Introduction & Policy Statement

Alta Resources prioritizes the protection of your privacy. We aim to transparently communicate the methods by which we collect, utilize, and disclose your personal information. Please be aware that Alta Resources retains the authority to amend, adjust, or update this Privacy Policy periodically. Any revisions will be communicated by publishing an updated version on our websites, accompanied by a modification of the “Effective Date” at the header of this Policy. In the event of significant changes, we will directly notify you. To stay informed about any modifications, we advise you to regularly review this Policy.

This Privacy Policy provides a comprehensive understanding of our data practices by elucidating the following key points: the specific categories of personal information collected, the diverse sources from which this information is obtained, the purposes guiding the utilization of your personal data, potential disclosure mechanisms, the duration for which your information is retained, an overview of your privacy rights along with guidance on their exercise, and the procedures governing any alterations to this Privacy Policy

The Categories of Personal Information We Collect

Employees

Personal Information Collection – Throughout the recruitment process, we gather information from you in relation to your application. The data we collect encompasses:

• Personal details: Name, address, telephone number, email address, and additional contact information.
• Information provided in resumes, CVs, and letters, including but not limited to employment history, academic qualifications, professional qualifications, and skills.
• Employment history at Alta, including the employee ID if applicable.
• Additional relevant details such as employment preferences, willingness to relocate, current salary, desired salary, awards or professional memberships, professional licenses, permits, certifications, and any other work-related credentials.
• Data generated by interviewers and recruiters based on interactions with you, whether through recruitment events, campus hiring events, or basic Internet searches.
• Information supplied by third-party recruiters, staffing companies, or executive search agencies, where applicable.
• Recommendations provided on your behalf by others.
• Documentation required under immigration laws, including but not limited to personal information described under Cal. Civ. Code § 1798.80, such as a bank account number for direct deposit purposes or an insurance policy number.
• Sensitive identifiers, including Social Security, driver’s license, state identification card, or passport numbers.
• Religion, if voluntarily shared by an employee in support of a request for religious accommodation.

We may acquire information about you directly from you or from various sources, always ensuring it is permissible and in accordance with applicable law. This information may be gathered:

• Directly from you or through your use of the website (altaresources.com)
• From referrers, referees, and former employers.
• Through conversations with recruiters and other Alta associates or representatives, including data obtained from internet searches and professional networking websites (such as LinkedIn) where you have publicly shared information about yourself.
• Via third-party recruiters, staffing companies, or executive search agencies contracted by Alta.
• Through background checks, where applicable. If permitted by law, we may engage a third party to conduct pre-employment background screenings. You will be provided with detailed information about the nature of such checks before they commence, and no checks will be initiated without your express prior consent, if required by applicable law. This comprehensive approach ensures transparency and compliance throughout the information-gathering process.

Who Will Have Access to Your Information

Typically, access to your Personal Information within Alta is limited to individuals who require it for the outlined purposes in this Privacy Notice. This includes individuals such as your potential future managers, direct colleagues, as well as personnel involved in recruitment, HR, and IT.

Alta Resources does not engage in the sale of your Personal Information, nor do we share it with third parties for cross-context behavioral advertising. However, your Personal Information may be disclosed in compliance with applicable laws and requirements, as outlined below:

California: Alta discloses your personal information and/or sensitive personal information only to the minimum extent necessary to achieve the purpose of the disclosure and only if the disclosure is permitted by the California Privacy Rights Act (“CPRA”) and other applicable laws.

In addition, any supplementary third-party providers rendering employee benefits shall procure access to personal information solely upon the express consent and authorization of the employee in question.

Third Party Service Providers

Alta discloses your personal information to service providers and contractors only subject to written contracts in compliance with the CPRA and any other applicable law.

Hireright (US): Alta Resources uses Hireright to perform employee background checks in the United States locations. HireRight is a leading global provider of on-demand employment background checks, drug testing, Form I-9 and employment and education verifications.

100 Centerview Drive, Suite 300

Nashville, TN 37214

United States

Phone: (866) 521-6995

Ceridian (Global): Alta Resources securely stores employee data using Dayforce, Inc., previously known as Ceridian. Dayforce, Inc. is a reputable provider of human resources software and services, serving a diverse workforce spread across the United States, Canada, Europe, the Middle East, Africa (EMEA), and the Asia Pacific Japan (APJ) region. Dayforce, Inc.
3311 East Old Shakopee Road 
Minneapolis, MN 55425-1640
Phone: (952) 853 – 8100

In Addition:

Government or Administrative Agencies:

This may encompass, for instance:

• Internal Revenue Service for tax payment purposes.

•Employment Development Department, as necessary for state payroll taxes and in response to unemployment or state disability insurance claims.

• OSHA/CalOSHA for reporting work-related death or serious injury or illness.

• Department of Fair Employment and Housing to address employment charges.

• California Department of Industrial Relations for the resolution of workers’ compensation claims.

Public Disclosure: Alta may divulge your personal information to the public in scenarios such as press releases, where, for example, promotions or awards are announced. If you prefer not to have your personal information included in press releases, please contact the HR Department. It’s important to note that Alta refrains from disclosing sensitive personal information to the public.

Legal Obligations:

Your Personal Information may be disclosed in accordance with our legal obligations, including instances where it is necessary to comply with the law, regulations, contractual obligations, or respond to a court order, administrative or judicial process, such as a subpoena, government audit, or search warrant.

Public Bodies and Authorities:

We may disclose your Personal Information upon request from a governmental or regulatory entity or body, or when we have a good faith belief that such disclosure is essential to (1) comply with legal or regulatory requirements or fulfill legal processes; (2) prevent crime; (3) avert any terrorist activity or threat to national security; (4) safeguard the personal safety or well-being of Site users or any other individual.

Legal Proceedings:

Alta Resources reserves the right to disclose your Personal Information to the extent permitted by applicable law when it is necessary to establish, exercise, or defend against potential, threatened, or actual legal claims.

Vital Interests:

We may also disclose your Personal Information when deemed necessary to protect your vital interests or the vital interests of another person.

How Long We Keep Your Personal Information

Alta retains your personal information only for the duration necessary for the purpose for which it was collected, aligning with our record retention schedule. We will keep your personal data, in a format that allows us to identify you, no longer than required for the specific processing purpose. Storage beyond this period is solely for compliance with legal obligations, resolution of disputes, enforcement of agreements and rights, or when it is not technically and reasonably feasible to remove it. In cases where applicable, we endeavor to delete your personal data promptly upon request, within a reasonable timeframe.

Protecting Your Data

In the context of safeguarding your Personal Information, Alta Resources implements robust security measures to prevent unlawful or unauthorized processing, as well as accidental loss or damage to the data. These measures are designed to maintain the confidentiality, integrity, availability, and overall security of your Personal Information.

Alta has established written security management policies and procedures, which serve to prevent, detect, contain, and correct any breaches or violations of the protective measures in place. These policies and procedures allocate specific data security responsibilities and accountabilities to designated individuals. Furthermore, they incorporate a risk management program that includes regular risk assessments, providing a comprehensive framework of controls to ensure the safeguarding of your Personal Information.

When engaging third-party service providers who may access your Personal Information, Alta insists on contractual agreements that mandate similar security controls. This ensures that the third parties adhere to stringent security measures consistent with Alta’s commitment to protecting your information.

The Purposes for Which We Use Your Information

Alta Resources will process your Personal Information, including Sensitive Personal Information where permitted, for our business purposes, specifically focusing on recruitment, management, and planning activities. This encompasses:

• Assessment of Suitability: We evaluate your suitability not only for the immediate role you are applying for but also consider your potential fit for future positions that may become available within our organization.
• Application Management: Efficient management and administration of your application are crucial for a smooth and seamless recruitment process.
• Communication Facilitation: We use your information to facilitate effective communication, promptly addressing any queries or concerns you may have during the application process.
• Eligibility Verification: Verifying your eligibility to work is a standard part of our process, ensuring compliance with relevant regulations.
• Data Analytics: Conducting data analytics, including an examination of our candidate pool, helps us refine and improve our recruitment processes over time.
• Opportunity Notification: If you have opted to receive notifications, we may inform you about relevant opportunities within our organization.
• Legal Compliance: Processing your Personal Information is also necessary to comply with applicable laws and monitor our adherence to regulatory requirements.

Alta will process Personal Information when required by law, deemed necessary for the potential employment contract, or when there is a legitimate interest that is not outweighed by your data protection interests or fundamental rights and freedoms. We take into careful consideration the safeguards in place to protect your privacy.

Sensitive Personal Information will be processed by Alta when necessary to fulfill a legal obligation or to exercise specific rights, either yours or those of Alta Resources, concerning your prospective employment.

In cases where local law mandates or for new or additional purposes, Alta will seek your consent to process your Personal Information. For instance, obtaining your prior consent may be required under applicable law for specific types of processing related to Sensitive Personal Information or Personal Information concerning criminal offenses and convictions. This approach ensures that your privacy rights are respected and upheld throughout the processing of your information.

Legal Reason for Use

To assess your suitability for employment for the role for which you are applying (excluding background checks), as well as future roles that may become available, Alta Resources conducts necessary background checks. This process is essential for Alta’s legitimate interests to ensure that it recruits the appropriate employees. Additionally, it involves taking steps prior to entering an employment contract with you, particularly when you are being considered for employment. Verifying eligibility to work involves actions before entering into an employment contract, aligning with Alta’s legitimate interests in adherence to relevant immigration and/or employment laws and regulations. Managing and administrating your application, as well as facilitating communication, are necessary steps for Alta to secure suitable employees. Effective communication within the organization and with you is also crucial for maintaining an efficient recruitment process. Compliance with or monitoring applicable laws and regulations is essential for fulfilling Alta’s legal obligations as a business entity and safeguarding the rights and interests of Alta, its employees, candidates, and others.

Alta processes employees’ health information to fulfill its legal obligations, which include accommodating disabilities, conducting direct threat analyses, managing workers’ compensation, undertaking occupational health surveillance, ensuring compliance with health and safety regulations, conducting fitness-for-duty examinations, administering leaves of absence and sick time, facilitating wellness programs, and responding to medical emergencies. This Privacy Policy excludes health information governed by specific healthcare privacy laws, such as the Health Insurance Portability and Accountability Act (HIPAA), the Health Information Technology for Economic and Clinical Health Act (HITECH Act), or California’s Confidentiality of Medical Information Act (CMIA).

Regarding the use of employees’ protected categories of information, Alta gathers data concerning race, age, national origin, disability, sex, and veteran status to meet legal obligations, including reporting requirements under the Federal Equal Employment Opportunity Act, the Federal Office of Contracting Compliance Programs for government contractors, and California’s Fair Employment and Housing Act. Disability status information ensures that employees receive necessary assistance during emergencies. For diversity and inclusion programs, characteristics such as age, sex, race, disability, and veteran status are collected and used for analytics. The collection of military and veteran status information aids compliance with leave requirements and tax purposes. Other characteristics, such as age, religion, pregnancy, childbirth, breastfeeding, marital status, familial status, and protected classifications, are collected for specific purposes including birthday celebrations, identity verification, accommodations under applicable law, I-9 documentation, and Alta events. Alta emphasizes the voluntary nature of collecting personal information about membership in protected categories, except where mandated by law, and ensures its use strictly complies with applicable laws and regulations.

Your Privacy Rights and How to Exercise Them

Your California Privacy Rights (CPRA)

Subject to applicable law, Employees have the following rights:

Right to Know: You have the right to submit a verifiable request for copies of specific pieces of your personal

information collected in the preceding 12 months or at your option since January 1, 2022. Please note that the CPRA’s right to obtain copies does not grant a right to the whole of any document that contains personal

information, but only to copies of “specific pieces” of personal information. There may be some specific

information about you that we are not permitted by law to provide to you because of legal restrictions or because the information is used for security purposes, such as information collected in an internal investigation. You may make these requests up to twice in a 12-month period. Moreover, Employees have a right to know categories of information collected, the sources of personal information, our purpose for collecting and using personal information, and categories of external recipients to which personal information is disclosed, but not the individual sources or recipients. This information is provided above. Alta does not always track individualized sources or recipients.

Right to Delete: You have the right to submit a verifiable request for the deletion of personal information that you have provided to Alta. Certain information that we hold about you may not be deleted. We are not permitted to delete information that we need in order to operate our business, administer our employees, protect our legal obligations and rights, or to provide security for our employees, our systems and our Alta.

Right to Correct: You have the right to submit a verifiable request for the correction of inaccurate personal

information maintained by Alta, taking into account the nature of the personal information and the purposes of processing the personal information.

Right to Opt Out of Sale and Sharing: You have the right to opt out of the sale of your personal information and the disclosure of your personal information for cross-context advertising. As noted above, Alta does not sell personal information or disclose personal information for cross-context advertising.

Right to Limit Processing of Sensitive Personal Information: You have the right to tell us not to process sensitive

personal information except for the purpose for which it was originally collected. Sensitive personal information includes the following categories of information described above: personal information, characteristics of protected classifications, sensitive identifiers, health information, biometrics, religion, sex life, sexual orientation, personal communications, financial account information, and log in credentials. We describe the purposes for which we collect this information above and we do not process this information for other purposes.

Alta is committed to not discriminating against you for exercising your rights. We diligently respond to all requests from individuals seeking to exercise their data protection rights, adhering to applicable data protection laws. It is important to note that Alta may deny or limit compliance with all or part of your request if doing so would violate another person’s rights or is otherwise permitted by applicable law.

Before addressing a request, we reserve the right to verify and authenticate your identity along with the relevant information connected to your request. In this process, Alta may request the following information: (a) First, Middle (if available), and Last Name; (b) Physical Address; (c) Month/Year of Birth; (d) Valid Email Address; and (e) Valid Telephone Number

How to Exercise Your Rights?

If, at any time, you have questions or concerns about the operation of this Notice or believe that we have not adhered to this Notice, please email us: [email protected]

FOR MORE INFORMATION

For questions or concerns about Alta’s privacy policies and practices, please mail: [email protected]

Changes to this Policy

Alta Resources reserves the right to amend this Notice, with changes taking effect immediately upon publication. Substantial modifications will be highlighted or communicated to you via email.