California Job Applicant – Notice at Collection

Your Privacy Is Important to Us.

Policy Statement

Your privacy is important to Empyrean, and we are committed to protecting your information.  This privacy notice (“Notice”) describes the personal information that we collect from our job applicants and the purposes for which we may use such information, in accordance with the California Consumer Privacy Act (as may be amended, modified or supplemented from time to time, and together with any implementing regulations, “CCPA”).  If you are a California resident, please review the following information about our privacy practices.

Terms used herein have the meaning ascribed to them in the CCPA.  We are a “business.”  “Personal information” under the CCPA means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California resident or a household.  It does not include deidentified information, aggregate consumer information or publicly available information, as those terms are defined in the CCPA.

Personal Information We Collect

We may collect certain categories of personal information about you through your interactions with us, including:

  • Identifiers such as, your name, address, date of birth, email address, phone number(s), social security number, driver’s license number, passport number, online identifiers or other similar identifiers.
  • Additional information subject to Cal. Civ. Code §1798.80(e), including your signature, identification card number, bank account or other financial information.
  • Characteristics of protected classifications under certain federal or state laws, including sex/gender, sexual orientation, gender identity/expression, race, color, religion, national origin, immigration or citizenship status, ancestry, disability, medical condition, pregnancy, age, military or veteran status or marital/partnership status.
  • Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
  • Professional or employment-related information, including former employers, professional titles, compensation (including bonuses), performance information, and background checks.
  • Internet or other electronic network activity information, including information regarding your interaction with our website or use of certain online tools, usage of social media and certain of your interactions through social media, and audio, electronic, visual or similar information, such as photographs, voicemails, interactions on video communications platforms, and IP addresses.
  • Inferences drawn from any of the information identified above to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitude, including your potential interest in certain benefits or other services.

How We Use Collected Information

We may use your personal information for business or commercial purposes such as:

  • Performing services for purposes of your prospective employment with us; onboarding management; technology management and work from home set up; verifying information; or monitoring compliance with the Firm’s policies and procedures.
  • Communicating with you about your employment or a potential position, including salary, other payments or benefits information, performance evaluations, references, application forms, emergency contact information or other human resources information.
  • Responding to operational due diligence requests from investors or prospective investors or otherwise communicating with them regarding the Firm’s business, operations, policies and procedures.
  • Compliance with federal and state securities laws, rules and regulations, including laws, rules and regulations applicable to registered investment advisers, and for periodic internal audits and/or external investigations or audits.
  • Conducting security maintenance and enhancements, assisting law enforcement agencies or for regulatory or other legal purposes.
  • Undertaking internal research to help improve our products or services.

Contact for More Information

If you have any questions or concerns about this California-specific Employee Notice at Collection, please contact our General Counsel, Marty Meekins at mmeekins@empyrean.com or (310) 843-3000.