California Careers Privacy Notice

Effective Date: January 1, 2024

Atria Senior Living, Inc., our subsidiaries, and our affiliates (collectively “Atria,” “us,” “we,” or “our”) provides this California Careers Privacy Notice (“Notice”) to explain our practices regarding the collection of Personal Information about candidates through our job application process, including our careers website (atriacareers.com) (“Applicants”). This Notice explains what Personal Information we collect about California Applicants, why we collect it, how we use and share it, and the rights you have relating to your Personal Information under the California Consumer Privacy Act, as modified by the California Privacy Rights Act of 2020 (the “CCPA”). This Notice supplements our other privacy policies and notices, including our Privacy Policy. In the event of a conflict between any other policy, statement, or notice and this Notice, this Notice will prevail as to California Applicants.

California consumers can find additional disclosures in our California Consumer Privacy Notice. If you are an Atria employee, please see our California Employee Privacy Notice for additional disclosures.

Unless otherwise noted, the disclosures that describe how and why we collect, use, and disclose Personal Information also describe how we have collected, used, and disclosed personal information in the preceding twelve (12) months.

I. How and Why We Collect Your Personal Information

“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 you. Personal Information includes “Sensitive Personal Information.” Personal Information does not include information that is publicly available, de-identified, or aggregated.

We collect the following categories of Personal Information about California Applicants. Note that the Personal Information we collect about you may vary depending on the nature of your interactions with us and may not include all of the examples listed below.

Category of Personal Information	Categories of Sources from which Information was Collected	Purposes for Collection and Use
*Personal Information*
Identifiers including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, driver’s license number, passport number, or other similar identifiers	Directly from you Automatically when you use our website From service providers that help us to run our business From third parties that help us run our business	To open and maintain your application records To assess your eligibility for employment To communicate with you regarding your application To comply with applicable laws and regulations To manage the security of our premises and systems To detect and prevent fraud against you and/or us
Personal Information described in Cal. Civ. Code § 1798.80(e), including your name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, education, employment, and employment history	Directly from you From service providers that help us to run our business From third parties	To open and maintain your application records To assess your eligibility for employment To communicate with you regarding your application To comply with applicable laws and regulations To manage the security of our premises and systems To detect and prevent fraud against you and/or us
Characteristics of protected classifications under California or federal law, including age and date of birth, marital status, race, ancestry, ethnic origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, genetic information, and disability	Directly from you From service providers that help us to run our business From third parties	To comply with applicable laws and regulations
Internet or other electronic network activity information, including Internet or other similar activity, browsing history, search history, and information regarding your interactions with our websites, applications, logs, device data and registration, social media account information or advertisements	Automatically when you use our website From service providers that help us to run our business From third parties	To facilitate your use of our website To provide you with tailored recommendations, and updates To show you relevant ads while you are browsing the internet or using social media To improve our website, set default options, and provide you with a better application experience To protect the security of our website To detect and prevent fraud against you and/or us
Geolocation data, including location data inferred from your device IP address	Automatically when you use our website From service providers that help us to run our business From third parties	To provide you with tailored recommendations, and updates To show you relevant ads while you are browsing the internet or using social media To improve our website, set default options, and provide you with a better application experience To protect the security of our website To detect and prevent fraud against you and/or us
Audio, electronic, visual, thermal, olfactory, or similar information	Directly from you Automatically while you are on Company property	To manage the security of our premises and systems
Professional or employment-related information, including: Skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, application form, or cover letter; Answers to behavioral or other screening questions in an application or interview; Information contained in any personal webpages or documents you choose to share with us; Information relating to professional licenses, training, disciplinary actions, and membership in professional organizations; Information relating to membership in civic organizations	Directly from you From service providers that help us to run our business From third parties	To open and maintain your application records To assess your eligibility for employment To comply with applicable laws and regulations To detect and prevent fraud against you and/or us
Non-public education information, including school(s) attended, grades, transcripts, records of attendance, disciplinary records, and other information relating to your secondary and post-secondary education	Directly from you From service providers that help us to run our business From third parties	To open and maintain your application records To assess your eligibility for employment To comply with applicable laws and regulations
Inferences used to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	Drawn from the other categories of Personal Information we collect	To assess your eligibility for employment To manage the security of our premises and systems To detect and prevent fraud against you and/or us
Sensitive Personal Information
Social security, driver’s license, state identification card, or passport number	Directly from you From service providers that help us to run our business From third parties	To assess your eligibility for employment To comply with applicable laws and regulations To manage the security of our premises and systems
Account log-in in combination with any required security or access code, password, or credentials allowing access to an account	Directly from you	To open and maintain your application records To manage the security of our premises and systems To detect and prevent fraud against you and/or us
Personal Information that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, citizenship or immigration status, or union membership	Directly from you	To comply with applicable laws and regulations
Personal Information collected and analyzed concerning a consumer’s health (i.e., drug-screening information)	Directly from you From service providers that help us to run our business	To assess your eligibility for employment
Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation	Directly from you	To comply with applicable laws and regulations

Unless otherwise specified, the sources of this Personal Information, the purposes for which we use it, and the categories of persons to which we disclose it are the same as those listed for Professional or Employment-Related 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.

II. How Long We Keep Your Personal Information

We keep the categories of Personal Information described above for as long as is necessary for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;
Your Personal Information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case);
Your Personal Information may be maintained indefinitely according to legal or regulatory requirements, including applicable legal holds, or for data backup or recovery purposes; or
We are otherwise required or permitted to keep your information by applicable laws or regulations.

Where 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.

III. How We Sell, Share, and Disclose of Applicant Personal Information

As defined in the CCPA, we sell, share, and disclose for a business purpose Consumer Personal Information to our service providers, contractors, and third parties.

Sales and Sharing of Personal Information

Under California law, a “sale” of Personal Information does not necessarily involve an exchange of money. Instead, the term also includes disclosures of Personal Information to third parties that may use the information for their own purposes, such as cookie providers. Similarly, under California law, “sharing” Personal Information refers to disclosing of Personal Information to third parties for cross-context behavioral advertising. In this context we sell and/or share the following categories of Personal Information.

As defined by California law, we sell and/or share identifiers, Personal Information described in Cal. Civ. Code § 1798.80(e), internet or other electronic network activity information, geolocation data, and inferences for analytics, marketing, and advertising, including targeted advertising and cross-context behavioral advertising. We sell to and share with advertising networks; service providers, vendors, and suppliers; data analytics providers; and social networks. We do not have actual knowledge that we sell or share the Personal Information of consumers under sixteen (16) years of age.

Disclosures for a Business Purpose

We disclose the categories of Personal Information listed in Section I to our affiliated and related companies; our service providers, vendors, and suppliers; our professional advisors; public authorities or government bodies; and external auditors for the following business purposes:

Auditing related to ad impressions;
Ensuring security and integrity of Personal Information;
Debugging to identify and repair errors that impair existing intended functionality;
Short-term, transient use, including, but not limited to, non-personalized advertising;
Performing services on our behalf;
Providing advertising and marketing services (except for cross-context behavioral advertising);
Undertaking internal research for technological development and demonstration;
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us;
Processing, maintaining, or collecting Personal Information on our behalf;
Detecting or protecting against malicious, deceptive, fraudulent or illegal activity; and
For internal use by the service provider.

IV. Submitting Requests Relating to Your Personal Information

If you are a resident of California, 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 to CAprivacyrequest@atriaseniorliving.com or call us at (800) 928-9145. Please note that, if you submit a request to know, delete, or correct, you may be asked to log into your account or to provide two-to-three (2-3) pieces of Personal Information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will 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 webform or toll-free number listed above.

Right to Know. You have the right to know what Personal Information we have collected about you, including:

1. The categories of Personal Information we have collected about you, including:

The categories of sources from which the Personal Information was collected;
Our business or commercial purposes for collecting, selling, sharing, or disclosing Personal Information;
The categories of recipients to which we disclose Personal Information;
The categories of Personal Information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information; and
The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to whom we disclosed that particular category of Personal Information.

2. 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 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. You have the right to opt-out of the sale of your Personal Information, and to request that we do not share your Personal Information for cross-context behavioral advertising. To opt-out, please visit our cookie preference center located in the footer of this website. If you choose to use the Global Privacy Control (“GPC”) browser signal, you will only be opted-out of online sales or sharing of Personal Information, and will need to turn it on for each browser you use.

Right to Limit Use and Disclosure of 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. For this reason, we do not offer a way for you to submit such a request.

Rights Related to Automated Decision-Making. You have the right to opt out of automated decision-making, including profiling, that we use to evaluate certain personal aspects relating to your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.

V. How to Contact Us

If you have any questions about how Atria handles your Personal Information or if you need to access this notice in an alternative format because of a disability, please contact our Human Resources Department at:

Phone: 1-800-928-9145
Email: CAprivacyrequest@atriaseniorliving.com