NETJETS CALIFORNIA PRIVACY NOTICE FOR APPLICANTS - EFFECTIVE DATE: JANUARY 1, 2023

NetJets and its subsidiaries and US affiliates (“NetJets”, “us”, “we”, or “our”) provides this California Privacy Notice for Applicants (“Notice”) to explain our practices regarding the collection and use of Personal Information about California individuals during our job application and pre-employment process, including through our careers website (netjets.com/en-us/careers) (“Applicants”). This Notice explains what Personal Information we collect about California Applicants, why we collect it, how we use and share it, and the rights you have relating to your Personal Information under the California Consumer Privacy Act, as modified by the California Privacy Rights Act of 2020 (the “CCPA”).

As used in this Notice, the term “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.

1. PI WE COLLECT

We collect, and within the past twelve (12) months, have collected the following Personal Information about our Applicants. Note that the Personal Information we collect about you may vary depending on the nature of your interactions with us and may not include all of the examples listed below.

  • Identifiers
    • This may include, but is not limited to, name, alias, title, username and password for our careers website, telephone number, email address, mailing address, IP address, signature, social media usernames, and professional license numbers.
  • Personal records under Cal. Civ. Code § 1798.80(e)
    • This may include, but is not limited to, name, physical and electronic signature, address, telephone number, education, employment, and employment history.
  • Protected classification characteristics under California or federal law
    • This may include, but is not limited to, age and date of birth, marital status, race, ancestry, ethnic origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, genetic information, and disability.
  • Internet or other electronic network activity information
    • This may include, but is not limited to, browser type and language, operating system, website access time, duration of visit, referring website address, browsing and search history on our websites, webpages viewed immediately before and after our websites, information related to your interactions with our websites, social media pages, emails, online chat, text message communications, and advertisements.
  • Geolocation data
    • This may include, but is not limited to, your geographic location inferred from your device IP address.
  • Audio, electronic, visual, thermal, olfactory, or similar information
    • This may include, but is not limited to, security camera recordings, photographs to the extent contained on documents you provide; audio recordings as may relate to your application.
  • Professional or employment-related information
    • Skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, application form, or cover letter;
    • Answers to behavioral or other screening questions in an application or interview;
    • Information contained in any websites or documents you choose to share with us;
    • Information relating to professional licenses, training, disciplinary actions, and membership in professional organizations;
    • Information relating to membership in civic organizations.
  • Non-public education information
    • This may include, but is not limited to, school(s) attended, grades, transcripts, records of attendance, disciplinary records, and other information relating to your secondary and post-secondary education, including any graduate or professional degrees.
  • Inferences drawn from other personal information
    • This may include, but is not limited to, preferences, characteristics, predispositions, behavior, or attitudes based on other personal information collected about you.
  • Sensitive Personal Information
    • Social security, driver’s license, state identification card, or passport number;
    • Personal Information that reveals an Applicant’s racial or ethnic origin, religious or philosophical beliefs, union membership, or genetic data;
    • and
    • Personal Information collected and analyzed concerning an Applicant’s health or physical attributes.
  • Additional Categories
    • We also collect some PI that does not directly fit within one of the categories defined by the CCPA.
    • This may include, but is not limited to:
      • Citizenship, immigration, visa status, and work authorization information (including information from related documents, such as those you provide with your US Citizenship and Immigration Services Form I-9);
      • Languages spoken;
      • Willingness to relocate;
      • Driving record;
      • Criminal records and background check information;
      • Credit check information for some positions; and
      • Drug and alcohol screening information.

We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

We also collect publicly available information about you, including information that is lawfully made available to the general public from federal, state, or local government records.

2. SOURCES OF PI

We may collect, or have collected, your PI directly from you, automatically when you use our website, from service providers that help us to run our business, from third parties, and automatically while you are on Company property, as well as drawn from the other categories of Personal Information we collect.

3. USE OF PI

We use and, within the past twelve (12) months, have used the Personal Information we collect to:

  • Open and maintain your application records
  • Assess your eligibility for employment
  • Communicate with you regarding your application
  • Comply with applicable laws and regulations, including tax and filing requirements
  • Arrange or reimburse expenses related to your travel for interviews or in connection with your candidacy for employment, contact you during travel, as necessary with travel service providers, or in an emergency.
  • Comply with NetJets policies
  • Manage the security of our premises and systems
  • Detect and prevent fraud against you and/or us
  • Facilitate your use of our website
  • Provide you with tailored recommendations, and updates
  • Improve our website, set default options, and provide you with a better application experience
  • Perform internal research and operate our business

4. SHARING OF PI

We do not and, within the past twelve (12) months, have not sold or shared for cross-context behavioral advertising the Personal Information of California Applicants that we collect in relation to your application(s) for employment at NetJets. If you also interact with us as a consumer, please review our California Consumer Privacy Notice for more information about our practices in that context.

We disclose and, during the last 12 months, have disclosed the above categories of Personal Information to our service providers that help us run our business, benefits providers, and governmental authorities for the following business purposes.

  • Ensuring security and integrity of Personal Information;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Short-term, transient use, including, but not limited to, nonpersonalized advertising;
  • Performing services on our behalf;
  • Undertaking internal research for technological development and demonstration;
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us;
  • Processing, maintaining, or collecting Personal Information on our behalf;
  • Detecting or protecting against malicious, deceptive, fraudulent or illegal activity; and
  • For internal use by the service provider.

5. RETENTION OF PI

We keep the categories of Personal Information described above for as long as is necessary for the purposes described in this Notice or otherwise authorized by law and consistent with our document retention policies. This generally means holding the information for as long as one of the following apply:

  • Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
  • Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;
  • The information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
  • We are otherwise required or permitted to keep your information by applicable laws or regulations.

Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.

6. CALIFORNIA PRIVACY RIGHTS

If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please complete our data privacy request form or call us at 1-855-689-2391. Please note that, if you submit a request to know, request to delete, or request to correct, you may be asked to log into your account or to provide 2-3 pieces of Personal Information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the webform or toll-free number listed above.

Right to Know. You have the right to know what Personal Information we have collected about you, which includes:

  • The categories of Personal Information we have collected about you, including
    • The categories of sources from which the Personal Information was collected;
    • Our business or commercial purposes for collecting or disclosing Personal Information;
    • The categories of recipients to which we disclose Personal Information;
    • The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information.
  • The specific pieces of Personal Information we have collected about you.

Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions.

Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.

Rights Related to Automated Decision-Making. You have the right to opt out of automated decision-making, including profiling, that we use to evaluate certain personal aspects relating to your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us, including retaliation against you as a job applicant.

7. CONTACT US

For more information on your California privacy rights, contact us here.