| Evolve Bank & Trust

This California Job Applicant Privacy Policy (“Privacy Policy”) describes how Evolve Bank & Trust (“Company,” “we,” “us,” or “our”) collects, uses and discloses Personal Information about current and former job applicants (“you,” “your,” or “applicant”).

In this Privacy Policy, “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 and “Sensitive Personal Information” refers to certain types of Personal Information that are deemed particularly sensitive (for example, government identification numbers, health or biometric information, account access credentials, precise geolocation, or racial or ethnic origin). For purposes of this Privacy Policy, references to Personal Information include Sensitive Personal Information, unless otherwise indicated. Personal Information does not include information that is de-identified in accordance with applicable law or lawfully made publicly available from you, government records, or widely distributed media.

1. Updating this Privacy Policy

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date. If we make material changes to the ways in which we process your information, we will use reasonable efforts to notify you (such as by emailing you or posting a notice on our applicant portal) and will take additional steps as required by applicable law.

2. Our Collection and Use of Information

We collect Personal Information about you as part of your job application with us from a variety of sources, including from you directly, from your references, and from our vendors that help manage the application process. We collect, and over the past 12 months have collected, the following categories of Personal Information, including Sensitive Personal Information (denoted by *):

Identifiers such as name, email address, IP address, home address, date of birth and phone number.
Personal information categories listed in the California Customer Records Statute such as name, signature, address, social security number*, telephone number, passport number*, driver’s license* or state identification card number*.
Protected classification characteristics under California or federal law such as race*, color*, national origin or ancestry*, sex (including gender, pregnancy, sexual orientation* and gender identity*), age, physical or mental disability,* veteran status, and citizenship.
Internet or other similar network activity such as information regarding your interaction on our website and surveillance information (such as CCTV footage related to your activities at our physical locations).
Geolocation data such as IP address (approximate location).
Audio, electronic, visual, thermal, olfactory or similar information such as photographs, video recordings and voice recordings (such as CCTV footage related to your activities at our physical locations).
Professional or employment-related information such as resume, curriculum vitae, cover letter, professional qualifications, employment history, criminal records, proof of eligibility to work, references, and any other information provided during the application or interview.
Non-public education information collected by certain federally funded institutions such as education records.
Inferences drawn from other Personal Information such as a profile reflecting your characteristics, intelligence, or aptitude.
Government identifiers* such as social security number, driver’s license, birth certificate, permanent resident card, state identification card or passport number.
Account access credentials* such as account login in combination with any required security or access code, password or credentials allowing access to accounts you use in relation to your job application.
Health Information* such as information that can reveal characteristics of your health including any medical conditions that you communicate to us.

We use the above Personal Information for various business purposes related to your application, including:

Recruiting and hiring, including background verifications to the extent permitted by applicable law, maintaining personnel records of job applicants, entering into and honoring employment contracts, and making salary and benefits decisions.
Improving employment practices, including equality and diversity in the workplace.
Managing, planning, and organizing the operations of our business, including by facilitating business planning and restructuring exercises.
Safeguarding our business interests, including our intellectual property and confidential information, and the security, availability and resilience of our premises and IT systems.
Preventing fraud, crime, harassment, discrimination, or other misconduct, handling investigations, claims, grievances, and disciplinary proceedings, and defending or pursuing legal claims.
Planning and executing a transaction involving the sale, transfer, merger, consolidation, restructuring, or re-organization of any part(s) of our business or our assets, or merging with, acquiring or forming a joint venture with any other business.
Complying with legal and regulatory obligations, including: ensuring that tax and other statutory dues are paid; responding to requests from foreign and domestic law enforcement, regulators and courts; carrying out verifications in relation to your right to work; equal opportunities monitoring; investigating claims of discrimination or harassment; making reasonable adjustments for disabled applicants; and complying with leave management procedures.

We only use and disclose your Sensitive Personal Information for the purposes specified in the California Consumer Privacy Act.

3. How the Company Discloses Your Information

In certain circumstances, we may disclose your Personal Information to third parties for legitimate purposes subject to this Privacy Policy, including:

Vendors who provide job application-related services, or otherwise help facilitate your application for employment, including recruitment portal providers, facility access and security, cloud storage and IT services, personnel records management, and background checks and other verifications (“Service Providers”).
Background check providers (including screening, background and criminal records checks).
Referees whose details you provide us, so they can provide a reference.
Recruitment agencies and recruitment services companies where relevant for the role or position you are applying for (“Recruitment Agencies”).
Law enforcement, courts, regulators, counterparties, and other third parties in connection with a legal obligation (“Legal Parties”), including if reasonably necessary or appropriate to:
- Comply with any applicable federal, state or local law or regulation, civil, criminal or regulatory inquiry, investigation or legal process or enforceable government request;
- Respond to legal process (such as a search warrant, subpoena, summons or court order);
- Cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state or local law; or
- Exercise or defend legal claims, protect against harm to our rights, property, interests or safety or the rights, property, interests or safety of, third-parties, or to the public required or permitted by law.
Third parties in connection with or anticipation of an asset sale, merger, bankruptcy, or other business transaction (“Business Transaction Parties”).
Other third parties with your permission or upon your direction.

In the preceding 12 months, we disclosed the following categories of Personal Information, including Sensitive Personal Information (denoted by *), about applicants:

Categories of Personal Information	Categories of Recipients
Identifiers Personal information categories listed in the California Customer Records Statute Professional or employment-related information Non-public education information collected by certain federally funded institutions	Service Providers, Background Check Providers, Referees, Recruitment Agencies, Legal Parties
Government identifiers*	Service Providers, Background Check Providers, Legal Parties
Protected classification characteristics under California or federal law	Service Providers, Legal Parties
Internet or other similar network activity Geolocation data Account access credentials* Health Information*	Service Providers

We do not sell Personal Information or share Personal Information for cross-context behavioral advertising purposes, nor have we done so in the preceding 12 months. We do not have actual knowledge that we sell or share for cross-context behavioral advertising purposes Personal Information of individuals under 16 years of age.

4. How We Retain Your Information

We retain your Personal Information for as long as is reasonably necessary for the purposes specified in this Privacy Policy, and, if you are successful in your application, for the purposes of your employment with the Company. When determining the length of time to retain your Personal Information, we consider various criteria, including whether we need the Personal Information to evaluate your application, for purposes of your employment, comply with our legal obligations, enforce our contractual agreements, prevent harm, promote safety, security and integrity, or protect ourselves, including our rights, property or business.

5. Your Rights

As a California resident, you may have the rights listed below in relation to Personal Information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

Right to Know. You have a right to request the following information about our collection, use and disclosure of your Personal Information:
- categories of Personal Information we have collected and disclosed for a business purpose;
- categories of sources from which we collected Personal Information;
- the business or commercial purposes for collecting Personal Information;
- categories of third parties to whom the Personal Information was disclosed for a business purpose; and
- specific pieces of Personal Information that we have collected.
Right to Correct. You have a right to request that we correct inaccurate Personal Information maintained about you.
Right to Delete. You have a right to request that we delete your Personal Information.

You may exercise any of these rights by contacting us using the below contact information. We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as government issued ID* or date of birth before providing a substantive response to the request. You may designate, in writing, including through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

6. How to Contact Us

Should you have any questions about our privacy practices or this Privacy Policy, please email the Human Resources Department at CAPrivacyPolicy@getevolved.com or contact us via telephone at 866.367.2611.