California Applicant Privacy Disclosures

Effective Date: July 1, 2025

These California Applicant Privacy Disclosures (“CA Applicant Disclosures”) inform California residents applying for or interested in applying for a role at eMoney Advisor, LLC or one of its affiliates, (collectively “eMoney,” “we,” or “us,” or “our”) of our practices regarding the collection, use, and disclosure of your personal information as a job applicant through our Careers website (the “Site”), including through a recruiter, to facilitate your job application (“Applicant Personal Information”). These CA Applicant Disclosures should be read in association with all other Company policies that may be provided to you as part of the application process.

Unless otherwise noted, these CA Applicant Disclosures describe how and why we collect, use, and disclose personal information subject to the CCPA, as well as how we have collected, used, and disclosed that personal information in the prior 12 months.

I. COLLECTION AND USE OF APPLICANT PERSONAL INFORMATION

We may collect Applicant Personal Information from a variety of sources, including directly from you, from recruiters, automatically when you visit our Site, from our service providers and contractors, and from our affiliates. This includes:

Identifiers: such as name, postal address, phone numbers, email address, and similar identifiers.
Personal Information Categories in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)): such as name, signature, address, telephone number, national identification number (i.e., Social Security Number, Driver’s License), education, employment, and employment history.
Characteristics of protected classifications: such as age and date of birth, race, ancestry, ethnic origin, sex, gender, gender identity, military or veteran status, medical condition, disability.
Internet or other electronic network activity information: such as browser type and language, operating system, website access time, duration of visit, referring website address, browsing and search history on our Site, webpages viewed immediately before and after our Site, and information related to your interactions with our Site.
Geolocation data: such as geographic location inferred from your device IP address or otherwise provided by you.
Sensory information: such as security camera recordings, videos, photos, and audio, including job interview recordings.
Professional or employment-related information: such as skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, application form, or cover letter; answers to behavioral or other screening questions in an application or interview; information contained in any websites or documents you choose to share with us; professional licenses, training, disciplinary actions, and membership in professional organizations; and membership in civic organizations.
Non-public education information: such as school(s) attended, grades, transcripts, records of attendance, disciplinary records, and other information relating to your secondary and post-secondary education, including any graduate or professional degrees.
Inferences drawn from the Applicant Personal Information above, except from characteristics of protected classifications: such as preferences, characteristics, predispositions, behavior, or attitudes.
Sensitive Personal Information: such as Social Security number or driver’s license number; race or ethnic origin; citizenship or immigration status; and information relating to any disability or medical condition that is relevant to your role, including information relevant to accommodation requests.

II. USE OF APPLICANT PERSONAL INFORMATION

We may use and disclose the categories of Applicant Personal Information identified for our business purposes, including:

Recruiting and hiring, such as opening and maintaining your application records; communicating with you regarding your application; confirming eligibility, qualification, and background checks; communicating with any references, former employers, or other parties that provide information related to your candidacy; and providing you with relevant jobs and opportunities in your area.
Operating our business, such as providing and maintaining the functionality of our Site; reviewing the usage of and improving the quality of our Site and our recruiting function; conducting internal operations pertaining to research, analytics, testing, monitoring, communications, risk management, and administration; and management planning.
Technology and security purposes, such as providing you with a better application experience.
Fulfilling our legal obligations, such as complying with applicable legal and regulatory requests and obligations (including investigations); fulfilling work authorization, identity verification, immigration, audit, health, safety, employment, and other legal requirements; providing reasonable accommodations; establishing or defending legal claims and allegations; complying with applicable laws, regulations, or legal process; seeking advice from lawyers, auditors, and other professional advisers; and preventing, investigating, identifying, or taking other action regarding legal claims, compliance, regulatory, and investigative activities.
Maintaining security and preventing fraud, such as maintaining the security of our Site and business operations and preventing, detecting, or investigating fraud, suspected or actual illegal activity, violations of company policy or rules, or other misconduct.
Carrying out corporate transactions, such as disclosing Personal Information as part of a corporate transaction or proceeding, such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.

III. DISCLOSURE OF APPLICANT PERSONAL INFORMATION

To carry out the business purposes described above, we may disclose Applicant Personal Information to the following recipients: eMoney corporate affiliates; service providers, vendors, and contractors, including data analytics, security, background check, human resources, and information technology providers; references, former employers, or other parties that provide information related to your candidacy; business partners; professional advisers; and state or federal governmental agencies.

IV. RETENTION PERIOD CRITERIA FOR APPLICANT PERSONAL INFORMATION

To determine the appropriate retention period for Applicant Personal Information, we consider applicable legal requirements; the amount, nature, and sensitivity of the Applicant Personal Information; the potential risk of harm from unauthorized use or disclosure of Applicant Personal Information; the purposes for which we process Applicant Personal Information, and whether we can achieve those purposes through other means.

V. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and other tracking technologies (such as web beacons) to collect and store information about your interactions with our Site, including information about your browsing behavior.

Cookies are small files that a website transfers to your device through a web browser that enable the Site’s systems to recognize your device and to capture and remember certain information. Web beacons (also known as tracking pixels) are tiny graphics embedded invisibly on a webpage or in an email that may be used to deliver or communicate with cookies, to count users who have visited certain pages, and to understand usage patterns. In general, our Site uses cookies and other tracking technologies as follows:

Where necessary to run our Site;
To optimize the functionality of our Site, including by personalizing content for you, greeting you by name and remembering your preferences (e.g., your choice of language or region);
For analytics purposes—for example, to help us understand how our Site is used.

Our Site uses analytics technology, including Google Analytics, to understand how users interact with the Site, improve our web experience, and better market our products. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

VI. YOUR PRIVACY RIGHTS

Subject to certain limitations, the California Consumer Privacy Act (“CCPA”) provides California residents the right to submit certain requests relating to their Personal Information as described below.

Right to Opt-Out of Sharing and Sale of Applicant Personal Information.

We do not sell Applicant Personal Information or share it for cross-context behavioral advertising.

Right to Limit Use and Disclosure of Sensitive Personal Information.

We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

Right to Know. You have the right to send us a request, no more than twice in a twelve-month period, for any of the following:

The categories of Personal Information we have collected about you, including:

The categories of sources from which the Personal Information was collected.
Our business or commercial purposes for collecting, selling, or sharing Personal Information.
The categories of recipients to which we disclose Personal Information.
The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information.

The specific pieces of Personal Information we have collected about you.

Right to Delete. You may request that we delete your Applicant Personal Information that we have collected directly from you and are maintaining. Where we use deidentification to satisfy a deletion request, we commit to maintaining and using the information in deidentified form and will not attempt to reidentify the information.

Right to Correct. If you believe that any of the Applicant Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.

To exercise the right to know, right to delete, or right to correct, you may submit a request by clicking here, or calling us at 1-888-362-8482 and including your name, address, email address, and phone number. We will contact you for further information if necessary. In order to complete your request, you will be required to respond to any follow up inquires we may make, and we may deny your request if you do not do so.

Any Request to Know, Request to Delete, and Request to Correct you submit to us is subject to an verification process. Typically, you will be asked to provide 2-3 pieces of Personal Information that we will match against our records to verify your identity. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the Applicant about whom we collected Applicant Personal Information.

You may use an authorized agent to submit your request. If you use an authorized agent to submit a request, we may require proof that the agent has been authorized by you to do so, and take other steps permissible under the CCPA, to ensure it is a proper request by an authorized agent.

If you choose to exercise any of your privacy rights under the CCPA, we will not discriminate or retaliate against you.

VII. CHANGES TO THESE CA APPLICANT DISCLOSURES

We reserve the right to amend these CA Applicant Disclosures at any time in order to address future developments affecting eMoney or the Site, and industry or legal trends. Any changes will become effective upon the posting of the revised CA Applicant Disclosures on the Site. By continuing to use the Site following such changes, you will be deemed to have agreed to such changes. If you do not agree with these CA Applicant Disclosures, in whole or part, you can choose to not continue to use the Site or otherwise provide Applicant Personal Information to us.

VIII. CONTACT US

If you have any questions regarding these CA Applicant Disclosures, please contact us by email at privacy-px@emoneyadvisor.com using the subject title of “California Applicant Privacy Disclosures.”