Financial Analyst - Accounting and Treasury Operations

Effective Date: January 1, 2023 

The California Consumer Privacy Act (“CCPA”) requires Mission Lane LLC (“Mission Lane”  “we”, “us” and “our”) to inform California residents who apply for our jobs (“Job Applicants”) about the categories of “Personal Information” (“PII”) we collect about them and the purposes for which we collect, use or disclose that information.  This Job Applicant Privacy Policy and Notice at Collection contains disclosures required by the CCPA and applies only to “Personal Information that is subject to the CCPA.  Some of the data collection and uses described below may not apply to you.   

We may also provide you additional privacy notices regarding our collection, use or disclosure of information. Please read this Policy and any other privacy notices carefully. Please note that this Policy does not form part of any employment contract or contract to provide services.

Individuals with disabilities can access this notice by using assistive technology such as a screen reader.

• Types of Personal Information We Handle

We collect, store, and use various types of information that identifies, relates to, or could reasonably be linked to you in connection with your application for employment at Mission Lane. We collect such information either directly from you or (where applicable) from another person or entity, such as an employment agency, recruitment company, or others who provide references.  We will collect additional Personal Information throughout the course of your application process.

The information we collect from and about Job Applicants includes, where applicable:

• Personal and online Identifiers such as full name, home and business addresses, telephone numbers, and email addresses, or unique online identifiers.

• Categories of information described in Section 1798.80(e) of the California Civil Code (such as Social Security number, or driver’s license or state identification number)

• Characteristics of protected classifications under California or federal law

• Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement)

• Professional or employment-related information, including:

o  Recruitment, employment, or engagement information such as application forms and information included in a resume, cover letter, references or otherwise provided through the application and recruitment process, and our evaluations of your performance during the interview process.

o  Career information such as job titles; work history; work dates and work locations; salaries; information about skills, qualifications, experience, publications, speaking engagements; and professional memberships.

o   Business travel and expense information such as travel itinerary information and expenses incurred for travel during the interview process.

o   Other information that you may voluntarily choose to include on your resume or in connection with your application.

• Education Information such as institutions attended, degrees, certifications, training courses, publications, and transcript information.

• Background check information, including any information required to perform a background check in accordance with applicable law, such as citizenship status, and passport or other photo ID.

• Audio or visual information such as CCTV footage, as well as other information relating to the security of our premises collected during in-person interviews, visits to our offices, or other parts of the recruitment process, or where relevant, audio/video recordings of online interviews. 

• Health-related information, only as necessary to provide necessary accommodations at your request during the recruitment process.

• Inferences drawn from the above information about your predicted characteristics and preferences.

• Other information that directly or indirectly identifies you, such as date and place of birth, citizenship, and permanent residence.

2.   How We Use Personal Information

We have or will collect, use, share, and store Personal Information for Mission Lane’s business purposes, which include, where applicable:

• Processing, evaluating, and communicating with you about your application, including to check references, carry out background checks where we deem necessary and in compliance with applicable legal requirements, and communicate with you about other jobs that may interest you.

• Human resources management and administration, including determining compensation, scheduling, fraud prevention and investigation, IT and informational security purposes, conducting internal analyses and audits in accordance with applicable legal requirements.

• Engaging in the recruitment process, including job advertising, interviewing, testing, and selecting and hiring new personnel.

• Legal compliance, such as complying with applicable laws, and responding to and cooperating with legal or regulatory requests and investigations.

• Exercising our legal rights, including seeking legal advice from our external lawyers or in connection with litigation.

• Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics.

• Internal operations.

• Activities to maintain and improve our business.

• Other one-time uses.

We may also use Personal Information for any other legally permitted purpose (subject to your consent, where legally required).

Except where you provide such information voluntarily on your resume or in your application, we do not collect Personal Information that is considered “sensitive” under applicable law during the recruitment process. Such voluntary information may include equal opportunity monitoring data which could include information about your race or ethnicity, religious beliefs, sexual orientation, or health. We only use this information to monitor equality of opportunity and diversity in our recruitment process.

Sensitive information. Note that certain of the information we collect, including race, ethnicity, religious beliefs, sexual orientation, biometrics and health information, is considered "sensitive personal information" under California law.  We only collect such information for the purposes disclosed in this Notice, and not for any purposes for which California law provides a "right to limit" such use.

1.     How We Share Personal Information

We may disclose certain Personal Information to the following types of entities or in the following circumstances (where applicable):

• Internally and among Mission Lane affiliates: to employees within the Mission Lane entities that participate in the recruitment process, such as HR managers and employee interviewers.

• Service Providers: such as travel providers, testing companies, and applicant tracking system providers. These entities process your Personal Information on Mission Lane’s behalf in performing services for Mission Lane, and are subject to restrictions on use of your Personal Information.

• Recruiters: to the extent you are working with a recruiter in connection with your application for employment and your recruiter is authorized by you to obtain feedback from us regarding your application and interview process.

• Legal compliance and exercising legal rights: when required to do so by law, regulation, or court order or in response to a request for assistance by the police or other law enforcement agency; and to seek legal advice from our external lawyers or in connection with litigation with a third party.

• Business Transaction Purposes: in connection with the sale, purchase, or merger of all or a portion of our business.

• Consent: with your consent and as permitted by law, we may share Personal Information with any other third parties in any other circumstances.

4.   Data Retention 

The Personal Information we collect from Job Applicants will be retained for as long as necessary to satisfy the purposes for which it was collected and our legal obligations.  As described above, these purposes include our business operations (including maintaining your information for a period of time to consider you for other opportunities) and complying with reporting, legal and accounting obligations. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the Personal Information, the purposes for which we process the Personal Information and whether we can achieve those purposes in other ways, the applicable legal requirements, and our legitimate interests.  If you are offered and accept employment with Mission Lane, the Personal Information we collected during the application and recruitment process as described herein will become part of your employment record. If you do not become an employee, or, once you are no longer an employee of Mission Lane, we will retain and securely destroy your Personal Information in accordance with our document retention policy and applicable laws and regulations.

5.  Additional Privacy Information for California Residents 

California residents have certain rights regarding their Personal Information. Subject to certain exceptions, if you are a California resident, you may request:   

• access to your Personal Information including the right to know the categories of Personal Information we have or will collect about you and the reason we will or have collected such information;
• correction of the Personal Information that we have or will hold about you that is inaccurate;
• deletion or removal of your Personal Information.

You also have the right not to be discriminated against (as provided for in California law) for exercising your rights.

Exceptions to Your Rights: There are certain exceptions to these above rights. For instance, we may retain your Personal Information if it is reasonably necessary for us or our service providers to provide a service that you have requested or to comply with law or to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for that activity.

Exercising Your Rights: To exercise one of the rights above, you may contact us as provided below.

We will take reasonable steps to verify your identity before responding to a request. In doing so, we may ask you for verification information so that we can match at least two verification points with information we maintain in our files about you. If we are unable to verify you through this method, we shall have the right, but not the obligation, to request additional information from you.

California law places certain obligations on businesses that “sell” Personal Information to third parties or “share” Personal Information with third parties for “cross-context behavioral advertising” as those terms are defined under the California Consumer Privacy Act (“CCPA”). We do not “sell” or “share” the Personal Information covered by this Policy and have not done so in the twelve months prior to the effective date of this Policy.

6. How to Contact Us About This Policy

If you have questions about our collection, use, or disclosure of Personal Information, please contact recruiting@missionlane.com