Workday Privacy Policy

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Introduction

This privacy notice (“Notice”) applies to California residents, and applies solely to visitors, users, and others who reside in the State of California when you apply or are recruited for a job with us. This Notice describes the categories of personal information that we collect and the purposes for which we use that information.   

We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice. For this Notice, “personal information” has the meaning provided in the CCPA, but excludes information exempted from the CCPA’s scope.  

This Notice does not create or form part of any contract for employment or otherwise.

If you have questions about this Notice, please contact our Legal Department at:

Lower, LLC
Attn: Legal Department
8621 Robert Fulton Drive, Ste. 150
Columbia, MD 21046

OR

Legal@Lower.com

Lawful Bases

We will only collect and process personal data about you where we have lawful bases. Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us using the information provided above.

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Information We Collect About Candidates

We collect information that you voluntarily provide when you apply for a job and throughout the job application process. While throughout the job application process, we may collect your personal information from other sources based on the personal information you provide us and combine the information.

A. Below is the information you voluntarily provide that we collect:

• Personal Contact Information like your home address, telephone number, and email address;
• Biographical Information like your name, gender, education, professional work history, and information you make publicly available through career networking, and job search websites;
• Immigration status and other information that would allow us to verify your employment eligibility;
• Professional qualifications such as certifications, licenses, and memberships;
• Information necessary to complete background, credit, and other additional checks or verifications when permitted by law, and information received during the course of the process;
• Employment history;
• Information you provide in your job application or to recruiters like your job application, resume or CV, cover letter references, education history, work history, criminal history (where permitted by applicable law), another information you provide in the course of your discussions with recruiters or throughout the job application process;
• Information provided to understand or assess your accommodation requests regarding your potential disabilities or health conditions, if applicable;

B. Based on the information you voluntarily provide, we may collect other personal information (permitted by applicable law) form additional sources such as:

• Prior employers;
• Educational institutions;
• Pre-employment screening services;
• Job board websites; and,
• Social media and other publicly-available sources.

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How We Use Personal Information About Candidates

We may use the listed personal information for the following purposes:

• Recruiting, interviewing and evaluating job candidates;
• Analyzing and improving our application and recruit process;
• Conducting background checks and other pre-employment screening (where permitted by law);
• Accommodating disabilities or health conditions;
• Communicating with you regarding your candidacy and job opportunities within the company; and
• Business operations;
• Compliance with internal policies and procedures, and other legal requirements;
• Compliance with lawful requests or legal regulations;
• Detecting, investigating and helping prevent security, fraud or technical issues;
• Sharing information to comply with requests from government authorities, courts, or law enforcement;

We may share the personal information with the following third-parties:

• Government and legal authorities;
• Our attorneys, business advisors, and other professional advisors;
• Our subsidiaries, other affiliate organizations, and business partners.

Other Information about this Notice

We reserve the right to change this Notice at any time. The “Last Update” heading at the bottom of this Notice indicates when it was last revised. Any changes will become effective when we post the revised notice. You are responsible for periodically visiting this Notice to check for any changes.

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Your Rights 

Under the CCPA, you have the right to request the following, as applicable:

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A.    Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).

B.    Deletion Request Rights

You have the right to request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary to:

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

This list is not exhaustive.

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C.    Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at privacy@lower.com. 

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must 1) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and 2) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

D.   Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to the registered email associated with the account. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

Children’s Privacy

We do not knowingly collect information from children under the age of 18.

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Last Update

This Notice was last updated in May 2024.