Last Updated and Effective Date: 12/20/22
The purpose of this Notice for Job Applicants (“Notice”) is to inform individuals who inquire about and/or apply for employment with BRE Hotels & Resorts (”BRE” or “we” or “us”) how we collect, use and disclose Personal Information (as defined below), the retention periods for such information, and your privacy rights.
For purposes of this Notice, “Personal Information” is information that relates to an identified or identifiable person. In addition, “Sensitive Personal Information” is (1) Personal Information that requires special handling under applicable law and may include information such as racial and ethnic origin, religion, medical information, Social Security number, financial account information, and biometric information.
This Notice applies only to information that we collect about you in connection with your job application but not, for example, to information that may be collected through the BRE website, which is subject to the BRE Privacy Policy.
Contents
- Source, Collection and Use of Personal Information
- Source, Collection and Use of Sensitive Personal Information
- Disclosure of Personal Information
- Selling or Sharing of Personal Information
- Summary of Prior 12-Month Personal Information Handling Practices
- Accuracy of Your Personal Information
- Your Privacy Rights
- Questions
- Updates
1. Source, Collection and Use of Personal Information
We may collect the following categories of Personal Information about you when you inquire about and/or apply for employment with us. We may collect and use such information for the purposes identified below.
We collect the Personal Information either directly from you or from other sources, such as recruiters, background check providers, your former employers, and information available about you through public sources and widely distributed media.
| Category of Personal Information | Sources | Purposes for Collection or Use of Personal Information |
|---|---|---|
|
Personal Contact Information, such as name, home addresses, home telephone numbers and personal email addresses
Business Contact Information, such as name, job title, business addresses, business telephone numbers and business email addresses Job-Related Information and Qualifications, such as education, awards, qualifications, certificates, licenses, professional memberships, time and attendance, and any other information you choose to provide in your resumes and/or applications References, such as opinions and comments of any previous employers Any other information that you store on our equipment and computer systems, such as your account credentials for our career portal and any other electronic communications or documents that you create or upload to our systems. |
We retain your information for as long as necessary to fulfill the purposes for which we collected the information, or as required by law. |
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2. Source, Collection and Use of Sensitive Personal Information
We may collect the following categories of information, which may be considered Sensitive Personal Information, in connection with your application for employment.
We collect the Sensitive Personal Information either directly from you or from other sources, such as recruiters, background check providers, your former employers, and information available about you through public sources and widely distributed media.
Under California law, Sensitive Personal Information creates a heightened risk of harm for personnel. We only collect and use such information for certain permitted purposes identified below. Because we use your Sensitive Personal information for these permitted purposes, there is no need for us to provide a Limit Use and Disclosure of Sensitive Personal Information right under California law.
| Category of Personal Information | Retention Period | Purposes for Collection or Use of Sensitive Personal Information |
|---|---|---|
|
National Identification Information, such as your country of birth or the country where you are a registered national or citizen, and any visa or other right to work
Diversity Information, such as your ethnicity/race, disability status, veteran status, gender, and sexual orientation Health and Disability Records, such as information relating to any disability or health condition that is relevant to your candidacy, including the results of any pre- or post-employment physical or screening examination, alcohol and/or drug testing Health and Safety Records, such as information relating to health and safety in the work place, accidents and near misses Health Screening Information, such as your temperature or responses to health screening questionnaires Location and Proximity Information, such as information relating to contact tracing and social distancing |
We retain your information for as long as necessary to fulfill the purposes for which we collected the information, or as required by law. |
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3. Disclosure of Personal Information
We may disclose your Personal Information as described below:
- Vendors or service providers who perform services in relation to our human resources and business operations and process personal information on our behalf (including service providers for talent management, data storage, IT services, and other purposes);
- Internal staff, including members of the HR team, managers in the business area in which you work, directors, and IT staff, if necessary for the performance of their roles or relevant to your job application;
- Business partners or affiliates for tracking purposes;
- BRE designated first responders, if necessary to assist in the event of an emergency.
- A newly formed or acquiring organization if BRE is involved in a merger, sale or a transfer of some or all of its business.
- With our business advisors, such as legal advisors, insurers, accountants, and auditors, to the extent this is necessary for them to provide us with their professional services;
- With legal or regulatory authorities and other governmental agencies as necessary to comply with our legal obligations or for a legitimate purpose such as to protect the rights and property of BRE, our customers, and the public, and to detect and respond to suspected illegal activity and threats to the safety of any person or of our systems or services;
- Any recipient, if required to comply with the law or in the event of a life-threatening emergency; and
- Any recipient, as permitted by law.
4. Selling or Sharing of Personal Information
Except as disclosed above, we do not sell or otherwise share your Personal Information with third parties. We also do not knowingly share for cross-context behavioral advertising, sell or disclose the Personal Information of children under the age of 18.
5. Summary of Prior 12-Month Personal Information Handling Practices
We provide in the chart below a summary of our prior 12-month personal information handling practices. You can learn more about the information we collect at or before the point of collection above in the Source, Collection, and Use of Personal Information; Source, Collection, and Use of Sensitive Personal Information; and Disclosure of Personal Information sections.
| Category of Personal Information | Source | Business or commercial purpose of disclosure and recipients of Personal Information |
|---|---|---|
| Identifiers, such as your name, postal address, email address, social security number, passport number, and driver’s license number. | You or from other sources, such as recruiters, background check providers, and information available about you through public sources and widely distributed media |
Sold We have not sold your identifiers with third parties. Shared for Cross-Context Behavioral Advertising Service Providers Other |
| Category of Personal Information | Source | Business or commercial purpose of disclosure and recipients of Personal Information |
|---|---|---|
| Any personal information described in subdivision (e) of Section 1798.80, such as your name, postal address, telephone number, driver’s license or state identification card number, education, and employment history | You or from other sources, such as recruiters, background check providers, and information available about you through public sources and widely distributed media |
Sold We have not sold your personal information with third parties. Shared for Cross-Context Behavioral Advertising Service Providers Other |
| Category of Personal Information | Source | Business or commercial purpose of disclosure and recipients of Personal Information |
|---|---|---|
| Characteristics of protected classifications under California or federal law, such as your race, national origin, gender, and age. | You or from other sources, such as recruiters, background check providers, and information available about you through public sources and widely distributed media |
Sold We have not sold any characteristics of protected classifications with third parties. Shared for Cross-Context Behavioral Advertising Service Providers Other |
| Category of Personal Information | Source | Business or commercial purpose of disclosure and recipients of Personal Information |
|---|---|---|
| Geolocation data, such as your address. | You or from other sources, such as recruiters, background check providers, and information available about you through public sources and widely distributed media |
Sold We have not sold your geolocation information with third parties. Shared for Cross-Context Behavioral Advertising Service Providers Other |
| Category of Personal Information | Source | Business or commercial purpose of disclosure and recipients of Personal Information |
|---|---|---|
| Professional or employment-related information, such as your employment history, title and credentials, and performance data. | You or from other sources, such as recruiters, background check providers, and information available about you through public sources and widely distributed media |
Sold We have not sold your employment-related information with third parties. Shared for Cross-Context Behavioral Advertising Service Providers Other |
| Category of Personal Information | Source | Business or commercial purpose of disclosure and recipients of Personal Information |
|---|---|---|
| Education information, such as your education history, achievements, and credentials. | You or from other sources, such as recruiters, background check providers, and information available about you through public sources and widely distributed media |
Sold We have not sold your education information with third parties. Shared for Cross-Context Behavioral Advertising Service Providers Other |
| Category of Personal Information | Source | Business or commercial purpose of disclosure and recipients of Personal Information |
|---|---|---|
| Sensitive Personal Information, such as those listed under Source, Collection, and Use of Sensitive Personal Information. | You or from other sources, such as recruiters, background check providers, and information available about you through public sources and widely distributed media |
Sold We have not sold your Sensitive Personal Information with third parties. Shared for Cross-Context Behavioral Advertising Service Providers Other |
6. Accuracy of Your Personal Information
BRE provides you with the ability to review your Personal Information as part of the online application process and to make changes by editing or deleting your Personal Information. You may also ask us to withdraw your application if you no longer want to be considered for a position at BRE. If so, we will withdraw your information and retain it in accordance with the retention periods noted above.
7. Your Privacy Rights
The California Privacy Rights Act (“CPRA”) affords California job applicants certain rights with respect to their Personal Information, subject to certain exceptions. Subject to certain limitations you have the following rights:
- (1) Right to Delete. You have the right to request us to delete the Personal Information we have collected about you.
- (2) Right to Correct. You have the right to request us to correct inaccurate Personal Information we maintain about you.
- (3) Right to Know and Access. You have the right to know and access the Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about you.
- (4) Right to Data Portability. You have the right to receive the information under right (3) in a format, to the extent technically feasible, that is portable, usable, and allows you to transmit the Personal Information to a person without impediment, where the processing is carried out by automated means.
- (5) Rights Related to Sharing for Cross-Context Behavioral Advertising or Sale. We do not share your Personal Information for cross-context behavioral advertising or sell your Personal Information. As such, there is no need to exercise your opt out of sale or sharing right. If you have any Questions, please contact us below.
- (6) Rights Related to Sensitive Personal Information. As described in the Source, Collection, and Use of Sensitive Personal Information section above, we only use your Sensitive Personal Information for permitted purposes. As such, there is no need to exercise your right to limit the use or disclosure of Sensitive Personal Information. If you have any Questions, please contact us below.
- (7) Right to No Discrimination. You have the right not to be discriminated against for exercising any of your privacy rights. This includes us not: (a) denying you goods or services; (b) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (c) providing you a different level or quality of goods or services; (d) suggesting to you that you will receive a different price or rate for goods or services or a different level or quality of goods or services; and (e) retaliating against you for exercising your privacy rights.
You may exercise your privacy rights by calling (844) 431-2130 and entering “3” as your pin number or by completing our web form here. In some instances, we will need to verify your identity before honoring your privacy right request. We will verify your identity by asking you to provide personal information related to your employment. We will honor your privacy rights request within 45 calendar days of receipt, unless we request an extension as permitted by data privacy laws.
You may exercise your privacy rights through an authorized agent. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us below.
8. Questions
If you have any questions about this Notice, please contact us at privacy@revantage.com.
9. Updates
We may update this Notice from time to time. When we do, we will notify you of any material changes