California Job Applicant Privacy Notice and Policy
Last Updated: December 29, 2022
Overview
This Starry, Inc. California Job Applicant Notice and Policy (this “Policy”) explains what information we collect from California job applicants, and how we use, share, and store this information where applicable. In this Policy, Starry, Inc. may also be referred to as “Starry”, “the Company”, “we”, and/or “our”. Starry takes privacy seriously, and is committed to protecting the privacy and security of your personal information.
Information We Collect About You
For the purposes of this Policy, “personal information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Below are examples of the categories of personal information that we may collect about you and an explanation of the primary reason for the collection and use of such information. Please note that not all collection categories will apply to your job application or interaction with the Company.
| Category of Information | Primary Purpose for Collection and Use oF Information |
|---|---|
| Identifiers, such as real name, alias, postal address, email address, or other similar identifiers. | To identify you, communicate with you, to comply with applicable laws, and to collect and/or track job applications prior to employment. |
| Other identifying information, such as geographic location and employment preferences. | To contact and interview you; to collect and/or track job applications; to assess qualifications for employment opportunities. |
| Professional or employment-related information, such as work history, academic and professional qualifications, educational records, references, and interview notes. | To evaluate your eligibility for employment; to collect and/or track job applications. |
| Inferences drawn from any of the information listed above, such as profile or summary about an applicant's preferences, characteristics, attitudes, intelligence, abilities, and aptitudes. | To conduct business management and planning; for making decisions about salary and compensation; to assess qualifications for a particular job or task. |
Sources of Information
We collect information about you directly from you in many cases. We may also receive information about you from other sources, including third parties or publicly available sources.
How Else We Use Your Information
In addition to the purposes and uses described above, we may use your personal information to:
- Effectively operate, manage, and maintain our business.
- Comply with applicable laws or regulations.
- Comply with contractual obligations.
- Detect and prevent fraud or crime.
- Enforce, exercise, and/or defend legal claims.
Our Disclosure of Your Information
Starry may share your personal information with third parties only if necessary to enable recruitment and job placement services. We will never sell your information.
The table below shows, for each category of personal information we collect, the categories of recipients to whom we may disclose such information for our business purposes. Please note, in addition to the recipients identified below, we may disclose any of the categories of personal information we collect with government entities, as may be needed to comply with the law or prevent illegal activity.
| Category of Information | Categories of Recipients to Whom We Disclose Information |
|---|---|
| Identifiers, such as real name, alias, postal address, email address, or other similar identifiers. |
|
| Professional or employment-related information, such as work history, academic and professional qualifications, educational records, references, and interview notes. |
|
| Inferences drawn from any of the information listed above, such as profile or summary about an applicant’s preferences, characteristics, attitudes, intelligence, abilities, and aptitudes. |
|
We Do Not Sell Your Information
As noted above, Starry never sells your personal information or otherwise shares your personal information with any third parties in exchange for monetary or other consideration.
Information Retention Starry maintains policies that comply with applicable state and federal law with respect to the length of time it retains applicant and/or employee information.
Your Rights and How to Exercise Them The California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”) provide California employees with certain rights, including, as applicable here:
- Right to Know: you have the right to request disclosure of (i) categories of personal information collected, (ii) sources of personal information, (iii) third parties to whom we have disclosed the personal information, and (iv) what personal information was shared and to whom. You may also request disclosure of specific pieces of personal information collected.
- Right to Delete: you have the right to request that we delete certain personal information collected from you.
- Right to Correct: you have the right to request that inaccurate personal information collected by us is corrected.
You have several options for submitting a request to exercise your rights to know, correct, and/or delete your information:
- You can email the Starry Legal team (privacy@253000xa.com).
- You can contact Starry’s customer support team as follows:
- Email support@253000xa.com
- Toll Free Number 888-231-9403
- You can write to us at:
Starry, Inc.
Attn: Legal Department
38 Chauncy Street, 2nd Floor
Boston, MA 02111
Additionally, you can submit the information request form below:
When you make a request, we may ask for up to four basic pieces of personal information to reasonably verify your identity, which we will match with our records. If you choose to make a request by submitting the form linked above, you will also receive an email confirmation with instructions to complete an additional step that we require you take to help verify your identity and email address. If we are unable to verify your identity, we may not respond to or process your request.
Once we have verified your identity, we will respond to requests to exercise rights to know, correct, and delete information as soon as possible, and in all cases within 45 days of our receipt of the request or date we verified your identity, whichever is later.
You May Also Submit a Request Through an Authorized Agent
You may authorize a third party to submit a request on your behalf as your authorized agent. Your authorized agent can submit a request using the same options described above and we will validate your identity using the same process described above. We will only provide requested personal information to the email address that we have on file. If your authorized agent must receive the information directly to their own email address instead of yours, you or the agent may contact Starry directly at privacy@253000xa.com.
No Retaliation or Discrimination
The Company will not discriminate or retaliate against you for exercising any of your rights under applicable federal or state law.
How We Protect Your Information
We use technical, administrative, and physical safeguards to protect against unauthorized access to, use of, or disclosure of the information that we collect and store. But no security program is 100 percent secure. As a result, we cannot guarantee that we will prevent every unauthorized attempt to access, use, or disclose information.
We Conduct an Annual Review of our Policies and May Change this Policy
We conduct a data protection assessment and review our policies on an annual basis, and subsequently throughout the calendar year as needed, to determine whether updates are necessary, or to reflect any changes in circumstances and to comply with applicable regulations. We also conduct annual employee training to familiarize employees with our privacy and data security policies.
We may change our information collection practices over time. To the extent that our practices materially change, the Policy that was in place at the time that you submitted personal information will generally govern. In addition, this Policy may be updated to notify you of additional purposes for which we process your personal information.
Questions?
If you have any questions about this Policy, or if you need to access this Policy in an alternative format due to having a disability, please email legal@253000xa.com or send a letter to us at the following address:
Attn: Legal Department
38 Chauncy Street, 5th Floor
Boston, MA 02111