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Applicant Privacy Notice

Last updated April 10, 2023

This Applicant Privacy Notice describes the personal information Rachel Comey Studio (“Rachel Comey”, “us”, or “we”) collect when you apply for a position with us, how we use it, and with whom we share it. Note, this Applicant Privacy Policy only applies to applicants of Rachel Comey who are residents of California. This notice does not apply to third party sites or services outside of Rachel Comey.


I. Information Collection, Use, and Retention

When you apply for a position at Rachel Comey, we collect or receive personal information at various stages in the application process as described below.

  • Complete an application: When you apply for a position with Rachel Comey, we collect from you your identifiers (name, email address, home and mobile telephone number, home address), your sensitive identifiers (social security number, government ID, or other national identifier), and your professional or employment information (resume/CV, certifications or licenses, qualifications, employment history, educational history, and references) We use your identifiers, sensitive identifiers, and your professional or employment information to review your background and skills, determine your qualifications for the role you are applying to, and to confirm information related to your education.  
  • Participate in an in-person interview: If you participate in an on-site interview with Rachel Comey, we will collect, from you, when you register with any of our security desks as a visitor to any of our locations, your identification information (driver’s license, government identification card, or passport) some of which is considered sensitive information, and sensory information (video of you captured through our CCTV footage) when you come to one of our locations. We use this information to ensure the security of Rachel Comey personnel and property, and to verify your identity for purposes of the interview.
  • Information from references: When you provide references with your application, we will receive from your references your professional or employment information (confirmation of details on your resume/CV, certifications, qualifications, employment history, educational history). We will analyze these and make inferences from them, such as their thoughts on your behavior, intelligence, abilities, and aptitudes. We use this personal information to assess your suitability for the position for which you have applied.

 

Information Collected Automatically by Cookies

In addition to the personal information, you provide directly to us, we also collect information from you automatically as you use our Services via “cookies.” 

We use usage, device, and location information to: (i) track you within the Services; (ii) enhance user experience; (iii) conduct analytics to improve the Services; (iv) prevent fraudulent use of the Services; and (v) diagnosis and repair Services errors, and, in cases of abuse, track and mitigate the abuse. You can read more about how Rachel Comey uses cookies by reading our Cookie Policy

Third party marketing and analytics cookies may be considered sharing under the California Privacy Rights Act (“CPRA”). If you are a California resident and wish to opt out please contact us by either telephone at 800-416-1265 or email us at online@rachelcomey.com.

Particular third party cookies on our Website include:  

    • Google Analytics. We use Google Analytics to collect information on your use of the Website to improve our Website. In order to collect this information, Google Analytics may set cookies on your browser, or read cookies that are already there. Google Analytics may also receive information about you from applications you have downloaded that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to our Websites or to another application which partners with Google is restricted by the Google Analytics Terms of Use and the Google Privacy Policy available here. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here. To opt out of this cookie, follow the instructions in the YOUR INFORMATION CHOICES section of the Privacy Policy or visit our cookie management platform.

I. Information Sharing

General Sharing:  

Rachel Comey may share applicant personal information in the following instances:  

  • Within Rachel Comey: We share applicant personal information among our hiring decision-makers (i.e. human resources department, senior management, and hiring managers) for the legitimate business purposes of assessing applications and making hiring decision.
  • With service providers: We share your personal information with our service providers that assist us in providing the Services, such as our outside recruitment providers, IT support, cloud and hosting provider, and email provider.
  • For legal purposes: We share applicant personal information with third parties, such as legal advisors, law enforcement agencies, or governmental/regulatory bodies in order to protect our legal interests and other rights, protect against fraud or other illegal activities, for risk management purposes, and to comply with legal obligations.
  • During a corporate reorganization: In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, we would share applicant personal information. We will also share applicant personal information if we undergo bankruptcy or liquidation, in the course of such proceedings.

Sharing in the Preceding Twelve (12) Months

For Business Purposes. In the preceding twelve (12) months, Rachel Comey has disclosed the following categories of personal information for a business purpose to the following categories of third parties:

  • With service providers: In the preceding twelve (12) months, Rachel Comey has shared applicant identifiers and professional or employment information with service providers that assist us in the application process. These service providers include our cloud and hosting provider, talent acquisition providers, and IT support provider.  
  • With government entities. In the preceding twelve (12) months Rachel Comey has shared applicant identifiers, sensitive information, professional or employment information with government entities to comply with federal, state, and local laws.

    For Sale. Rachel Comey does not sell Applicant data.

Your Information Choices

  • Correct or View Your Information. You may access your Rachel Comey career’s account to correct or view certain personal information you have provided to us and which is associated with your account.
  • Opt Out of Online Advertising. Some of the companies that provide advertising services on our Services may participate in industry-developed programs designed to provide consumers with choices about whether to receive tailored ads that are based on your online activities. To learn more and to opt out of such targeted advertising from participating companies, please visit the websites of the Network Advertising Initiative, the Digital Advertising Alliance. To successfully opt out, you must have cookies enabled in your web browser (see your browser's instructions for information on cookies and how to enable them). Your opt out only applies to the web browser you use, so you must opt out of each web browser on each device you use. Once you opt out, if you delete your browser's saved cookies, you will need to opt out again. If you opt out, you will still see ads from NHL, but the ads will be less relevant to you and your interests.

III. Your Rights as California Residents

The California Privacy Rights Act, (“CPRA”) entitles California residents to certain rights. To the extent the CPRA applies to our processing of your personal information, you are entitled to the following rights: 

  • Right to Access/Know. You have the right to request what personal information we have collected, used, disclosed, and sold about you. You may only submit a request for access twice within a twelve-month period. See below to learn how to exercise this right. 
  • Right to Deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions. For example, if we are required by law to retain the information that you are asking to be deleted, we would not be able to delete the information until we are legally permitted to delete it. (e.g. federal and state labor laws, federal and state employment laws).
  • Right to Opt-Out of Sale/Sharing. You have the right to opt-out of the sale or sharing of your personal information to third parties.  does not have actual knowledge that it sells or shares personal information of individuals under the age of sixteen (16) years.  We currently only sell or share personal information under CPRA via cookies.  Our use of third-party cookies may be deemed a sale or sharing under the CCPA/CPRA. To exercise your right to opt-out of the sale or sharing of your personal information through cookies, please visit our cookie management platform
  • Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, opt-out, correct, or limit use of sensitive personal information under the CPRA.  
  • Right to correct: You have the right to correct inaccurate personal information that we collect or maintain. 
  • Right to limit use of sensitive personal information: You have the right to limit the use of your sensitive personal information when such use goes beyond that which is necessary for providing the services or certain other permissible purposes. Sensitive information includes Social Security number, driver’s license number, biometric information, precise geolocation, and racial and ethnic origin. 


To exercise your right to access/know or delete your personal information, you may submit a request toll-free at 800-416-1265 or via email at online@rachelcomey.com. For requests submitted via telephone or email, you must provide us with name, zip code, that you are an applicant, and your preferred contact method (email address or phone number), which allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it.  If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information. Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. To exercise your right to opt-out of the sale or sharing of your personal information via cookies, please utilize our cookie management platform.


IV. Do Not Track

We will not place cookies or collect information via cookies when your browser is set to Do Not Track (DNT). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.


V. Information Security

Rachel Comey employs data collection, storage and processing practices and security measures designed to protect Personal Information against unauthorized access, alteration, disclosure or destruction. Where appropriate, we use firewalls and limits on who can access databases that store Personal Information.

Please keep in mind that it is not possible to achieve a perfect state of data security. Although we maintain reasonable administrative, physical and electronic security measures designed to protect your Personal Information from unauthorized access, we cannot ensure absolute security of any information you transmit to us or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your un-encrypted electronically stored Personal Information. To the extent the law of your jurisdiction allows for notification of a breach via e-mail or conspicuous posting on the Services, you agree to accept notice in that form. However, no security measure or modality of data transmission over the Internet is 100% secure and we are unable to guarantee the absolute security of the personal information we have collected from you.  


VI. Personal Information of Individuals Under the Age of Sixteen (16)

Rachel Comey’s application process is not intended for use by individuals under the age of sixteen (16). If we learn that we have collected or received personal information from individuals under the age of sixteen (16), we will delete the personal information. If you believe we have personal information on individuals under the age of sixteen (16), please contact us at the contact information provided below.


VII. Changes to this Privacy Notice

This Privacy Notice is subject to change at any time. Changes to this Privacy Notice will be posted on this page and will indicate the date the changes go into effect. If we make any changes that materially affect your privacy rights, we will announce those changes by posting and obtain your consent, if required.


VIII. Contact Us

For questions on this Privacy Notice or the protection of your personal information and privacy rights, please contact Rachel Comey: online@rachelcomey.com and 800-416-1265.

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