Privacy Notice to California Applicants & Employees
Last updated: August 31, 2023
This Privacy Notice to California Applicants and Employees (“Notice”) is effective as of the date listed below, and supplements the information contained in other applicable policies and procedures of Safehold, Inc. (“Safehold,” “we,” or “us”). Safehold has adopted this Notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (together, “the CCPA”).
This Notice applies solely to prospective, current, and former job applicants, employees, and contractors of Safehold (each, as applicable, a “Role”) who are residents of California (each, an “Employee,” “You,” or “Your”). This Notice describes the collection, use, disclosure, and destruction of Your Personal Information by Safehold in connection with Your Role. This Notice also applies to Personal Information about other individuals that You provide to Safehold in connection with our administration of Your Role, such as Personal Information about Your emergency contacts or, if applicable, participants in, or beneficiaries of, Your employee benefits (collectively, “Related Individuals”).
1. INFORMATION SAFEHOLD COLLECTS
Safehold collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual person, including You or a Related Individual (defined as “Personal Information” in the CCPA). In particular, Safehold (or its service providers or agents) may collect from or about You or has collected from or about You the following categories of Personal Information within the last twelve (12) months:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
The above “Identifiers,” physical characteristics or description, birth date, gender, race, ethnicity, marital status, veteran status, citizenship status, telephone number, state identification card number, insurance policy number, education and employment, employment history, bank account number, credit card number, debit card number, or any other financial information, compensation information, medical information, or health insurance information. Personal Information also may include information about any spouse/domestic partner, children and other dependents, as well as emergency contacts and beneficiaries under Safehold’s benefit plans.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Health and wellness information.
Information about health and wellness, including information relating to participation in wellness programs.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Internet or other similar network activity.
Browsing history, search history, information on an applicant’s, employee’s, or visitor’s interaction with a website, application, or advertisement.
Physical location or movements.
Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information.
Current or past job history, performance evaluations, licenses, certifications, organization memberships.
Non-public education information (per the Family Educational Rights and Privacy Act).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student or professional disciplinary records.
Inferences drawn from other Personal Information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We also may collect “Sensitive Personal Information” which is defined as Personal Information that is not publicly available and reveals one or more of the following: Social Security, driver’s license, state identification card, or passport number; 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 an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, and any other status protected by applicable anti-discrimination laws, or union membership; the contents of mail, email, and text messages unless Safehold is the intended recipient of the communication; genetic or biometric data; or Personal Information collected and analyzed concerning health, sex life, or sexual orientation.
“Personal Information” does not include: publicly available information from government records; information that we have a reasonable basis to believe is lawfully made available to the general public by You or from widely distributed media; information made available by a person to whom You disclosed such information without restriction; de-identified or aggregated information; and information excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Safehold obtains Personal Information from the following categories of sources:
- directly from You or Your agents, such as from documents You provide to us related to Your application for employment or in connection with Your Role with Safehold;
- indirectly from You or Your agents, such as information we collect from You in the course of considering You for employment or in administration of Your Role;
- directly and indirectly from activity on our external and internal websites, such as submissions through our websites or website usage details collected automatically; and
- from third parties that provide services to us or otherwise interact with us in connection with Your application for employment or in connection with Your Role.
2. USE OR DISCLOSURE OF PERSONAL INFORMATION
We may use or disclose the Personal Information that we collect for one or more of the following “Business Purposes”:
- to fulfill or meet the reason for which the information is provided, such as for Role-related matters, including but not limited to hiring decisions, administering benefits, employee review and discipline, termination, and post-termination;
- to provide You with information that You request from us;
- to provide You with emails and notices concerning Your Role, benefits, Safehold, or other information or news that may be of interest to You;
- to carry out our obligations and enforce our rights arising from any agreements, policies and procedures related to Your Role;
- to provide, maintain, support, and improve Safehold’s services, technologies, and websites and to present website content to You;
- as necessary or appropriate to protect the rights, property or safety of us, our clients, customers, employees and others;
- to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- to respond to Your requests, such as verifying employment in order for you to obtain a mortgage or other financial services;
- to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred; and
- as described to You when collecting Your Personal Information and as otherwise required or permitted under the CCPA.
Additionally, Safehold may use or disclose Sensitive Personal Information to fulfill or meet the reason You provided the information, including to provide or administer employment benefits or to evaluate equal employment opportunity compliance; to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; to respond to Your requests under the CCPA; for any other purpose described to You when we collect Your Sensitive Personal Information; and for any other acceptable and permissible purposes as set forth in the CCPA.
Safehold may disclose Personal Information to our “service providers”, to our “contractors”, and to “third parties” (each as defined by the CCPA) for Business Purposes. When we disclose Personal Information for Business Purposes, we enter into an agreement with the receiving party that describes the purpose for sharing the Personal Information, and that requires the receiving party to keep that Personal Information confidential. In the case of disclosures to our service providers, our service providers are obligated not to use the Personal Information for any purpose other than performing the services according to their agreement with us. In the case of our contractors, our contractors are obligated not to use the Personal Information for any purpose unrelated to the Business Purpose for which we’ve engaged them.
We may disclose Your Personal Information to the following categories of entities:
Name, address, social security number of You and your spouse/domestic partners and any dependents; birth date; medical condition; compensation information
Provision and administration of benefits programs, including health insurance, leave benefits and retirement plans
Health, disability and leave insurers and/or administrators, and third-party providers handling Safehold’s 401(k) plans
Name, address, Social Security number, compensation information, bank account information
Payroll and taxes
Payroll provider, federal, state and local tax authorities
Compliance with subpoenas, court orders, and/or government investigations
Parties in litigation, federal and state government and quasi-governmental and regulatory agencies
3. SALES AND SHARING OF PERSONAL INFORMATION
“Sell,” “Selling,” or “Sold” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Information to another business or a third party for monetary or other valuable consideration. “Share,” “Sharing,” or “Shared” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
We do not Sell or Share, and have not Sold or Shared, Your Personal Information. We will not Sell or Share Your Personal Information without providing notice to You and getting Your consent.
We retain each category of Personal Information for as long as it is reasonably necessary for one or more Business Purposes. However, due to the nature of the Personal Information we collect and the Business Purposes for which it is received, it is not possible to predict the length of time that we intend to retain Your Personal Information. Instead, we use the following criteria to determine whether it remains reasonably necessary to retain Personal Information: the initial Business Purposes for which the Personal Information was collected or a subsequent Business Purposes in accordance with the CCPA; whether there is a retention period required by applicable contracts with third parties, professional rules of conduct, or applicable law or regulation; the existence of threatened or actual litigation for which Safehold is required to preserve Personal Information; and/or generally accepted best practices in our industry.
When we determine that it is no longer reasonably necessary to retain Your Personal Information based on the above criteria, we will delete Your Personal Information.
5. YOUR RIGHTS AND CHOICES
You may request information about our collection, use, and disclosure of Your Personal Information, whether or not it was collected electronically. For purposes of this Section 5, You includes Related Individuals.
“Verifiable Request” means that the identifying information You provide in connection with a request matches the Personal Information Safehold already maintains. If You submit a Verifiable Request, we will provide You with information regarding:
- the categories of Personal Information we have collected about You; the categories of sources from which Your Personal Information was collected; our Business Purposes for collecting, Selling, or Sharing Your Personal Information; the categories of third parties with whom we disclose that Personal Information; and the specific pieces of Personal Information we collected about You; and
- what categories of Personal Information we disclosed for a Business Purpose, and to which categories of recipients we disclosed it.
You also have the right to request a copy of Your Personal Information, and/or to request that we transmit Your Personal Information to another entity. To the extent technically feasible, we will comply with Your request and provide and/or transmit Your Personal Information in a structured, commonly used, machine-readable format.
You also have the right to request that we delete any of Your Personal Information that we collect or maintain by submitting a Verifiable Request. We may deny Your deletion request if retaining Your Personal Information is necessary for a purpose recognized by the CCPA. If we deny a request, we will give You our reason for doing so.
You further have the right to request that we correct any of Your Personal Information that is inaccurate by submitting a Verifiable Request. We will correct any inaccurate Personal Information pursuant to Your request to the extent possible using commercially reasonable efforts. We may deny Your correction request if the Personal Information is accurate. We may also delete Your Personal Information instead of correcting it to the extent such deletion would not negatively impact You.
You also have the right to request that we limit the use and disclosure of Sensitive Personal Information by submitting a Verifiable Request. If You submit such a Verifiable Request, we may continue to use or disclose Your Sensitive Personal Information to carry out one of the purposes recognized by the CCPA. If We continue to use or disclose the information, We will give You our reason for doing so.
You may submit a Verifiable Request for the information listed above, or exercise any of Your rights enumerated under this Notice, by calling us at +1 866 930 9400 or by completing a form on our website https://www.safeholdinc.com/contact-us/
After we receive Your Verifiable Request, we will provide to You, in writing and free of charge (unless Your request is excessive, repetitive, or manifestly unfounded), the requested information. Unless you specify a shorter period for the request and processing Your request does not require disproportionate effort, we will process Your request with respect to Personal Information we have collected from January 1, 2022 to the time of processing Your request. You can choose to have this information delivered to You by postal mail or electronically. We will try to respond to Your verified request within forty-five (45) days of receipt, but if we require more time (up to another forty-five (45) days) we will inform You of the reason and extension period in writing. Please note that we are not required to comply with Your request for information more than twice in any 12-month period. If applicable, our response will explain the reasons why we cannot comply with Your request.
If You choose to exercise any of the rights enumerated under this Notice, we will not: deny You goods or services; charge You different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide You a different level or quality of goods or services; or suggest that You may receive a different price or rate for goods or services or a different level or quality of goods or services.
HOWEVER, PLEASE BE AWARE THAT IT IS NECESSARY FOR SAFEHOLD TO HAVE PERSONAL INFORMATION ABOUT YOU IN ORDER FOR YOU TO BE EMPLOYED BY US AND FOR US TO PROVIDE YOU WITH EMPLOYEE BENEFITS. ADDITIONALLY, IT MAY BE A FUNCTIONAL NECESSITY FOR US AND/OR OUR TECHNOLOGIES TO HAVE PERSONAL INFORMATION ABOUT YOU IN ORDER TO OPERATE, AND WE MAY NOT BE ABLE TO PROVIDE SOME OR ALL OF OUR BENEFITS OR SERVICES TO YOU IF YOU DIRECT US TO DELETE YOUR PERSONAL INFORMATION.
6. CHANGES TO THIS POLICY
We may amend this Notice from time to time. When we make changes to this Notice, we will notify You by email or on a Safehold website.
7. CONTACT INFORMATION
If You have any questions or comments about this Notice, the ways in which we collect, use, disclose, or destroy Your Personal Information, or Your choices and rights regarding Your Personal Information, please do not hesitate to contact us at: +1 866 930 9400.