California Consumer Privacy Notice
Effective Date: [January 1, 2020]
This Notice was created on January 15, 2020, and is intended for California residents only.
If you are not a California resident, this California Consumer Privacy Notice does not apply to you.
This Notice was created by Sourced, LLC dba Sourced ( “we”, “our”, or “us”), following the instructions of California Consumer Privacy Act (“CCPA”), and it will apply to any California resident (“California consumer” as defined under CCPA, or “you”) of whom we may collect Personal Information (defined below), regardless of if you are or not a user of sourcedllc.com (“Site”), and any mobile application, application programming interfaces, and other services offered by us (collectively the “Services”). If you are a California consumer, this Notice explains your rights for managing your Personal Information, including opting-out of certain uses of your Personal Information.
1. Sourced Role under CCPA
Sourced as a Business in California
Under CCPA framework, Sourced is defined as a Business as to activities of collecting, sharing, and determining the means of processing California consumer information for Commercial Purposes. Sourced may collect Personal Information about you in order to provide Services to our customers including the customers’ end-users. Personal Information is information that identifies, relates to, describes, is cable of being associated with, or could reasonably be linked, directly or indirectly, with you. Commercial Purpose means to advance our commercial or economic interests.
Sourced as a Service Provider in California
Under CCPA framework, in certain scenarios, Sourced may be considered as a Service Provider who processes Personal Information on behalf of a Business – Sourced’s customer, and Sourced’s customer may disclose your Personal Information to Sourced for a Business Purpose pursuant to a written contract between Sourced and our customer. Business Purpose means the use of Personal Information for the Business’s or Service Provider’s operational purposes, including auditing, detecting security incidents, debugging, short-term/transient use, performing customer services, internal research, and maintain/improve/upgrade/enhance services.
2. Sourced’s Purposes for Collecting or Selling Personal Information
- Commercial Purpose
Sourced is a recruiting services company. We provide services to customers through a combination of our software solution which collects Personal Information and shares with our team for their internal operational purposes – specifically to engage with a person with regard to opportunities that fit that person’s skillsets and professional background. By sharing your Personal Information with our customers, we aspire to help you get to where you want to be professionally and personally and hope that through our Services you will get better career development from companies that you want to work with and that need your profession.
- Business Purpose
- to maintain Services for you, including to send you alerts about your account, debug errors, and resolve problems related to your account;
- to analyze, research and better understand how users access and use our Site and Services, both on an aggregated and individualized basis, to maintain, support, and improve our Site and Services, to respond to user preferences, and for research and analytical purposes;
- to keep you informed of our programs, products and other services we think may be of interest to you; or
- to otherwise communicate with you about Sourced.
If you are not a user of Sourced’s Site or Services, you believe that Sourced has collected your Personal Information and you want to assert your rights governed under CCPA (see below) with regard to your Personal Information, we may require you to provide additional necessary Personal Information so that we can verify your identify and facilitate your request.
We will not use your Personal Information we collected for materially different, unrelated, or incompatible purposes other than the purposes indicated above without providing you notice.
3. Categories of Sources of Personal Information
- Non-user Information:
- Your Public Profiles. Sourced may collect your Personal Information related to your profession that you published on the open websites and shared with the general public.
- Sourced Data Vendors. Sourced may collect your Personal Information from our Data Vendors who are legally able to or authorized by you to share your Personal Information related to your profession.
- Sourced’s Customers. Sourced may collect your Personal Information from our customers who are legally able to or authorized by you to use Sourced’s Services to process your Personal Information related to your profession.
- User Information: In order to use Sourced’s Site and Services, you, as a user, will provide your Personal Information to Sourced to create an account and facilitate your activities on Sourced’s Site.
4. Personal Information We Collected for the Preceding 12 Months
|Categories of Data||Examples||Collected by Sourced|
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||Name, alias, email|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||Name, phone number|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NOT COLLECTED|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NOT COLLECTED|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NOT COLLECTED|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||NOT COLLECTED|
|G. Geolocation data.||Physical location or movements.||NOT COLLECTED|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NOT COLLECTED|
|I. Professional or employment-related information.||Current or past job history or performance evaluations||Job title, skills, education, work history|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NOT COLLECTED|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NOT COLLECTED|
Specifically, Sourced collected Personal Information differently based on your role as a non-user or a user:
- Categories of Non-user Personal Information Collected: real name, alias, phone number, email, approximate location (city/metro area, not your actual address), job title, skills, education, work history, professional social network profile picture, professional social network link, and inferences drawn from the aforementioned information.
- Categories of User Personal Information Collected: real name, alias, address, phone number, mobile phone number, email, payment information, company name, computer/web browser/IP address information from cookies, web beacons and other identifiers, and other specific information you choose to provide us with or that you choose to include in your account.
5. Personal Information We Sold for the Preceding 12 Months
Through Sourced’s paid Services, we share non-user information with our customers so that they may reach out to you for career opportunities that you may have interest in, and which may better fit to your professional background.
If you are a user, your information provided in your user account is confidential to Sourced, and we neither sell your Personal Information nor share your Personal Information with others. Besides you, however, your Personal Information may be shared with your company’s Admin and other users who have the authority to view your Personal Information.
6. Personal Information We Disclosed for Business Purposes for the Preceding 12 Months
As a Service Provider to our customers, Sourced may receive your Personal Information from a customer who requires Sourced to process that information. In that case, we may disclose your Personal Information with that customer only for that customer’s business purpose.
If you are a user of Sourced’s Site or Services, Sourced does not disclose your Personal Information to others in order to facilitate Sourced’s Business Purposes. Your Personal Information will only be used internally within Sourced in order to provide services to you.
7. Categories of Third Parties We Shared Personal Information With
In order to provide Services to our customers and for Sourced’s Commercial Purposes, Sourced may share your Personal Information with our customers. Our customers are: employers and recruiters.
8. California Consumers’ Rights under CCPA
CCPA provides California consumers’ rights to control how their Personal Information is collected and shared by businesses. “California consumer” means a natural person who is a California resident as defined in 18 CCR §17014.
As a California consumer, you have the following rights regarding how Sourced processes your Personal Information:
- Right to Notice: Provides you the right to request Sourced disclose the categories of Personal Information to be collected and the purposes for which the categories of Personal Information will be used.
- Right to Access: Provides you the right to access your Personal Information free of charge, not more than twice within a year, upon Sourced’s verification of your identity. You can request Sourced to disclose categories of Personal Information collected, sold or disclosed; categories of sources of where the information was collected; Business or Commercial Purposes of collecting or selling the information; categories of third parties to whom the information was disclosed or sold; and the specific piece of information collected by Sourced.
- Right to Delete Information: Provides you the right to request Sourced delete your Personal Information that Sourced collected, upon a verifiable request, unless such Personal information was collected for the purpose of completing a transaction involving you; detecting security-related incidents or illegal activities; debugging or fixing errors; protecting other consumers’ rights or other rights protected by law; preventing criminal offenses; engaging in scientific, historical or statistical reach in the public interest; internal uses that are reasonably aligned with your expectation; or compliance with a legal obligation.
- Right to Equal Services and Prices: Provides you the right not to be discriminated against for exercising your rights under CCPA. Examples of discrimination include: denying goods or services to you, charging you different prices or rates for goods or services, providing you with a different level or quality of goods or services, or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
- Right to Opt-out: Provides you the right to request to opt-out and delete your personal information collected by Sourced.
9. Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of our receipt. If we have the necessity to request for additional information from you to verify your identity, we will use that information solely for purposes of verification. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to your email address linked to your account. If you do not have an account with us, we will deliver our written response by email in our record or an alternative way at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. Notwithstanding the foregoing, we have no obligation to respond to you if your Personal Information was collected for a single, one-time transaction if such information is not sold or retained by Sourced.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We have no obligation to provide you with responses for more than two times in a 12-month period.
10. Designated Methods for Asserting California Consumers’ Rights under CCPA
We respect your privacy. If you wish to assert your CCPA rights, please use the following contact methods to reach out to us:
Consumer Support Email: [email protected]
Security Report/Complaint: [email protected]
Attn: Legal Department
2401 Tremont Ct
Brentwood, CA 94513
We understand that not everyone is willing to learn about opportunities out there for one’s professional development. We respect your preference and choice.
If you are a user of Sourced’s Sites or Services, you can review, correct, update, delete, or change most of your Personal Information used to establish your account by using your account settings or opt-out of receiving certain e-mails and other communications from us by e-mailing us at [email protected] You are able to opt-out of receiving marketing e-mails from us, however, you cannot opt-out of receiving all e-mails from us, such as e-mails about the status of your account with us.
If you are not a user of Sourced’s Sites or Services, you can opt-out by providing your name and email address via this link, and we will remove your information from our system, or follow-up with you if we need further information in order to honor your request. Please note, we may need to retain certain Personal Information about you in order to ensure that we can verify and continue to honor your request to opt-out. We will maintain the minimum amount of information necessary for this purpose, and will not share this information with our customers, employers, recruiters or other users of our Sites and Services.
12. Children’s Privacy
Sourced Site and Services are intended for users who are 16 years old or older. We do not knowingly collect Personal Information from children under the age of 16. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records.
13. Processing in the United States
Please be aware that your Personal Information and communications are processed and maintained on our servers or databases in the United States. By visiting and using the Site or Services, you are agreeing to the collection, use, transfer, and disclosure of your Personal Data and communications will be governed by CCPA and other applicable laws in the United States.
We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information with encryption in transit and at rest. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk.
15. Privacy Notice Changes
We may change this Notice from time to time without giving you notice. In addition, according to CCPA, we are required to update this Notice annually. If we decide to change this Notice, we will inform you by posting the revised Notice on the Site. Those changes will go into effect on the “Effective Date” shown in the revised Notice. By continuing to use the Site or Services, you are consenting to the revised Notice.
PLEASE PRINT A COPY OF THIS NOTICE FOR YOU RECORDS AND PLEASE CHECK THE SITE FREQUENTLY FOR ANY CHANGES.
Click here for California Consumer Privacy Act