California Job Candidate Privacy Notice

Last Updated:  May 2024

This Job Applicant Notice (“CA Notice”) describes how Battery Ventures and its affiliates (“Battery,” “we,” “us,” or “our”) processes personal information of California job applicants in the human resources (“HR”) context. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act (CPRA), and any terms defined in the CCPA and CPRA have the same meaning when used in this CA Notice.

This CA Notice applies to Battery’s processing of your personal information as a job applicant and does not cover your use of Battery’s services outside of the job application process. If you use the Battery’s website and services, please see the Battery’s general website privacy policy for additional information.

Categories of Personal Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we will collect the following categories of personal information from you, however, please note that the list of examples is intended to be illustrative and not exhaustive:

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, if you agree to provide the information as part of the application process.
• From technologies you use or interact with in connection with your job application. For example, online identifiers such as IP address and device IDs as well as usage information may be collected from your devices when you are using or interacting with Battery job application platform.
• Third-party sources. For example, from a reference supplied by you.

Use of Personal Information

We may use the personal information we collect for one or more of the following purposes within the context of your application for a job with Battery:

• To evaluate you as a possible employee, owner, director, officer, or contractor for Battery.
• To comply with our health, safety, compliance, and fraud-prevention obligations.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations or investigations.
• To establish, exercise, or defend legal claims.
• To authorize, grant, administer, monitor, and terminate access to or use of company systems, facilities, records, property, and infrastructure.
• To manage travel (e.g., car service/rentals, flights, hotels) and expenses (e.g., reimbursement, corporate credit card) associated with the job application process.
• In the event of a merger, acquisition, disposition of all or substantially all of the relevant assets of the business, bankruptcy, or similar event (including due diligence related thereto).
• To create anonymous, aggregated or de-identified data that we use and share to analyze our application and recruitment activities, business and for other lawful business purposes.
• As described to you when collecting your personal information.
• As otherwise authorized or required by applicable law.

Disclosure of Personal Information

We may share your personal information with other parties as necessary for the purposes described above. For example, we may disclose your personal information with:

• Our subsidiaries, and other affiliates, for purposes consistent with this CA Notice or to operate shared infrastructure, systems, and technology.
• Service providers. Companies that provide us with services that help us manage the recruiting process and operate our business, such as job boards, recruiters, interviewing and testing, pre-employment screening, interview travel booking and expense reimbursement (where applicable), relocation (where applicable), and recruitment analytics.
• Government authorities, law enforcement and others. Government authorities, law enforcement, courts, and others as described in the compliance, safety and fraud prevention section above.
• Business transfers. Parties to transactions and potential transactions whereby we sell, transfer, or otherwise share some or all of our business or assets, including your personal information, such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
• Professional advisors. Lawyers, immigration advisors, and other outside professional advisors.
• Customers and business partners. Customers, other companies, and individuals with whom Battery does business or is exploring a business relationship.

We do not sell any information regarding job applicants to third parties for monetary or other valuable consideration.

Retention of Personal Information

Except as explained below, we retain the categories of personal information listed above as reasonably necessary to fulfill the purposes outlined in this CA Notice or a related and compatible purpose consistent a reasonable person’s expectation, unless a longer retention period is required or permitted by law. In many situations, we must retain all, or a portion, of your personal information to comply with legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes.

We will retain application information for applicants beyond consideration of the immediate position for which the application is submitted in case future positions or opportunities become available at Battery. Application information for successful applicants becomes part of the applicant’s employment file and is treated accordingly. You have the right to request that we delete certain personal information that we have collected.

Please contact us by email: hr@battery.com to make a request to delete your personal information.

Sensitive Information

The following personal information elements, which are also identified above, may be classified as “sensitive” under the CCPA (“sensitive information”): Social Security number, work-related accounts and passwords, financial account information, health information, citizenship and immigration status, race and ethnicity, trade union membership, information regarding sexual orientation and religious affiliation. We may use this sensitive information for the purposes set forth above regarding personal information.

Your Rights Under the CCPA and CPRA

Subject to certain exceptions, California residents can exercise their right to know, correct, and delete personal information subject to the limitations of the CCPA. If you are a California resident, you can submit a request for the right to delete and a request for the right to know. You may also contact us by email: hr@battery.com.

Changes to Our Privacy Notice

Battery recognizes that protecting your personal information is an ongoing responsibility and so it will update this CA Notice as it undertakes new practices involving your personal information. We reserve the right to amend this CA Notice at our discretion and at any time. Where required by law, we will provide notification of such changes.

Contact Information

If you have any questions or comments about this CA Notice or the ways in which Battery collects and uses your personal information described here, please do not hesitate to contact us by email: hr@battery.com