Culligan International Company
California Applicant Privacy Notice
Effective Date: September 9th, 2024
The purpose of this Applicant Privacy Notice (“Applicant Privacy Notice”) is to inform Culligan International Company’s (collectively, “Culligan,” “Company,” “us,” “we,” or “our”) California workforce job applicants of our practices regarding the collection, use, and disclosure of their personal information (“Applicant Personal Information”), and the rights they have under the California Consumer Privacy Act, as amended (the “CCPA”). “Applicant(s)” means California residents applying for workforce jobs with Culligan.
This Applicant Privacy Notice should be read in conjunction with our Privacy Policy, Terms and Conditions, and any other documents that govern your relationship with us. By using our website, products, and services (collectively, “Services”), including submitting a job application with us, you consent to our Terms of Service and the privacy practices disclosed in this Applicant Privacy Notice. Please do not use our Services if you do not consent.
If you interacted with us in a commercial capacity, please review our Privacy Policy for more information.
Unless otherwise noted, the disclosures herein cover our activities in the twelve (12) months preceding the Effective Date, as well as our current practices.
- How and Why We Collect, Use, and Disclose Your Applicant Personal Information
As used in this Applicant Privacy Notice, the term “Applicant Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with Applicants. Applicant Personal Information does not include information that is publicly available, de-identified, or aggregated, and the CCPA exempts certain additional categories of information from its purview, such as information subject to other laws and regulations. This Applicant Privacy Notice applies only to information governed by the CCPA.
Culligan may collect, use, and disclose Applicant Personal Information for business purposes consistent with applicable laws as identified below. Where Culligan discloses applicable Applicant Personal Information to recipients, such as our service providers, it does so for the same business purposes described below. These examples may vary depending on the nature of your interactions with us.
Category of Applicant Personal Information | Business Purposes for Collection, Use, or Disclosure | Categories of Recipients to whom Applicant Personal Information is Disclosed for a Business Purpose |
Identifiers, such as name, telephone number, email address, mailing address, IP address, or other similar identifiers | • To open and maintain your application records
• To assess your eligibility to work with us • To communicate with you regarding your application • To comply with applicable laws and regulations • To manage the security of our premises and systems • To detect and prevent fraud against you and/or us |
• Service providers
• Affiliates • Information technology vendors
|
Personal information described in Cal. Civ. Code § 1798.80(e), such as name, electronic signature, address, telephone number, education, employment, employment history
Some of these pieces of information may overlap with other categories. |
• To open and maintain your application records
• To assess your eligibility to work with us • To communicate with you regarding your application • To comply with applicable laws and regulations • To manage the security of our premises and systems • To detect and prevent fraud against you and/or us |
• Service providers
• Affiliates • Information technology vendors
|
Characteristics of protected classifications under California or federal law, including age and date of birth, marital status, race, ancestry, ethnic origin, sex, gender, gender identity, religion or creed, military or veteran status, medical condition, or disability | • To comply with the U.S. Equal Employment Opportunity Commission (“EEOC”) and other applicable laws and regulations
• To assess your eligibility to work with us |
• Service providers
• Affiliates
|
Internet or other electronic network activity information, such as browser type and language, operating system, website usage, emails, or text message communications | • To communicate with you
• To improve our website • To protect the security of our website • To detect and prevent fraud against you and/or us |
• Service providers
• Information technology vendors
|
Geolocation data, such as location data inferred from your device IP address, or your device and mobile location | • To help you find jobs that are close to your location | • Service providers
• Information technology vendors
|
Sensory information, such as security camera recordings if you interview at our facilities, photographs to the extent contained on documents you provide, audio recordings of phone calls and/or phone interviews | • To open and maintain your application records
• To detect and prevent fraud against you and/or us • For safety and security |
• Service providers
• Affiliates
|
Professional or employment-related information, such as skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, or application form;
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; Information relating to professional licenses, training, or disciplinary actions. |
• To open and maintain your application records
• To assess your eligibility to work with us • To comply with applicable laws and regulations • To detect and prevent fraud against you and/or us • For safety and security |
• Service providers
• Affiliates
|
Non-public education information, including school(s) attended, grades, and other information relating to your education | • To open and maintain your application records
• To assess your eligibility to work with us • To assess qualifications for a particular job or task • To comply with applicable laws and regulations • To manage workplace safety and security • To verify your identity and stated credentials |
· Background check providers
· Information technology vendors
|
Inferences used to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | • We will only use this information for recruitment efforts and will not impact your current application or future ability to work with us with us. | • Service providers |
Personal Information that does not fall directly within the categories listed in the CCPA, such as visa status and work authorization information | • To open and maintain your application records
• To assess your eligibility to work with us • To comply with applicable laws and regulations • To detect and prevent fraud against you and/or us • For safety and security |
• Service providers
• Affiliates
|
- Sensitive Personal Information
Culligan may collect, use, and disclose sensitive Applicant Personal Information for valid business purposes consistent with applicable laws as identified below. Where Culligan transfers applicable sensitive Applicant Personal Information to recipients, such as our service providers, it does so for the same business purposes described below. These examples may vary depending on the nature of your interactions with us.
Category of Sensitive Applicant Personal Information | Purposes for Collection, Use, or Disclosure | Categories of Recipients to whom Applicant Personal Information is Disclosed for a Business Purpose |
Personal Information that reveals an Applicant’s racial origin | • To process job applications and maintain records
• To complete activities related to recruiting and onboarding • To verify your identity and stated credentials • To comply with applicable laws and regulations |
• Service providers
• Data analytics providers • Background check vendors
|
Personal Information collected and analyzed concerning an Applicant’s health | • To assess your eligibility to work with us
• To comply with applicable laws and regulations |
• Service providers
|
Citizenship and immigration status | • To assess your eligibility to work with us
• To comply with applicable laws and regulations |
• Service providers |
In addition to the categories of Applicant Personal Information above, we may also collect Applicant Personal Information that you submit to us on a voluntary basis which we would not otherwise request. For example, information included on your CV when you submit an application to us, or information you may volunteer in an interview.
- Disclosing Your Applicant Personal Information
We may disclose each of the categories of Applicant Personal Information identified above to the respectively identified categories of recipients for operational or business purposes consistent with the purposes for collection or use designated, as is reasonably necessary and proportionate to achieve those purposes, or for another purpose that is compatible with the context in which the Applicant Personal Information was collected including, but not limited to:
- Auditing related to ads;
- Providing advertising and marketing services, as applicable;
- Helping to ensure security and integrity;
- Debugging, repairing, and improving functionality;
- Short-term, transient use;
- Performing services on our behalf;
- Internal research for technological development; and
- Verifying quality and/or safety.
In addition to the other purposes for collection, use, and disclosure of Applicant Personal Information described in this Applicant Privacy Notice, we may collect, use, and disclose Applicant Personal Information as required by law, regulation, or court order; to respond to governmental and/or law enforcement requests; to identify, contact, or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense, or declaration in a case or before any jurisdictional and/or administrative authority, arbitration, or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may use and disclose Applicant Personal Information to other parties in connection with the sale, assignment, merger, or reorganization of the company or its affiliates.
- Sources of Applicant Personal Information
We may collect Applicant Personal Information from the following sources:
- Directly from you. For example, throughout the application process with us, including through our IT systems, company forms, and other processes where you submit information to us.
- Automatically when using our electronic systems. For example, we may collect your usage history when you use our websites, systems, and applications.
- Automatically when you visit our facilities. For example, security camera footage.
- From service providers that help us run our business. For example, information technology vendors and other service providers.
We may also collect publicly available information about you, including information that is lawfully made available to the general public from federal, state, or local government records.
- Cookies and Tracking Technologies
We may use tracking technologies, such as cookies, including tracking technologies managed by vendors or external parties. For more information about how we use these technologies, please see our Privacy Policy.
- Sales and Sharing of Applicant Personal Information
We do not sell Applicant Personal Information or share it for cross-context behavioral advertising.
- How Long We Keep Your Applicant Personal Information
- We store the Applicant Personal Information we collect as described in this Applicant Privacy Notice for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
- Submitting Requests Relating to Your Applicant Personal Information
If you are a resident of California, you have the right to submit certain requests relating to your Applicant Personal Information as described below. To exercise any of these rights, please email us at CAPrivacyRequest@culligan.com or call us toll-free at . Please note that if you submit a request to know, request to delete, or request to correct, you will be asked to provide two-to-three (2-3) pieces of Applicant Personal Information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed.
Right to Know. You have the right to know what Applicant Personal Information we have collected about you, which includes:
- The categories of Applicant Personal Information we have collected about you, including:
- The categories of sources from which the Applicant Personal Information was collected;
- Our business purposes for collecting, selling, or sharing the Applicant Personal Information;
- The categories of recipients to whom we disclosed Applicant Personal Information;
- The categories of Applicant 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 Applicant Personal Information.
- The specific pieces of Applicant Personal Information we have collected about you.
Right to Delete Your Personal Information. You have the right to request that we delete Applicant Personal Information we collected from you, subject to certain exceptions.
Right to Correct Inaccurate Information. If you believe that Applicant Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.
Right to Opt-Out of Sales and Sharing of Personal Information. We do not sell your 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 Applicant Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.
Rights Related to Automated Decision-Making. We do not use automated decision-making for purposes to which the rights related to automated decision-making apply under the CCPA.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us, including retaliation against you as a job applicant.
- Security
We take steps to ensure that your information is treated securely and in accordance with this Applicant Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.
By using our Services or providing Applicant Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.
- Change in Statement
We reserve the right to amend this Applicant Privacy Notice at any time without advance notice in order to address future developments of Culligan, our website, or changes in industry or legal trends. We will post the revised Applicant Privacy Notice on our website. You can determine when the Applicant Privacy Notice was revised by referring to the “Effective Date” legend on the top of this Applicant Privacy Notice. Any changes will become effective upon the posting of the revised Applicant Privacy Notice on our website.
- How to Contact Us
If you have any questions about how Culligan handles your Applicant Personal Information or if you need to access this Applicant Privacy Notice in an alternative format or language, please contact us at:
Email: CAPrivacyRequest@culligan.com
Phone: 877-225-8757