Applicant, Employee, and Contractor Privacy Policy

Last Updated: December 31, 2024

This Applicant, Employee, and Contractor Privacy Policy (“Policy”) describes the information collected by or on behalf of Hughes Marino, Inc. and its parent, affiliates, and subsidiaries (“Hughes Marino,” “we,” “us,” or “our”) from applicants, employees and contractors, and how the information is collected, used, and shared. When appropriate, we may provide additional notice at the point of collection with respect to any additional processing activities not mentioned in this document. If you have questions or concerns about this Policy, please contact us as set forth below.

Scope

This Privacy Policy only applies to Hughes Marino applicants, employees, and contractors. Provisions of this Privacy Notice dealing with individuals employed with Hughes Marino are not applicable until you begin working for us. If you are not an applicant, employee or contractor, please visit our general Privacy Policy.

Nothing in this Policy is intended to create an employment contract between you and Hughes Marino. We may change this Policy from time to time. All changes will be effective immediately upon posting. We will provide notice of any material changes.

IF YOU ARE A CALIFORNIA RESIDENT, PLEASE SEE THE CALIFORNIA RESIDENTS’ PRIVACY RIGHTS SECTION BELOW FOR ADDITIONAL TERMS THAT MAY APPLY TO YOU.

1. Information We Collect

We may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”) during the course of your employment. Although providing us Personal Information may be optional in some instances, certain Personal Information is required during the scope of your application process and employment or work for Hughes Marino. If we are not able to collect and use certain Personal Information, we may not be able to work with you.

Sources from Which We Collect Personal Information

Information You Provide to Us

We collect Personal Information that you provide directly to us. This may occur when you submit information through our HRIS system, through our communication channels and other platforms, and when you otherwise provide your information to us.

Job Applications. To submit job application materials online, you will be redirected from our Site to a website operated by our vendor. You may be required to create an account with that vendor. We encourage you to review the terms and privacy policy posted on that vendor’s website since this Policy does not govern your use of that website. If you send us your job application materials directly, we will only use and share those job application materials to evaluate your qualifications to work with us.

Data from Third-Party Sources

Examples of third-party sources include employment screening agencies, background check agencies, recruiting agencies, service providers, former employers and/or schools and educational institutions, publicly available information on websites or social media (e.g., when applying through LinkedIn, where relevant for recruitment purposes and allowed by applicable law), and others where they are legally allowed to disclose your Personal Information to us. We may combine that Personal Information with other data we may already have.

2. How We Use Your Information.

We use Personal Information that we collect for the following purposes:

To Manage the Application Process. We may use your Personal Information to process your job application, to verify the information you have provided in your application, to communicate with you regarding your application, to answer your questions regarding the application process and to confirm your eligibility for a position. We may also save your information for future job openings within Hughes Marino for a reasonable amount of time consistent with applicable state law and our document retention policies.
To Manage the Hiring Process. We may use your Personal Information in the hiring process to conduct interviews. We may also use your Personal Information to perform background and reference checks, with your consent, if you are offered a position.
Recruiting. We may use Personal Information to communicate with you regarding the recruiting process, to learn where you heard about Hughes Marino, and to evaluate and improve our recruiting process.
To Communicate with You. We may use your Personal Information to provide information to you, to respond to your questions, to notify you of changes to your compensation and benefits program or to notify you of emergencies.
To Manage the Onboarding Process. We will collect Personal Information when you complete new hire paperwork to assist us in administering salary and benefits and to assist us with complying with governmental and legal requirements.
To Administer Compensation and Benefits Programs. We will use the Personal Information you provide to process payroll, pay taxes, address employment related tax issues, administer benefits and handle work related expense reimbursement. We may also use this Personal Information to manage requests for accommodations requests. We also use this to administer employee claims such as under workers’ compensation or unemployment benefits.
To Manage the Internal Personnel Process. To manage all aspects of your relationship with us – including without limitation, payroll, compensation, corporate travel and reimbursable expenses, Key-man insurance, resource planning and allocation, and other general and human resource related processes.
For Performance Management. Hughes Marino collects Personal Information in order to assess your performance, assist in career development, conduct pay and grading reviews, and to handle any disciplinary actions. We may also use Personal Information to respond to violations of company policies. We use Personal Information for purposes of the internal performance improvement and disciplinary process and to respond to complaints.
Monitoring. We may monitor any activity you perform online while using a Hughes Marino device and activity while connected to our network may be tracked by Hughes Marino, such as monitoring the websites you visit and your activity on those websites. We may also track the emails you send using your Hughes Marino-provided email address, the phone calls and other communications you send and receive using a Hughes Marino-provided device, if applicable. We also collect information from your mobile application when you download the required mobile management software application on your personal device. For more information, please review the Employee Handbook and the Company-Provided Equipment Acknowledgement if you are an employee. If you are a contractor, please review the Independent Contractor Company-Provided Equipment & Personally Owned Equipment Agreement.
Education and Professional Services. We may use your Personal Information to assist with education, training, and professional and career development.
Law Enforcement and Courts. We may disclose your Personal Information in response to a subpoena, a search warrant or other legally valid process. We may use your Personal Information to cooperate with law enforcement or other government entities if you are suspected of having violated applicable laws.
To Respond to Legal and Regulatory Requests. We comply with lawful requests by public authorities (e.g., a court or government agency), including to meet taxation rules and other laws and regulations to which Hughes Marino is subject.
Record Keeping. We use Personal Information to comply with applicable legally required or industry standard business and employment record keeping requirements and to respond to governmental requests for information.
Health and Safety. We use Personal Information to protect your health and safety, or the health and safety of others. We may also use this information to respond to an emergency (e.g., if you become injured while performing services for Hughes Marino).
Protect Our Legal Rights. We may use your Personal Information to protect our legal rights, to defend a claim or lawsuit, and to investigate or prevent actual or suspected loss or harm to persons or property. We may use your Personal Information to seek legal, accounting, or other professional advice. When necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Hughes Marino or any other party.
Security. We may use your Personal Information to monitor the use of our information systems and electronic resources, to conduct internal audits and investigations and for safety and security of Hughes Marino employees, visitors and facilities. We also may use such information to protect Hughes Marino against illegal activity and misconduct such as fraud, deceptive practices and data security incidents. We use this to offer, operate, maintain, deliver, troubleshoot and update our programs, network and systems used by Hughes Marino in the course of its business.
To Terminate Our Relationship and Manage Post-employment or Post-contractual Relationship. We manage voluntary and involuntary exit of employees and contractors (including resignations, breaches of contract, termination of employment, retirement) and administer any termination and post-termination matters.

3. Retention of Personal Information

We will keep Personal Information for the period necessary to fulfill the purposes described in this Policy, unless a longer retention period is permitted or required by law.

4. Disclosure of Personal Information

We may share Personal Information with the following categories of parties, in compliance with applicable laws:

Employees and Affiliates. We may disclose Personal Information with our employees and affiliates who have a need to know the information for our business purposes, including evaluating applicants, resource planning, and talent and recruiting, human resources and business administration functions. All Hughes Marino employees who access or process applicant, employee, or contractor Personal Information are required to comply with Hughes Marino’s privacy and security policies.

Third Parties and/or Service Providers. We may disclose Personal Information with third parties and/or service providers that provide services for us. This includes those third parties that help us provide and administer our human resources and business functions, such as payroll, IT, insurance, and training providers. Any such third-party service providers may collect or access information about you only for the purposes of performing services specified in the applicable services contract with Hughes Marino, and we require these providers to undertake security measures to protect Personal Information.

Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Hughes Marino or any other party.

Professional Advisors. We may disclose Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to Hughes Marino.

Change in Ownership. In the event Hughes Marino is the subject of a change of control or in the event the Site changes ownership, in whole or in part, or in the event of a bankruptcy, receivership or a similar transaction, we may provide Personal Information to the subsequent owner(s).

Other. We may disclose Personal Information with third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

5. Use and Disclosure of Non-Personal Information

Hughes Marino may collect, use, disclose, transfer and otherwise process de-identified and anonymized information that it receives or creates for any purposes in its sole discretion, in compliance with applicable laws. Hughes Marino is the sole and exclusive owner of such de-identified and anonymized information, including if Hughes Marino de-identifies Personal Information so that it no longer considered Personal Information under applicable laws.

6. Access and Manage Personal Information

For employees, you may access, review, update and correct certain Personal Information you provide to us through the online tools available to you. You can access these tools through Hughes Marino’s HRIS System. We will require proper credentials for you to be able to access your Personal Information.

7. Data Security

We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.

You understand that no data transmission over the internet or device can be guaranteed to be 100% secure. While we strive to protect Personal Information, we do not guarantee the security of Personal Information and you provide Personal Information at your own risk.

CALIFORNIA RESIDENTS’ PRIVACY RIGHTS

This Section provides additional terms that apply to applicants, employees, or contractors that are residents of California. In the event of a conflict between this Section and the remainder of this Policy, this Section shall take precedence for California residents. In this Section only, any capitalized terms not defined in this Policy have the meanings set forth in the California Consumer Privacy Act of 2018, as amended, and including its implementing regulations (the “CCPA”).

The Collection, Source, Purpose and Sharing of Your Personal Information.

Categories of Personal Information. In the last twelve (12) months, we have collected the following categories of Personal Information:

Identifiers consisting of: real name, alias, postal address, internet protocol address (“IP Address”), email address, social security number, driver’s license number, or other similar identifiers
Protected Classifications consisting of: 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, genetic information (including familial genetic information)
Internet Activity consisting of: browsing history, search history, and information regarding an interaction with an internet website, application, or advertisement.
Professional and Employment Related Information consisting of: information regarding your employment history and previous work experience, licenses or certifications and information regarding military service. We also collect time and attendance information and information in support of eligibility for employment, as well as job title, position, office location, department, employment agreement, start and end date, attendance at work, working time records, absence records, holiday dates, sick leave, or any other absence, appraisals, performance reviews, disciplinary and grievance procedures, training needs and training received, career plans, reported wrongdoings, travel arrangements, travel expenditures for which you have filed expenses, hobbies, social preferences, and answers to feedback surveys.
Education Information: Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
Inferences drawn from information identified in this subdivision to create a profile about an individual reflecting the individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Sensitive Personal Information: social security number, driver’s license, state identification card, passport number, financial account password or credentials allowing access to an account; individual’s racial or ethnic origin, religious or philosophical beliefs, or union membership; or contents of an individual’s mail, email, and text messages unless the business is the intended recipient of the communication health information.

Categories of Sources from Which Personal Information is Collected. The categories of sources from which your Personal Information is collected is described in Section 1 (Information We Collect).

Purposes for Collecting Personal Information. Our purposes for collecting your Personal Information are described in Section 2 (How We Use Your Personal Information).

Categories of Third Parties / Service Providers with Whom Personal Information is Disclosed for a Business Purpose. In the last 12 months we disclosed the categories of Personal Information listed above for our business purposes. The categories of third parties and / or service providers with whom we disclose Personal Information in the last 12 months are described above in Section 3 (Disclosure of Personal Information).

In the past 12 months, we have not used or disclosed Sensitive Personal Information for any reason other than the reasons for which it may have been provided to us.

We Do Not Sell or Share Personal Information for a Commercial Purpose.

In the last 12 months, we have not Sold or Shared Personal Information of applicants, employees, or contractors for compensation or cross-contextual behavioral advertising and we currently do not Sell or Share Personal Information. You have the right to opt-out of the Sale or Sharing of your Personal Information.

We do not have any actual knowledge that we have sold or shared Personal Information of any individual under the age of 16 for monetary compensation or for cross-context behavioral advertising.

California Residents Data Rights.

California Residents have the right to make the following requests with regard to their personal information:

Right to request disclosure of categories. California Residents have a right to request access to the following information: (a) the categories of personal information we collected from you in the 12 month period prior to your request, (b) the categories of sources from which the personal information was collected, (c) the business or commercial purpose for collecting your personal information(d) the categories of third parties with whom we disclosed your personal information; and (e) the categories of personal information we disclosed in the 12 month period prior to who your request. California Residents also have a right to access a list of categories of personal information we sold or disclosed for a business purpose in the last 12 months, if any.
Right to request access. California Residents have a right to request that we disclose to you the specific pieces of Personal Information that we have collected about you in the 12-month period prior to your request and receive a copy of your electronic personal information in a readily usable format.
Right to correct inaccurate data. California Residents have a right to request the correction of personal information we collected about you.
Right to deletion. California Residents have a right to request that we delete personal information we collected from you. We will comply with such request, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.

How to Exercise Your Rights. To exercise your California rights described in this Section, you may submit your request to us by contacting us at any of the following:
1-833-389-0117
Privacy@hughesmarino.com
Submit Form: California Privacy Related Concerns

Verifiable Request. In order to verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request. This information may vary depending on the Personal Information we already have.

We will only use Personal Information we collect during the verification process for the purpose of verifying your identity. If you maintain an account with us, we may use that account to respond to your request and/or verify your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why.

Authorized Agents. You may only make a request to exercise your rights on behalf of yourself, or a parent or legal guardian may make a request on behalf of their minor child. You also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. If an authorized agent contacts us to exercise the above rights, we will need to verify their identity as well as your identity. We will also require proof of your written authorization to the agent to be your agent and to make the specific request submitted, unless the agent is subject to a Power of Attorney under California probate laws. If the agent is a Power of Attorney under California probate laws, we may require evidence of that status.

Right to Non-Discrimination. California residents have the right to not receive discriminatory treatment for exercising any of their rights under the CCPA.

California’s “Do-Not-Track” Requirement. We currently do not respond to “do not track” requests.

Contact Us

If you have questions or concerns regarding this Policy, contact us at:

For Employees or Contractors:
Hughes Marino Human Resources
Phone: 1-844-662-6635
Email: HR@hughesmarino.com
Address: Attn: Human Resources Department
1450 Front Street
San Diego, CA 92101

For Applicants:
Hughes Marino Privacy
Phone: 1-833-389-0117
Email: Privacy@HughesMarino.com
Address: Attn: Legal Department
1450 Front Street
San Diego, CA 92101

Applicant, Employee and Contractor Privacy Policy