California Consumer Privacy Act Notice for California Applicants for Employment

Effective date: January 1, 2023

Funding Circle USA, Inc. (“Funding Circle,” “we,” “us,” “our”) are providing this California Consumer Privacy Act Notice for California Personnel (“Notice”) to applicants who are California residents. The California Consumer Privacy Act (CCPA) requires covered businesses to provide certain privacy notices to California consumers, and this requirement now applies to applicants for employment as well. This Notice describes our processing of Personal Information about you in connection with your application for employment.

Categories of Personal Information

Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular individual or household. “Personal Information” does not include publicly available information, deidentified or aggregated information, or information covered by certain sector-specific privacy laws. “Sensitive Personal Information” refers to information that reveals social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of mail, email, and text messages unless we are the intended recipient of the communication; genetic data; and biometric information.

In the following charts, we identify (1) the categories of Personal Information and Sensitive Personal Information (as listed in the CCPA) that we plan to collect and use, and have collected and used within the preceding 12 months about applicants for employment ; (2) the categories of third parties to which we have disclosed each category of Personal Information or Sensitive Personal Information for our operational business purposes within the preceding 12 months; (3) the criteria we use to determine the retention period for each category of Personal Information or Sensitive Personal Information.

Category	Examples	Category of Third Parties Information is Disclosed to for Operational Business Purposes	Retention Period Criteria
Identifiers	A real name, postal address, email address, social media account information	Our corporate affiliates Third-party service providers that provide services to us Government authorities or other parties pursuant to law Professional advisers, such as our accounting and legal advisers	We use the following criteria to determine the period of time for which we retain each category of Personal Information: The length of time we have an ongoing relationship with you (for example, for as long as you are employed or engaged with us); For as long as reasonably necessary for business purposes (for example, for internal reporting and reconciliation purposes); Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records for a certain period of time before we can delete them); or Whether retention is necessary in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, social security number, address, telephone number, passport number, driver's license or state identification card number, address history, education history, employment history, work authorization and citizenship status	See above	See above
Protected classification characteristics under California or federal law	Age, (40 years or older), Age (40 years or older), gender, race, ethnicity, or disability.	See above	See above
Professional, application, or employment-related information	Current or past job history, resume, information submitted into an application form, any references supplied, criminal or credit check information	See above	See above
Education information	Information about your educational attainments (this category is defined to exclude any publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	See above	See above

Below, we provide this information related to Sensitive Personal Information. We collect Sensitive Personal Information about our employees and other personnel where we determine this is required or appropriate, such as to comply with our legal and contractual obligations (such as for payroll, benefits, and tax reporting), administer leaves of absence and other benefits, facilitate benefits coverage for dependents and beneficiaries, and facilitate our diversity program.

Category	Examples	Category of Third Parties Information is Disclosed to for Operational Business Purposes	Retention Period Criteria
Identification numbers	Social security number, driver’s license, state identification card, or passport number.	Our corporate affiliates Third-party service providers Government authorities or other parties pursuant to law Professional advisers, such as our accounting and legal advisers	We use the following criteria to determine the period of time for which we retain each category of Personal Information: The length of time we have an ongoing relationship with you (for example, for as long as you are employed or engaged with us); For as long as reasonably necessary for business purposes (for example, for internal reporting and reconciliation purposes); Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records for a certain period of time before we can delete them); or Whether retention is necessary in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Racial or ethnic origin	Racial or ethnic origin	Our corporate affiliates Third-party service providers Government authorities or other parties pursuant to law Professional advisers, such as our accounting and legal advisers	See above

Category

Examples

Category of Third Parties Information is Disclosed to for Operational Business Purposes

Retention Period Criteria

Identification numbers

Social security number, driver’s license, state identification card, or passport number.

Our corporate affiliates
Third-party service providers
Government authorities or other parties pursuant to law
Professional advisers, such as our accounting and legal advisers

We use the following criteria to determine the period of time for which we retain each category of Personal Information:

The length of time we have an ongoing relationship with you (for example, for as long as you are employed or engaged with us);
For as long as reasonably necessary for business purposes (for example, for internal reporting and reconciliation purposes);
Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records for a certain period of time before we can delete them); or
Whether retention is necessary in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Racial or ethnic origin

Our corporate affiliates
Third-party service providers
Government authorities or other parties pursuant to law
Professional advisers, such as our accounting and legal advisers

See above

Sources of Personal Information

We obtain the categories of Personal Information listed above (including Sensitive Personal Information) directly from you, as well as from the following categories of sources: our corporate affiliates, publicly-available databases, third-party business partners, and other third-party sources.

Use of Personal Information

We use Personal Information (including Sensitive Personal Information) to operate our business including to manage the application process, sending or facilitating communications with you, fulfilling our legal and contractual obligations, establishing or defending legal claims, promoting diversity and other hiring initiates, and such other purposes as we may disclose to you from time to time.

CCPA Rights and Requests

California residents may make the following types of requests under the CCPA:

Requests to Know, Delete, or Correct

Requests to Know

To the extent provided by the CCPA, you may request that we disclose the following information to you about our collection and use of your Personal Information (including Sensitive Personal Information) over the past twelve (12) months or other CCPA-specified period: (1) the categories of Personal Information we collected about you; (2) the categories of sources from which we collected this Personal Information; (3) the categories of Personal Information that we have disclosed to third parties, (4) the business or commercial purpose for disclosing Personal Information; and (5) specific pieces of information we collected about you.

Requests to Delete

To the extent provided by the CCPA, you may request that we delete Personal Information that we have collected from you. We may limit or deny your deletion request in certain cases, in accordance with exceptions specified in the CCPA.

Requests to Correct

To the extent provided by the CCPA, you may request that we correct inaccurate Personal Information that we maintain about you, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information. We may limit or deny your correction request in certain cases, in accordance with exceptions specified in the CCPA.

How to Submit Requests to Know, Delete, or Correct

You may submit a Request to Know, Request to Delete, and/or Request to Correct in one of the following ways: 1) emailing us at hr-us@fundingcircle.com (preferred); 2) submitting the Individual Data Request form, available at https://www.fundingcircle.com/us/ccpa/employment-rights/; or 3) calling us at 877-226-9058.

We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as the email you provided us in your application, in order to verify your identity and protect against fraudulent requests. We also may verify your identity through our existing authentication practices for your work email account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information.

Authorized Agents

If you wish to use an authorized agent to make a CCPA request on your behalf, please direct the authorized agent to use the submission methods noted above. As part of our verification process, we may request that the authorized agent provides, as applicable, proof concerning status as an authorized agent, which also may include proof of registration with the California Secretary of State to conduct business in California; and/or a power of attorney pursuant to Probate Code sections 4121-4130.

We may also require you to verify your own identity directly with us; or directly confirm with us that you provided permission to submit the request on your behalf.

Nondiscrimination

You have the right to be free from unlawful discriminatory treatment under the CCPA for exercising any of your CCPA rights.

Contact us

If you have any questions or requests in connection with this Notice or other privacy related-matters, please contact us at:

Address:

Funding Circle USA, Inc.
Attn: Data Protection Officer

707 17th Street, Suite 2200
Denver, CO, USA 80202
USA

Telephone: (855) 385-5356, extension 3 (Mon - Fri, 8:00am – 5:00pm MT)
Email: hr-us@fundingcircle.com