Applicant CCPA Notice

CALIFORNIA APPLICANT PRIVACY NOTICE

Effective date: Jan 1, 2023

This California Applicant Privacy Notice (the “CA Applicant Notice”) explains how the Transform Holdco LLC family of companies (“Transformco,” “our,” “we,” or “us”) Collect, use, and disclose the Personal Information of California job applicants, candidates, and others who provide Personal Information through our job application process, including the Personal Information we collect on https://jobs.sears.com/us/en (collectively, “Applicants”). In this CA Applicant Notice, we use the word “you” or “your” to refer to anyone within the scope of this CA Applicant Notice.

As used in this CA Applicant 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 an individual or household. Personal Information does not include information that is publicly available, deidentified, or aggregated.

Unless otherwise noted, the disclosures contained within this CA Applicant Notice cover our activities in the prior 12 months from the effective date, as well as our current practices.

1. How and Why We Collect Your Personal Information

General Personal Information

We collect, use and disclose Personal Information about our Applicants as follows (whether we Collected a specific category of Personal Information depends on the nature of your interaction with us):

Category of Personal Information	Purposes for Collection, Use, and Disclosure
Identifiers including real name, alias, postal address, unique personal identifier, online identifier, IP address email address, account name, or other similar identifiers	To communicate with you To open and maintain Applicants records To assess your eligibility for employment To comply with applicable laws and regulations To manage the security of our premises and systems
Personal Information described in Cal. Civ. Code § 1798.80(e), including your Identifiers listed above, signature, social security number, passport number, driver’s license or state identification card number, and financial information	To communicate with you To assess your eligibility for employment To open and maintain Applicants records To comply with applicable laws and regulations To manage the security of our premises and systems
Characteristics of protected classifications under California or federal law, including age range to confirm employment eligibility, race/ethnicity (voluntary self-identification), gender (voluntary self-identification}, and potential need for disability accommodation (voluntary).	To comply with applicable laws and regulations To comply with U.S. Equal Employment Opportunity Commission (“EEOC”) and California Civil Rights Agency (“CCRA”) requirements, and other equal opportunity initiatives
Commercial information, including products or services purchased	To reimburse you if you travel for an interview and seek reimbursement To reimburse you for personal expenses paid (e.g., meals, mileage) for the recruitment process
Internet or other electronic network activity information, including browsing history, search history, and information regarding your interactions with our websites, systems, and applications	To improve our website, set default options, and provide a better application experience To facilitate your use of our website To communicate with you
Geolocation data, data based on location data inferred from your device IP address	To facilitate your use of our website To provide you with tailored recommendations, and updates
Audio, electronic, visual, or similar sensory information, including closed-circuit images or recordings	To manage the security of our premises and systems
Professional or employment-related information, including: Recruitment information (such as skills, qualifications, references, recommendations, languages spoken, and other information included in a resume, application form, or cover letter) Background information commonly used for security screenings, including citizenship, immigration, visa status, and work authorization information; and criminal records information	To manage job duties, evaluate performance, and operate our business To provide compensation and benefits To comply with applicable laws and regulations To assess your eligibility for employment
Non-Public education information, including grades, transcripts, records of attendance, disciplinary records, and other information relating to your secondary and post-secondary education	To review your qualifications and credentials To open and maintain your application records To comply with applicable laws and regulations To manage the security of our premises and systems

Sensitive Personal 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.

2. Sources of Personal Information

We Collected the Personal Information identified above from the following sources (whether we Collected information from a specific source depends on the nature of your interaction with us):

Directly from you. We Collected information from you when you visited or created a profile on our careers page, during the recruiting process and throughout your interactions with us as Applicants, including through our information technology systems, company forms and processes where Applicants submit information to us (e.g., pre-employment forms), and surveys.
Automatically when using our systems. We Collected information about you when you used our information technology services and when you accessed our facilities (e.g., video surveillance information).
Created by us. We Collected information about you that we created, such as interview notes, credentials for access to our recruitment systems
Service Providers. We Collected information about you from certain Service Providers that provide information to help us perform recruitment functions and run our business (for example, background check providers).
Recruitment Agencies. We Collected information from recruitment agencies who provided your application materials and information about your candidacy.
References and Verifications. We Collected information about from other parties who provide references (for example, former employers) and to verify your qualifications (for example, universities or other organizations where you may have earned a degree or completed a certification)
Affiliates. We disclose Personal Information among the companies within the Transformco family of companies and affiliates. We receive information within this “family,” as permitted, to enable us to manage our business and workforce.
Other parties. We may have received information about you from other parties when necessary to manage or operate our business or to evaluate your candidacy for employment.
Parties to corporate transactions. As permitted by law, we may receive Personal Information as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or at transfer, divestiture, or sale of all or a portion of a business or assets.

3. Disclosures of California Employee Personal Information

We have not Sold or Shared for cross-context behavioral advertising the Personal Information of California Applicants that we collect in the context of your application with us. If you also interact with us as a Consumer, please review our California Consumer Privacy Notice here for more information about our practices in that context.

We disclosed the Personal Information described in this CA Applicant Notice to service providers that help us run our business, and manage our human resources activities.

We have also disclosed, or may disclose in the future, the Personal Information described in this CA Applicant Notice in other circumstances when required to or permitted by law. These circumstances include:

disclosures among the companies within the Transformco family of companies and affiliates, when permitted by law, to manage recruitment activities, and other human resources services across the Transformco family of companies and affiliates;
disclosures to provide products or services requested by Applicants;
disclosures required or permitted by law to defend against legal claims;
to law enforcement agencies, courts, regulatory agencies and others when the disclosure is required or permitted by law, including to comply with valid legal process; and
as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or at transfer, divestiture, or sale of all or a portion of our business or assets.

4. How Long We Keep Your Personal Information

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information (which includes the categories of Personal Information set forth in the charts and sections above) for as long as necessary to fulfill the purposes we Collected it for, as required to satisfy any legal, obligations, or as necessary to resolve disputes. To determine the appropriate retention period for Personal Information, we consider applicable legal requirements, the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes we process your Personal Information for, and whether we can achieve those purposes through other means. For certain types of Personal Information, we will only maintain it for a limited duration. Where Personal 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.

5. Submitting Requests Relating to Your Personal Information

If you are a California Applicant, you have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please submit a request by calling us at 1 888-527-6415 or by email at hrpc@transformco.com. Please note that, if you submit a request to know, request to delete or request to correct, you will be asked to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you may 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 toll-free number or email 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
1. The categories of sources from which the Personal Information was Collected
2. The categories of sources from which the Personal Information was Collected
3. The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of third parties 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 certain 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.

Right to Opt Out of Sales and Sharing of Personal Information. We do not sell or share Personal Information about Applicants and, therefore, we do not offer a way for you to submit such a request.

Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use Sensitive Personal Information for the purpose of inferring characteristics about you, or for any other reasons besides the permitted business purposes. For this reason, we do not treat the Sensitive Personal Information we collect as subject to a limit use of Sensitive Personal Information request and, therefore, we do not offer a way for you to submit such a request.

Right to Non-Discrimination for the Exercise of Your Privacy Rights. We will not discriminate against you if you choose to exercise any of the privacy rights described above.

6. How to Contact Us

If you have any questions about how we handle your Personal Information or if you need to access this CA Applicant Notice in an alternative format, please contact: hrpc@transformco.com