Effective Date: January 1, 2022

Last Reviewed on: June 5, 2023


This Privacy Notice (“Notice”) for California Residents is supplemental to the information contained in Eighth Light Limited’s (“we,” “us,” or “our”) Privacy Policy. We adopt this notice to comply with the California Privacy Rights Act of 2023 (“CPRA”). This Notice applies to individuals (“candidates,” “employees,” “you”) who reside in the State of California and describes your privacy rights under the CPRA.


Information We Collect


Category Examples Collected

A. Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

YES

D. Commercial Information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

NO

G. Geolocation data

Physical location or movements.

NO

H. Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information.

YES


I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO


K. Inferences Drawn from other personal information

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES



Personal information does not include:

  • Publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public..

  • De-identified or aggregated consumer information.

  • Information excluded from the CCPA’s or CPRA’s scope, like:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.


Sources of Personal Information

Eighth Light LLC obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, data you provide from an employment application.

  • Publicly available sources. For example, data published to online social media platforms and job boards.

  • Third parties used during the hiring and employment processes. Examples of third parties may include, but are not limited to background check providers and professional references.


Use of Personal Information

We may use the personal information we collect for the following purposes:

  • Respond to your inquiries and requests for information.

  • Review and evaluate employment applications and requests.

  • Communicate to you about our latest insights, employment opportunities, and company updates.

  • Comply with applicable legal requirements and industry standards.

  • Perform data analytics and industry research.

  • As described to you when collecting your personal information or as otherwise set forth in the CPRA.


Sharing of Personal Information

Eighth Light LLC may disclose your personal information to a contractor, client, stakeholder or service provider for a business purpose. When we disclose your personal information for a business purpose, we do not sell your information.

Your personal information with the following categories of third parties:

  • Service Providers who assist us in carrying out critical business functions. For example, data you provide on a job application is shared with our Applicant Tracking System’s Service Provider.

  • Government authorities, as required by law.

  • Clients or prospects who are interested in engaging 8th Light LLC for a business need

  • Third Parties in the event of a merger, acquisition, or sale of assets.

Eighth Light LLC will not collect or request additional categories of personal information or use the personal information we collected for materially different, unrelated purposes communicated to you.

In the preceding twelve (12) months, we have disclosed the following categories (corresponding with the table above) of personal information for a business purpose: Category A, Category B, Category C, Category H, Category I, Category K.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights

The CCPA and CPRA provide California residents with specific rights regarding their personal information. This section describes your CCPA and CPRA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal and sensitive information unless responding to the request is impossible or involves disproportionate effort. Once we confirm your verifiable request, we will provide the following:

  • Know what personal information we collect about you and how it is used and shared.

  • Request deletion of your personal information.

  • Whether your information is sold or shared.

  • Access and obtain a copy of your personal information.

  • Correct any inaccurate personal information.

  • Non-discrimiationation for exercising your privacy rights.


Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records.


Exercising Access, Data Portability, and Deletion Rights
If you would like to exercise any of the rights described above, you may do so by contacting datasecurity@8thlight.com

You may only make a verifiable request for access or data portability twice within a 12-month period. The verifiable request must:

  • Provide enough information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable request to confirm the requestor’s identity or authority to make the request.


Response Timing and Format
We endeavor to respond to a verifiable request within thirty (30) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically. Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another without hindrance, specifically by electronic mail communication.


Personal Information Sales Opt-Out and Opt-In Rights
Eighth Light LLC does not sell your personal information.


Non-Discrimination
We will not discriminate against you or exercising any of your CCPA or CPRA rights. Unless permitted by the CCPA or CPRA, we will not:

  • Deny you services

  • Provide you a different level of service.

  • Discriminate in making employment decisions.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits employees that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make a request, please contact us at: datasecurity@8thlight.com.

Security

We take significant measures to protect the personal information we request and collect from unauthorized access, disclosure, alteration, or destruction. However, no security measure is impenetrable, and we cannot guarantee the absolute security of your personal information.

Changes to this Notice

We may update this Notice from time to time. The effective data at the top of this Notice indicates when it was last revisited. We encourage you to review this notice periodically to stay informed of any changes.

Contact Us

If you have any questions or concerns about our privacy practices, this Notice, or exercising the rights within this Notice, please contact us at:

Eighth Light LLC.
25 East Washington Street, Unit #509
(877) 407- 4154

datasecurity@8thlight.com