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Privacy Notice to Candidates Applying to Jobs at Sequoia

Updated August 17, 2023

  1. Notice to Candidates. Candidates, please read this notice (“Notice”) carefully. Sequoia Benefits and Insurance Services, LLC and its affiliates (collectively, “Sequoia”, “we” “us” or “our”) is required by certain data privacy laws, including the European Union’s General Data Protection Regulation of 2016 (GDPR), the UK Data Protection Act (UK GDPR), and California Civil Code Sec. 1798.100 et seq. and Sec. 1798.145(m)(3) (CCPA), to provide candidates for employment (“Candidates”, “you”, “yours” or “your”) you with notice about how we collect and use your personal information. This includes how the information collected during the application process is used and how you can access and correct certain information that we may collect. This Notice applies to information obtained or disclosed in connection with the online application process, interviews, offline correspondence and through other personal communications with Sequoia personnel.
  2. Alternative Format. This Notice can be provided in audio format by contacting contactus@sequoia.com.
  3. No Offer. This Notice does not constitute an offer of employment or form part of a contract for employment.
  4. Categories of Personal Information We Collect. All personal information provided during the application process is completely voluntary, however, failure to provide sufficient personal information may render Sequoia unable to consider your candidacy. We may collect the following categories of information on Candidates, as allowed under the applicable law:
    Identifiers Including your first name, middle name, and surname, former names, and aliases
    Contact Information Including mailing address, phone number, and email address
    Job Application Data Including resume, cover letter, references, prior employment history, prior employer obligations, educational background, job skills, and other job-related information
    Professional Qualifications Including professional licensures, credentials, certifications, qualifications, and other licensure-related information
    Biographical Information Including date of birth, nationality, right to work in certain countries including the US, immigration status, ethnicity, gender identity, and veteran status, including where you make such information available on social networking profiles such as LinkedIn
    Employment History Including positions held, companies, salary, role, job description, and location
    Background Check Information Including criminal background and credit information, where permissible by law
    Information to Understand and Assess Disability Status and Health Condition Including vaccination status, disability status, health status, disease state, and relevant medical information related to health condition
    Other Information Including other personal information collected during the recruiting process
  5. Sources of Personal Information. We collect personal information from you during the application process, along with other sources available to us. This may include the following sources of information such as the following: (i) pre-employment screening and recruiting services, such as recruiters or placement agencies; (ii) prior employers that provide employment verification or history; (iii) references that you authorize us to contact on your behalf; (iv) third-party job posting and recruiting websites; (v) your university or other educational institution; (vi) publicly available online information about you such as on social media or the internet; (vii) your online activity on the www.sequoia.com website; and (viii) Sequoia personnel that you may communicate with during the recruiting process.
  6. Purposes of Data Collection. As permissible under applicable laws, we may collect data on Candidates for the following business purposes: (i) recruiting, including through the www.sequoia.com, the Sequoia recruitment process, interviewing and evaluating candidates for open positions, conducting background checks and pre-employment screening; (ii) analyzing and improving the application process and recruiting activities; (iii) accommodating disabilities and health status of Candidates; (iv) communicating with Candidates about open positions; (v) related human resources and employment business operations; (vi) compliance with employment laws related to recruiting and hiring; (vii) compliance with internal recruiting policies and priorities; (vii) compliance with requests and legal obligations from government agencies; and (viii) protecting the rights, safety, privacy, and security of the company and any individual.
  7. Disclosure of Personal Information. As permissible under applicable laws, we may share your personal information with the following: (i) Company subsidiaries and affiliates, including those under common control or operations; (ii) Service providers, including those that provide services in our recruiting and interviewing processes such as third-party recruiters, interviewers, testing companies, pre-employment screening providers, relocation companies, travel providers, providers of other recruitment related services, and professional services providers such as accounting firms, immigration advisors, and law firms; (iii) Government agencies for purposes of compliance with regulatory or legal obligations; and (iv) In the event of business transactions, such as mergers or acquisitions, divestiture, sale of assets, acquisition, dissolution, bankruptcy or change of control event.
  8. How We Share Your Data. In the last twelve (12) months, we have shared information in the following categories: Identifiers, Contact Information, Job Application Data, Professional Qualifications, Biographical Information, Employment History, Background Check Information, Information to Assess Disability and Status of Health Condition and Other Information with company subsidiaries and affiliates, service providers, and government agencies.
  9. Candidate Privacy Rights. We provide Candidates with the privacy rights described in this section. You have the right to exercise these rights via an authorized agent who meets the agency requirements of under applicable law, and any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”) via email, phone number or address listed below. This process may consist of, but is not limited to, our verifying your identity through established protocols, or our asking you to confirm information previously submitted to Sequoia. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the person about whom we collected personal information (“PI”). If we cannot comply with a request, we will explain the reasons in our response. You are not required to create an account with us to make a Verifiable Consumer Request. We will use personal information provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.
  10. Response to Requests. We will make commercially reasonable efforts to identify personal information that we collect, process, store, disclose and otherwise use and to respond to your requests. We reserve the right to direct you to where you may access and copy responsive personal information yourself. If your request is excessive, repetitive, unfounded or overly burdensome, we may determine that the request warrants a fee, or we may refuse it, and we will give you notice explaining why we made that decision. In such case, you will be provided with a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.
  11. Your Rights. Your rights include the right to send us a request, no more than twice in a twelve (12) month period, for any of the following:
    1. The Right to Know. You have the right to know the following: (i) the categories of personal information we have collected about you; (ii) he categories of sources from which we collected your personal information; (iii) the business or commercial purposes for our collecting or selling your personal information; (iv) the categories of third parties to whom we have shared your personal information (v) the specific pieces of personal information we have collected about you; (vi) the right to make or obtain a transportable copy; (vii) a list of the categories of personal information disclosed for business purposes, or that no disclosure occurred; (viii) list of the categories of personal information sold about you, or that no sale occurred.
    2. Right to Correct Information. Except to the extent, we have a basis for retention under the law, you may request that we correct your personal information that we have collected directly from you and are maintaining.
    3. Right to Delete Information. Except to the extent, we have a basis for retention under the law, you may request that we delete your personal information that we have collected directly from you and are maintaining. Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. Note also that we are not required to delete your personal information that we did not collect directly from you.
    4. Right to Non-Discrimination. You have the right to non-discrimination based on your exercise of privacy rights. We will not discriminate against you in a manner prohibited by law because you exercise your privacy rights.
    5. Right to Notice of Additional Disclosures. You may also request information regarding additional disclosure of your personal information, including as defined by certain state laws such as California Civil Code Sec. 1798.83, (California’s “Shine the Light” law), to a third party for that party’s direct marketing purposes. We do not disclose Candidate information to third parties for direct marketing purposes.
    6. Right to Opt Out. You have the right to opt out in sale of your personal information. We do not sell your personal information. Accordingly, we do not offer an opt-out of the sale to personal information.
  12. Exclusions. Notwithstanding anything to the contrary, we may collect, use, retain and disclose your personal information as required or permitted by applicable law and this may override your privacy rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.
  13. Changes to Notice. Sequoia reserves the right to change the contents of this Notice at any time. The date at the top of this Notice indicates the date when it was last revised. You should check this site to confirm any changes.
  14. Childrens Privacy. The Sequoia candidate process and related website is not intended for those under the age of eighteen (18) years old.
  15. Contact Information and Making Requests. Sequoia welcomes questions and comments about this Notice and your California privacy rights. Questions, comments, and requests should be directed to Sequoia’s privacy team as follows:
    Via email: contactus@sequoia.com
    Via phone:  1-833-521-0026
    Via U.S. Mail:
    Sequoia Benefits & Insurances Services, LLC
    1850 Gateway Drive
    Suite 700
    San Mateo, CA 94404