal
information, in our policies and procedures.
Questions
We
welcome any questions about our privacy practices and this notice. If you have
any concerns as to how your data is processed, you can contact us at ir@valiantcapital.com or call us at 888-861-5301 and ask
for Rachel Hermens.
For information about how we handle personal information collected about individuals please find our CCPA Privacy Policy