California Consumer Privacy Act Employee and Applicant Disclosure
Gemini is aware of its obligations under the California Consumer Privacy Act (“CCPA”) and is committed to processing your data securely and transparently. This CCPA Employee and Applicant Disclosure (“CCPA Disclosure”) sets out, in line with the CCPA, the categories of data that we may collect on you as an Applicant or Employee of the Company and the purposes for which the categories of Personal Information may be used. It also describes the privacy rights of California residents under the CCPA and how they can exercise those rights. If you are an Applicant or Employee located in California, please note that the Company does not “sell” Personal Information collected from Applicants, as that term is defined under California Civil Code § 1798.140.
For purposes of this notice, “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person that the Company collects about its applicants, who reside in California, in their capacity as applicants for positions with the Company. It does not include publicly available information or information that has been aggregated or de-identified.
The CCPA does not apply to certain information, such as information subject to the Health Insurance Portability and Accountability Act (HIPAA), the Fair Credit Reporting Act (FCRA), and certain other state or federal privacy laws.
Categories of Personal Information We Collect
In the past 12 months, we have collected Personal Information relating to Applicants and Employees who are California residents from the following resources:
What personal information do we collect and use? The categories of Personal Information we may collect, use, or process about you may include the following: | Why we collect your data and how we use it? We need to collect your Personal Information to: |
|---|
Identifiers: Your personal details including your name, address, email address, phone number(s), including right to work information such as government identification numbers, your work permit or visa status. | To evaluate Applicants’ qualifications for employment with the Company; To communicate with Applicants and Employees; To conduct background checks; To determine Applicants’ eligibility to work and provide immigration assistance; To demonstrate Applicants’ agreement to, or acceptance of, documents presented to them, e.g., employment contracts; To evaluate and improve the recruiting process; Process payment or payroll and Employee benefit plan and program administration, including enrollment and claims handling; To fulfill our obligations to relevant government authorities and comply with legal obligations; Maintain personnel records; For recordkeeping purposes; Comply with record retention requirements required by law; Communicate with employees and/or employees’ emergency contacts and plan beneficiaries; Comply with applicable state and federal labor, employment, tax, benefits, workers’ compensation, disability, equal employment opportunity, unemployment claim information requests, workplace safety, and related laws; Prevent unauthorized access to or use of Company property, including the information systems, electronic devices, network, and data; Respond to valid requests for data pursuant to a subpoena, court order, legal process, law enforcement requests, legal claims, and government inquiries; Carry out our contractual obligations or enforce our rights arising from any contracts between us. |
Professional or Employment-Related Information: Employment history evaluations, membership in professional organizations and professional certifications | To evaluate applicants’ qualifications for employment with the Company; Collect and process employment applications, including confirming eligibility for employment, background and related checks, and onboarding; To evaluate and improve the recruiting process; For recordkeeping purposes; Manage conflicts of interest. |
Education Information: Non-public information such as academic transcripts, educational discipline records, and academic counseling records | To evaluate applicants’ qualifications for employment with the Company; and To evaluate and improve the recruiting process; For recordkeeping purposes. |
Characteristics of protected classifications under California or Federal law: Gender, gender identity, sexual orientation, religion, marital status, race, ethnicity, whether you are a member of a trade union or a veteran, or have a disability, to the extent you provide us such information, and request for family care leave, request for leave for an employee’s own serious health condition, request for pregnancy disability leave, and age. | As necessary to comply with federal and state Equal Opportunity laws; For purposes of diversity analytics and to design diversity and inclusion programs; Administer the Employee benefit plan and program design and administration, including leave of absence administration We collect this category of information on a purely voluntary basis, except where collection is required by law. We may also collect information with respect to disability and/or medical condition, as necessary, to comply with federal and state law related to reasonable accommodation. |
Financial Information: Bank account and billing address. | Process payroll; Manage Company expenses, corporate credit cards and expense reimbursements, as well as administering equity, compensation, bonus, and insurance programs. |
Inferences drawn from other Personal Information: Certain inferences concerning an individual’s preferences, characteristics, attitudes, philosophical or religious beliefs, intelligence, abilities, and aptitudes. | To evaluate and improve the recruiting process; Employee job performance, including goals and performance reviews, promotions, discipline, and termination; and Other human resources purposes. |
Other Uses and Disclosures
We may collect, use and disclose your Personal Information for other purposes not listed in this notice. If we do so, we will make it known to you at the time we collect, use or disclose your Personal Information and obtain your consent.
Rights to Know, Delete, and Correct
If you are a California resident, you may request that we disclose to you the following information:
The categories of Personal Information described above that we have collected about you and the categories of sources from which we collected such Personal Information
The business or commercial purposes for collecting or sharing such Personal Information
The categories of Personal Information about you that we have disclosed to or shared with third parties for a business purpose and the categories of third parties to whom we have disclosed or shared such Personal Information
The specific pieces (e.g., copies) of Personal Information we have collected about you.
California residents also have the right to submit a request for deletion or correction of their Personal Information under certain circumstances, although in some instances, we may decline to honor your request. For example, we may decline to honor your request if we cannot verify your identity or confirm that the Personal Information that we maintain relates to you, or if we cannot verify that you have the authority to make a request on behalf of another individual. In other instances, we may decline to honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA. Nonetheless, you have the right to be free from unlawful discrimination and retaliation for exercising your rights under the CCPA.
If you are a California resident and would like to exercise your rights to know, delete, or correct your Personal Information as described above, please submit your request by contacting us at privacy@gemini.com. Once we receive your request, we may verify your identity through your account or by requesting additional information sufficient to confirm your identity, such as photos of your government ID. Right to Opt Out of Sharing Personal Information for Cross-Context Behavioral Advertising
California residents have a right to opt out of sharing Personal Information for cross-context behavioral advertising purposes. You may request to opt out of the “sale” or “share” of your Personal Information (as these terms are defined under California law) at any time by emailing us at privacy@gemini.com. Submitting an opt-out request does not require you to create an account with us.
Protecting Your Personal Information
We are aware of the requirement to ensure your Personal Information is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such. These policies and procedures are covered as part of our information security program.
Where we share your Personal Information with third parties it is only pursuant to a legal obligation, and we provide written instructions to them to ensure that your Personal Information is held securely and in line with applicable privacy laws and regulations. Third parties must implement appropriate technical and organizational measures to ensure the security of your Personal Information.
Questions
If you have any questions, please contact privacy@gemini.com. If you are a current employee, please reach out to a member of the Privacy Team.. 