Hall Capital California Personnel Privacy Notice

Hall Capital California Personnel Privacy Notice.

Effective Date | January 1, 2023

This California Personnel Privacy Notice (“Personnel Privacy Notice”) applies to the employees, former employees, independent contractors and job applicants (including, in each case, individuals associated with their personnel records (e.g., beneficiaries and dependents)) of Hall Capital Partners LLC (“Hall Capital”, “we”, “us” or “our”) who are residents of California (collectively, “California Personnel”).

This Personnel Privacy Notice is designed to meet our obligations under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), and sets forth our policies for the collection, use, storage, sharing, disclosure and protection of “personal information” of California Personnel, as required for all California employers. If any Hall Capital policy, statement or notice and this Personnel Privacy Notice conflict, then this Personnel Privacy Notice will prevail as to California Personnel, unless stated otherwise.

This Personnel Privacy Notice does not apply to personal information that Hall Capital collects from or about clients, business partners or any non-California Personnel.

Personal Information Collected From Or About California Personnel.

Hall Capital collects, retains, discloses and otherwise processes personal information about California Personnel as follows (and has done so in the prior 12 months):

Identifiers: name, alias, postal address, unique personal identifiers, online identifier, Internet Protocol address, email address
Personal Records: name, signature, address, telephone number and financial information (e.g., direct deposit information). Some personal information included in this category may overlap with other categories
Personal Characteristics or Traits: personal information that is considered protected under U.S. law, such as age, gender, nationality, race, veteran status, disability status or other information related to medical conditions
Internet Usage Information: information regarding your interaction with Hall Capital systems
Geolocation Data: approximate, and potentially precise, location of the device or equipment you are using, or the location from which you are accessing our systems. We may also track the location of equipment that Hall Capital owns.
Professional, educational or employment-related information: current or past job history, confirmation of graduation from undergraduate institutions, and other professional or educational-related information
Inferences from personal information Collected: inferences from other information we collect about you, e.g., based on your performance or other information, we may recommend skills training that may benefit you

We generally do not collect non-public education records, sensory data or biometric information.

Sensitive Personal Information: Certain information that we collect is deemed “sensitive” under California law. Sensitive personal information includes race, ethnicity, sexual orientation, and government identification numbers (e.g., Social Security numbers). We may collect and use government identification numbers for the purposes described below, which are consistent with the permitted “business purposes” enumerated in CCPA.

We may collect additional personal information that is not reflected by a category above, in which case we will treat it as personal information but may not include it when we describe our practices by category of personal information as required under CCPA. Personal information does not include (i) de-identified or aggregated data, (ii) publicly available information from government records, or (iii) information excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or personal information covered by certain sector-specific privacy laws, including the Gramm-Leach-Bliley Act (GLBA).

We may collect this information directly from you during recruitment and hiring and in the course of your employment and from public sources. Other information may be generated automatically when you use or otherwise interact with our systems or may be provided to us by third parties, such as from a reference supplied by you.

Uses of Personal Information.

Generally, Hall Capital processes the above categories of personal information for employment purposes and for the operation of our business, aligned with the business purposes defined in Cal. Civ. Code § 1798.140(e) (2), (3), (4), (5), (7), and (8), including for one or more of the following purposes (collectively, “Business Purposes”):

To evaluate you as a possible employee, owner, or contractor, including background and related checks, onboarding successful candidates, and related recruiting efforts;
To manage the performance of job duties, including, for example, evaluating appropriateness for a particular position at Hall Capital, or promotion to a new position;
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 process payroll and to administer and maintain employee benefit plans, including enrollment and claims handling, and leave of absence administration;
To satisfy applicable record retention requirements;
To communicate with you and/or your emergency contacts and plan beneficiaries;
To promote adherence to Hall Capital’s policies and respond to complaints, grievances, and suspected violations of such policies;
To facilitate the secure use of Hall Capital’s information systems and prevent unauthorized access to, use, or disclosure/removal of Hall Capital’s property, including our information systems, electronic devices, network, and data;
To comply with legal obligations as part of our general business operations, including applicable state and federal labor, employment, tax, benefits, workers compensation, disability, equal employment opportunity, workplace safety, securities, and related laws, guidance, or recommendations; and
To perform other legitimate business purposes, including, for example, responding to questions and comments, supporting accommodations, and other purposes that are related to and/or compatible with any of the foregoing purposes.

Retention of Personal Information.

Hall Capital has implemented a document retention policy reasonably designed to comply with applicable law. If you make a deletion request, Hall Capital will review your personal information to confirm whether Hall Capital has a legitimate ongoing Business Purpose for that personal information, will limit the retention to the confirmed purposes for as long as the Business Purpose continues.

Disclosure of Personal Information.

Hall Capital may disclose personal information to a select group of business partners, service providers and vendors, such as payroll processors, benefits providers and software platform operators (e.g., applicant and employee management portals), and professional advisors. Hall Capital may also disclose personal information (i) when such disclosure is required by law, court of law, or as requested by any governmental, self-regulatory organization or law enforcement authority; (ii) to the extent necessary for a reorganization, restructuring, merger, acquisition or transfer of assets related to our business; (iii) to exercise, establish or defend legal rights; or (iv) to protect the interests of Hall Capital or our employees, business partners, service providers or another third party.

California Personnel Rights And How To Exercise Them.

California law provides California Personnel with certain rights regarding your personal information. Starting January 1, 2023, California Personnel have the rights described below but exceptions do apply.

Right to Know: You can ask that we disclose to you the categories of personal information we collected about you, the categories of sources for the personal information we collected about you, our purpose for collecting your personal information, and the categories of third parties to whom we disclosed your personal information. You also can request that we provide you the specific pieces of personal information that we collected about you.
Right to Delete: You can ask us to delete the personal information that we collected from you. Please note that in certain instances we may not be able to process your request, such as due to the existence of a legal obligation or pursuant to other permitted exceptions.
Right to Correct: You can ask us to correct inaccurate personal information that we maintain about you.
Right to Limit Use and Disclosure of Sensitive Personal Information: CCPA allows you to limit use and disclosure of sensitive personal information (defined above) about you, unless an exception applies.

Hall Capital will not discriminate or retaliate against you in a manner prohibited by the CCPA for your exercise of your privacy rights.

You can submit a request by contacting us at compliance@hallcapital.com and at 800-588-0544. Subject to applicable exceptions, Hall Capital will honor verified requests. To verify a request, Hall Capital may ask you to provide us information that we can match with other information we have about you. The information we request depends on whether you are an active employee or terminated employee and it may include, for example, your full date of birth or last four digits of your Social Security number. You can also have an authorized agent submit a request on your behalf, but Hall Capital will require proof of authorization from the agent, and you must verify your identity with us and confirm you gave the agent permission to submit the request on your behalf.

Selling and Sharing Personal Information: Hall Capital has never sold your personal information nor provided it to third parties for cross-context behavioral advertising (a concept known as “sharing” under California law). Hall Capital has no plans to sell or share your personal information in the future, and will update this policy if that changes.

Hall Capital may collect, use and disclose personal information as required or permitted by applicable law which may override your rights under the CCPA. Hall Capital is not required to honor your requests if doing so would infringe upon our or another person’s or party’s rights or conflict with applicable law.

How Hall Capital Protects Personal Information.

Hall Capital is committed to protecting the security of personal information. Hall Capital uses access management, intrusion detection, encryption and other security management tools to help protect personal information from unauthorized or unlawful access, disclosure or other use.

Changes to this Personnel Privacy Notice.

Hall Capital may update this Personnel Privacy Notice from time to time in response to changing legal requirements or business developments. Because of this, we advise that you check this privacy notice from time to time in order to familiarize yourself with any updates. When we update this Personnel Privacy Notice, we will change the Effective Date and will make the updated policy available to you.

Contact.

If your questions about Hall Capital’s processing of your personal information are not addressed in this Personnel Privacy Notice, please contact us by (i) emailing us at compliance@hallcaptial.com, (ii) calling us at 800-588-0544 or (iii) completing the form available here.