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Privacy Notice for California Residents

Privacy Notice for California Residents (“Notice”)

Introduction

The Brattle Group (“Brattle,” “we,” “our”) is committed to protecting your privacy and personal information. In accordance with the California Consumer Privacy Act of 2018 (the “CCPA”), this Notice describes how we collect, use, and disclose your personal information.

Scope

This Notice applies to job applicants, prospective job applicants, persons attending our recruiting events, contractors, employees, visitors to our website and subscribers to our email communications residing in the State of California (“you” or “your”), and supplements The Brattle Group’s Privacy Statement and Recruitment Privacy Notice.

Categories of Personal Information We Collect

We may collect the following categories of Personal Information from you:

  • Personal Identifiers
    • Examples: Name, preferred name, date of birth, aliases, email address, government issued identification including but not limited to social security or tax identification, driver’s license or state ID, passport or other similar identifiers.
  • Protected Class Information – Information that is considered a “protected classification” under California or Federal law.
    • Examples: Age, race, national origin, citizenship, gender, physical or mental disability, and veteran or military status.
  • Internet or Network Activity – Information about your activities on the internet or other electronic network activity information on devices managed by Brattle.
    • Examples: Browsing history, files downloaded, data inputted, network traffic, logons to Brattle network, other interactions with data and information about the employee’s Brattle-managed device(s)
  • Geolocation Data – Information that can be used to identify the physical location of Brattle-managed devices, assets or resources.
    • Examples: Location information derived from your Brattle-managed device’s DPS coordinates, Cell ID, computer addresses, Wi-Fi, VPN, or Bluetooth.
  • Professional or Employment – Information about your professional and employment status and background.
    • Examples: Current or past employment history, human resources data, and data necessary for benefits and related administrative services.
  • Inferences – Information drawn from any of the above categories that is used to create a profile on you.
Sources of Personal Information

We collect Personal Information you voluntarily provide to us. If you are visiting our website or online job application, we may also automatically collect information from you (e.g. IP address, device identifiers). In addition, we may collect Personal Information about you from recruiters, prior employers, professional references, educational institutions, pre-employment screening services, job-related social media sites (such as LinkedIn), and other publicly available sources, etc.

How We Use Your Information

We collect, use and disclose your personal information for the following purposes:

  • To administer human resources activities.
    • Examples: Evaluating your eligibility for employment; confirming your employment, educational and military histories; checking your references; providing benefits; managing your participation in any retirement plan.
  • To process payroll.
    • Examples: Calculating your salary and withholding for State or Federal taxes, processing social security payments or any benefits offered or required by Brattle; to make salary payments, other payments, direct deposits or necessary calculations.
  • To process legal activities.
    • Examples: complying with any legal obligation; responding to lawful requests for information.
  • To process business (e.g. client) requests.
    • Examples: to highlight your knowledge, background, experience for business development purposes, to respond to client inquires or questionnaires.
  • To maintain information technology systems.
    • Examples: maintaining the safety, security, and integrity of our websites, services, databases, networks, hardware, servers or equipment and other technical assets (collectively, “Brattle systems”); mitigating errors or vulnerabilities in Brattle systems.
Retention Period

How long we retain your Personal Information depends on the nature of the information and the purpose for which it was originally collected. In all cases, we will take reasonable steps to destroy, or erase from our system(s), all Personal Information which is no longer required for the purpose(s) it was originally collected.

We Do Not “Sell” or “Share” Your Personal Information for Purposes of the CCPA

We do not and will not “sell” or “share” your Personal Information. We also will not “share” your personal information with third parties for cross-context behavioral advertising purposes. We will not use your personal information to make any automated decisions affecting you.

Your Rights as a California Resident

Under the CCPA, California residents have the following rights:

  • Right to Know About Personal Information Collected, Disclosed, or Sold:
    • You have the right to be informed about our information practices, and the specific pieces of Personal Information we hold about you.
  • Right to Request Deletion of Personal Information:
    • You may have the right to request that we delete your Personal Information.
  • Right to Request Correction of Inaccurate Personal Information:
    • You may have the right to request that we correct inaccurate Personal Information about you.
  • Right to Opt Out of the Sale of Personal Information:
    • We do not currently sell Personal Information triggering the CCPA’s opt-out requirements. If we did or do, you would have the right to opt-out of that sale.
  • Right to Opt Out of Sharing of Personal Information:
    • We do not share your Personal Information for cross-content behavioral advertising purposes. If we did or do, you would have the right to opt-out of that sharing.
  • Right to Limit Use and Disclosure of Sensitive Personal Information:
    • You may have the right to limit our use and disclosure of your sensitive Personal Information.
  • Right to Non-Discrimination for Exercise of CCPA Rights:
    • We will not discriminate against you for exercising your rights under the CCPA.
  • Right to Private Cause of Action for Data Breaches:
    • You may have the right to initiate a private cause of action in the event of a data breach.
  • Minors:
    • If you are a California resident and we know you are under 16 years of age, we will not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate to any other business or third party.
Exercising Your CCPA Rights: Contact Us

If you are a California resident, you may exercise your rights by submitting a verifiable request for us to delete, correct, etc. any Personal Information we hold about you. Upon receiving such a request, we will take reasonable steps to verify your identity. If we need additional information to verify your identity, we will contact you to request that information. If we are able to verify your identity, we will respond to your request. If we deny your request, even if only in part, we will explain the reason in our response.

If you have questions about Brattle’s privacy policies and procedures, or concerning your Personal Information, you may contact the Human Resources Department by calling 617-864-7900 or emailing HR@Brattle.com.

Changes to This Notice; Not a Contract

We will process your personal information in accordance with this Notice, unless otherwise required by applicable law. We reserve the right to update and change this Notice from time to time to reflect any changes in how we process your personal information or changing legal requirements. We encourage you to visit our Website to stay informed about our privacy practices. This Notice does not form a contract between you and The Brattle Group. It is within your discretion to provide us with Personal Information. If you do not provide us with all of the Personal Information we request, we may not be able to process your application.