(Applicable to California Residents)
Last Updated: December 2023
Our Commitment to Privacy
What Personal Information We Collect
Depending on your specific interactions with us, we may receive and use the following information about you:
Application Information. If you submit a physical or electronic application for employment using a website, recruitment portal, via email, or otherwise, we will collect the personal information contained in your application. This generally includes information contained in your resume/CV, such as: name, contact information, work experience, educational history, references, qualifications, country of origin or residency.
Sensitive Personal Information. Where permitted by law, you have the option to provide personal information that is considered “sensitive,” under some circumstances, such as: race or ethnic origin. We collect this information for equal opportunity monitories. You will not be prejudiced if you decide to provide this information. In addition, if you provide health information related to disabilities or work restrictions, we will also collect this information so that we may make the appropriate accommodations and arrangements.
Location Data. We may collect information related to your geolocation based on your IP address (when submitting information online) and your stated address or place of residency.
Audio/Visual Data. If you provide photos, video submissions, leave voicemails, visit our offices or facilities, or participate in video conferencing communications with us, we may collect audio, electronic, and visual information associated with such activities. We may also gather publicly available images associated with your social media profiles (such as your LinkedIn profile).
Professional Work History. We gather information about your work history and professional experience (such certifications, specialties, and awards) if you provide it to us. We may also gather information about your work history from references you provide.
Education Information. If you provide information pertaining to your education history, we will collect this information.
Interview and Assessments. As part of the application process, we will collect information during interviews and assessments with you and others (such as recruiting partners and references) about you. We will collect responses and information your provide as part of assessments and interviews
Internet/Electronic Network Activity Information. If you access or use our website, recruitment portal, physical facilities, or video conferencing platforms, those systems automatically collect information associated with your use, such as your IP address, browser and device identifiers, information associated with cookies and other tracking technologies, and other information regarding your usage of such systems, such as access/exit times and locations, check-in status, and signature (for sign-in purposes).
Information from Third Parties. We may receive information from third parties associated with your application process. For example, we may receive your resume or application from a recruitment partner, references from your former employers, transcripts from universities you attend, and other information
Background Check Information. Certain Applicants may be subject to pre-employment background checks as part of the on-boarding process. As part of this process, we may receive information from third-party background check providers related to your criminal records, verifications for employment qualifications, finances, and other matters. Background checks, credit checks, and other investigatory checks will be conducted to the extent permitted by and consistent with applicable law. Background check information may not be subject to the CCPA
Information Required for Legal Compliance. If we are required by law to obtain personal information about you, such as right to work, tax, familial status, etc., we will collect such information in accordance with our legal obligations and applicable law.
Onboarding Information. Successful applicants who are offered employment with Lugano will undergo onboarding which will result in collection of more personal information related to the provision of employment, including tax information, Social Security Numbers, government ID numbers, right to work information (if required/permitted by local law), emergency contact information, familial information, and similar personal information associated with employment at Lugano. Additional notices regarding data collection and use practices will be provided at the time of onboarding.
For purposes of compliance with the CCPA, in the past twelve months, Lugano has collected the following categories of personal information from Applicants (as described in more detail, above): (1) identifiers; (2) characteristics of protected classifications under California or federal law; (3) internet or other electronic network activity information; (4) geolocation data; audio, electronic, and visual information; (5) professional or employment-related information; (6) education information; (6) sensitive personal information.
How We Use Applicant Personal Information
We use the personal information we collect as follows:
To Process Employment Applications and Onboard New Hires. We collect most personal information to evaluate your candidacy, including to open and maintain Applicant files, communicate with you, conduct employment related background screening and checks, and evaluate your application.
Recruiting and Applicant Communications. We use personal information to communicate with you as part of the candidacy process and as part of your workforce relationship with us. Personal information may be used to evaluate career development, consider Applicants for roles and positions, and to communicate company policies.
For Diversity and Equal Opportunity Monitoring. We collect certain categories of personal information for equal opportunities monitoring.
To Conduct Evaluations. We collect and review your personal information from multiple sources to assess your suitability for employment or work with Lugano. This may include obtaining pre-employment background checks.
Safety and Security Purposes. We process personal information to ensure the safety and security of Lugano, its property, and others, and for the prevention, detection, or investigation of fraud, suspected or actual illegal activity, or other misconduct, and the resultant harms or impacts to individuals.
Travel and Entertainment. We use personal information to ensure the proper capture and reimbursement of travel, personal, and other expenses, if offered to you as part of the Application process.
Enforce our Lugano Policies. We use personal information to support and maintain compliance with our company policies, procedures, and operations.
Required Disclosures: We may disclose personal information to comply with applicable legal and regulatory requests and obligations including investigations.
Legal Defense: We may process personal information to establish or defend legal claims and allegations.
Professional Advice: We may process personal information in connection with seeking advice from lawyers, auditors, and other professional advisors.
For Similar Purposes: When necessary or advisable we may process your personal information for purposes like those mentioned above, and consistent with the purpose for which you provided your personal information.
How We Disclose Applicant Personal Information
The purpose for which personal information will be collected and processed will be consistent with your role as an Applicant for employment with Lugano.
Collecting Personal Information
The following is a list of the categories of recipients of personal information from Lugano.
Applicant Recruiting Partners. These are the persons or entities who assist in facilitating recruitment and review of potential Applicants. These entities include recruiting firms, job search services (such as Indeed), social media companies (such as LinkedIn), and professional recruiting agents.
References. We may share personal information with other persons or entities with whom you provide a reference, including past employers, educational institutions, professional bodies, personal references, former colleagues, and others.
Human Resources Service Providers. We share personal information with the persons or entities who assist in providing human resources and workforce management services, including background check providers, human resources software services providers, insurance providers, employee payment and benefits providers, governmental entities, and similar entities.
Business Services Providers. These are those persons or entities with whom we have a relationship to provide business operations services and support to Lugano. These providers may include the following:
IT Operations Providers. These include cloud computing service providers, internet service providers, data backup and security providers, functionality and infrastructure providers, and similar service providers
Professional Service Providers. These include lawyers, accountants, consultants, security professionals, and other similar parties when disclosure is reasonably necessary to comply with our legal and contractual obligations, prevent or respond to fraud or abuse, defend ourselves against attacks, or protect the rights, property, and safety of us, our customers, and the public.
Operations Providers. These include service providers with whom we partner to provide day-to-day business operations, including real estate advisors, event planners, food services providers, entertainment providers, payment processors, banks, facilities management providers.
Legally Required Parties. Persons to whom we are required by law to provide information, such as pursuant to a subpoena or a court order.
Reorganization Recipients. Persons involved in the consideration, negotiation, completion of a business transaction, including the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration
Authorized Recipients: To any party when authorized by the individual to whom it pertains to share it.
Lugano is located and operates in the United States. By submitting personal information to us, you understand that we may transfer your personal information to a country foreign to you, including the United States, for processing. The laws that apply to the use and protection of personal information in the United States, or other countries or jurisdictions in which we transfer or process personal information, may be different from the laws and protections in your country. These transfers may include transfers to our service providers located in foreign jurisdictions. The services we provide are performed entirely within the United States, and the services offered are not intended for data subjects located in foreign jurisdictions. The accessibility of our websites in foreign jurisdictions is not an indication that we intend to offer services in those jurisdictions.
Retention of Personal Information
We will retain personal information only for so long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider: (i) the amount, nature, and sensitivity of the personal information; (ii) the potential risk of harm from unauthorized use or disclosure of your personal information; (iii) the purposes for which we process your personal information and whether we can achieve those purposes through other means; and (iv) the applicable legal requirements. In some circumstances, you may ask us to delete your personal information. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
How We Protect Personal Information
We have implemented and maintain reasonable security procedures and practices, appropriate to the nature of the information, to protect your personal information from unauthorized access, destruction, use, modification, or disclosure. However, no security measure is perfect, so we cannot guarantee the security of your personal information. Periodically, our operations and business practices are reviewed for compliance with policies and procedures governing the security, confidentiality, and quality of our information. In general, our business practices limit employee access to confidential information and limit the use and disclosure of such information to authorized persons, processes, and transactions.
Your Privacy Rights
California Residents have certain rights under the CCPA. For information on how to exercise these rights, please see below.
The Right to Know. The right to know what personal information Lugano has collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom the business discloses personal information, and the specific pieces of personal information the business has collected about you.
The Right to Deletion. The right to delete personal information that the business has collected about you, subject to certain exceptions.
The Right to Correction. The right to correct inaccurate personal information that a business maintains about a consumer.
The Right to Opt-Out of the Sale/Sharing. If we sell or share personal information, the right to opt-out of the sale or sharing of your personal information by Lugano.
The Right to Limit the Use of Sensitive Personal Information. If Lugano uses or discloses sensitive personal information for reasons other than those permitted by the CCPA, the right to limit the use or disclosure of sensitive personal information by Lugano.
Non-Discrimination. The right not to be discriminated against for exercising any of the rights conferred by the CCPA.
Lugano will honor the privacy rights afforded to individuals in accordance with applicable law.
Exercising Your CCPA Rights
Applicants who are California residents may submit CCPA requests themselves or using an authorized agent. CCPA requests are subject to our verification measures which vary depending on the type of request made and the sensitivity of the information you request. We may ask you to provide a few pieces of information to confirm your identity in our records. If you authorize an agent to submit a request on your behalf, we may require the agent to provide proof that you gave the agent signed permission to submit the request and may verify the agent’s identity and authority to act on your behalf.
Submitting Access, Deletion, and Correction Requests
To make an access, deletion, correction, or limitation request, email the People Team at email@example.com.
Limiting the Use of Your Sensitive Personal Information
Californian’s have the right to limit a business’s use or disclosure of sensitive personal information. However, Lugano does not use or disclose sensitive personal information for any purpose other than for permissible purposes under the CCPA.
Opting Out of the Sale/Share of Your Personal Information
Contact Us Regarding Your Privacy Rights
If you would like additional information related to your privacy, please email the People Team at firstname.lastname@example.org. Please submit your CCPA rights requests using the methods described above.