This Notice of Privacy Practices for Job Applicants and Employees (“Privacy Notice”) describes how ACI Jet (“ACI Jet”, “we”, “our” and “us”) gathers, processes, and uses information in connection with our recruiting, hiring, human resources administration, and benefits administration activities. This Notice applies to job applicants, candidates for employment, and employees who are residents of the State of California (“Consumers”) and from whom we collect “Personal Information” as defined in the California Consumer Privacy Act (“CCPA.”) We provide you with this Notice because under the CCPA, California residents who are job applicants and employees qualify as Consumers. For purposes of this Notice, when we refer to Consumers, we mean you only to the extent you are a job applicant or employee who resides in California.

1. Information We Collect

When you apply for a job with us, are evaluated for employment, and/or are employed as a member of our workforce team we may collect certain information from and about you. The information may be and is used in connection with our recruiting, hiring, human resources administration, and benefits administration activities. This information may include:

• Contact information, such as name, telephone number, fax number, physical address, email, and username;
• Previous work experience, desired compensation, education, degrees, language, and other skills and employment-related information;
• Professional and other work-related licenses, permits, and certifications;
• Awards and professional memberships;
• Information regarding your use of our website, as described in our use of cookies;
• Work authorization status;
• Information relating to references;
• Information from social media sites if you choose to link your application to a social media;
• Any other information you elect to provide to us (e.g., employment preferences, willingness to relocate, and supplemental documents such as training records);
• Personal Identifiers (social security number, driver’s license or state identification card number, passport number);
• Account Information (your account log-in, in combination with any required security or access code, password, or credentials allowing access to the account);
• Protected Classifications (racial or ethnic origin, religious or philosophical beliefs, union membership, or sexual orientation);
• Medical and Health Information; and
• Geolocation Data (IP address and/or GPS location, latitude & longitude).

Sensitive Personal Information

Certain types of information are considered sensitive personal information in certain jurisdictions. This includes the following: information on race, religion, ethnicity, nationality or national origin, age, gender identity, sex, life or sexual orientation, criminal convictions and offenses, marital status, medical or health information (including disability status), genetic or biometric information, religious or philosophical beliefs, political party or trade union membership, background check information, and veteran status.

Under the California Privacy Rights Act (“CPRA”), the following information is also defined as sensitive personal information: precise geolocation, social security number; driver's license number, state identification card number, passport number, account log-in/financial account/debit card/credit card number in combination with any required security or access code, password, or credentials allowing access to an account, and the contents of a consumer's mail, email and text messages, unless the business is the intended recipient of the communication.

Depending on the stage of an application, in addition to the information you provide to us, we may obtain information about you from other third parties, such as platforms used to collect application information, recruiters, references, former employers, and law enforcement agencies.

Of the below categories of Personal Information, the following are categories of Sensitive Personal Information ACI Jet may collect:

• Personal Identifiers (social security number, driver’s license or state identification card number, passport number);
• Account Information (your log-in to the applicant tracking system or onboarding account log-in, in combination with any required security or access code, password, or credentials allowing access to the account); and
• Medical and Health Information.

Personal information does not include:

• Publicly available information from government records;
• Information that a business has a reasonable basis to believe is lawfully made available to the general public by the job applicant or from widely distributed media;
• Information made available by a person to whom the job applicant has disclosed the information if the job applicant has not restricted the information to a specific audience; and
• De-identified or aggregated information.

2. How We Use Information

The information that you submit during a job application process, while completing employment-related forms during your onboarding after you are hired, and gathered from you for employee benefits-related purposes during the term of your employment may be used for personnel recruitment, management, and planning purposes including the following:

• To analyze your qualifications for the job you applied for or future jobs that may match your profile;
• To communicate with you regarding your job application, your inquiries and requests, other job openings, or important notices;
• To conduct criminal history, background, and employment checks, if we offer you a position;
• If hired, to comply with local, state, and federal law and regulations requiring employers to maintain certain records (such as immigration, compliance records, travel records, personnel files, wage and hour records, payroll records, accident or safety records, and tax records), as well as local, state, and federal law, regulations, ordinances, guidelines, and orders relating to any infectious diseases; 
• To support our efforts to maintain a diverse workforce; and
• To comply with or monitor our compliance with any applicable law or regulation.

3. Accuracy of Information You Provide

You are responsible for the accuracy and completeness of information you provide to ACI Jet. 

4. How We Share Your Information

We may share your information in the following circumstances:

• Vendors and Service Providers. We may share your information with vendors and service providers that we believe need the information to perform a technology, business, or other professional function for us, including providing products or services to you or our clients on our behalf, creating or maintaining our databases, researching and analyzing the people who request information from us, preparing and distributing communications, or responding to inquiries;
• Business Transition. If ACI Jet, or any portion of our assets, are acquired by, merged with, transferred to, or invested in by another company, we may share your personal information with that company or other third parties involved in the business transition. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy; 
• Legal. We share information where necessary to comply with applicable law, to respond to requests from law enforcement agencies or other government authorities or third parties, as permitted by law, and without your consent when it is necessary to protect our customers, employees, or property; in emergency situations; or to enforce our rights under our terms of service and policies; and
• ACI Jet does not and will not sell your Personal Information or Sensitive Personal Information for any monetary or other valuable consideration. ACI Jet does not and will not share your Personal Information or Sensitive Personal Information for cross-context behavioral advertising. 

5. Use of Cookies and Other Tracking Technologies

Cookies are small files that a website may transfer to a user’s computer that reside there for either the duration of the browsing session (session cookies) or on a permanent, until deleted, basis (persistent cookies) that may be used to identify a user, a user’s machine, or a user’s behavior. We make use of cookies under the following circumstances and for the following reasons:

• To provide you with services available through the website and to enable you to use some of its features;
• To authenticate users and prevent fraudulent use of user accounts;
• To identify if users have accepted the use of cookies on the website;
• To compile data about website traffic and how users use the website to offer a better website experience; and
• To understand and save visitor preferences for future visits, such as remembering your login details or language preference, to provide you with a more personal experience and to avoid you having to reenter your preferences every time you use the website.

You may delete cookies from your web browser at any time or block cookies on your equipment, but this may affect the functioning of or even block the website. You can prevent saving of cookies (disable and delete them) by changing your browser settings accordingly at any time. It is possible that some functions will not be available on our website when use of cookies is deactivated. Check the settings of your browser. Below you can find some guidance:

• Safari
• Opera
• Internet Explorer
• Google Chrome
• Mozilla

Do Not Track (DNT) is a privacy preference that users can set if they do not want web services to collect information about their online activity. We do not respond to DNT signals.

6. Retention and Disposal

We will retain your personal information (collected through offline and online methods) for as long as it is necessary for the purposes described in this Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. When we dispose of information as part of our retention policies, we use secure means, such as either physically or electronically erasing information or making it anonymous in a non-recoverable manner. 

7. Security

We implement the appropriate organizational, technical, and physical security measures and controls to protect the confidentiality, integrity, and availability of the personal information entrusted to us. However, as no security system is wholly failsafe or impenetrable, the transmission of information via the internet is not completely secure. We cannot guarantee the security of our database or the information you supply while being transmitted to us over the Internet. Although we strive to protect your personal information in accordance with this Policy, we will not be liable for disclosure of personal information obtained due to errors in transmission or security breaches. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at dataprivacy@acijet.com

8. California Notice at Collection

Under the California Privacy Rights Act (“CPRA”), you are entitled to be informed about the following, at or before the point of collection of your personal information:

• the categories of personal information we will collect, the purposes for which those categories of personal information will be collected or used and whether such information will be sold or shared;
• the categories of sensitive personal information to be collected and the purposes for which those categories of sensitive personal information will be collected or used and whether such information is shared; and
• the length of time we intend to retain each category of personal information, including sensitive personal information, or the criteria used to determine such period.

To the extent that we collect your personal information that is subject to the CPRA, that information and our practices are described below. The categories we use to describe the information are those enumerated in the CPRA; categories not listed are not collected. Certain personal information may fall into multiple categories.

Category	Examples	Retention Period
Identifiers	Name, email address, phone number, and contact address, username, password. Source: Directly from you Purpose of collection and use: All purposes listed in Section 2 of the Notice above Categories of Parties With Whom PI is Shared: Affiliates; Service Providers	If hired, this data will be retained for the duration of employment plus 5 years. If not hired, we will retain your Personal Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	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. Source: Directly from you; generated in the course of your use of the Services Purpose of collection and use: All purposes listed in Section 2 of the Notice above. Categories of Parties With Whom PI is Shared: Affiliates; Service Providers	If hired, this data will be retained for the duration of employment plus 5 years. If not hired, we will retain your Personal Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.
Protected classification characteristics under California or federal law	Age (40 years or older), national origin, marital status, gender, veteran or military status Source: Directly from you Purpose of collection and use: All purposes listed in Section 2 of the Notice above. Categories of Parties With Whom PI is Shared: Affiliates; Service Providers.	If hired, this data will be retained for the duration of employment plus 5 years. If not hired, we will retain your Personal Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.
Internet or other similar network activity	Device ID, browsing history, search history, and information regarding your interaction with an internet website, or application. Source: Automatically generated when you use the Services. Purpose of collection and use: All purposes listed in Section 2 of the Notice above. Categories of Parties With Whom PI is Shared: Affiliates; Service Providers.	Internet/Network activity on our website is retained for 14 months. If hired, third party data will be retained for the duration of employment plus 5 years. If not hired, we will retain your Personal Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.
Education information	Institutions attended, degrees obtained, and courses taken Source: Directly from you Purpose of collection and use: All purposes listed in Section 2 of the Notice above. Categories of Parties With Whom PI is Shared: Affiliates; Service Providers.	If hired, this data will be retained for the duration of employment plus 5 years. If not hired, we will retain your Personal Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.
Inferences drawn from other information	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Source: We do not actively create profiles of the preferences or interests of our employees; however, certain information may be collected incidentally about you over the course of your employment, either directly from you or from the individuals you interact with, for instance in performance evaluations. Purpose of collection and use: All purposes listed in Section 2 of the Notice above. Categories of Parties With Whom PI is Shared: Affiliates; Service Providers.	If hired, this data will be retained for the duration of employment plus 5 years. If not hired, we will retain your Personal Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.

9. Changes to our Job Application Notices

We reserve the right to modify, alter, or update the terms and conditions of this Notice from time to time without prior notice. We will post those changes on this page in addition to updating the “Last Updated” at the top of this webpage. Modifications shall become effective immediately upon being posted, distributed, or disseminated

10. Contact Us

If you have any questions about this Notice or our information handling practices, please contact us at dataprivacy@acijet.com or call (844) 600-9715.

11. Access to Privacy Policy

For more information, please review ACI Jet’s Privacy Policy here.