Applicant Privacy Notice

Last Updated: February 18, 2025

Generate-Ubiquity Management, LLC (“Company ,” “we,” or “us”) is committed to protecting the privacy and security of your personal information, and this Applicant Data Privacy Notice (“Privacy Notice”) describes how we collect and process personal information about you during the employment application and recruitment process. This Privacy Notice applies to job applicants only. By using our “Applicant Portal,” or similar online employment application-related website serviced for, or by us, or by otherwise submitting an employment application to us, you acknowledge you have read and understood this Privacy Notice.

In Summary:

This Privacy Notice applies to our use of personal information for talent management and recruitment purposes. It explains how Company collects your personal information, how we use your personal information, how we secure your personal information, when we may disclose your personal information to third parties, and when we may transfer your personal information outside of your home jurisdiction. This Privacy Notice also describes your rights regarding the personal information that we hold about you, including how you can access, correct, and request erasure of your personal information. We will only process your personal information in accordance with this Privacy Notice unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.

This Privacy Notice does not cover your interactions with Company outside the context of applying for, learning more about, or interviewing for a position, such reviewing our products and services online, where applicable.

Website Privacy Policy

For information regarding how the Company collects data on our website or our other online services, including if you submit your application online, or during any other engagement with us, please see our Privacy Policy.

Online Monitoring. Please be aware that the Company uses cookies and other tracking technologies on our websites to monitor and record any and all activities and communications to, from, and on the website in order to safeguard, improve, and analyze usage of the website, and for the other purposes listed in our website privacy policy. You have the ability to manage some of the types of information gathered about you by opening the Cookie Preference Center on our Site. For the avoidance of doubt, you hereby acknowledge, agree, and consent to the monitoring and recording of all such activities and communications on our websites.

Collection of Personal Information

For the purposes of this Privacy Notice, the term “personal information” means any information about an identifiable individual collected in connection with the recruitment process or otherwise as defined in accordance with applicable privacy law. Company may collect personal information directly from you, as a job applicant, or may receive personal information from third parties, for example, in connection with a background, employment, or reference check, subject to your consent where required by law. Personal information excludes anonymous or de-identified data that is not associated with a particular individual. We may collect, store, and process the following categories of personal information, in connection with our recruiting activities:

Categories of Personal Information
Personal contact details such as name, date of birth, driver’s license/state identification numbers, title, addresses, telephone numbers, and personal email addresses.
Work history and other relevant experience including information contained in a résumé, CV, cover letter, references, or job application.
Education information including degrees awarded, transcripts, and other information provided in support of the job application.
Social media accounts that you choose to provide as part of your application (such as your LinkedIn profile).
Information collected during phone screenings and interviews.
Details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits.
Membership in professional organizations, licenses, and certifications.
Reference information and information received from background checks, where applicable, including information provided by third parties.
Information necessary to confirm and/or demonstrate your ability to work in a particular jurisdiction.
Information related to previous applications to Company or previous employment history with Company .

We may collect and process the following special categories of personal information when you voluntarily provide them, or we receive them from a third party with your consent, when relevant for a particular position to carry out our obligations under employment law, or as applicable law otherwise permits. The following special categories of personal information are considered sensitive under the laws of your jurisdiction and may receive special protection:

Collection and Use of Special Categories of Personal Information
Social Security Number.
Passport and visa information, and immigration status and documentation.
Data relating to criminal convictions or offences.
Physical or mental health condition or disability status to determine appropriate workplace accommodations and evaluate fitness for a particular position.
Where we have a legitimate need to process special categories of personal information about you for purposes not identified above, we will only do so only after providing you with notice and, if required by law, obtaining your prior, express consent.

Unless otherwise noted to you, the personal information is mandatory in connection with our recruiting activities. Failure to provide or allow us to process mandatory personal information may affect our ability to accomplish the purposes stated in this Applicant Data Privacy Notice. Where we have a legitimate need to process special categories of personal information about you for purposes not identified above, we will only do so only after providing you with notice and, if required by law, obtaining your prior, express consent.

Use of Personal Information

We only process your personal information where applicable law permits or requires it in connection with carrying out our application and recruitment process, to take steps necessary to enter into an employment contract with you, where the processing is necessary to comply with a legal obligation that applies to us, for our legitimate interests or the legitimate interests of third parties, or with your consent if applicable law requires consent. We may process your personal information for the following legitimate business purposes:

How We Use Personal Information
Identifying and evaluating job applicants, including assessing skills, qualifications, and interests for the purposes of determining suitability for the position for which you have applied.
Verifying your information and carrying out employment, background, and reference checks, where applicable, subject to your consent where required by applicable law.
Communicating with you about the recruitment process, scheduling, your application, and onboarding, where applicable.
Keeping records related to our hiring processes, for only as long as appropriate under the circumstances.
Creating and submitting reports as required by applicable laws or regulations.
To comply with our legal, regulatory, or other corporate governance requirements.
Analyzing and improving our application and recruitment process.
Maintain and administer payroll and employee benefit plans, including enrollment and claims handling.
To prevent fraud.
To conduct internal audits and investigate complaints, grievances, and suspected violations of our policies.
To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.
To respond to law enforcement requests and as required by applicable law or court order.
Exercise or defend legal rights of Company and its employees, affiliates, customers, contractors, and agents

In addition to using your personal information for the position for which you have applied, we may, with your consent, retain and use your personal information to inform you about and consider you for other positions that may be appropriate for you. If you want us to consider you for other positions, you may contact us as specified below under Contact Us and we will retain your personal information for that purpose.

We will only process your personal information for the purposes we collected it for or for compatible purposes. If we need to process your personal information for an incompatible purpose, we will provide notice to you and, if required by law, seek your consent. We may process your personal information without your knowledge or consent only where required by applicable law or regulation.

Third Party Disclosures

We will only disclose your personal information to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the recruitment process, including third-party service providers who provide services to us or on our behalf. We may use third-party service providers for various purposes, including, but not limited to, obtaining employment verification and background checks, and data storage or hosting. These third-party service providers may be located outside of the country in which you live or the country where the position you have applied for is located.

We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal information consistent with our policies and any data security obligations applicable to us. We do not permit our third-party service providers to process your personal information for their own purposes. We only permit them to process your personal information for specified purposes in accordance with our instructions.

We may also disclose your personal information for the following additional purposes where permitted or required by applicable law:

To our affiliates or parent company (which may fall outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to administer the application and recruitment process.
As part of our regular reporting activities to our affiliated and parent companies.
To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal information necessary for the specific purpose and circumstances.
To protect the rights and property of Company .
During emergency situations or where necessary to protect the safety of persons.
Where the personal information is publicly available.
If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data-sharing to what is absolutely necessary, and we will anonymize the data where possible.
For additional purposes with your consent where such consent is required by law.

Data Security

We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal information against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal information to those employees, agents, contractors, and other third parties that have a legitimate business need for such access. However, no transmission of information via the Internet or wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that there are security and privacy limitations of the Internet which are beyond our control and accordingly, the security, integrity and privacy of data exchanged between you and us cannot be guaranteed. We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data 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 requirements, or as necessary to resolve disputes. To determine the appropriate retention period for personal information, we consider our statutory obligations, 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 we process your personal information for, and whether we can achieve those purposes through other means. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. If you are offered and accept employment with Company , the personal information we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our employee personal information policies. If you do not become an employee, or, once you are no longer an employee of Company , we will retain and securely destroy your personal information in accordance with our document retention policy and applicable laws and regulations.

Privacy Rights; Privacy Appeals; Complaints

Data Privacy Rights. Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, California residents are entitled to certain data privacy rights:

Right to Know(Specific Pieces of Personal Information). You have the right to know the specific pieces of your personal information that we have collected about you.
Right to Know(Categories of Personal Information). You have the right to know (i) the categories of personal information we have collected from you; (ii) the categories of sources from which the personal information is collected; (iii) the categories of your personal information we have sold or disclosed for a business purpose; (iv) the categories of third parties to whom your personal information was sold or disclosed for a business purpose; and (v) the business or commercial purpose for collecting or selling your personal information.
Right to Delete. You have the right to request that we delete your personal information that we have collected and retain.
Right to Correct. You have the right to request that we correct inaccurate personal information that we have collected and retain.
Nondiscrimination. You have the right not to be subject to discrimination for asserting your rights under the CCPA.

Submit a Privacy Request. To submit a privacy request, you (or your authorized agent) may contact us in accordance with the “Contact Us” section listed below. However, any such authorized agent must be registered with the California Secretary of State to conduct business in California.

Privacy Request Verification Process. If you (or your authorized agent) make any request related to your personal information, Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, Company will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email, request certain contact information or government identifiers, and we will match at least two pieces of such personal information with data that we have previously collected from you before granting you access to, erasing, or correcting, specific pieces or categories of personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA’s rights are absolute, and such rights are subject to legal and regulatory exceptions and exemptions. For more information about the CCPA, please see: https://oag.ca.gov/privacy/ccpa.

Opt-Out Rights / Do Not Sell My Personal Information. California residents have the right to opt out of the “sale” of their personal information. However, Company does not sell your personal information to third parties for profit or monetary or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).

Opt-Out Rights / Do Not Share My Personal Information. California residents have the right to opt out of the “sharing” of their personal information. Company uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners, and such features, tools and marketing relationships involve the disclosure of your personal information to third parties and may constitute the “sharing” of your personal information for CCPA purposes. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” or a “Do Not Sell/Share My Personal Information” link on the footer of the Site) to set your cookie preferences. You, or your authorized agent, may also contact us in accordance with the “Contact Us” section listed below.

Children. The Site is not directed at, and should not be used by, minors under the age of sixteen (16), and therefore Company does not knowingly sell or share the personal information of minors under sixteen (16) years of age.

Limit Use of Sensitive Personal Information. Company does not use or disclose sensitive personal information for reasons other than those set forth in the CCPA, and therefore we do not provide individuals with the ability to limit how we use or disclose such sensitive personal information.

Changes to This Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any updates. If we would like to use your previously collected personal information for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent before using your personal information for a new or unrelated purpose. We may process your personal information without your knowledge or consent only where required by applicable law or regulation.

Contact Us

If you have questions regarding this Privacy Notice or our handling of your personal information, would like to request more information from us, or would like to exercise a data privacy right, please contact our Privacy Champion at: please contact us (mail) Ubiquity, ATTN: Privacy Champion, 121 W. Trade St., Ste 1275, Charlotte, NC 28202 or (email) info@ubiquitygp.com.