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This EMPLOYMENT PRIVACY NOTICE FOR CALIFORNIA RESIDENTS, as defined by the California Consumer Privacy Act of 2018 and codified in California Civil Code section 1798.10 et seq. (hereinafter “CCPA” or “Act”) is adopted by ACRA LENDING a dba of CITADEL SERVICING CORPORATION (collectively, “we,” “us,” or “our”) and applies solely to job applicants, employees, owners, directors, contractors and other personnel of Acra Lending who reside in the State of California (“Consumer” or “you”). In compliance with the CCPA, this Notice provides you with our business practices as to the categories of Personal Information we collect about you and the purposes for which it will be used and disclosed. All capitalized terms not defined herein shall have the same meaning as set forth in the Act. We recommend that you retain a copy of this Privacy Notice for your records.

EMPLOYMENT PRIVACY NOTICE – Effective as of January 1, 2020 (Updated July 28, 2020)

Personal Information We Collect

We are committed to protecting the privacy and security of Personal Information. In the course of our business, we ask job applicants, prospective employees, and employees to provide necessary Personal Information relating to your employment or prospective employment. Acra Lending will only collect and process your personal information in accordance with this Notice, unless otherwise required by applicable law.

Generally, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). In particular, we have collected the following categories of Personal Information from its Employees within the last twelve (12) months.

Category Examples Collected

A. Identifiers. A real name, alias, postal address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. E.g. information obtained from pre-hire documents such as job applications, resume, etc.

Unique personal identifier, online identifier, Internet Protocol address, cookies, beacon or other similar website related identifiers. E.g. information obtained from visiting web-based employment platforms.

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, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. E.g. information obtained from pre-hire documents such as job applications, resume, etc.

Some personal information included in this category may overlap with other categories.

C. Protected classification characteristics under California or federal law. Age, 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. E.g. information obtained from pre-hire documents such as job applications, resume, etc. YES
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered. YES
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.

E.g. information obtained from visiting web-based employment platforms.

G. Geolocation data. Physical location or movements. E.g. information obtained from use of personal devices like fobs to access secure locations and systems. YES
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. E.g. recorded customer service calls. YES
I. Professional or employment-related information. Current or past job history. E.g. information obtained from pre-hire documents such as job applications, resume, etc. 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. E.g. information obtained from pre-hire documents such as job applications, resume, job interviews, writing samples, continuing education requirements, etc. YES
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. E.g. information obtained from post-hire documents such as performance evaluations, etc. YES

Personal Information does not include:

  • Publicly available information from federal, state or local government records.
  • De-identified or aggregated consumer information.
  • Information exempted from the CCPA’s scope, like:
    • Personal Information covered by certain sector-specific privacy laws, including without limitation, the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994;
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), if applicable.

Sources of Personal Information

  • We obtain the categories of Personal Information listed above from the following categories of sources:
    • Directly from you and your authorized agents. For example, from documents you provide to us related to the services for which you have engaged us.
    • Indirectly from you and your authorized agents. For example, through information we collect from our employees over the course of your employment with Acra Lending.
    • Directly from your activity on your assigned company equipment (computer and telephone).
    • From service providers that help us provide employment related services. For example, from Paylocity in regards to clocking in and out, requesting time off, and documenting meal breaks.
    • From third-parties that interact with us in connection with our recruiting efforts. For example, from Indeed, LinkedIn, or Jobvite.

Use of Personal Information

  • We carefully evaluate how we use data to make sure that we are using your information to personalize our services and provide value for you. We may use or disclose the Personal Information we collect for one or more of the following business purposes:
    • To make an employment and/or job-related decision that involves you, including but not limited to, hiring and separation decisions.
    • To assess qualifications for a particular job or task, conduct performance reviews, determine performance requirements, gather evidence for disciplinary actions and address grievances.
    • To manage working hours, appropriate labor environment and improvement of work efficiencies.
    • To effectively process payroll and work-related claims.
    • To administer and maintain group health insurance benefits, benefits claims, 401K and/or retirement plans.
    • To provide you with information that you request from us.
    • To offer you company sponsored discounts.
    • To communicate with you through email alerts and other notices concerning employee rights, benefits, events or news.
    • To fulfill or meet the reason for which the information is provided. For example, if you provide us with emergency contact information in your application, we will use it to contact your designated person in case of an emergency.
    • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
    • To create and administer learning and development courses, including but not limited to training and educational seminars.
    • To comply with local, state and federal laws and regulations, including but not limited to, requiring employers to maintain certain records.
    • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
    • As necessary or appropriate to protect the rights, property or safety of us, our employees and others.

    We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

    • We do not sell your Personal Information.
    • We understand that sharing information with third parties is big responsibility. We are committed to only sharing information when needed for a legitimate business or legal purpose, and then only with recipients who will protect the data. We only disclose your Personal Information to a third party for a business purpose and only to the extent necessary to administer benefits, services and conduct human resource activities. When we disclose Personal Information for a business purpose, we enter a written agreement that describes the purpose and requires the recipient to keep that Personal Information confidential and not use it for any purpose except performing the agreement. We may disclose Personal Information to satisfy a legal or regulatory requirement, including responding to a subpoena or other lawful government request and will share only information that is necessary to comply with that requirement. We may also share information if needed to enforce our legal rights, detect or prevent fraud or security concerns and protect public safety. If we are involved in a merger, acquisition or any form of transfer or sale of some or all of our business, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding we may share your Personal Information in connection with that transaction.
    • In the preceding twelve (12) months, we have disclosed the following categories of Personal Information described above for a business purpose:
      • Category A: Identifiers.
      • Category B: California Customer Records personal information categories.
      • Category C: Protected classification characteristics under California or federal law.
      • Category K: Inferences drawn from other personal information.
      • We disclose your Personal Information for a business purpose to the following categories of third parties:
        • Our partners.
        • Service providers.
        • Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with your employment with the company.

Changes to Our Privacy Notice

      • We reserve the right to update this Employment Privacy Notice at our discretion and at any time. We will notify you when we make changes to this Employment Privacy Notice. In the event that we would like to use your previously collected Personal Information for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your Personal Information for a new or unrelated purpose. Acra Lending may process your Personal Information without your knowledge or consent only where required by applicable law or regulation.
Contact Information

If you have any questions or comments about this notice, our Employee Privacy Notice, the ways in which we collect and use your Personal Information, please do not hesitate to contact the HR Department or Legal Department at:

HR Department:

Legal Department:

Acra Lending
Attn: Legal Dept.
25531 Commercentre Drive, Suite 160
Lake Forest, CA 92630

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