PLEASE READ THIS NOTICE CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND YOUR RIGHTS AND CHOICES.

 

INTRODUCTION

 

Hera Fine Jewelry, Inc. (also referred to herein as “we,” “us,” and “our”) is committed to protecting the privacy and security of your personal information. We also believe in transparency, and this Notice explains how we treat your personal data when you apply for a job with us or one of our affiliates. Please read this Notice carefully to learn more about how we process personal information and what rights you may have under applicable law.

 

When does this Notice apply? This Notice describes our practices regarding the personal information we receive, collect, use, share, and otherwise process in connection with your application for employment with us and our hiring process. It also describes your rights regarding your personal information. This Notice does not, however, create or form a part of any employment contract. For information about how we process personal information in other contexts, please see our Privacy Policy, which this notice supplements.

 

Our Role and Contact Information. We act as the “data controller” with respect to the information described in this Notice. Our contact information is provided at the end of this Notice.

 

HOW WE PROCESS PERSONAL INFORMATION

 

What personal information do we collect? We collect and process the following personal information for the purposes described below, including in the “How Do We Share Personal Information?” “Additional HR Processing Activities” sections of this Notice. For residents of California, pursuant to the California Consumer Privacy Act, as amended (“CCPA”), we have identified the categories of personal information collected.

 

 

Additional HR Processing Activities. In addition to the specific processing activities described above, we also process personal information for the following purposes:

• Personnel and Human Resources Management. This includes, for example, ordinary business practices related to the establishment, maintenance, and termination of relationships; personnel management and administration (including before, during, and after your relationship with us); business management and planning; administering benefits; conducting performance reviews and disciplinary proceedings; providing training; processing work-related claims (for example, insurance and worker’s compensation claims); and addressing labor relations issues.

• Operations Management. This includes, for example, the establishment, performance, and management of our business activities (such as maintaining internal networks and IT systems); operation, evaluation, and improvement of our recruiting system; accounting and auditing; preventing fraud; obtaining or maintaining insurance coverage; managing risks; and obtaining professional advice.

• Security Management. This includes, for example, ensuring the security of our premises and information held by us as well as the safety of our personnel; preventing fraud; and network and information security.

• Legal and Regulatory Compliance. This includes, for example, obtaining and releasing personal information as required by law or court order; maintaining records that can include personal information, such as government identifiers, information relating to sickness, leave, and retirement; and establishing, exercising, or defending legal claims, whether in court, administrative, or other proceedings.

• Anonymous Data. Under some circumstances we may anonymize your personal data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you. We will process such data only in a de-identified fashion and will not attempt to re-identify such data.

• Consistent Purposes. We may also process the information described above for purposes that are consistent with, related to, and/or ancillary to the purposes and uses described in this Notice for which your personal information was provided to us.

 

How will we disclose your information? We may share each of the categories of personal information described above in the following contexts. We will only disclose your personal information where, when required by law, the recipient has provided written assurances that it will protect any personal information disclosed to it in accordance with applicable law.

• Team Members. Your information may be shared internally for human resources and operational purposes. This includes members of our Human Resources team, managers, and others who participate in interviews with you.

• Affiliates. We share personal information with our subsidiaries and affiliates and with their respective officers, directors, employees, and agents.

• Corporate Transactions. We may disclose your information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of our company or some or all of our assets. If our business is acquired by or merged with another company, your information may be transferred to the new owners.

• Disclosures with Your Consent. We may ask if you would like us to share your information with third parties who are not described elsewhere in this Notice. We will only disclose your personal information in this context with your consent

• Legal Obligations. We disclose personal information in response to subpoenas, warrants, court orders, and other legal process, and to comply with relevant laws, including certain tax obligations. We may also share information in order to establish or exercise our legal rights, to pursue claims, to defend claims, and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies or contracts.

• Service Providers and Advisors. We share personal information with our and our affiliates’ contractors, service providers, insurers, and professional advisors (including attorneys, accountants, consultants, and auditors) that need access to the information to provide services on our behalf or perform functions for us. You may also interact with individuals who are independent contractors of the company, and they will receive the information you share with them.

 

Legal Basis of Processing. We process your personal information for the following purposes related to your application for employment:

• To Carry Out Our Legitimate Interests. Processing is necessary for the purposes of our pursuit of our legitimate interests in managing your potential employment, in our ongoing assessment and verification of your suitability for working with us, and in keeping records of your relationship with us. We also have a legitimate interest in processing data to detect and prevent fraud and to deal with complaints, claims, and lawsuits made against us.

• To Carry Out Our Legal Obligations and, where applicable, to Perform a Contract. Processing is necessary for our compliance with our legal obligations in the field of employment law, such as taking steps to enter a relationship with you, the performance of your relationship with us, and the performance of any employment agreement.

• With Your Consent as provided in this Notice. If we ask you to review and sign this Notice to obtain your express consent to the processing of your personal information for certain types of purposes identified in this Notice, and you do so, we will process your personal information in accordance with the Notice and your express consent, which you keep a right to withdraw at any point in time.

 

How do we collect this data? We will collect information from you (including in your application and interviews). We may also collect information from third parties, including references, former employers, government agencies, background check providers, credit bureaus, publicly available resources, websites, and others.

 

What if you do not provide personal data? You may object to our collection of data, but certain information is mandatory. If you do not provide the required information, we will not be able to perform certain activities necessary to process your application for employment.

 

YOUR RIGHTS AND CHOICES

 

Depending on where you reside, you may have certain rights regarding your personal information. Please contact Human Resources if you wish to exercise or learn more about your rights under applicable law.

 

California

 

California residents can learn more about your rights under the CCPA below. All terms used in this section shall have the meanings given in the CCPA, when applicable.

 

CCPA Notice at Collection. We collect and process personal information as described in the “How We Process Personal Information” section of this Notice. The relevant CCPA categories for this information are indicated above. We may provide a separate notice at collection if we collect additional information or intend to use information for additional purposes. This Notice relates to personal information we may collect and process in the course of your application for employment with us. For information about how we process personal information outside of this context, please see our Privacy Policy.

 

Data Practices During the Last 12 Months. For information about our data practices during the last 12 months, please see our Privacy Policy.

 

No Financial Incentives. For purposes of the CCPA in the context of our employment or contractual relationship with you, we do not offer financial incentives or any price or service difference in exchange for the retention or sale of your personal information. For information about financial incentives offered in other contexts, please see our Privacy Policy.

 

CCPA Individual Rights. California residents have the rights described below. However, these rights do not apply in all instances and are subject to certain exceptions as a matter of law.

• Right to Know. You have the right to request: (1) the specific pieces of personal information we have collected about you; (2) the categories of personal information we have collected about you; (3) the categories of sources from which the personal information is collected; (4) the categories of personal information about you that we have sold or shared and the categories of third parties to whom the personal information was sold or shared; (5) the categories of personal information about you that we disclosed for a business purpose and the categories of third parties to whom the personal information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, selling, or sharing personal information; and (7) the categories of third parties to whom we disclose personal information. Our response will cover the 12-month period preceding our receipt of a verifiable request unless a longer period is requested by you.

• Right to Delete. You have a right to request the erasure/deletion of certain personal information collected or maintained by us. As described herein, we will delete your personal information from our records and, as applicable, notify any service providers and contractors (as defined under applicable law) to delete your personal information from their records. However, we are not required to honor a deletion request if an exemption applies under the law.

• Right to Correct. You have a right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes for which we process the personal information. We will use commercially reasonable efforts to correct the inaccurate personal information as directed by you.

• Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to limit our use and disclosure of your sensitive personal information to that use which is necessary to perform our services and provide our goods as requested by you, or as otherwise permitted by law. We only use or disclose sensitive personal information for purposes permitted by the CCPA and to which the right to limit does not apply.

• Right to Opt-Out. You have the right to direct us to stop selling or sharing your personal information to third parties and to refrain from doing so in the future. For purposes of the CCPA in the context of our employment or contractual relationship with you, we do not sell or share personal information as defined under applicable law.

 

Submission Process. You may submit a request to exercise one of the above rights via a toll-free telephone call to (914) 530-0488, by email to hola@herafinejewelry.com, or via our online submission form. If a request is submitted in an incorrect manner or if it is deficient, we will either (1) treat the request as if it had been submitted via the designated manner, or (2) provide you with specific directions on how to submit the request or remedy any deficiencies, as applicable.

 

Verification Process. We are required to verify the identities of those who submit requests to exercise certain of the above rights. To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you will be required to provide your name, email address, mailing address, and/or telephone number. We will inform you if we cannot verify your identity.

• If we cannot verify the identity of the person making a request for categories of personal information, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our privacy policy.

• If we cannot verify the identity of the person making the request for specific pieces of personal information, we are prohibited from disclosing any specific pieces of personal information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer.

• If we cannot verify the identity of the person making a request to delete, we may deny the request.

• If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor. In such cases we may not be required to comply with the request or may request additional information reasonably necessary to verify the request.

 

Authorized Agents. Authorized agents may submit requests via the methods identified in this Policy. If you use an authorized agent to submit a request to know or a request to delete, we may require: (1) the authorized agent to provide proof that you gave the agent signed permission to submit the request; (2) you to verify your identity directly with us; and (3) you to directly confirm with us that you provided the authorized agent permission to submit the request. However, we may not require these actions with respect to confirmed guardianship, conservatorship, power of attorney, or other protective arrangement in accordance with applicable law.

 

Excessive Requests. If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.

 

Non-Discrimination. You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CCPA. We do not discriminate against individuals for exercising their rights under the CCPA..

 

OTHER IMPORTANT INFORMATION

 

International Data Transfer. We are headquartered and have operations in the United States, and personal information will be transferred to, stored in, and processed in the United States and other countries in which we or our partners, service providers, and/or agents maintain facilities. By sending us personal information or using the Site, you agree and consent to the processing of your personal information in locations such as the United States, which may not offer the levels of protection required in other countries. We rely on recognized legal bases to lawfully conduct cross-border/international transfers of personal information, such as express consent, when transfer is necessary for us to deliver services pursuant to an agreement, or when the transfer is subject to safeguards that assure the protection of the personal information. For more information, please see our Privacy Policy.

 

How long do we store and use your information? We will retain and use your personal information as needed to fulfill the purposes for which it was collected and to meet our legal obligations, which will depend on the status of your relationship with us. When we no longer have a purpose for retaining your personal information, we will destroy it in accordance with applicable law and our policies. Where required by law, we take reasonable steps to delete the personal information we collect if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We are required by law to maintain records of consumer requests submitted under the CCPA and how we responded to such requests for at least 24 months. We only use this information for recordkeeping purposes. For more information, please contact Human Resources via the contact information provided below.

 

How do we protect your information? We have adopted security measures designed to protect personal information under our control. From time to time, we review our security procedures to consider appropriate new technologies and methods. But, no security system is perfect, and no data transmission is 100% secure. Although we strive to protect personal information, we cannot guarantee or warrant the security of any information transmitted to or from the Site or services. Your use of the Site is at your own risk. We cannot guarantee that your data will remain secure in all circumstances. If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.

 

Updates and Changes. We may add to, change, update, or modify this Notice to reflect any changes to how we treat your information or in response to changes in law. If we update this Notice, we will make an updated copy of it available to you.

 

CONTACT INFORMATION

 

For more information, if you have any questions or concerns, or if you wish to exercise your rights or lodge a complaint with us, you may contact us by using the information below:

In Writing: Hera Fine Jewelry, Inc, 

276 Greenpoint Avenue, Ste 241,

 Brooklyn New York 11222, United States

 

By Email: hola@herafinejewelry.com

 

By Telephone: (914) 530-0488