California Consumer Privacy Act
Privacy Notice for Employees, Prospective Candidates and Other Personnel (California Residents)
Effective Date: January 1, 2023
This Notice is being provided to you in satisfaction of certain of Sixth Street’s obligations under the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act of 2020 (“CPRA”). Sixth Street respects your privacy. This Privacy Notice describes the types of Personal Information we collect about California residents who are Sixth Street (1) employees or prospective employees, owners, directors, officers, contractors, advisers, servicers, or consultants (collectively, “Sixth Street Personnel”), (2) emergency contacts of Sixth Street Personnel, and (3) individuals related to Sixth Street Personnel for whom Sixth Street administers benefits (collectively with Sixth Street Personnel and emergency contacts, “Covered Individuals”).
Sixth Street is responsible for providing this Privacy Notice to any Covered Individual whose Personal Information is provided to Sixth Street by Sixth Street Personnel. Certain terms used in this Notice have the meaning given to them in California Civil Code § 1798.100 et seq., as amended. This Notice is reviewed annually and may be updated from time to time.
Information We Collect And How We Use The Information
Over the course of your relationship with us, including during your job application process, at the beginning of your employment and during the course of your employment with us, it is routine for us to collect, process and store Personal Information and Sensitive Personal Information about you. Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Sensitive Personal Information means Personal Information that reveals your social security, driver’s license, state identification card, or passport number; your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to your account; your precise geolocation; your racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of your mail, email, and text messages unless we are the intended recipient of the communication; your genetic data; the processing of your biometric information for the purpose of uniquely identifying you; and Personal Information collected that analyzes your health, sex life or sexual orientation. Personal Information and Sensitive Personal Information do not include aggregate information nor any publicly available information as defined under the CPRA.
In the past twelve (12) months and going forward, we may collect and/or process the following categories of Personal Information and Sensitive Personal Information from you for the following purposes and to the following persons:
|CATEGORIES OF PERSONAL INFORMATION AND SENSITIVE PERSONAL INFORMATION OBTAINED||BUSINESS OR COMMERCIAL PURPOSE(S) FOR PROCESSING||CATEGORIES OF THIRD PARTIES TO WHOM YOUR PERSONAL INFORMATION OR SENSITIVE PERSONAL INFORMATION MAY BE DISCLOSED|
|Identifiers and other contact information, including your name, work and personal contact details (including postal addresses, phone numbers, fax numbers and email addresses), and emergency contact information|
|Sensitive Personal Information and other characteristics of protected classifications under California law, including age, date of birth, race, gender, sex, ethnicity, nationality, place of birth, citizenship status, disability, military and veteran status, marital status, and dependent information|
|Sensitive Personal Information for identification, including Social Security number, driver’s license or state identification card number, passport number and country of issuance, employee ID number, account name, CCTV footage, and photograph|
|Professional or employment-related information relating to compensation, benefits and payroll information, including bank account details, salary-related information, tax-related information, benefits elections, health insurance information, insurance policy number, details regarding leaves of absence, and injuries or other medical issues|
|Professional or employment-related information relating to your position, including job title, job description, training, performance management information (e.g., evaluations, offer letter), information regarding immigration status and eligibility for work, office location, and general location data regarding corporate travel destinations|
|Professional, employment-related and talent management information, including resume information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, and information received in connection with background checks and references|
|Internet or other electronic network activity, including your use of Sixth Street’s IT resources, assigned equipment, IP address, user ID, online identifiers, the time and duration of internet and network connections and how you use technology resources, including emails you send/receive, websites browsing history, internet search history, software and files you download and voicemails you receive|
Further Detail About Our Uses Of Personal Information and Sensitive Personal Information
As indicated in the table above, we may use Personal Information and Sensitive Personal Information in at least five different ways, depending on the category of Personal Information or Sensitive Personal Information involved. We have provided further detail regarding each of these five uses below:
- Managing our workforce: managing work activities and personnel generally, including recruiting; performing background checks; determining suitability for employment or promotion; determining physical and/or mental fitness for work; accommodating a disability or illness; reviewing and evaluating performance; determining eligibility for and processing salary increases, bonuses, and other incentive-based compensation; providing references; managing attendance, absences, leaves of absences, and vacations; administering payroll services; reimbursing expenses; administering health, dental, and other benefits; training and development; making travel arrangements; securing immigration status; monitoring staff; creating staff directories; investigating suspected misconduct or non-performance of duties; managing disciplinary matters, grievances, and terminations; reviewing staffing decisions; administering, organizing, and arranging participation in firm sponsored events or programs; and providing access to facilities.
- Operating our facilities and preparing for and responding to emergencies: ensuring business continuity; protecting the health and safety of our staff and others; safeguarding, monitoring, and maintaining our IT infrastructure, office equipment, facilities, and other property; detecting or preventing theft or fraud, or attempted theft or fraud; and facilitating communication with you and your designated contacts in an emergency.
- Conducting business operations: operating and managing our IT, communications systems and facilities, and monitoring the use of these resources; performing data analytics; improving our services; allocating and managing company assets and human resources; making insurance claims; strategic planning; project management; compiling audit trails and other reporting tools; maintaining records relating to business activities, budgeting, and financial management; and managing mergers, acquisitions, sales, reorganizations or disposals and integration with purchasers or sellers.
- Satisfying legal and compliance obligations: complying with legal requirements, such as tax, record-keeping and reporting obligations; conducting audits, management and resolution of health and safety matters; complying with requests from government or other public authorities; responding to legal process such as subpoenas and court orders; pursuing legal rights and remedies; defending litigation and managing internal complaints or claims; conducting investigations; and complying with internal policies and procedures.
- Detecting, investigating, and preventing activities that may violate our policies or be fraudulent or illegal: preventing, detecting and investigating security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, remediating such activity and prosecuting those responsible for that activity.
Further Detail About How We May Disclose Your Personal Information and Sensitive Personal Information
We do not sell Personal Information or Sensitive Personal Information or share such information for purposes of cross-context behavioral advertising, and have not done so within the past twelve (12) months. Further, to the extent we have any Personal Information related to your minor children, we have no actual knowledge that we “sell” or “share” the Personal Information of individuals under the age of sixteen (16).
In addition to the purposes indicated in the table above, we may disclose Personal Information or Sensitive Personal Information about you (a) if we are required or permitted to do so by law or legal process, for example, for the exercise of legal proceedings, a request from a law enforcement agency or if we believe in good faith that such disclosure is necessary to comply with a legal obligation or request or to enforce our terms and conditions, (b) when we believe disclosure is necessary or appropriate to protect the rights, property or safety of Sixth Street, our clients, a third party, or the public, (c) in conjunction with (i) the making, management, or disposition of any of our investments or (ii) business continuity, or (d) to a third party that acquires, or is interested in acquiring, all or part of our business in connection with a corporate sale, merger, reorganization, dissolution or similar event. We may also disclose Personal Information or Sensitive Personal Information about you in other circumstances where we have your consent.
From What Sources Do We Collect Your Personal Information or Sensitive Personal Information
In the past twelve (12) months and going forward, we may collect Personal Information or Sensitive Personal Information from the following sources:
- As provided by you, whether directly or indirectly, including via your devices;
- Your prior employer and/or references;
- Third-Party Service Providers, including recruiting agencies, background check providers, information technology consultants, etc.; or
- Other publicly accessible sources
How Long We Retain Your Personal Information or Sensitive Personal Information
The time period for which we keep Personal Information or Sensitive Personal Information depends on the type of information or the purposes for which we collected it as set out in this Privacy Notice. In all cases we keep it for as long as necessary and proportionate to fulfill those purposes, or for as long as we are required to do so for backups, archiving, and prevention of fraud and abuse.
How We Protect Your Information
We implement and maintain reasonable security appropriate to the nature of the Personal Information and Sensitive Personal Information that we collect, use, retain, transfer or otherwise process, including encrypting Personal Information and Sensitive Personal Information in transit and at rest. While we are committed to developing, implementing, maintaining, monitoring and updating a reasonable information security program, all risk cannot reasonably be eliminated. Data security incidents and breaches can occur due to vulnerabilities, criminal exploits or other factors that cannot reasonably be prevented. Accordingly, while our information security program is reasonably designed to manage data security risks and thus help prevent data security incidents and breaches, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security.
Your California Privacy Rights
As a California resident, you have the right to:
- Know what Personal Information we collect about you, including the categories of Personal Information collected, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about you (“Right to Know”);
- Request deletion of your Personal Information that we have collected or maintained, subject to certain exceptions (“Right to Request Deletion”);
- Request that we correct inaccurate Personal Information that we maintain about you (“Right to Correct”);
- If we are determined to sell or share your Personal Information, to opt-out of the sale or sharing of your Personal Information (the “Right to Opt-Out”);
- If we use or disclose your Sensitive Personal Information for reasons other than those permitted under the CPRA, to direct us to limit the use or disclosure of your Sensitive Personal Information by us (“Right to Limit Use of Sensitive Personal Information”); and
- Not receive discriminatory treatment by us for the exercise of your privacy rights conferred by the CPRA, including your right not to be retaliated against for the exercise of these rights (“Right to be Free from Discrimination and Retaliation”).
Exercising Your Privacy Rights
Method to Submit Your Requests. If you wish to exercise any of the rights listed above or if you consider that we have processed your Personal Information or Sensitive Personal Information in violation of applicable law, please email us at SixthStreetPrivacy@sixthstreet.com or call us at 888-306-1447. You can also submit requests online using the following link: https://sixthstreet.com/privacy-policy/.
Verification Procedures. To verify your identity and respond to your requests, we will ask you for at least two pieces of Personal Information and, for requests for specific pieces of Personal Information, we will ask you for at least three pieces of Personal Information. The information we require may vary depending on your relationship to us, and may include your full legal name, residential address, email, phone, as well information we may have on file about you or other information that may be necessary to verify your identity. If you are requesting on behalf of another individual, such as a member of your household, we may request additional information from you and/or such individual to verify their identity. If you are legally entitled to such rights, you may designate an agent to submit a request on your behalf. The agent can be a natural person or a business entity that is registered with the California Secretary of State. If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our agent verification process, including by providing written authorization signed by you directing the agent to act on your behalf.
How To Contact Us
If you have any questions regarding this Privacy Notice or our privacy practices, please email us at SixthStreetPrivacy@sixthstreet.com or call us at 888-306-1447.