Privacy Policy for California Applicants

For California applicants: This policy explains how we collect, source, use, disclose, and retain the following types of Personal Information about you. This policy also explains your rights under California regulation and how to exercise those rights.

Types of Information Collected

  1. Personal Identifiers
    1. Examples: Name, alias, postal or mailing address, email address, telephone number, social security number, driver’s license or state identification card number, passport number, and signature
  2. Pre-Hire Information
    1. Examples: Job application, resume, job interview notes, and candidate evaluation records, work experience and previous employers, professional memberships, personality or cognitive characteristics from potential assessments
    2. Post Offer: Background check results, drug screening results (Separate required disclosures for any background screening will be provided)
  3. Education Information
    1. Examples: Transcripts or records of degrees and vocational certifications obtained
  4. Characteristics of Protected Classifications Under California or Federal Law for Applicants
    1. Examples: Collected on a purely voluntary basis, except where collection is required by law, and used only in compliance with applicable laws and regulations, for diversity and inclusion reporting and related purposes.
    2. Company does not collect or process sensitive personal information or characteristics of protected classifications for the purpose of inferring characteristics about the Applicant.

Collection (Sources) of Personal Information

  1. You
    1. Examples: Job application, resumes, assessments completed, any other information you provide during the application process
  2. Vendors or Service Providers
    1. Examples: Online recruiting platforms, recruiters
  3. Third Party Sources
    1. Examples: References
  4. Public Records
    1. Examples: Court records, law enforcement, certifying and licensing organizations
  5. Automated Technologies
    1. Examples: Company’s website may track logins and activity to include the Careers page
  6. Acquired Companies
    1. Examples: If your employer is acquired by our Company, we may collect personal information from that employer

Business Purpose

  1. To communicate with Applicants
  2. To comply with state and federal law and regulations requiring employers to maintain certain records
  3. To evaluate your job application and candidacy for employment
  4. To obtain and verify background check and references
  5. To demonstrate Applicant acceptance of documents present to include acknowledgements, offer letter, or other required documentation
  6. To monitor compliance with Company policies and procedures
  7. To exercise Company’s rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel
  8. For training purposes especially as it may relate to improving or assisting our recruiting and hiring process
  9. Company collects information about race, age, national origin, disability, sex, and veteran status as necessary to comply with legal obligations, including the reporting requirements of the federal Equal Employment Opportunity Act, and California’s Fair Employment and Housing Act, and for purposes of diversity analytics.

Disclosure of Personal Information

We do not sell or share any personal information such as for external behavioral advertising. In most circumstances, all personal information is held confidential with the following exceptions:

  • Government or administrative agencies, such as federal or state agencies who may request information about you.
  • Legally required disclosure such as court order, subpoena, civil discovery request, other legal process, or as otherwise required by law as well as legal compliance or protection when disclosure is necessary to comply with the law or to protect the rights, property, or safety of Company, our users, or others. This includes law enforcement agencies in the event of criminal investigations.
  • Service providers or contractors as well as affiliated companies
  • Corporate transactions such as a corporate merger, consolidation, bankruptcy, the sale of all, or substantially all, of our membership interests and/or assets or other corporate change, including to any prospective purchasers.

Retention of Personal Information

If Company hires you, the information collected about you during the job application process may become part of your personnel file and may be used to administer the employment relationship and for related reporting and recordkeeping purposes. Company will retain this application information for the entire duration of your employment relationship with Company and for as long thereafter as permitted or required by applicable law.

Company will retain information of applicants who are not hired for 5 years after the record is collected.

Privacy Rights of Individuals

  • The right to know about the personal information a business collects about them and how it is used and shared;
  • The right to delete personal information collected from them (with some exceptions);
  • The right to opt-out of the sale or sharing of their personal information;
  • The right to non-discrimination for exercising their CCPA rights.
  • The right to correct inaccurate personal information that a business has about them;
  • The right to limit the use and disclosure of sensitive personal information collected about them.
  • Ways to exercise these rights:
    • Submit a request to
    • Submit a request to:
      Aperture Hotels
      c/o Banyan Tree Management, LLC
      3344 Peachtree Rd NE Suite 800
      Atlanta, GA 30326
      ATTN: Human Resources

Our company will not unlawfully discriminate or retaliate against you for exercising your privacy rights under the California Privacy Rights Act.

If you become employed by the Company, the Company will notify you of additional categories of Personal Information that it collects, receives, and maintains for business purposes.

For our full privacy policy, please visit: