Effective: January 1, 2020
Information Specific to California Employees and Applicants
This California Personnel Privacy Notice (“Notice”) describes how LiveRamp, Inc., a Delaware corporation, with its principal place of business at 225 Bush Street, 17th Floor, San Francisco, CA 94104 (“LiveRamp”), collects, uses, and discloses personal information about job applicants, our individual employees (current and former employees), contractors, and their beneficiaries and emergency contacts who are residents of California in the context of our working relationship with the relevant individuals (“personal information”). We may update this Notice at any time. We may also provide you additional privacy notices regarding our collection, use or disclosure of information.
This Notice does not form part of any employment contract or contract to provide services. If you provide services to LiveRamp through or in connection with another company, we are not responsible for that company’s privacy practices.
This Notice does not apply to our handling of data gathered about you in your role as a consumer using LiveRamp’s websites or as a client of LiveRamp products. Please refer to the sections above for more information about that data.
1. Types of Personal Information We Handle
We collect, store, and use various types of personal information through the application and recruitment process or during the relevant engagement or employment with us. We collect such information either directly from you or (where applicable) from another person or entity, such as an employment agency or consultancy, background check provider, or other referral sources.
The type of information we have about you depends on your role with us and may include, where applicable:
Identification and contact information and related identifiers such as full name, date and place of birth, citizenship and permanent residence, home and business addresses, telephone numbers, email addresses.
Professional or employment-related information, including:
- Recruitment, employment, or engagement information such as application forms and information included in a resume, cover letter, or otherwise provided through any application or engagement process; and copies of identification documents, such as driver’s licenses, passports, and visas; and background screening results and references.
- Career information such as job titles; work history; work dates and work locations; employment, service or engagement agreements; appraisal and performance information; information about skills, qualifications, experience, publications, speaking engagements, and preferences (e.g., mobility); absence and leave records; professional memberships; disciplinary and grievance information; and termination information.
- Financial information such as salary, payroll, pension or retirement contribution information; and bank account and tax information.
- Business travel and expense information such as travel itinerary information, corporate expenses and Company credit card usage.
- Performance review information such as self, employee, and manager reviews.
Education Information such as institutions attended, degrees, certifications, training courses, publications, and transcript information.
Internet, electronic network, and device activity and device information and related identifiers such as information about your use of the Company network, information, and communication systems, including user IDs, passwords, IP addresses, device IDs, web logs, and audit trails of system access.
Geolocation information for device recovery if you use a Company-issued device.
Audio or visual information such as CCTV footage, as well as other information relating to the security of our premises; recorded presentations in which you participate; and photographs taken at Company functions.
Biometric information that we use for authentication and security purposes, such as imagery of the face (for ID pictures).
Legally protected classification information such as race, sex/gender, gender identity/expression, sexual orientation, marital status, military service, nationality, ethnicity, request for family care leave, and criminal history.
Health information about you, and, if applicable, your beneficiaries, such as medical conditions and other information provided in statements of health forms, disability status, health and safety incidents or accidents, sickness records, and health issues requiring adaptations to your working environment or working practices.
2. How We Use Personal Information
Data on employees and applicants has not been sold or shared in the last 12 months. We collect, store, use, and disclose personal information for LiveRamp’s and our service providers’ business purposes, which include, where applicable:
HR management and administration including training, compensation and benefits, invoices, leave, scheduling, career development, performance appraisals and recognition, investigating and resolving inquiries and complaints, providing references, succession planning, organizational changes, preparing analyses and reports, and communicating with our workforce about updates or relevant information about perks, benefits and discounts, and changes to LiveRamp products and services.
Performance of business operations, including providing and monitoring IT systems for any lawful purpose; maintaining accounts and internal directories, crisis management, protecting occupational health and safety; participating in due diligence activities related to the business; business succession planning and conducting internal analyses and audits.
Recruitment, including job advertising, interviewing, and selecting and hiring new staff.
Security operations, including detecting security incidents, debugging and repairing errors, and preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution; and monitoring and controlling logical and physical access to LiveRamp devices, data, premises and locations (including through use of CCTV).
Legal Compliance such as complying with anti-bribery, tax, social security and immigration obligations, and responding to and cooperating with legal or regulatory requests and investigations.
LiveRamp may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.
Category Categories of Sources Purpose for Collecting Identifiers: Identifiers such as a real name, alias, postal address, unique personal identifier, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Directly from the employee or applicant, background information providers, virtual test-centers and interview information, recruiting services Management and administration, business operations, recruitment, security, legal compliance Categories from CA Civil Code 1798.80: name, social security number, address, telephone number, driver’s license or state identification card number, employment, credit card number, debit card number, or any other financial information Directly from the employee or applicant, background information providers, virtual test-centers and interview information, recruiting services Management and administration, business operations, recruitment, security, legal compliance Professional or employment-related information Directly from the employee or applicant, background information providers, virtual test-centers and interview information, recruiting services Management and administration, business operations, recruitment, security, legal compliance Internet or electronic network activity information Directly from the employee or applicant Management and administration, business operations, recruitment, security, legal compliance
Note regarding Sensitive Personal Information: While LiveRamp uses certain “sensitive” personal information (e.g., social security number, driver’s license number) for identity verification and other employment-related purposes, it does not infer characteristics about consumers based on such personal information.
3. With Whom We Disclose Personal Information
We will disclose workforce personal information to the following types of entities or in the following circumstances (where applicable):
- Internally: to people within LiveRamp to carry out the purposes described in this Notice, including to your manager, human resources, as well as personnel within LiveRamp, such as payroll, IT, legal, internal audit, compliance, and finance.
- Service Providers: such as compensation and benefits providers, tax and other professional advisors, external auditors, technology service providers, corporate card issuers, travel management providers, travel providers, human resources suppliers, background check companies, and employment businesses (in relation to contractors or agency workers).
- For Business Operations to provide another entity (such as a potential or existing business counterparty or customer) with a means of contacting you in the normal course of business, for example, by providing your contact details, such as your phone number and email address.
- Legal Compliance: when required to do so by law, regulation, or court order or in response to a request for assistance by the police or other law enforcement agency.
- Litigation Purposes: to seek legal advice from our external lawyers or in connection with litigation with a third party.
- Business Transaction Purposes: in connection with the sale, purchase, or merger of a business.
LiveRamp does not sell or share (as defined by the CCPA/CPRA) the information collected about you. However, we may disclose certain personal information for business purposes as described in the chart below.
Category Categories of Third Parties We Disclose to Whether We “Sold” or “Shared” in the Last 12 Months Identifiers: Identifiers such as a real name, alias, postal address, unique personal identifier, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Service providers, auditors, recruiting services, contractors, and legal counsel No Categories from CA Civil Code 1798.80: name, social security number, address, telephone number, driver’s license or state identification card number, employment, credit card number, debit card number, or any other financial information Service providers, auditors, recruiting services, contractors, and legal counsel No Professional or employment-related information Service providers, auditors, recruiting services, contractors, and legal counsel No Internet or electronic network activity information Service providers, security services, auditors, recruiting services, contractors, and legal counsel No
4. Exercising Rights and Choices
California law provides consumers with specific rights regarding their personal information, including the right to opt out of sale or sharing and the right to limit the use and disclosure of sensitive personal information, access (request the categories and specific pieces of personal information we’ve collected), correct, and delete. Please be aware, however, that our ability to provide some of these options is limited for employment-related data because of conflicting obligations and our ability to continue to provide the opportunity for employment and avoid disruption to business operations.
California employees and applicants may exercise their California privacy rights by:
- Submitting a request via: My Privacy Choices
- To contact us by phone please follow the two steps below:
- Step 1: Call 866-467-8688
- Step 2: Enter the applicable service code:
- Step 1: Call (844) 678-0045
- Step 2: Enter the applicable service code:Opt out Request (Do Not Sell or Share or Limit the Use of My Sensitive Personal Information): 1Access Request: 2Category Request: 3Deletion Request: 4
Correction Request: 5
Employee Request: 6
Business Representative Request: 7
- Step 3: You will need to provide the following information:
- First Name, Last Name
- Phone Number
- Home Address
Right to Non-Discrimination for Exercise of Your Consumer Rights: You have the right not to receive discriminatory treatment by LiveRamp for the exercise of your privacy rights under California law. Employees, applicant’s, and independent contractors will not be retaliated against for the exercise of privacy rights.
5. How to Contact Us About this Notice:
If you have questions about exercising rights with respect to your employee or applicant personal data, please contact us here. Information submitted through this form may be seen by internal employees and contractors outside of the legal and people and culture departments.
For What Period Do We Retain Personal Information
LiveRamp will retain information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine LiveRamp’s retention periods include: (i) the purposes for which the data was collected; (ii) the length of time business partners obligate LiveRamp to retain or delete data based on their data collection practices and privacy obligations; (iii) whether there is a legal obligation to which LiveRamp is subject; (iv) whether retention is advisable in light of LiveRamp’s legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations); and (v) whether you have requested that we delete your personal information.