Aledade Applicant Privacy Policy

Last revised: December 30, 2022

Thank you for your interest in working with Aledade, Inc. (“Aledade,” “we,” “our,” “us”). This Privacy Policy (“Policy”) applies to the personal information about our California-based recruits and job applicants, and describes:

1. Scope of this Policy.

Personal information. We use “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked – directly or indirectly – to you within the context of you acting as a job applicant. For this Policy, “personal information” does not include (a) aggregated or deidentified information that is not capable of being associated with or reasonably linked to an individual, or (b) public information lawfully available from governmental records.

Not a contract for employment. This Policy is not a contract and does not create any legal rights or obligations. This Policy also is not intended to replace other notices or disclosures we may provide to you in connection with your application for a job or eventual role with us, which will supersede any conflicting disclosures contained in this Policy.

2. Changes and Updates to this Policy.

We will update this Policy from time to time. When we make changes to this Policy, we will change the “Last revised” date at on this page. If we make material changes to this Policy, we will notify you by email or through other appropriate communication channels. All changes are effective from the date of publication unless otherwise provided in the notification.

3. Personal Information We Collect.

This section describes the categories of personal information we may collect about you during the recruitment process and when you apply for a job with us. The types of personal information listed in each category are examples only and are not exhaustive.

  • Personal identifiers and contact information, such as your full name, email address, home address and telephone number.
  • Professional history and qualifications, such as your previous employers, positions and work experience, professional licenses, certificates or other qualifications, and employment references or referrals.
  • Educational history and qualifications, such as your highest level of education, the schools you attended and when you were in attendance, degrees, certificates or other educational qualifications you earned, and your transcripts or educational references.
  • Financial information, such as your previous or desired salary, bonus, benefits, expenses, and stock or equity grants.
  • Background check and reference check information, when permitted by applicable law, we may choose to conduct a background check and/or a reference check in connection with your potential employment such as to verify professional and educational history and qualifications or to identify criminal history that may be relevant for a position with us. The results of the background check and/or reference check may include personal information we do not already have about you.
  • Audio / visual recordings: such as a recording of image or voice in connection with phone calls, virtual interviews, and other events, where permitted by law.
  • Equal opportunity information, such as age, race, ethnicity, national origin, citizenship, sex, gender identity, sexual orientation, religion, disability or accommodation request, or marital or veteran status when you choose to provide it, but it will not be used in the hiring decision.
  • Web log and cookie information, such as device identifiers, user ID, IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and/or clickstream data, cookie identifier, browsing and search history. For more information, please refer to the general Privacy Notice on our website.
  • Other application and interview information, including any personal information you choose to share with us in your interview or application, CV, resume, transcripts or other supporting documentation.

Sensitive Information. Please note that some of the information described above may also be considered “sensitive information” under applicable law. The following personal information elements we may collect about job applicants may be classified as “sensitive” under certain privacy laws (“sensitive information”):

  • Social Security number, driver’s license number, passport number
  • Job applicant-related accounts and passwords
  • Financial account information
  • Information relating to racial and ethnic origin, disabilities, citizenship / immigration status, sexual orientation, and gender identity

We use personal information, including this sensitive information for the purposes set forth in the Personal Information We Collect, How We Collect Personal Information, and How We May Use Personal Information sections below.

We do not sell sensitive information about individuals acting in their capacity as job applicants, and we do not share or otherwise disclose sensitive information about individuals acting in their capacity as job applicants for the purpose of targeted advertising or cross-context behavioral advertising, nor use such information for the purpose of inferring characteristics about our job applicants.

4. How We Collect Personal Information.

We collect personal information from the following sources:

  • You, including information you provide in your application or during an interview.
  • Third parties, including:
    • business contacts such as those that refer you as a job candidate;
    • references, recruiters, job-related social media sites (such as LinkedIn);
    • service providers and other third parties that collect it on our behalf, such as communications providers, scheduling providers and application providers; and
    • publicly available sources.

5. How We May Use Personal Information.

We use the personal information we collect during the recruiting process and when you apply for a job with us to:

  • Identify you as a potential candidate and review your application for a position with us.
  • Verify the information provided to us in connection with your application or received from other sources.
  • Determine your eligibility and suitability for the potential position or other opportunities with us.
  • Facilitate the recruiting and interview process.
  • Communicate with you about the status of your application or other opportunities with us that may be of interest to you.
  • Assess and improve the performance and success of our recruiting and hiring process.
  • Conduct internal investigations, audits, compliance, risk management, problem resolution and security operations.
  • Fulfill contractual obligations to you and other third parties.
  • Comply with applicable law, rule, regulation, legal proceeding and government investigations, including relating to tax reporting and immigration.

Please note that if you accept an offer from us, we may transfer the personal information we collected about you during the recruiting and job application process to your personnel file with us.

6. Who We Share Personal Information With.

We may share your personal information with the following third parties for the purposes described below:

  • Within Aledade. We share personal information relating to job applicants and recruits within our family of companies for internal administrative purposes and uses that are consistent with this Policy.
  • Recruiters and job application providers. We often engage recruiters and job application providers to assist us in identifying potential job applicants and processing job applications we receive. For these third parties to assist us in the recruiting and job application process, we share personal information about potential and current personnel with them.
  • Background check providers. When permitted by applicable law, we may choose to conduct a background check in connection with a job application, such as to verify professional and educational history and qualifications or identify criminal history that may be relevant for a position with us. To facilitate the background check, we share personal information about the relevant job applicant with trusted background check providers.
  • Other service providers. In addition to the third parties identified above, we engage other third parties to perform certain functions on our behalf in connection with the uses of personal information described in the Personal Information We Collect, How We Collect Personal Information and How We May Use Personal Information sections above, including assisting us with our recruiting process, personnel management, benefits and services offerings and other related business operations. Depending on the function the third party serves, the service provider may process personal information on our behalf or have access to personal information while performing functions on our behalf.
  • Business transaction or reorganization. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
  • Legal obligations and rights. We may disclose personal information to third parties, such as legal advisors and law enforcement:
    • in connection with the establishment, exercise, or defense of legal claims;
    • to comply with laws and regulations or to respond to lawful requests and legal process;
    • to protect our rights and property and the rights and property of our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
    • to detect, suppress, or prevent fraud;
    • to reduce credit risk and collect debts owed to us;
    • to protect the health and safety of us, our customers, or any person; or
    • as otherwise required by applicable law.
  • Consent. We may disclose personal information about you to certain other third parties with your consent.

Please note we do not sell the personal information of our job applicants, and we do not share or otherwise disclose such personal information to third parties for the purpose of displaying advertisements that are selected based on personal information obtained or inferred over time from an individual’s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”).

7. How You Can Control Your Privacy Preferences.

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

The Right to Know

The right to confirm whether we are processing personal information about you and – under California law only – to obtain certain personalized details about the personal information we have collected about you, including the:

  • categories of personal information collected;
  • categories of sources of the personal information;
  • purposes for which the personal information were collected;
  • categories of personal information disclosed to third parties (if any), and the categories of recipients to whom the personal information were disclosed;
  • categories of personal information shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal information were disclosed for those purposes; and
  • categories of personal information sold (if any), and the categories of third parties to whom the personal information were sold.

The Right to Access & Portability

The right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

The Right to Correction

The right to correct inaccuracies in your personal information, considering the nature of the personal information and the purposes of the processing of the personal information.

The Right to Control Over Sensitive Information

The right to exercise control over our collection and processing of certain sensitive information.

The Right to Deletion

The right to have us delete the personal information we maintain about you. After receiving and appropriately verifying a request to delete, we will delete the personal information we have collected about you, except for situations where specific information is necessary for us to:

  • perform a contract we entered into with you;
  • maintain the functionality or security of our systems; or
  • comply with or exercise rights provided by the law.

In addition, the law permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided it to us or that are reasonably aligned with your expectations based on your relationship with us.

Non-discrimination / Non-retaliation. Depending on your state of residency, you have the right to not receive retaliatory or discriminatory treatment if you exercise any of the above rights.

8. How to Exercise Your Rights.

To submit a request to exercise one of the privacy rights identified above, please:

  • Email us at privacy@aledade.com with the subject line “Applicant Opt-Out Request” and sufficient information in the content of the message to identify you in our records;
  • or Contact us at 866-252-0873.

Before processing your request, we will need to verify your identity. In order to verify your identity, we will generally either require the successful authentication of your work-related account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. We may at times need to request additional personal information from you, taking into consideration our relationship with you and the sensitivity of your request.

In certain circumstances, we may decline a privacy rights request, particularly where we are unable to verify your identity.

Authorized Agents. In certain circumstances, you may designate an agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

9. How Long We Retain Personal Information.

We retain personal information only for as long as is reasonably necessary to fulfil the purpose for which it was collected. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax, and accounting requirements set by a legislature, regulator, or other government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

Once retention of the personal information is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), then we will securely store the personal information and isolate it from further processing until deletion or deidentification is possible.

10. Contacting Us.

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

Mail:

Aledade, Inc.

Attn: Privacy Officer

4550 Montgomery Avenue, Suite #950N

Bethesda, MD 20814

Email: privacy@aledade.com