California Applicant and Employee Privacy Notice

Effective Date January 1, 2023

Under the California Consumer Privacy Act (“CCPA”), API Hub, Inc. (“Clearbit”, “we” or “us” or “our”) is required to provide its employees who are California residents a notice that identifies the categories of personal information that may be collected and why Clearbit collects such information.

Please note that this California Applicant and Employee Notice (the “Notice”) does not form part of any employment contract or contract to provide services.

This Notice does not apply to our handling of data gathered about you in your role as a user of Clearbit services (such as when visiting our website), for the business data we collect and process when providing our services to customers, or for the personal data available to customers or other users of our services. When you interact with us as in that role, the privacy policy associated with the relevant service applies.

1. Definitions

1.1 “Personal information” has the meaning as defined in the CCPA, and includes information that is collected by Clearbit about you in the course of employment for employment related purposes and encompasses any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

1.2 “Process”, “processed” or “processing” means any operation or set of operations which is performed on personal information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal information.

1.3 “Employees”, “employee” or “you” means an identified or identifiable natural person who is a California resident and who is acting as a Clearbit job applicant, employee, or contractor. In this context “job applicant” refers to any person who has submitted his or her candidacy with Clearbit; “employee” refers to any person who is employed at Clearbit as a full-or part-time employee or temporary worker, and “contractor” means a natural person who provides any service to a business pursuant to a written contract.

2. Personal Information We Collect About You

We collect, store, and use various types of personal information through the application, recruitment, engagement, or employment processes. We collect such information either directly from you or (where applicable) from another person or entity, such as an employment agency or consultancy, recruitment or professional networking website, background check provider, or others who provide references. We will collect additional personal information throughout the course of your employment or other provision of services to us.

Listed below are the categories of personal information that Clearbit may process about employees. The personal information we process may vary depending on your role with Clearbit, such as whether you are a job applicant or whether you are a current or former employee:

2.1 Identifiers, including real name, alias, postal address, unique personal identifiers such as a device identifier, email, account name, social security number, driver’s license number, passport number or other similar identifiers.

2.2 Characteristics of Protected Classifications Under California or Federal Law, including the following: race, skin color, national origin, religion (includes religious dress and grooming practices), sex/gender (includes pregnancy, childbirth, breastfeeding and/ or related medical conditions), gender identity, gender expression, sexual orientation, marital status, medical condition (such as genetic characteristics, cancer or a record or history of cancer), disability (such as mental and physical including HIV/AIDS, or cancer), military or veteran status, request for family care leave, request for leave for an employee’s own serious health condition, request for pregnancy disability leave, and age.

2.3 Internet or Other Electronic Network Activity Information, including browsing history, search history, application access location and information regarding an employee’s interactions online within Clearbit’s network or on a Clearbit-issued device.

2.4 Professional or Employment-related Information, including job related data, maintained as part of the employment relationship that is present in: a job application or resume; an employment contract; a contractor agreement; a performance review; a disciplinary record; information from employee expenses; payroll and benefits related data; or internal and external contact information.

2.5 Education Information, including information about an employee’s educational background, such as education records, report cards, and transcripts.

2.6 Audio or Visual Information, including CCTV footage, as well as other information relating to the security of our premises collected during in-person interviews or other parts of the recruitment process, and photographs or videos submitted.

2.7 Health-Related Information, which may include your beneficiaries and include medical conditions and other information provided in statement of health forms, disability status, health and safety incidents or accidents, sickness records, and health issues requiring adaptations to your working environment or working practices.

2.8 Financial Information, including salary, payroll, pension or retirement contribution information; and bank account and tax information.

2.9 Biometric Information, including imagery of your face and voice recordings that we process for authentication and security purposes.

2.10 Sensitive Personal Information, such as Social Security number and driver’s license number. Some other information listed in this section 3, such as biometric information, may be considered “sensitive personal information” under California law.

2.11 Inferences, including any information drawn from any of the personal information categories referenced above to create a profile about an employee reflecting the employee’s characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

2.12 Other Information that Directly or Indirectly Identifies You, including date and place of birth, citizenship, and permanent residence (and such information about your dependents or emergency contacts); and information on any publicly available social media profile of yours that mentions your connection to us or our services.

3. Purposes for Collecting Your Personal Information

Clearbit collects the personal information identified in Section 3 above for the reasons listed below.

3.1 To Recruit Employees, including to conduct employment related background screening and checks.

3.2 To Administer Benefits, such as medical, dental, optical, commuter, and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, insurance and accident management and provision of online total reward information and statements.

3.3 To Pay and Reimburse for Expenses, including salary administration, payroll management, payment of expenses, to administer other compensation related payments, including assigning amounts of bonus payments to individuals, administration of departmental bonus pools and administration of stock option payments.

3.4 To Conduct Performance-Related Reviews, including performance appraisals, career planning, skills monitoring, job moves, promotions and staff restructuring.

3.5 To Monitor Work-Related Licenses and Credentials, including provisioning software licenses for use in the course of an employee’s work related responsibilities, ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies.

3.6 To Provide Our Employees with Human Resources Management Services, including providing employee data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of employee claims, and travel administration.

3.7 To Assist You in Case of Emergency, including maintenance of contact details for you, and your dependents in case of personal or business emergency.

3.8 To Monitor Eligibility to Work in the U.S., which means monitoring and ensuring compliance of employees’ ability to work in the U.S.

3.9 To Conduct Healthcare-Related Services, including employment-related medical screenings for return to work processes and medical case management needs; determining medical suitability for particular tasks; identifying health needs of employees to plan and provide appropriate services, including operation of sickness policies and procedures.

3.10 To Facilitate Better Working Environment, which includes conducting staff surveys, providing senior management information about other employees, and conducting training.

3.11 To Ensure a Safe and Efficient Working Environment, which includes Clearbit actions relating to disciplinary actions, COVID healthcare screenings, and code of conduct processes and investigations.

3.12 To Maintain Security on Clearbit Websites and Internet Connected Assets, which includes hosting and maintenance of computer systems and infrastructure; management of Clearbit’s software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; and monitoring email and Internet access.

3.13 To Comply with Applicable Law or Regulatory Requirements, such as legal (state and federal) and internal company reporting obligations, including headcount, management information, demographic and health, safety, security and environmental reporting.

3.14 To Exercise Our Legal Rights, such as seeking legal advice from our external lawyers or in connection with litigation with a third party.

We may also use personal information for any other legally permitted purpose (subject to your consent, where legally required).

4. When We Disclose Your Personal Information

We may disclose your personal information to the following types of entities or in the following circumstances (where applicable):

  • Internally: to people within Clearbit to carry out the purposes described in this Notice, including to your manager, human resources, as well as personnel within Clearbit, such as payroll, IT, legal and finance.
  • Vendors: such as compensation and benefits providers, tax and other professional advisors, technology service providers, corporate card issuers, travel management providers, travel providers, human resources suppliers, background check companies, and employment businesses (in relation to contractors or agency workers).
  • Recruiters: to the extent you are working with a recruiter in connection with your application for employment and your recruiter is authorized by you to obtain feedback from us regarding your application and interview process.
  • Business operations: to provide another entity (such as a potential or existing business counterparty or customer) with a means of contacting you in the normal course of business, for example, by providing your contact details, such as your phone number and email address.
  • Legal compliance and exercising legal rights: when required to do so by law, regulation, or court order or in response to a request for assistance by the police or other law enforcement agency; and to seek legal advice from our external lawyers or in connection with litigation with a third party.
  • Business Transaction Purposes: in connection with the sale, purchase, or merger of a business.
  • Consent: with your consent and as permitted by law, we may share personal information with any other third parties in any other circumstances.

5. Data Retention

The personal information we collect about employees will be retained for as long as necessary to satisfy the purposes for which it was collected and our legal obligations. As described above, these purposes include our business operations and complying with reporting, legal and accounting obligations. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process the personal information and whether we can achieve those purposes in other ways, the applicable legal requirements, and our legitimate interests.

6. Your Choices

California residents have certain rights regarding their personal information. Subject to certain exceptions, if you are a California resident, you may request:

  • access to your personal information including the right to know the categories of personal information we have or will collect about you and the reason we will or have collected such information;
  • correction of the personal information that we have or will hold about you that is inaccurate;
  • deletion or removal of your personal information.

You also have the right not to be discriminated against (as provided for in California law) for exercising your rights.

There are certain exceptions to these above rights. For instance, we may retain your personal information if it is reasonably necessary for us or our vendors to provide a service that you have requested or to comply with law or to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for that activity.

To exercise one of the rights above, you or your authorized agent may contact us as provided below.

We will take reasonable steps to verify your identity before responding to a request. In doing so, we may ask you for verification information so that we can match at least two verification points with information we maintain in our files about you. If we are unable to verify you through this method, we shall have the right, but not the obligation, to request additional information from you.

California residents have certain rights with respect to our collection of sensitive personal information. We do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA.

California law places certain obligations on businesses that “sell” personal information to third parties or “share” personal information with third parties for “cross-context behavioral advertising” as those terms are defined under the CCPA. We do not “sell” or “share” the personal information covered by this Notice and have not done so in the twelve months prior to the effective date of this Notice.

7. Updates

We may update this Notice at any time. We may also provide you additional privacy notices regarding our collection, use or disclosure of information. Please read this Notice and any other privacy notices carefully.

8. Further Information

If you have any questions about this statement, please contact