Effective Date: [Month Day, Year] 

Green SM USA Inc. ("Green SM," "GSM," "we," "our," or "us") respects your privacy and is committed to protecting your personal information. This Applicant Privacy Notice ("Notice") explains how we collect, use, disclose, retain, and protect personal information relating to job applicants, including applicants for driver positions, in accordance with the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and other applicable California privacy laws. 

This Notice applies to all individuals who apply for employment or engagement with Green SM USA Inc., including through our online driver application/registration portal. 

 

1. Personal Information We Collect 

Depending on the recruitment process and the position you apply for, we may collect the following categories of personal information about you: 

• Identifiers: full name, home address, email address, telephone number, date of birth, driver's license number, Social Security number or other government-issued identification number (where permitted by law), and IP address. 

• Professional or employment-related information: employment history, prior job titles, qualifications, professional references, certifications, licenses, and driving experience. 

• Education information: schools attended, degrees, and certifications relevant to the role. 

• Application materials: resume, CV, cover letter, and any documents or answers you submit through our application form. 

• Interview and assessment records: notes, evaluations, and scores from interviews, driving tests, or other recruitment assessments. 

• Driver eligibility information: Motor Vehicle Record (MVR) and driving history, where permitted by law and relevant to the driver role. 

• Background check information: criminal history and other background screening results, obtained only where authorized by you and permitted by applicable law. Criminal history is only collected after a conditional offer of employment is made. 

• Drug and alcohol screening results: where required or permitted by law and applicable to the position. Drug screening complies with California laws regarding off-duty cannabis use. 

• Sensitive personal information: such as government-issued ID numbers, precise geolocation collected through the application (if applicable), or driver's license details. We collect and use sensitive personal information only as reasonably necessary to evaluate your application and verify your eligibility to drive, and not to infer characteristics about you. 

• Biometric information: Facial templates and photographs used for identity verification and shift access. 

• Technical/online information: IP address, browser type, device identifiers, cookies, and similar data collected automatically when you use our recruitment website or application portal. 

• Any other information you voluntarily provide during the recruitment process, including responses to optional demographic questions (if any), which are always collected on a voluntary, opt-in basis. 

We do not knowingly collect personal information from individuals under the legal working age. 

  

2. Sources of Personal Information 

 We may collect the personal information described above from the following sources: 

• Directly from you: through your online application, registration form, or communications with us. 

• Through the recruitment process: during interviews, phone screens, or in-person assessments. 

• Recruiters or staffing agencies working on our behalf. 

• Publicly available sources: such as professional networking profiles you make available. 

• References you provide to us. 

• Background and drug screening providers engaged to conduct checks you have authorized. 

• Criminal history is only collected after a conditional offer of employment is made. 

• Government agencies and departments of motor vehicles, where legally permitted, to verify licensing and driving eligibility. 

• Service providers that support our recruitment technology, hosting, and application processing. 

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3. How We Use Your Personal Information 

We use your personal information for the following business purposes: 

• Reviewing, processing, and assessing your application and eligibility for the position; 

• Verifying your identity, qualifications, licenses, and certifications; 

• Contacting you regarding your application and scheduling interviews; 

• Conducting background checks and drug screening where applicable and authorized; drug screening complies with California laws regarding off-duty cannabis use; 

• Verifying your driving eligibility (license, MVR) for driver roles; 

• Complying with applicable federal, state, and local legal obligations (e.g., labor, tax, and transportation regulations); 

• Detecting, preventing, and investigating fraud, security incidents, or unlawful activity; 

• Maintaining recruitment and employment eligibility records as required by law; 

• Improving and administering our recruitment process and application platform. 

We do not use sensitive personal information to infer characteristics about applicants, and we do not use your personal information for automated decision-making that produces legal or similarly significant effects without appropriate safeguards. 

If you separately and affirmatively opt in, we may also use your contact information to send you future recruitment opportunities or marketing communications. You may withdraw this consent at any time by contacting us using the information in Section 7. 

 

4. Disclosure of Personal Information 

We may disclose the categories of personal information described in Section 1 to the following categories of third parties, solely to support the purposes described in Section 3: 

• Recruitment and staffing service providers; 

• Background screening providers; 

• Drug and alcohol testing providers; 

• Driver qualification and licensing verification providers; 

• IT, hosting, and cloud service providers; 

• Green SM affiliated companies, for shared recruitment administration; 

• Government authorities and regulators, where required by law; 

• Professional advisors (e.g., legal, audit), where necessary to protect our legal interests. 

All third parties who receive personal information from us are required to protect it consistent with this Notice and applicable law, and are restricted from using it for purposes unrelated to the services they provide to us. 

We do not sell applicants' personal information. We do not share applicants' personal information for cross-context behavioral advertising. 

 

5. Retention of Personal Information 

We retain applicant personal information only for as long as reasonably necessary to: 

• Complete and administer the recruitment process for the position applied for; 

• Meet legal, regulatory, tax, accounting, or recordkeeping obligations (including transportation and driver-eligibility recordkeeping requirements); 

• Resolve disputes or respond to legal claims; 

• Enforce our agreements; or 

• Protect Green SM's legal interests. 

Retention periods vary depending on the type of information, whether your application is successful, and applicable legal requirements. If you are not hired, we retain application records for at least 4 years to comply with California Government Code § 12946. After this period, the information is securely deleted or de-identified, unless a longer period is required by law. 

  

6. Your California Privacy Rights 

Subject to certain exceptions under applicable law, California residents have the right to: 

• Know what personal information we have collected, used, disclosed, and the sources and purposes of that collection; 

• Access a copy of the specific pieces of personal information we hold about you; 

• Correct inaccurate personal information we maintain about you; 

• Delete personal information we have collected from you, subject to certain legal exceptions (e.g., completing the recruitment process, legal recordkeeping); 

• Limit the use and disclosure of sensitive personal information to what is necessary to perform the services reasonably expected by an average applicant; 

• Know about disclosures of your personal information to third parties; 

• Not be discriminated against for exercising any of these privacy rights; and 

• Appeal a decision we make in response to your privacy request, as described below. 

Because we do not sell personal information or share it for cross-context behavioral advertising, there is no applicable opt-out right for those activities. Certain rights may be limited by exceptions under the CCPA/CPRA or other applicable law (for example, information needed to complete the hiring process or comply with a legal obligation). 

  

7. How to Exercise Your Rights 

To submit a privacy request (to know, access, correct, delete, or limit the use of sensitive personal information), please contact us: 

• Email: privacy@greensm.com  

• Mail:  

• Green SM USA Inc. 

• 9881 Irvine Center Drive 

• Irvine, CA 92618 

  

We will verify your identity before responding to your request, which may require you to provide additional information matching what we have on file. You may also designate an authorized agent to submit a request on your behalf, subject to our ability to verify the agent's authority and your identity. 

If you disagree with our response to your request, you may appeal by replying to our decision notice or contacting us at the email above within [30] days. We will respond to your appeal within the time required by California law. 

We will not discriminate against you for exercising any of these rights. 

  

8. Security 

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction, appropriate to the sensitivity of the information collected. These measures include access controls, encryption where appropriate, and restricting personal information access to personnel and service providers who need it to perform recruitment-related functions. No security measures are completely infallible, and we cannot guarantee absolute security. 

  

9. Changes to this Notice 

We may update this Applicant Privacy Notice from time to time to reflect changes in our practices or applicable law. The revised version will be posted on this page with an updated Effective Date. We encourage you to review this Notice periodically. 

  

10. Contact Us 

If you have questions or concerns regarding this Notice or our privacy practices, please contact us at: 

Green SM USA Inc.  

Email: privacy@greensm.com  

Address: 9881 Irvine Center Drive, Irvine, CA 92618