Job Applicant 

Privacy Policy and CA Notice at Collection  

Last Updated: August 5, 2026

We review and update this Policy at least annually and whenever there are material changes to our data practices or applicable law.

Scope of Applicability

FrankCrum and/or our affiliate companies (collectively, “FrankCrum,” “Company,” “we,” “our,” or “us”) respect your privacy and are committed to protecting it through our compliance with this Job Applicant Privacy Policy and CA Notice at Collection (collectively, “Policy”). This Policy describes the Personal Information (“PI”) we collect, both online and offline (through our “Site(s)” or “Service(s)”), about Job Applicants, for what purposes we use and disclose it, how long we retain it, and whether we sell it or share it for cross-context behavioral advertising purposes. This Policy also incorporates and serves as our California Residents: Notice at Collection and disclosures required under the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (herein referred to as “CCPA”). This Policy applies to individuals who apply for employment with FrankCrum in the United States and applies only to information collected in connection with recruitment, application review, interviewing, pre-employment screening, hiring decisions, applicant communications, legally required reporting, and related applicant administration.

This Applicant Privacy Statement applies only to your interaction with the Company in the capacity of a job applicant. This Policy does not apply to general website visitors who are not Job Applicants, independent contractors, temporary staffing employees, Covered Employees, or other non-employee individuals unless expressly stated in a separate written notice.

Please refer to the following policies if needed:

California Residents: Notice at Collection

Collection of Personal Information and Sensitive Personal Information
When you apply for a position or interact with us regarding potential job openings, we collect Personal Information ("PI") from you in a variety of different situations and using a variety of different methods, including, but not limited to, through our website, your mobile device, through email, in physical locations, through written materials, through the mail, and/or over the telephone.
 
Based on your interactions, transactions, and use of our website, we collect - and have collected during the preceding 12 months - the following categories of PI about Job Applicants. For each category of information, we identify below the categories of third parties, service providers, and contractors to whom we have disclosed the information in the last twelve (12) months. The examples provided in each category are not intended to be an exhaustive list or an indication of all specific pieces of information we collect from or about you in each category, but rather the examples are to provide a meaningful understanding of the types of information that may be collected within each category.
 

Categories of Personal Information Collected and Source

Business Purpose

Third parties with whom Personal Information is disclosed, shared or sold

Retention Criteria

Identifiers. e.g. contact information including first name, last name, alias, date of birth, postal address, telephone number, unique personal identifier, online identifier, Internet Protocol ("IP") address, email address, Social Security number, driver’s license, state identification card number, or passport number provided by you.

Source: Directly from you, Service Providers, automatically through Site.

  • Business operations and service delivery.
  • Communicate with you regarding your candidacy for employment.
  • Comply with applicable laws.
  • Control and monitor Site access.
  • Debug, identify, and repair errors that impair existing intended functionality of Site.
  • Detect security incidents.
  • Engage in lawful monitoring of job applicant activities and communications.
  • Respond to and communicate with Job Applicants.
  • Respond to law enforcement, subpoenas, and court orders.
  • Serve interest-based advertising.
  • Understand and track website usage, improve website performance, analyze trends, and enhance the user experience.
  • Verify and respond to Job Applicant requests.  
Disclosed:
  • Affiliated entities.
  • Advertising, analytics, marketing, tracking, and retargeting providers.
  • Communication Services Providers. 
  • Consumer reporting agencies.
  • Data brokers.
  • Financial institutions.
  • Government agencies.
  • HRIS. 
  • IT, cybersecurity, and risk vendors.
  • Law enforcement, courts, and attorneys.
  • Marketing support provider. 
  • Recruiting and staffing firms or agencies.
  • Social media platforms.
  • Talent acquisition management systems.
Sold or Shared:
  • We sell certain information (not for monetary consideration but for other valuable consideration) to data analytics vendors, behavior analytics vendors, social media platforms, video content hosts and platforms, Ad Trackers, and other marketing, tracking, and retargeting vendors or providers.
  • We share the data with these third parties for cross-context behavioral advertising.

Retained as long as necessary to fulfill the purposes stated for this category, for the duration of our relationship, and for any additional period required or permitted by applicable legal, regulatory, contractual, security, fraud prevention, or recordkeeping obligations.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) ("California Customer Records"). e.g. name, signature, Social Security number, physical characteristics or description, photograph, address, phone number, passport number, driver's license or state identification card number, education, employment history, membership in professional organizations, professional licenses and certifications, bank account number, or any other financial information, medical information, or health insurance information if voluntarily disclosed by you during the application process..

Some Personal Information included in this category may overlap with other categories.

Source: Directly from you or internally.

  • Business operations and service delivery.
  • Communicate with you regarding your candidacy for employment.
  • Comply with applicable laws.
  • Detect security incidents.
  • Engage in lawful monitoring of job applicant activities and communications.
  • Marketing and sales activities.
  • Respond to and communicate with Job Applicants.
  • Respond to inquiries. 
  • Respond to law enforcement, subpoenas, and court orders.
  • Understand and track website usage, improve website performance, analyze trends, and enhance the user experience.
  • Verify and respond to Job Applicant requests.  
Disclosed:
  • Affiliated entities.
  • Communication Services Providers. 
  • Consumer reporting agencies.
  • Financial institutions.
  • Government agencies.
  • HRIS.
  • IT, cybersecurity, and risk vendors.
  • Law enforcement, courts, and attorneys.
  • Marketing support provider. 
  • Recruiting and staffing firms or agencies.
  • Social Media platforms.
  • Talent acquisition management systems.
Sold or Shared:
  • We sell certain information (not for monetary consideration but for other valuable consideration) to data analytics vendors, behavior analytics vendors, social media platforms, video content hosts and platforms, Ad Trackers, and other marketing, tracking, and retargeting vendors or providers.
  • We share the data with these third parties for cross-context behavioral advertising.

Retained as long as necessary to evaluate candidacy, administer the application process, comply with applicable legal, audit, tax, equal employment opportunity, immigration, background-screening, and recordkeeping obligations, resolve disputes, maintain security, and consider applicants for future opportunities where permitted by law.  

Protected classification characteristics under California or federal law ("Protected Classes"). e.g. age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decision-making, military and veteran status, or genetic information (including familial genetic information).

Source: Directly from you, Service Providers, government agencies, or internally, if voluntarily disclosed by you or collected for legally required equal employment opportunity, accommodation, work authorization, background screening, or similar employment-related purposes.

  • Comply with applicable equal employment opportunity, anti-discrimination, accommodation, immigration, background-screening, and other applicant-related legal obligations.
  • Evaluate and administer requested accommodations.
  • Respond to law enforcement, subpoenas, and court orders.
Disclosed:
  • Affiliated entities.
  • Government agencies.
  • HRIS.
  • Law enforcement, courts, and attorneys.
  • Talent acquisition management systems.
Sold or Shared:
  • Not sold for monetary or other valuable considerations. 
  • Not shared for cross-context behavioral advertising. 

Retained only as long as necessary for the applicable applicant-related legal, compliance, accommodation, audit, recordkeeping, or dispute-resolution purposes in accordance with applicable law and retention schedules.

Internet or other similar network activity. e.g. date and time of your visit to our Site(s); webpages visited; links clicked on our Site(s); session identifiers; browser ID; browser type and characteristics; device ID and characteristics or attributes; referring URLs; mobile phone make, model and serial number; mobile service provider; operating system; form information downloaded; domain name from which our site was accessed; search history; interaction-level telemetry; cookies; and internet or other electronic network activity information related to usage of FrankCrum networks, servers, intranet, or shared drives, as well as FrankCrum-owned computers and electronic devices, including system and file access logs, security clearance level, browsing history, search history, and usage history.

Source: Automatically through our Site, careers pages, applicant portals, applications, or related recruiting systems.

  • Business operations and service delivery.
  • Control and monitor Site access.
  • Debug, identify, and repair errors that impair existing intended functionality. 
  • Detect security incidents.
  • Engage in marketing and sales activities.
  • Serve interest-based advertising.
  • Understand and track website usage, improve website performance, analyze trends, and enhance the user experience.
Disclosed: 
  • Advertising, analytics, marketing, tracking, and retargeting providers.
  • Communication Services Providers. 
  • Data brokers.
  • IT, cybersecurity, and risk vendors.
  • Law enforcement, courts, and attorneys.
  • Marketing support provider.
  • Social Media platforms.
Sold or Shared:
  • We sell certain information (not for monetary consideration but for other valuable consideration) to data analytics vendors, behavior analytics vendors, social media platforms, video content hosts and platforms, Ad Trackers, and other marketing, tracking, and retargeting vendors or providers.
  • We share the data with these third parties for cross-context behavioral advertising.

Retained only as necessary for security (e.g., logs), debugging, analytics controls, and complying with legal obligations.

Sensory data. e.g. your image when recorded or captured in visitor or premises security footage, and audio or video recordings of calls, interviews, or virtual meetings when disclosed to you or otherwise permitted by law.

Source: Directly from you, via Physical Locations, Service Providers, or internally.

  • Business operations and service delivery.
  • Comply with applicable laws.
  • Detect security incidents.
  • Legal compliance and records management.
  • Protect individuals or property.
  • Respond to law enforcement, subpoenas, and court orders.
  • To conduct virtual job interviews and evaluate candidate qualifications for employment opportunities.
Disclosed:
  • Affiliated entities.
  • Communication Services Providers. 
  • IT, cybersecurity, and risk vendors.
  • Law enforcement, courts, and attorneys.
  • Video content hosts and platforms.
Sold or Shared: 
  • Not sold for monetary or other valuable consideration 
  • Not shared for cross-context behavioral advertising. 

Security/call recordings are kept only as necessary for security, quality assurance, investigations, and compliance.

Professional or employment-related information. e.g. employment application information, resume or CV, work history, academic and professional qualifications, educational records, references, interview notes, assessments, background check information, drug testing results, work authorization information, salary expectations, compensation history where legally permitted and voluntarily disclosed, and other information relevant to evaluating your candidacy.

Source: Directly from you, Service Providers, or Internally.

 

  • Comply with applicable laws.
  • Conduct permissible background, education, and employment checks.
  • Perform human resources management services and support services.
  • Respond to law enforcement, subpoenas, and court orders.
Disclosed:
  • Affiliated entities.
  • Communication Services Providers. 
  • Consumer Reporting Agencies. 
  • Government agencies.
  • HRIS.
  • Law enforcement, courts, and attorneys.
  • Recruiting and staffing firms or agencies.
  • Talent acquisition management systems.
Sold or Shared:
  • Not sold for monetary or other valuable considerations. 
  • Not shared for cross-context behavioral advertising. 

Retained as long as necessary to fulfill the purposes stated for this category, for the duration of our relationship, and for any additional period required or permitted by applicable legal, regulatory, contractual, security, fraud prevention, or recordkeeping obligations.

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) ("FERPA Information"). e.g. Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Source: None.

  •  Not Collected.
Disclosed:
  • Not Disclosed.
Sold or Shared:
  • Not sold for monetary or other valuable consideration 
  • Not shared for cross-context behavioral advertising.

Not Applicable.

Form and other Electronic Submission Data. e.g. data submitted through the Site, including Career Sites forms.

Source: Directly from you .

  • Analytics and service improvement.
  • Respond to Job Applicant inquiries.
Disclosed: 
  • Advertising, analytics, marketing, tracking, and retargeting providers.
  • Communication services providers.
  • IT, cybersecurity, and risk vendors.
  • Marketing support provider. 
Sold or Shared:
  • Not sold for monetary or other valuable consideration 
  • Not shared for cross-context behavioral advertising. 

Retained to fulfill the inquiries and records management.

Financial Information. e.g. bank account number for direct deposit, routing number, and other financial account information if voluntarily disclosed by you during the application process.

Source: Directly from you.

  • Comply with applicable laws.
  • Direct Deposit.
  • To administer and reimburse expenses related to candidate interviews, including travel, lodging, meals, and other approved recruitment-related costs.
Disclosed:
  • Affiliated entities.
  • Communication services providers.
  • Financial institutions.
  • Transactional support vendors.
  • HRIS.
  • Law enforcement, courts, and attorneys.
  • Talent acquisition management systems.
Sold or Shared:
  • Not sold for monetary or other valuable considerations.
  • Not shared for cross-context behavioral advertising. 

Retained for the period necessary to administer and document interview-related expense reimbursements and associated business records.

Medical and health information. e.g. information you voluntarily provide in connection with a request for reasonable accommodation during the application or interview process, pre-employment medical or drug testing information where permitted by law, and related communications necessary to evaluate or administer the request or requirement.

Source: Directly from you, Service Providers, or Internally.

  • Comply with applicable laws.
  • Evaluate and administer applicant accommodation requests.
  • Conduct legally permitted pre-employment testing or screening.
  • Comply with applicable disability, health, safety, background-screening, audit, litigation, and recordkeeping obligations.
Disclosed:
  • Affiliated entities.
  • Communication Services Providers. 
  • Consulting/Investigation Firms.
  • Government agencies.
  • HRIS.
  • Law enforcement, courts, and attorneys.
Sold or Shared:
  • Not sold for monetary or other valuable considerations. 
  • Not shared for cross-context behavioral advertising. 

 

Retained only as long as necessary to evaluate or administer applicant accommodation requests, comply with applicable disability, health, safety, background-screening, audit, litigation, and recordkeeping obligations, and protect rights and safety as permitted by law.  

Travel and Expenses Information. e.g. business travel or work-related expenses relating to interview travels.

Source: Directly from you or internally.

  • To administer, process, document, and reimburse approved expenses related to candidate interviews, including travel, lodging, meals, and other recruitment-related costs.

 

Disclosed:
  • Affiliated entities.
  • Communication Services Providers. 
  • Financial institutions.
  • HRIS.
Sold or Shared:
  • Not sold for monetary or other valuable considerations. 
  • Not shared for cross-context behavioral advertising. 

Retained only for as long as reasonably necessary to administer business travel, process reimbursements, maintain accurate financial records, and satisfy legal, tax, and audit requirements.

Biometric Data. e.g biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints and palm/handprint reading.

Source: None.

  • FrankCrum does not collect biometric identifiers or biometric information from Job Applicants.
Disclosed:
  • Not Disclosed.
Sold or Shared:
  • Not sold for monetary or other valuable considerations.
  • Not shared for cross-context behavioral advertising. 

Not Applicable.

 

Inferences drawn from other information. e.g. profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.  

We do not use assessment results to infer protected characteristics such as health status, race, religion, or other sensitive attributes as stated below.

Source: Automatically through our Site and internally.

  • Evaluate applicant qualifications, work style, or role fit only where the information is generated through applicant assessments or evaluation processes and reviewed in connection with the recruiting process.

Disclosed:
  • Data analytics providers.
  • Transactional Providers.
  • HRIS.
Sold or Shared:
  • Not sold for monetary or other valuable considerations. 
  • Not shared for cross-context behavioral advertising. 

Retained only while necessary to support the documented purpose for which the inference was created.

 

What Sensitive Personal Information We Collect

Of the above categories of PI, the following are categories of Sensitive PI we collect from or about Job Applicants:
  • Identifiers (SSN, driver's license, state ID, passport).
  • California Customer Records (financial, health, and government ID data).
  • Protected Classes (race, ethnicity, religion, citizenship, sexual orientation, genetic data, etc.).
  • Professional/Employment Information (to the extent it includes health, religious, immigration, or drug-testing information).
  • Financial Information.
  • Credit/Financing Application Data.

Please Note: The Company does not knowingly collect Sensitive Personal Information from individuals who merely browse our website or submit an initial Job Application. However, Job Applicants who advance in the interview or hiring process may be asked to provide certain Sensitive PI, such as government-issued identification numbers, Social Security numbers, financial account information, or other information required for background screening, identity verification, onboarding, payroll setup, benefits administration, or legal and regulatory compliance purposes. Such information is collected only when necessary and is handled in accordance with applicable privacy and data protection laws.

Personal Information does not include:
  • Publicly available information from government records. 
  • Information that a business has a reasonable basis to believe is lawfully made available to the public by the Employee or from widely distributed media.  
  • Information made available by a person to whom the Employee has disclosed the information if the Employee has not restricted the information to a specific audience.  
  • De-identified or aggregated information. 

Sensitive Personal Information Categories Chart 

Sensitive Personal Information (“SPI”) is a subtype of PI consisting of the specific information categories listed in the chart below.  FrankCrum does not use or disclose SPI for purposes that would require a “Limit the Use of My Sensitive Personal Information” link under the CCPA.  Under the CCPA, SPI is subject to additional obligations when collected, used, or disclosed in ways that are not limited to permitted business purposes, including where it is used to infer characteristics about an individual. Of the above categories of PI, the following are categories of SPI FrankCrum collects from or about Job Applicants:

Sensitive Personal Information Category 

Collected to Infer Characteristics? 

Retention Criteria 

Government identifiers. e.g. as your Social Security number (“SSN”), driver's license, state identification card, or passport number

No 

N/A 

Complete account access. Credentials. e.g. usernames, account logins, account numbers, or card numbers combined with required access/security code or password.

No 

N/A 

Precise geolocation. e.g. GPS data from a job applicant’s mobile device that can provide its location in a geographic area, with an approximate radius of 1,850 feet. 

No 

N/A 

Racial or ethnic origin. 

No 

N/A 

Citizenship or immigration status. 

No 

N/A 

Religious or philosophical beliefs. 

No 

N/A 

Union membership. 

No 

N/A 

Mail, email, or text messages not directed to the Company. 

No 

N/A 

Genetic data. 

No 

N/A 

Neural Data. e.g. information generated by measuring a job applicant’s central or peripheral nervous system's activity that is not inferred from nonneural information.

No 

N/A 

Unique identifying biometric information. 

No 

N/A 

Health information. 

No 

N/A 

Sex life or sexual orientation information. 

No 

N/A 

Children's Personal Information (under age 16). 

No 

N/A 

 

Categories of Sensitive Personal Information Collected or Processed

We process SPI only for disclosed applicant-related purposes and, where applicable, for purposes permitted under CCPA:
  • Performing actions that are reasonably necessary and proportionate for the applicant relationship and that an average Job Applicant would reasonably expect in the context of applying for employment with us.
  • To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted PI.  
  • To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.  
  • To ensure the physical safety of natural people.  
  • Services performed for the Company in connection with recruitment and applicant administration, including maintaining applicant accounts or profiles, verifying applicant information, processing interview-related reimbursements where applicable, providing analytic services, storage, security, or similar applicant-related services for the Company.
  • Collecting or processing SPI only for disclosed applicant-related purposes and not for the purpose of inferring characteristics about a Job Applicant.

California Residents: Notice at Collection

If you are a California resident, the CCPA may provide you with the following rights regarding PI we collect, use, disclose, and retain about you in the employment context, subject to applicable exceptions and limitations. These rights do not override legal, regulatory, payroll, tax, benefits, litigation-hold, security, workers’ compensation, occupational health and safety, or employment-record retention obligations.
  • Right to Know and Data Portability Requests. You have the right to request that we disclose certain information to you about our collection and use of your PI (the "right to know"), including the specific pieces of PI we have collected about you (a "data portability request"). Our response will cover the 12-month period preceding the request, although we will honor requests to cover longer periods that do not extend past January 1, 2022, unless providing a longer timeframe would be impossible or involves disproportionate effort. You may exercise your right to know twice in any 12-month period. Once we receive your request and confirm your identity (see Section How to Exercise Your Rights), we will disclose it to you: 
    • The categories of: 
      • PI we collected about you; and 
      • sources from which we collected your PI. 
    • The business or commercial purpose for collecting your PI and, if applicable, selling or sharing your PI. 
    • If applicable, the categories of persons, including third parties, to whom we disclosed your PI, including separate disclosures identifying the categories of your PI that we: 
      • disclosed for a business purpose to each category of persons; and 
      • sold or shared to each category of third parties. 
    • When your right to know submission includes a data portability request, a copy of your PI, subject to any permitted redactions. 
  • Right to Delete and Right to Correct. You have the right to request that we delete any of your PI that we collected from you and retained, subject to certain exceptions and limitations (the "right to delete"). Once we receive your request and confirm your identity, we will delete your PI from our systems unless an exception allows us to retain it. We will also notify our Service Providers, contractors, and other recipients to take appropriate action. You also have the right to request correction of PI we maintain about you that you believe is inaccurate (the "right to correct"). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct PI that our review determines is inaccurate and notify our Service Providers to take appropriate action. 
  • Right to Limit Sensitive Personal Information Use and Disclosure to Permitted SPI Purposes. You have a right to ask businesses that use or disclose your SPI to limit those actions to just the CCPA's Permitted SPI Purposes listed above (the "right to limit"). We do not use or disclose your SPI for purposes that give rise to a right to “Limit the Use of Your Sensitive Personal Information” under CCPA. Because we do not use SPI for purposes that trigger the right to limit under California law, a “Limit the Use of My Sensitive Personal Information” link is not applicable currently. If our practices change, we will provide that link and update this Policy. 
  • Right to non-discrimination. You have the right not to be discriminated against or retaliated against for exercising any of your privacy rights under the CCPA. 
  • The right to designate an authorized agent to submit one of the above requests on your behalf. See below how you can designate an authorized agent within Section: Verification Process and Authorized Agents.

Responding to Your Requests to Know, Delete, or Correct 

We will confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please reach out to privacy@frankcrum.com. We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response to your verified email address. Our substantive response will tell you whether we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all the PI that we hold about you, or we may have destroyed, deleted, or made your PI anonymous in compliance with our record retention policies and obligations. 

Any disclosures we provide will cover information for the 12-month period preceding the request receipt date. We will consider requests to provide longer disclosure periods that do not extend past January 1, 2022, unless providing a longer timeframe would be impossible or involves disproportionate effort. 

For data portability requests, we will select a format to provide your PI that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. 

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Verification Process and Authorized Agents  

If you are a California resident, you can authorize someone else as an authorized agent who can submit a request on your behalf.
To do so, you must either:  
  • execute a valid, verifiable, and notarized power of attorney; or
  • provide other written, signed authorizations that we can then verify. When we receive a request submitted on your behalf by an authorized agent who does not have a power of attorney, that person will be asked to provide written proof that they have your permission to act on your behalf, and we will also contact you and ask you for information to verify your own identity directly with us and not through your authorized agent. We may deny a request from an authorized agent if the agent does not provide your signed permission demonstrating that you have authorized them to act on your behalf.

Response and Timing on Rights to Opt-Out

In response to your request to opt-out, we will process your request, as soon as feasibly possible, but no later than 15 business days from the date we receive the request. We will only use Personal Information provided from your request to comply with the request.

We will also notify our service providers, contractors, and certain other downstream recipients of your request to opt-out and instruct them to both:
  • Comply with your request.
  • Forward the request to their own downstream recipients, if applicable.

We may deny opt-out requests if we have a good-faith, reasonable, and documented belief that the request is fraudulent and will clearly explain our denial decision to the requestor. You can confirm that we processed your request to opt-out by going to our website and clicking Cookie Preferences where we will have a toggle button showing what Cookies are active. However, you may change your mind and opt back in at any time by re-toggling your Cookie Preferences.


Notice of Right to Opt-Out of Profiling, Automated Decision Making, and Targeted Advertising 

We do not engage in profiling or automated decision-making to make decisions that produce legal or similarly significant effects concerning Job Applicants. We also do not use automated decision-making technology to replace or substantially replace human decision-making for significant applicant or hiring decisions. Where required by applicable law, Job Applicants may contact us using the request methods described in this Policy to inquire about rights that may apply to their PI. If our practices change, we will update this Policy and provide any required notices, rights, or opt-out mechanisms.

If FrankCrum begins using automated decision-making technology, profiling, AI-enabled tools or similar technologies to make or substantially assist decisions that produce legal or similarly significant effects concerning Job Applicants, FrankCrum will provide any legally required pre-use notice, access rights, opt-out rights, appeal or human-review rights, and risk-assessment disclosures before or at the time required by applicable law. FrankCrum will also assess whether any such use requires a data protection assessment, cybersecurity audit, or other governance documentation under applicable law.

Response and Timing for Privacy Requests

We will process privacy requests in accordance with applicable law and within the timeframes required by the laws that apply to your request. We may take steps to verify your identity and authority before fulfilling certain requests, and we may request additional information where necessary to do so. Where permitted or required by law, we may deny a request in whole or in part, including where an exemption applies or where we are unable to verify the request. If we deny your request, we will explain the basis for the denial to the extent permitted by law. Where applicable law provides an appeal right, we will describe how to appeal a denial in our response.

Please Note: Privacy requests submitted by Job Applicants will be assessed in accordance with applicable law, the nature of the information involved, and the applicant relationship. Certain rights described in this Policy may not apply to all Job Applicants or to all categories of applicant-related PI.

How to Exercise Your Rights

To exercise your rights described above, please submit a verifiable request to us by either: 

 

Notice Regarding Sale, Sharing, and Opt-Out Preference Signals

We do not sell Job Applicant PI for monetary or other valuable consideration, and we do not share Job Applicant PI for cross-context behavioral advertising. As a result, we do not currently engage in practices that would require a “Do Not Sell or Share My Personal Information” link for Job Applicant PI. If a California opt-out preference signal or similar signal is received in connection with Company-controlled employment-related resources, we will evaluate and honor it to the extent required by applicable law, but such signals generally are not applicable where no sale or sharing occurs. Where required by applicable law, Job Applicants may still submit privacy requests using the methods described in this Policy. If our practices change in a way that constitutes a sale or sharing under applicable law, we will update this Policy and provide any required opt-out tools and disclosures.

Additional Categories or Other Purposes

We will not collect additional categories of PI or use the PI we collected for materially different, unrelated, or incompatible purposes without providing you with notice. If required by law, we will also seek your consent before using your PI for a new or unrelated purpose.

Sources of Personal Information

We collect your Personal Information from the following sources: 
  • Affiliated entities.
  • Applicant Tracking System (“ATS”).
  • Automatically through our Site(s) and utilizing Service(s) (e.g. session, security logs, cookies, pixels, limited internal analytics, and similar technologies.).
  • Company systems, networks, software applications, and databases you log into or use while applying for a position with the Company, including from vendors the Company engages to manage or host such systems, networks, applications or databases.
  • Directly from you, the applicant, when you apply for a position of employment or voluntarily submit information.
  • Employment agencies and recruiters.
  • Job board websites you may use to apply for a job with us.
  • Human Resources Information System (“HRIS”) (e.g. Employee tracking and talent management systems).
  • Internally, such as from interviewers, recruiters, hiring managers, applicant evaluations, testing, or other applicant-related observations and interactions.
  • Pre-employment screening services, such as background check providers, where permitted by law.
  • Prior employers or references that you authorize us to contact.
  • Professional references that you authorize us to contact.
  • Service providers, vendors, and business partners, including those that support our operations.
  • Social media platforms (e.g., Facebook, LinkedIn).
  • Via physical locations (e.g. badge logs, video surveillance). 
  • Publicly available sources.

To Whom We Disclose Personal Information 

We disclose PI only to the categories of recipients listed below for business and commercial purposes:
    • Affiliated entities.
    • Advertising, analytics, marketing, tracking, and retargeting providers (e.g., Google Analytics).
    •  Applicant Tracking System (“ATS”).
    • Business transaction recipients, such as a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets.
    •  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.
    • Communication service providers that facilitate, manage, and send/receive communications on our behalf via email, text/SMS, phone, or that record, transcribe, summarize, or process phone calls and video meetings.
    •  Consulting and investigation firms (e.g. HR consultants, safety consultants, and workplace investigators).
    •  Consumer reporting agencies, background-check providers, or similar recipients only where permitted by law and subject to applicable authorization, disclosure, certification, and adverse-action requirements.
    • Corporate clients (meaning an entity, as opposed to a natural person, that purchases any of our services).
    •  Data brokers.
    • Financial institutions and payment processors.
    •  Government or public agencies (as required by law).
    •  Human Resources Information System (“HRIS”).
    • IT, cybersecurity, privacy, risk and other operational vendors that support our systems and services (e.g. internet services providers).
    •  Law enforcement, courts, and attorneys.
    • Marketing support providers (e.g. Website host).
    •  Recruiting firms and/or staffing agencies.
    • Social media platforms (e.g., Facebook, LinkedIn).
    •  Transactional support vendors.  

We contractually require service providers, contractors, and other recipients that process PI on our behalf to keep it confidential and use it only for the limited purposes for which we disclose it to them, unless otherwise permitted or required by law.

These third parties may use tracking technologies to collect information about you when you use our website. The information they collect may be associated with your PI, or they may collect information, including PI, about your online activities over time and across different Site, apps, platforms, and other online Services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the provider responsible directly.

By selecting “View Details” through our Career site or initiating the application process, you may be redirected to a third-party application platform operated by a third party. Upon redirection, you engage directly with that third-party platform, which is governed by its own privacy practices. Before redirection and while interacting with our Site(s), we use analytics, advertising, retargeting, social media and similar technologies that may constitute a sale or sharing of website-collected applicant information under applicable law. We provide applicable opt-out mechanisms, including honoring applicable opt-out preference signals where legally required.

Reasons Why We Collect, Use, Retain, and Disclose Personal Information

We may collect, use, and disclose your PI for any of the following business and commercial purposes:
  • Advertising and Marketing. Provide and serve interest based and targeted advertising across desktop and mobile devices.
     
  • Analytics and Insights. To analyze and improve our recruitment activities by creating and using aggregated, de-identified, or anonymized data; and to understand applicant demographics for lawful business purposes, including diversity and equal opportunity initiatives.
  • Business Operations and Improvement. To evaluate and improve our recruiting methods, application processes, and overall business operations; manage relationships with vendors, service providers, and contractors supporting recruitment activities; and debug, identify, and repair errors in our systems.
  • Comply With Legal, Regulatory, and Recordkeeping Obligations. Comply with applicable state and federal labor, employment, tax, benefits, workplace safety, and related laws. Maintain required business, tax, employment, and compliance records and comply with record‑retention requirements.
  • Communications and Service Delivery. To communicate with you regarding your candidacy, potential opportunities with the Company, and updates to applicable terms, policies, or the careers site.
  • Consumer Requests. Verify, respond to, and retain your selections for privacy‑related opt‑out requests in accordance with applicable privacy laws.
  • Corporate Transactions. To evaluate or participate in corporate transactions, such as mergers or acquisitions, where applicant information may be reviewed or disclosed subject to appropriate confidentiality protections.
  • Credit, Background, and IdentityRelated Check. Conduct credit and background reference checks on clients for account review.
  • Disclosures to Third Parties and Authorities. To share information with service providers, government authorities, law enforcement, courts, or private parties where we have a good-faith belief it is necessary to comply with legal obligations, enforce our policies, or protect our rights and safety or those of others.
  • Expense Reimbursement. To administer, process, document, and reimburse approved expenses related to candidate interviews, including travel, lodging, meals, and other recruitment-related costs.
  • Fulfillment of Collected Purpose. To fulfill or meet the purpose for which the information was provided, such as using your contact information and application materials to assess your candidacy for employment.
  • Future Opportunities. To retain your information for consideration for future job openings, even if you are not selected for the position for which you initially applied.
  • Human Capital Analytics. Conduct internal analytics, including productivity and operational analysis, to improve workforce processes and business performance.
  • Operate, Maintain, and Improve Company Systems and Website. Facilitate the efficient and secure use of Company information systems. Debug, identify, and repair errors that impair intended website or system functionality.
  • Recruitment and Hiring Activities. To manage recruitment and hiring processes, including operating our careers site, recruiting, interviewing, and evaluating candidates; making and communicating decisions regarding your candidacy; conducting background checks and other pre-employment screening (where permitted by law); obtaining and verifying references and employment history; accommodating disabilities or health conditions; and establishing and retaining a job applicant profile to streamline future applications or consider you for other opportunities.
  • Security, Fraud Prevention, and Incident Response. Detect, investigate, and respond to security incidents or potentially unauthorized access, use, or disclosure of PI. Protect against malicious, fraudulent, or illegal activity and prosecute those responsible. Prevent identity theft.
  • Support Business Operations and Vendor/Service Provider Relationships. Evaluate, assess, and manage the Company’s business relationships with vendors, service providers, and independent contractors. 

Notice of Right to Opt-Out of the Selling and Sharing your Information

Depending on the state where you reside, you may have the right to tell us not to sell or share your PI . You have the full and free right to opt-out of our disclosure of your PI to any third parties where the disclosure constitutes “selling” or “sharing” as defined by specific state laws.

You may exercise your right to opt-out without fear of discrimination for doing so. To opt-out of our selling and sharing of your information, meaning we will not disclose your information to third parties for any monetary or other valuable consideration, you can do any of the following: Click  Your Privacy Choices to be taken to an online opt-out submission form.

You can use a Global Privacy Controls ("GPC") signal. FrankCrum will process opt-out preferences from GPC signals, which are in formats commonly used and recognized by businesses, such as an HTTP field header, as requests to opt-out of sale or sharing. The GPC signal opt-out will only apply to the browser you are using on your device; it will not apply to other browsers and/or devices to which GPCs are not activated or to offline sales. 

If you are unable to submit an opt-out through any of the above methods, please email privacy@frankcrum.com and we will assist in meeting your needs.

You can have an authorized agent submit a request on your behalf. To submit an opt-out through use of an authorized agent, you must provide that agent with written permission signed by you to submit an opt-out on your behalf, except when using an opt-out preference signal.

A request to opt-out need not be a verifiable consumer request. However, we may deny a request to opt-out if we have good faith, reasonable, and documented belief that a request to opt-out is fraudulent. If we deny your request to opt-out, we shall inform you of our decision not to comply and provide an explanation as to why we believe the request is fraudulent.

Use of Cookies, Pixels, and Other Tracking Technologies 

Our website stores or retrieves information on your browser, mostly in the form of cookies. A cookie is a small piece of data (text file) that a website - when visited by a user - places on the user’s device to remember information about the user, such as the user’s language preference or login information. This type of cookie is set by us and is referred to as a “first-party cookies.” Our website uses first-party cookies primarily to make the website work as you expect it to. For example, we use the information we collect through first-party cookies to allow you to navigate between pages efficiently, analyze how well our website is performing, and understand the content that you spent most of your time reviewing. We use first party cookies for website functionality and measurement, and we use third-party cookies and tracking technologies (such as advertising or analytics pixels) to support interest based and cross context behavioral advertising including advertising platforms, analytics providers, and retargeting partners. We also incorporate cookies and similar technologies, such as pixels, tags, and web beacons, from outside our website’s domain (“third-party cookies”). Third-party cookies gather information to enable our vendors to provide a range of services to us, including targeted advertising and measuring the success of our advertising campaigns.

Cross‑context behavioral advertising means targeted advertising based on PI obtained across businesses, websites, applications, or services with which the consumer interacts. Below is a detailed list of the categories of first and third-party cookies we use on our website. You can prevent the collection of data by non-essential performance, functionality, and marketing cookies by clicking on our which controls the collection of preferences on our website.

We make use of cookies under the following circumstances and for the following reasons:
Provide you with services available through the website and enable you to use some of its features.
  • Authenticate users and prevent fraudulent use of user accounts.
  • Identify if users have accepted the use of cookies on the website.
  • Compile data about website traffic and how users use the website to offer a better website experience.
  • Understand and save visitor preferences for future visits, such as remembering your login details or language preference, providing you with more personal experience, or avoid having to re-enter your preferences every time you use the website.
  • Track your browsing habits to enable us to show advertising which is more likely to be of interest to you, including advertising by third parties on our website.

We use third-party analytics, advertising, retargeting, social media, and similar technologies on our Site. Depending on the technology and applicable law, these activities may involve the sale or sharing of website-collected Job Applicant PI for cross-context behavioral advertising. You may manage cookie preferences through available cookie controls or your browser settings. Please note that disabling certain cookies may affect the functionality and performance of our Site.

Essential Cookies

Essential cookies are necessary for the website to function properly and cannot be switched off in our systems. They are usually only set in response to a website visitor’s request for services, such as a visitor setting up their privacy preferences, logging in, or filling in forms. You can set up your browser to block or alert you about these cookies, but blocking these cookies will prevent the website from working correctly or might prevent the website from working at all.

Non-Essential Cookies

Non-Essential cookies are not essential to the website functionality but serve some other unique purposes:  

  • "Performance" cookies (sometimes referred to as "analytics" cookies) collect information about how visitors interact with our website. These cookies may collect online identifiers such as IP address or device information, which are used in aggregated or anonymized form to improve website performance, for example:
    • Pages visited.
    • Links clicked within the website.
    • General traffic patterns.
    • Traffic sources.
  • "Functional" cookies (sometimes referred to as "preference" cookies) enable enhanced functionality and personalization, such as remembering your preferences and past choices on the website through secure authentication tokens. For example, functional cookies can collect:
    • Encrypted login session identifiers (not passwords).
    • Masked or tokenized user identifiers.
    • Language or regional preferences.
    • Saved display or accessibility settings.
  • "Marketing" cookies (sometimes referred to as "tracking" or "advertising" cookies) can track browsing behavior, content viewed, and interactions to support targeted advertising and cross-context behavioral advertising. This can include:
    • Links the user follows.
    • Ads the user clicks.
    • Browsing behavior across websites.
    • IP address and device information.

Information on Some of the Cookies in Use on our Site

For information on some of the cookies we use on our site and apps, please review the policies from some of our vendors:

Cookie Management 

You can control and manage cookies associated with your browser. If you are interested in controlling and managing cookies from your browser including any set by our website, please refer to http://www.allaboutcookies.org/manage-cookies/index.html for information on different ways to configure your browser’s cookie settings.

 If you want to clear all cookies left behind by the websites you have visited, here are links where you can download three third party programs that clean out tracking cookies.
Below you can find some guidance:
You can adjust your advertising preferences on mobile devices through your device settings.
Below you can find some guidance based on your type of mobile device:

Opt-Out Preference Signals

Opt-out preference signals provide consumers with a simple and easy-to-use method by which to exercise the right to opt-out of the selling and sharing of their information. Global Privacy Controls (“GPC”) or Universal Opt-Out Mechanism (“UOOM”) are user-enabled opt-out preference signals which can communicate a user’s “Do Not Sell or Share” request on behalf of the person or device. We will process opt-out preferences from GPC and UOOM signals which are in formats commonly used and recognized by businesses, such as an HTTP field header. We will treat a consumer’s use of GPCs or UOOMs as a valid request to opt-out of the selling and sharing of information for that browser. We currently do not connect browser use to consumers and, as such, you will need to use GPCs or UOOMs on all browsers in which you access our website and use our opt-out form to opt-out of offline sales.

Do Not Track ("DNT") is a privacy preference that users can set if they do not want web services to collect information about their online activity. We do not respond to DNT signals or other mechanisms (except for GPCs and UOOMs) that provide a choice regarding the collection of PI about activities over time and across different websites or online services. We encourage users who have DNTs to use GPCs or UOOMs.

Digital Advertising Alliance

Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (“DAA”) which maintains self-regulatory programs along with websites where people can opt out of interest-based advertising from their members. To opt-out of website interest-based advertising visit the DAA’s opt-out portal available at http://optout.aboutads.info/. To opt-out data collection for interest-based advertising across mobile applications by participating companies, download the DAA’s AppChoices mobile application opt-out offering found here: https://youradchoices.com/appchoices.

Non-Participant Opt-Out Options

Some of our vendors do not participate in the DAA self-regulatory program for online behavioral advertising or have developed their own processes for allowing consumers to opt-out: https://branch.app.link/optout.

Some devices and apps do not have access to web-based browser cookie opt-outs. To learn more about the advertising opt-outs provided by your mobile device’s operating system (like iOS and Android) or the device manufacture, click here.

Notice of Right to Opt-Out of Profiling, Automated Decision Making, and Targeted Advertising

Depending on your state of residence, you may have the right to opt out of targeted advertising and selling of your data. You may submit a request to exercise this right by clicking Your Privacy Choices or emailing privacy@frankcrum.com. Please see Section: Automated Decision-making, Profiling, and AI  for more details on our Company practices.

U.S. Consumer Privacy Rights 

Depending on your state of residence, the nature of your relationship with the Company, and the type of PI involved, you may have certain rights under applicable U.S. privacy laws, subject to applicable exceptions and limitations. Many state privacy laws do not apply, or apply only in a limited manner, to PI collected and used solely in the employment context. Accordingly, Job Applicants may have limited privacy rights with respect to their employment-related Personal Information, except to the extent otherwise provided by applicable law.

  • Access and Data Portability. You may confirm whether we process your PI and access a copy of the PI we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information, and it will be included in the response to your access request.
  • Correction. You may request that we correct inaccuracies in your PI that we maintain, considering the information's nature and purpose of processing. 
  • Deletion. You may have the right to request that we delete PI we maintain about you, subject to applicable exceptions, including where retention is required or permitted for recruitment, applicant evaluation, equal employment opportunity, immigration, background-screening, tax, security, compliance, litigation, audit, or recordkeeping purposes.
  • Opt-Out of Using Personal Information for Targeted Advertising, Profiling, and Sales (Where Applicable). You may request that we do not use your PI for these purposes.
  • Appeal. Appeal our decision regarding your privacy rights request (where required by law). Unless otherwise required by state law, your appeal rights apply to any denied request, and we will provide a written outcome within the period required by your state of residence. If we deny your request, you may appeal by emailing privacy@frankcrum.com with the subject line Privacy Rights Appeal.

Important: The scope of these rights varies by state and may not apply in all circumstances. Certain PI may be exempt from state privacy laws, including information collected, processed, disclosed, or retained pursuant to applicable federal or state financial privacy laws, insurance laws, or related regulations, as well as information processed solely in the employment, job applicant, benefits administration, or business-to-business context where an applicable law provides an exemption.

Contact Us

To exercise your rights, please submit a verifiable request to us by either:


How We Retain Your Personal Information 

 We maintain retention schedules aligned to legal, regulatory, tax, and contractual requirements and delete or de-identify data when no longer needed. For Job Applicants, we retain application materials and related PI for the period necessary to evaluate candidacy, administer recruitment activities, comply with equal employment opportunity, immigration, background-screening, tax, audit, litigation, and recordkeeping obligations, resolve disputes, maintain security, and consider applicants for future opportunities where permitted by law. We align retention to data minimization and reasonable expectations for each purpose.  

Data Minimization 

We limit our collection, use, and retention of PI to what is reasonably necessary and proportionate for the purposes described in this Policy.

External Links 

Our website contains links to other websites. We are not responsible for the privacy practices or the content of such websites. To help ensure the protection of your privacy, we recommend that you review the Policy of any website you visit via a link from our website.  If you access our website through a mobile device, your device or browser may prompt you to grant permission for features such as location, push notifications, or camera access. You can revoke these permissions at any time through your device settings.

Passwords  

If you create or use login credentials for an applicant portal, career site, or related recruiting system, you are responsible for maintaining the confidentiality of your username, password, and other access credentials and for protecting them against unauthorized use or disclosure.

Automated Decision-Making, Profiling, and AI 

We do not use automated decision-making systems, including machine learning or AI tools to make decisions that produce legal or similarly significant effects on you. This includes decisions relating to eligibility for, or access to, credit, employment, housing, financial services, essential or federally regulated services, or other outcomes that could meaningfully affect your rights or opportunities. If any automated output could influence how we present content or offer to you on the website, those outputs operate within predefined parameters and are either reviewed or overseen by people or constrained, so they do not produce legal or similarly significant effects.

We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. If we ever begin using profiling in a way that implicates additional rights (for example, under the laws of states that provide opt‑out rights for certain profiling), we will update this Policy and provide any required opt‑out mechanisms.

If we materially change how we use automated decision‑making, profiling, or AI—including if future law requires additional disclosures, access, appeal, or opt‑out rights for such processing—we will update this Policy and provide any required tools, disclosures, and instructions at or before the time those changes take effect.

Compliance With Law and Safety

We may disclose specific PI and/or SPI when we have a good-faith belief that disclosure is necessary or appropriate to comply with applicable law, legal process, regulatory requests, or law enforcement requests; to protect the rights, safety, and property of the Company, Job Applicants, employees, or the public; or to investigate, prevent, or respond to suspected fraud, security incidents, or unlawful activity.

How We Protect Your Personal Information 

We use commercially reasonable administrative, physical, and technical measures designed to protect your Personal Information from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your Personal Information transmitted to, through use, or in connection with the Services. Email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of Personal Information is at your own risk. The safety and security of your information also depend on you. You are responsible for taking steps to protect your Personal Information against unauthorized use, disclosure, and access.  

Children's and Minors' Data 

Our employment opportunities and applicant-facing portions of the Site are intended for individuals who are legally eligible to apply for employment. We do not knowingly sell or share the Personal Information of Job Applicants under the age of 16, and no one under 16 may provide Personal Information to or through the applicant-facing portions of the Site. If we learn that we have collected or received Personal Information from a child under 16 without required consent, we will delete that information. If you believe we might have information from or about a child under 16, please contact us at privacy@frankcrum.com.

International Visitors

Our website is intended only for U.S. audiences; individuals outside the U.S. should not submit PI.

Communications

We may contact you about your application, candidacy, interview scheduling, recruiting process, or other employment-related matters. If we send optional recruiting or talent-community communications, you may opt out by following the instructions provided in the communication or by contacting us. We may still send transactional, administrative, or legally required communications related to your application or our recruiting process.

Acknowledgment of this Policy

By accessing or using our Site(s) or using our Service(s), you acknowledge that you have read and understand this Policy.

Changes to Our Privacy Policy

We may update this Policy from time to time, and we will provide notice of any such changes to the Policy as required by law. The date the Policy was last updated is identified at the top of the page. We will notify you of changes to this Policy by updating the "last updated" date and posting the updated Policy on the Services. We may email or otherwise communicate reminders about this Policy, but you should check our Services periodically to see the current Policy and any changes we have made to it.

Job Applicants With Disabilities  

This Policy is available in formats accessible to applicants with disabilities. If you need this Policy in an alternative format, please contact us using the contact information below. 

Contact Information 

To exercise your rights or ask questions or comment about this Policy or our privacy practices, contact us at: privacy@frankcrum.com or via our toll-free number: 1-800-393-0815, Option 21. 

Affiliated Entities 

  • FrankCrum Corporate Inc.
  • FrankCrum General Agency, Inc.   
  • FrankCrum Insurance Agency, Inc.  
  • FrankCrum Staffing Inc.
  • Frank Winston Crum Insurance Company