Applicant Privacy Policy

This Applicant Privacy Policy (“Applicant Privacy Policy”) explains how Loop Now Technologies, Inc., and its affiliates (collectively, “Firework,” “our,” “us,” or “we”), handle Personal Information (i.e., Personal Data or other similar terms as defined by applicable law) in connection with recruitment and pre-employment activities. Please read this Applicant Privacy Policy carefully before submitting Personal Information to Firework as part of the applicant process.

California Consumer Notice of Collection

This Notice of Collection is provided to all California applicants subject to this Applicant Privacy Policy.

You can access specific topics in this Applicant Privacy Policy by clicking on the relevant links below:

WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

As part of our recruitment and pre-employment activities, we collect the following professional and educational Personal Information about applicants:

• Contact Information/Identifiers: name, gender, age, date of birth, email address, mailing address, telephone number, social media profiles, and in certain instances, identification documents, residency and work permit status, social security number (which may also be considered Sensitive Personal Information) or other taxpayer/government identification number.

• Professional and Employment-Related Information: professional qualifications, prior employment history, education history, additional information included in curriculum vitae, or references.

• Interview Information: notes collected by interviewers or other professional assessment information.

• Pre-employment Screening: if we offer you a job, we may collect additional background information such as credit history and eligibility information (as permitted by law). 

• Device Information and Other Unique Identifiers: device identifier, internet protocol (IP) address, or similar unique identifiers (to the extent you apply or otherwise interact with Firework careers portal).
• Sensitive Personal Information (where permitted and in accordance with applicable law): of the information listed above, social security number, driver’s license number, racial or ethnic origin, trade union membership, health and medical information (including where required, drug screening results), sexual orientation, and/or criminal history may also qualify as personal information. 

In many instances, the provision of the Sensitive Personal Information listed above is voluntary. We will let you know when that is the case, and if you decide not to share these with us, not doing so will not impact your application. 

We also may collect certain Personal Information or other information using cookies or similar digital technologies. For more information about how we use cookies, please review our Cookie Policy. 

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect your Personal Information in the following ways, pursuant to applicable law:

• Directly From You, when you create an account and profile in the Firework careers portal; share or use your social media profile to access the Firework career portal; sign up with us to receive open job postings; share your resume with us, either via the Firework careers portal or through other means; and/or participate in interviews or other recruitment activities.
• Other Sources, including employment or recruitment agencies, background check providers, references, or other publicly available sources.  

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use your Personal Information and Sensitive Personal Information for the following business purposes (“Processing Purposes”) associated with the administration of your application and our general business operations:

• To review and consider your application.
• For pre-employment screening if we decide to offer you employment.
• To consider you for opportunities we have now, or future ones, with Firework.
• To administer recruitment and staffing activities.
• To manage and improve our recruitment processes and our business operations related to the recruitment process.
• To comply with applicable laws, legal obligations and/or protect our legal interests.
• We use Sensitive Personal Information to evaluate Firework’s progress in achieving its diversity hiring goals, to ensure equal opportunity monitoring and reporting, to meet legal obligations, including providing workforce accommodations and for disability and workplace safety tracking administration.

If you are offered and accept employment with Firework, the information collected during the application and recruitment process may become part of your employment record.

TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?

Firework may disclose, and has disclosed in the preceding 12 months, all categories of Personal Information listed above to the following parties for the Processing Purposes identified above:

• Within Firework. We may disclose information to Firework affiliates and subsidiaries in the course of our normal business operations and as needed to address our corporate structure. 
• Service Providers. As part of normal business operations, Firework may disclose Personal Information to third-party service providers, including in connection with recruiting and human resources support, information technology and security support, and other normal business operations support. 
• Government Entities or Regulators. Firework may disclose Personal Information to governmental agencies and regulators (e.g., tax authorities, social security administration), external advisors (e.g., lawyers, accountants, and auditors), courts and other tribunals, and government authorities, to the extent required or permitted by applicable law.
• Business Transactions. In the event of mergers, reorganizations or similar corporate restructuring activities, we may disclose information with that company. In some instances, this may include your Personal Information. 
• Social Media Platforms and Networks. Some of our websites have features such as, plugins, widgets, or and other tools made available by social media platforms and networks that may result in information being collected or shared between us and these platforms and networks. Their use of your information is not governed by this Applicant Privacy Policy. 

WHAT IS OUR LEGAL BASIS FOR COLLECTING AND USING YOUR PERSONAL INFORMATION?

Firework relies on the following legal grounds for the collection, processing, and use of your Personal Information:

• With Your Consent: In certain circumstances, we ask for your consent to process your Personal Information for specific purposes. Provision of your consent is voluntary, and you have the right to withdraw your consent at any time.  However, in certain cases, withholding your consent may prevent us from proceeding with certain aspects of the recruitment process.
• When Pursuing Legitimate Interests: We process your Personal Information for our legitimate interests, such as to improve our recruitment process to ensure that we are able to hire suitable candidates and those of third parties while applying appropriate safeguards that protect your privacy.
• To Perform a Contract With You: We will process your Personal Information when processing of your Personal Information is necessary (e.g., for potentially entering into an employment relationship with you or the execution or performance of a contract with you).
• When we have Legal Obligations: We will process your Personal Information when we have a legal obligation to do so, for example, if we are responding to a legal process or an enforceable government request.

In some cases, your provision of Personal Information may be required by a statutory obligation or be necessary for us to enter into an employment/contractor relationship with you.

WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION?

You may have certain rights regarding your Personal Information. The rights available to you depend on our reason for processing your Personal Information and the requirements under applicable law (i.e., your rights will vary depending on whether you are located in, for example, California, the European Union, or United Kingdom). Specifically, you may have the following rights:

Access: You have the right to request access to the Personal Information we hold about you, along with other information such as the purposes of the processing, the recipients or categories of recipients to whom the Personal Information has been or will be disclosed, the sources of the Personal Information, retention, and transfers of Personal Information. 

Correction (Rectification): You have the right to request correction/rectification of inaccurate Personal Information we have about you. Depending on the purposes of the processing, you may have the right to have incomplete Personal Information completed, including by means of providing a supplementary statement.

Deletion (Right to be Forgotten): You have the right to request that we delete your Personal Information.

Restriction of Processing: You have the right to request the restriction of processing of your Personal Information. Where applicable, the respective Personal Information will be marked accordingly and may only be processed by us for certain purposes.

Data Portability: Under certain circumstances, you have the right to receive the Personal Information about you that you have provided to us, in a structured, commonly used and machine-readable format.

Objection to Processing: You have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Information by us. Where such right applies, we will no longer process the relevant Personal Information for such purposes.

Opt out of the sale or sharing of Personal Information: We do not and have not in the preceding 12 months, sold or shared (in this context, share means use of your Personal Information for cross-contextual behavioral advertising) your Personal Information. However, the use of technologies, such as cookies may constitute “sale” or “share” of Personal Information under California law. To opt out of the “sale” or “share” of your Personal Information as described in this section, visit DO NOT SELL OR SHARE MY PERSONAL INFORMATION.

• The following categories of Personal Information disclosed are considered “sale”/ “sharing” under California law: identifiers and device information.
• The following categories of third parties to whom Personal Information was disclosed are considered “sale”/ “sharing” under California law: social media platforms and networks.

Right of Non-Discrimination/Retaliation: We do not discriminate against individuals who exercise any of their rights described in this Applicant Privacy Policy, nor do we retaliate against individuals who exercise these rights.   

Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on the circumstances of the request. If you choose to assert any of these rights under applicable law, we will respond within the time period prescribed by such law.

Depending on where you are located, a person authorized to act on your behalf may make a verifiable request related to your Personal Information. If you designate an authorized person to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf. 

In any circumstances, your request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

 To exercise your rights, please contact us as stated in the “Contact Information” section of this Applicant Privacy Policy. 

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

Firework will retain your Personal Information, including Sensitive Personal Information, only for as long as it is necessary to fulfill the above-mentioned Processing Purposes, or as required to comply with applicable legal requirements. Even when the recruitment and pre-employment screening activities are complete, we may retain your Personal Information for various reasons, including but not limited to compliance with law and future employment opportunities.

INTERNATIONAL DATA TRANSFERS

In certain situations, we may transfer your Personal Information to countries where data protection laws are not considered to provide an equivalent level of privacy protection to that provided by the laws of your home country.  In such circumstances, Firework will take appropriate steps to provide an adequate level of data protection within the meaning of applicable data protection law, including by implementing the EU Standard Contractual Clauses and the UK Addendum to the EU Standard Contractual Clauses, where required.  You can request a copy of the appropriate safeguards referenced in this section by contacting us as stated in the “Contact Information” section of this Applicant Privacy Policy.

DO NOT TRACK

Please refer to the “Choices about Your Information and Your Rights” Section and “Opt-Out Preference Signal (Do Not Track)” of our Privacy Policy for information on “Do Not Track” signal recognition.

HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?

We maintain appropriate technical and organizational measures to protect against unauthorized or unlawful processing of Personal Information and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage to Personal Information.

WE DO NOT CONSIDER CHILDREN FOR EMPLOYMENT

We do not consider for employment, nor knowingly collect any Personal Information from, children who are not of legal age to consent to the collection and use of their Personal Information. We do not knowingly sell or share personal information of minors under the age of 16.

CONTACT INFORMATION

Any questions or concerns regarding the handling of Personal Information by Firework, or related to revocation of consent to collect, process, transfer, or disclose your Personal Information should be directed by email to privacy@fireworkhq.com, by phone at 800-717-0750, or mail at 2 West 5th Ave., Suite 400, San Mateo, CA 94402.

HOW DO WE UPDATE THIS APPLICANT PRIVACY POLICY?

We may update this Applicant Privacy Policy to reflect changes in the way we process Personal Information. We will notify you about such changes in the way we use your Personal Information in compliance with applicable law. 

Last Updated Date: February 2023