Last Reviewed: September 7, 2023

This Employee, Contractor, and Applicant Privacy Notice (“CA Notice”) applies solely to those who reside in the State of California and are a job applicant to, an employee of, owner of, director of, officer of, or a contractor (“consumers” or “you”) of Spectrum Equity Management, L.P., Spectrum Management Equity, Inc. and its affiliates (collectively referred to as “Spectrum”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act (CPRA), and any terms defined in the CCPA and CPRA have the same meaning when used in this CA Notice.

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

Categories of Personal Information We Collect

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

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

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

Categories of Personal Information Collected	Examples	Business Purposes
Identifiers	Name Email address Home address Business address IP address Phone number Social Security Number Online identifiers Employee ID Visa status	HR administration, such as benefits, payroll, and other employment-related purposes Job Application Process
Protected classification information	Marital Status Age Disability information (relating to any accommodations you request) Veteran or military status Race Sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions or events) National Origin Citizenship Sexual Orientation First Generation Status (e.g., college, financial	HR administration, such as benefits, payroll, and other employment-related purposes Job Application Process
Internet/electronic activity	Website interactions during application process, use of internal networks Geolocation information, such as general geographic location based on the log data we or third-party providers collect	HR administration, such as benefits, payroll, and other employment-related purposes, such as employee investigations, discipline, and cybersecurity Job Application Process
Professional/employment related information	Resumes/CVs Academic Data (e.g., GPA, transcripts, expected graduation year) Career Planning Information (e.g., geographic preferences for office location) References Background Checks Emergency contacts Dependents Employment information such as hire date, location, business unit, department, job title, salary, restrictions or accommodations, and other related information Performance-related information, such as performance reviews and disciplinary records Employment eligibility information, such as visa information	Business Purposes: HR administration, such as benefits, payroll, and other employment-related purposes Job Application Process
California Customer Records (Cal. Civ. Code § 1798.80(e))	Social Security Number Home address Business address Phone number
Inferences drawn from personal information	Performance reviews, job application vetting	HR administration, such as benefits, payroll, and other employment-related purposes Job Application Process

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

Directly from you. For example, if you agree to provide the information as part of the application process and through your role as an employee, owner, director, officer, or a contractor of Spectrum.
Third-party sources. For example, from a reference supplied by you or information that you provided to a job board to apply for a position.

Use of Personal Information

We may use the personal information we collect for one or more of the following purposes within the context of your role as a job applicant to, an employee of, owner of, director of, officer of, or a contractor of Spectrum:

To evaluate you as a possible employee, owner, director, officer, or contractor for Spectrum or its portfolio companies.
To manage the performance of job duties.
To fulfill or meet the reason you provided the information. For example, if you share your bank account number, we will use that information to process your compensation.
To comply with our health, safety, compliance, and fraud-prevention obligations.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations or investigations.
To establish, exercise, or defend legal claims.
To authorize, grant, administer, monitor, and terminate access to or use of company systems, facilities, records, property, and infrastructure.
To manage business travel (e.g., car service/rentals, flights, hotels) and personnel expenses (e.g., reimbursement, corporate credit card).
To effectively process payroll and in connection with incentive equity grants.
To administer and maintain employee benefit plans including group health plans, 401(k) plans and other welfare and retirement plans and perquisites.
In the event of a merger, acquisition, disposition of all or substantially all of the relevant assets of the business, bankruptcy, or similar event (including due diligence related thereto).
To create anonymous, aggregated or de-identified data that we use and share to analyze our application and recruitment activities, business and for other lawful business purposes.
As described to you when collecting your personal information.
As otherwise authorized or required by applicable law.

Disclosure of Personal Information

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

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

We do not sell any information regarding employment-related personal information to third parties for monetary or other valuable consideration.

Retention of Personal Information

Except as explained below, we retain the categories of personal information listed above as reasonably necessary to fulfill the purposes outlined in this CA Notice or a related and compatible purpose consistent a reasonable person’s expectation, unless a longer retention period is required or permitted by law. In many situations, we must retain all, or a portion, of your personal information to comply with legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes.
We will retain application information for applicants beyond consideration of the immediate position for which the application is submitted in case future positions or opportunities become available at Spectrum or at a Spectrum Equity portfolio company. Application information for successful applicants becomes part of the applicant’s employment file and is treated accordingly. You have the right to request that we delete certain personal information that we have collected. Please contact us by phone: 1-415-464-4600 or email: compliance@spectrumequity.com to make a request to delete your personal information.

Sensitive Information

The following personal information elements, which are also identified above, may be classified as “sensitive” under the CCPA and CPRA (“sensitive information”): Social Security number, work-related accounts and passwords, and financial account information. We may use this sensitive information for the purposes set forth regarding personal information.

Your Rights Under the CCPA and CPRA

Subject to certain exceptions, California residents can exercise their right to know, correct, and delete personal information subject to the limitations of the CCPA and CPRA. If you are a California resident, you can submit a request for the right to delete and a request for the right to know. You may also contact us at 1-415-464-4600 or by emailing us at compliance@spectrumequity.com.

Changes to Our Privacy Notice

Spectrum recognizes that protecting your personal information is an ongoing responsibility and so it will update this CA Notice as it undertakes new practices involving your personal information. We reserve the right to amend this CA Notice at our discretion and at any time. Any changes will become effective when we post the revised CA Notice on our privacy policy landing page of our website at www.spectrumequity.com. Your continuance in providing services to Spectrum or not requesting that we delete certain personal information constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this CA Notice or the ways in which Spectrum collects and uses your personal information described here, please do not hesitate to contact us by phone: 1-415-464-4600 or email: compliance@spectrumequity.com.