Privacy Notice

ESA Management, LLC Privacy Notice

Last Updated: February 23, 2023

Introduction
ESA Management, LLC (“ESA Management,” "We," “Our,” or “Us”) provides this Privacy Notice to describe the types of information we may collect from you or that you may provide when you visit www.esamgmt.com (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Privacy Notice applies to information we collect through this Website related to your employment, application, and/or job search directly from you email, text, and other electronic messages 9as well as other sources noted below) between you and ESA Management; and any other websites that link to this policy (collectively, the “Services”).

Information We Collect About You and How We Collect It
When you interact with the Services, we may collect information about you, including your name, email, contact information, education, employment history, and any other information you choose to provide. For example, we may collect this information from your when you apply for a job with ESA Management through ADP, create an account with us, contact us, or interact with us for any other purpose.

As you navigate through and interact with our Website, we (and other entities) may automatically collect information about your equipment, browsing actions, and patterns, including, IP address, browser type, Website usage statistics, and other information we collect through the use of cookies and similar technology.

 

How We Use Your Information
We use information that we collect about you or that you provide to us for any lawful purpose, including the following:

  • To process your application for employment.
  • To provide you with information that you request.
  • To operate, personalize, and improve our Services.
  • To maintain the security and integrity of our Website.
  • To comply with applicable laws and regulatory requirements, including in response to a court order, subpoena, or other lawful request.
  • With your consent or as otherwise disclosed at the time information is collected.

 

How We Share Your Information
We may share personal information we collect with third parties, including the following:

  • Other entities within our corporate family of companies and joint venture partners.
  • Contractors, service providers, and other third parties, including ADP, that we use to support our business and process your application for employment.
  • A potential or new buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by Company is among the assets transferred.
  • When required by law, to comply with any court order, law, or legal process, including to respond to any government or regulatory request.
    • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
    • With your consent or as otherwise disclosed at the time of data collection or sharing.

We may disclose aggregate or deidentified information without restriction.

 

Your Choices
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Cookies

You can adjust your browser settings to manage or reject cookies, or to notify you when a cookie is being placed in your browser These settings are usually found in the ‘Options’ or ‘Preferences’ menu of your browser.

However, disabling some or all cookies could mean you will be unable to access certain content on the Website or use all features.

Updating Your Information:

If you want to update or correct your information with us, including any contact information or application materials, please contact us using the telephone number or email in the “Contact Us” section at the end of this Privacy Notice. You may update your application materials by logging into your ADP account.

Promotional Emails:

If you receive any promotional email communication from us, you will be given the option to “unsubscribe” from further promotional email communications from us if you wish to stop receiving these communications.

If you opt out of receiving promotional emails, we will still send you messages related to our relationship with you, including application updates.

Links to Other Sites

The Services may contain links to websites or platforms owned or controlled by other companies, such as ADP and Vimeo. We are not responsible for the data collection and use practices and privacy policies on third-party websites that you may access from our Services. We encourage our users to be aware when they leave our Services and to read the privacy statements of any other sites that collect personal information.

 

Your California Privacy Rights

Under the California Consumer Privacy Act (“CCPA”), we are required to provide any California resident who is our job applicant with a notice related to “personal information” we collect about you. This notice contains disclosures required by the CCPA and applies only to “personal information” that is subject to the CCPA. 

Categories of Personal Information We Collect and Disclose. We collect and disclose the following categories of personal information about our job applicants who are California residents:

  • Personal and online identifiers (such as first and last name, Social Security number, and email address).
  • Characteristics of protected classifications under California or federal law (such as race, sex, and gender).
  • Internet or other electronic network activity information (such as interactions with a website, email, or application).
  • Geolocation information.
  • Professional or employment-related information (such as your employment history and resume).
  • Education information (such as your education history and transcripts).
  • Other information about you that is linked to the personal information above.

Sensitive Personal Information. Some of the information described above is also defined as “sensitive personal information” under the CCPA. We do not use or disclose sensitive personal information for purposes other than those specified in the CCPA.

Categories of Sources. As permitted by law, we may collect personal information about job applicants from the following categories of sources:

  • Employment references and/or verifications.
  • Recruiters, including individuals who refer you to ESA Management.
  • Service providers.
  • Background check providers.
  • Consumer reporting agencies.

Categories of Third Parties To Which We Disclose Personal Information. We may disclose the personal information we collect to the following categories of recipients:

  • Service providers. We disclose the personal information we collect to our service providers, such as those who help us manage the application process.
  • Employment references and/or verifications. We may disclose personal information to references, for example, to confirm certain information you provided to us.
  • Background check providers. As legally permitted, we may disclose personal information to background check providers to obtain a background check.
  • Government entities. As legally required, we may provide personal information to government entities.

We do not sell the personal information we collect about job applicants or share such information for targeted advertising purposes. 

How We Use Job Applicants’ Personal Information. We use and disclose the personal information we collect about job applicants for our commercial and business purposes to the categories of recipients listed above. Our commercial and business purposes include, without limitation:

  • Processing, evaluating, and communicating with you about your application, including to check references and communicate with you about other jobs that may interest you.
  • Other business purposes as identified in the CCPA, which include:
    • Auditing related to our interactions with you;
    • Legal compliance;
    • Detecting and protecting against security incidents, fraud, and illegal activity;
    • Debugging;
    • Performing services (for us or our service provider) such as analytics;
    • Internal research for technological improvement;
    • Internal operations;
    • Activities to maintain and improve our business; and
    • Other one-time uses.

How Long We Retain Personal Information. If you are hired, ESA Management will keep personal information about you for the duration of your employment with ESA Management and as otherwise required by law. If your application is not successful, we may retain and use your personal information for a further fixed period in accordance with our record retention protocols in order to consider you for other job opportunities where permitted by applicable law and/or for as long as necessary to comply with legal record retention requirements.

Your Rights. As a California resident, you have certain rights under the CCPA related to personal information ESA Management collects about you. You may be able to exercise the following rights, subject to certain exceptions and limitations:

  • The right to know the categories and specific pieces of personal information we collect, use, and disclose about you, the categories of sources from which we collected personal information about you, our purposes for collecting or disclosing personal information, and the categories of third parties with which we have disclosed personal information;
  • The right to request that we delete the personal information we have collected from you.
  • The right to correct inaccurate personal information we maintain about you.
  • The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

To exercise any of the above rights, please contact ESA Management using the following information and submit the verifying information, as further described below:

  • By email at dataprivacy@esa.com
  • By calling 877.651.2124.
  • Online through Priviliy.io at https://portal.privily.io/dataSubject?cStartId=a80cf585c61490a1d0dce42d25198db4.

Verification Process and Required Information. In some cases, we may need to request additional information from you to verify your identity or understand the scope of your request. Generally, we verify your identity by matching the information provided in your request with the information we maintain in our records. We will require you to provide, at a minimum a name and email address.

Authorized Agent. You may designate an authorized agent to submit a CCPA request on your behalf. If you would like an authorized agent to submit a request on your behalf, please contact us using the methods in above for instructions and details on proof and information required for use of an authorized agent. We may need to also contact you directly to verify the request.

Your Rights as a Consumer. We may collect information about you that is unrelated to your application to our company, if you are a consumer of our services. More information about our privacy practices and your rights as a consumer under state privacy laws can be found at our Privacy Notice.

Contact Us. For questions or concerns about ESA Management’s practices, please contact us by using the information below.

 

Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page, and we encourage you to periodically review this page for any updates.

 

Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact us at dataprivacy@esa.com.