ZWICKER & ASSOCIATES, P.C.
JOB APPLICANT PRIVACY NOTICE
This Job Applicant Privacy Notice (“Notice”) explains how Zwicker & Associates, P.C.
(hereinafter, “Zwicker”, “we”, “our” or “us”) collects, uses, discloses, and otherwise processes
personal information about job applicants and recruits. This Notice also describes certain rights
job applicants and recruits may have under state-specific laws based on their location.
This Job Applicant Privacy Notice is not a contract and does not create any legal rights or
obligations. This Job Applicant Privacy Notice 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
in our organization, which will supersede any conflicting disclosures contained in this Job
Applicant Privacy Notice.
In connection with our recruiting efforts, we make our website ("Site") available to job
applicants for the purpose of advertising open positions and accepting job application
information from prospective employees. We do this through our recruiting platform provider
which is an independent third-party recruitment services provider. The recruiting platform’s
terms of use and privacy policies may differ from Zwicker’s. If you submit information through
the recruiting platform, you acknowledge and agree that (1) Zwicker does not endorse or take
responsibility for the recruiting platform’s sites or their services; (2) Zwicker will not be liable to
you for any damage, loss or expense caused by the recruiting platform’s sites, including for any
security breach, information disclosure or loss of data, and you hereby expressly waive any claim
against Zwicker for such losses; and (3) before using the recruiting platform’s sites, you will
review their terms of use and privacy policies. (If you do not accept the recruiting platform’s
terms or policies or are unwilling to release Zwicker from liability for their actions or inactions,
you should not create an account there).
WHAT IS PERSONAL INFORMATION?
When we use the term “Personal Information” in this Notice, we 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 your role as a job
applicant or recruit. It does not include aggregated, deidentified, or anonymized information that
is maintained in a form that is not capable of being associated with or reasonably linked to you.
Where we maintain deidentified data, we will maintain and use the data in deidentified form and
not attempt to reidentify the data except as required or permitted by law.
INFORMATION WE COLLECT ABOUT JOB APPLICANTS AND RECRUITS AND
WHAT WE DO WITH IT
In connection with the recruiting process, we collected and disclosed for a business purpose the
following categories of Personal Information in the preceding 12 months from job applicants and
recruits as indicated in the chart below. The below information is also information which we
may collect and disclose throughout your recruitment and job application process. We do not
“sell” or “share”, as those terms are defined by the California Consumer Privacy Act as amended
by the California Privacy Rights Act, any personal information.
Categories of Personal Information We Collect:
We Disclose this Category of Information to:
Identifiers such as a real name, alias, postal address,
unique personal identifier, online identifier, Internet
Protocol address, email address, account name,
social security number, driver’s license number,
passport number, or other similar identifiers.
Recruiting platform and background
screening provider
Personal information as defined in the California
customer records law, such as name, signature,
social security number, passport number, driver’s
license or state identification number, contact
information, education, employment, employment
history and financial information.
Recruiting platform and background
screening provider
Characteristics of protected classifications under
California or federal law, 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 process.
Recruiting platform and background
screening provider
Commercial Information, including records of
personal property, products or services purchased,
obtained, or considered, or other purchasing or
consuming histories or tendencies
We do not disclose this information.
Internet and Network Information, such as technical
details about your visit to our online services
contained in log files or analytics data relating to
your usage and activity on our online services.
For more information, please refer to
the general Privacy Notice.
Professional or employment-related information
such as your previous employers, positions and
work experience, professional licenses, certificates
or other qualifications, employment references or
referrals, your previous or desired salary, bonus,
benefits, expenses, and stock or equity grants, and
information needed to establish your eligibility to
work for us, including visa information.
Recruiting platform and background
screening provider
Education information subject to the Federal
Family Educational Rights and Privacy Act, such as
your highest level of education, the schools you
attended and when you were in attendance, degrees,
Recruiting platform and background
screening provider
certificates or other educational qualifications you
earned, and your transcripts or educational records.
Inferences, such as inferences or predictions about
job applicants and recruits, and their abilities,
interests, or preferences based on the other Personal
Information we collect and the interactions we have
with them.
We do not disclose this information.
In addition to the categories of Personal Information identified above, we may also collect any
Personal Information you chose or choose to share with us in your interview or application, CV,
resume, cover letter, transcripts or other supporting documentation. We may collect Personal
Information in connection with a background check. We also may disclose Personal Information
about our job applicants or recruits, with their consent or direction, to certain other third parties.
Sensitive information we collected. The following Personal Information elements we collect
about our job applicants and recruits may be classified as “sensitive” under certain privacy laws
(“sensitive information”):
Social Security number, driver’s license number, passport number;
Information relating to racial and ethnic origin, citizenship or immigration status,
religious beliefs, health, disabilities, sexual orientation, and gender identity.
We disclose sensitive information as described above. We do not sell sensitive information about
individuals acting in their capacity as recruits or job applicants, and we do not share or otherwise
disclose sensitive information about individuals acting in their capacity as recruits or job
applicants for the purpose of targeted advertising, nor use such information for the purpose of
inferring characteristics about our recruits or job applicants.
We collected Personal Information from these sources. Although we often collect the
Personal Information described above directly from you, we may also collect this information
from other categories of sources such as: recruiters, job-related social media sites (such as
LinkedIn), and publicly available sources. In addition, we may also engage service providers
and other third parties who collect this information, such as recruitment platform providers and
background screening providers.
We collected and used this Personal Information for business purposes. Specifically, we use
the Personal Information collected during the recruitment process and when you apply for a job
with us to:
Identify you as a potential candidate and review your initial application for a position with
us;
Determine your eligibility and suitability for the potential position or other opportunities with
us;
Communicate with you about the status of your application or other opportunities with us
that may be of interest to you;
Conduct internal investigations, audits, compliance, risk management, problem resolution
and security operations;
Comply with applicable law, rule, regulation, legal proceedings, and government
investigations, including relating to tax reporting and immigration.
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 use or 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 used or disclosed in the
event of insolvency, bankruptcy, or receivership.
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.
Retention of Personal Information. We retain Personal Information that we collect about you
for as long as it is (l) legally permitted and (2) necessary in our discretion to comply with legal
obligations, maintain business and financial records, resolve disputes, maintain security, and to
detect and prevent fraud and abuse.
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), we will not further
process the Personal Information until deletion or deidentification is possible.
CONNECTICUT RESIDENTS ONLY
When Zwicker collects Social Security numbers in the course of our business, it is our general
policy to (1) protect the confidentiality of Social Security numbers pursuant to our internal
policies and procedures applicable to such information; (2) prohibit the unlawful disclosure of
Social Security numbers; and (3) limit access to Social Security numbers to only those personnel
or service providers who have a legitimate business need to access such information.
CALIFORNIA RESIDENTS ONLY
The following disclosures only apply to residents of the State of California.
No Sales or Targeted Advertising
Except as otherwise described in our website Privacy Notice in connection with job applicants
acting in their capacity as website visitors, we do not sell Personal Information about individuals
acting in their capacity as our recruits or job applicants, and we do not share or otherwise
disclose such Personal Information 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”).
Your California Privacy Choices
As a resident of the State of California, you may be entitled to certain rights (subject to certain
limitations at law) under California law as follows:
Right to Know: You have the right to confirm whether we are processing Personal
Information about you and to obtain certain personalized details about the Personal
Information we have collected about you, including the categories of Personal Information
that we have collected, used, or disclosed for a business purpose, the categories of sources
from which the Personal Information is collected, the business or commercial purpose for
collecting the Personal Information, and the categories of third parties to whom such
information was disclosed.
Right to Access & Portability: You have the right to obtain access to the Personal
Information we have collected 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.
Right to Delete: You have the right to request that we delete Personal Information that we
collect about you, subject to applicable legal exceptions.
Right to Correct: You have the right to request that we correct any inaccurate Personal
Information that we have collected about you.
Right to Non-Discrimination: We will not discriminate against or retaliate against you for
exercising any of these privacy rights afforded to you under California law. However, please
note that if the exercise of these rights limits our ability to process Personal Information, we
may no longer be able to engage with you in the same manner.
Submitting a Request to Us
If you wish to exercise any of the privacy rights identified above, you may submit your request
to us through the following channels:
Requests by mail
Zwicker & Associates, P.C.
ATTN: Privacy
80 Minuteman Road
Andover, MA 01810-1031
Requests by email privacy@zwickerpc.com
Requests by telephone (800) 446-6680
To make a verified consumer request under California law, we require that you submit proof of
your identity and confirm you are a resident of the State of California. In order for us to act on
your request, you must provide your name, home address, and the last four digits of your social
security number. This information will be used only for the purposes of verifying your identity
by comparing it to our records and processing your request. In some cases, we may need to ask
for additional information to verify your identity. We may not be able to comply with your
request if we are unable to confirm your identity because you did not supply the required
information or if we are unable to connect the information you submit in your request with
Personal Information in our possession.
In certain circumstances, we may decline a request to exercise the rights described above,
particularly where we are unable to verify your identity or locate your information in our
systems. If we are unable to comply with all or a portion of your request, we will explain the
reasons for declining to comply with the request.
Authorized Agents
You may also authorize an agent to submit a request on your behalf through the same means
identified above. An authorized agent must have your signed permission to submit a request on
your behalf or provide proof that they have power of attorney in accordance with California
probate law. Authorized agents that are business entities must be registered with the California
Secretary of State to conduct business in California. Before completing requests from authorized
agents, we may contact you directly to confirm you’ve given your permission and/or to verify
your identity.
UPDATES TO THIS NOTICE
We will update this Notice from time to time. When we make changes to this Notice, we will
change the "Last Updated" date at the bottom of this Notice. If we make material changes to this
Notice, we will notify you by email, by prominent posting on our website and our recruiting
platform, or through other appropriate communication channels. All changes shall be effective
from the date of publication unless otherwise provided in the notification.
CONTACT US WITH QUESTIONS
If you have any questions or requests in connection with this Notice or other privacy-related
matters, you may contact us through any of the methods below:
By Mail: By Email: By Telephone:
Zwicker & Associates, P.C.
ATTN: Privacy
80 Minuteman Road
Andover, MA 01810-1031
privacy@zwickerpc.com (800) 446-6680
Version: 4.0
Last Updated: September 10, 2024