Employment Privacy Policy

This California Employees Notice at Collection and Privacy Policy (“Notice and Policy”) describes College Avenue Student Loans LLC’s (“College Ave,” “we,” “us,” or “our”) practices regarding the collection, use, and disclosure of the personal information of job applicants, employees, independent contractors, owners, directors, and officers of College Ave who are California residents (“Employees”), describes the rights of Employees under the California Consumer Privacy Act (“CCPA”), and explains how Employees may contact College Ave to exercise those rights.

The privacy practices described in this Notice and Policy are effective as soon as posted or provided to you as indicated by the Last Updated date below. Should we change any of the practices described in this Notice and Policy, we will notify you by posting the changes to this website or as otherwise required by applicable law. Your continued employment with us following any such changes will constitute your agreement to these privacy practices.

How we collect personal information about Employees

College Ave collects personal information about Employees from the following sources: Employees, employment documents, recruiting servicers, benefit providers, government entities, service providers, and third parties. We may also collect personal information about an Employee’s spouse, dependents, beneficiaries, emergency contacts, and other individuals relevant to Employee.

What personal information we collect about Employees

College Ave has collected the following categories of personal information from Employees in the last 12 months.

Identifiers such as name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, signature, telephone number, or other similar identifiers.
Characteristics of protected classifications, such as family information (e.g., marital status, relevant information on spouse/dependents); benefits information (e.g., wellness information, COBRA information, healthcare plan information, insurance information); disability claims records (e.g., workers’ compensation records and disability claims records); medical reports or records (e.g., pre-employment drug tests, medical benefits-related documentation); or certain physical characteristics (e.g., age, disability, race, color, gender).
Professional information, such as employment history, employment verification information, promotions, service dates, training information, length of service, compensation, tax information, bank account data, current department/position, employment status, job performance, attendance records, disciplinary actions, recordings of customer servicing calls, relocation information, employee development information, payroll information, or other employment-related information.
Education information, such as resume and application information, education verification information, level of education, degrees received, certifications, etc.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, online applications used, and information regarding an Employee’s interaction with an Internet website, application, or advertisement.
Inferences drawn from any of your personal information to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes, such as inferences about your job performance, disciplinary determinations, or professional development.
Audio or visual information such as the content of video interviews and conferences, security cameras, call recordings, etc.
Sensitive personal information, including but not limited to, Social Security number, driver’s license, state identification card, passport number, health and medical records, disability information, benefits information, insurance coverage, Employee login credentials, and financial account information.
Commercial information, including records of personal property; products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies.

How we use personal information about Employees

We use the personal information about Employees for the following business purposes:

Performing human resource functions, including processing job applications, administering benefits, processing payroll, conducting analytics in an employee context, or managing other aspects of an employment relationship including, but not limited to, the establishment, maintenance, and termination of employment relationships.
Determining eligibility for initial employment, including the verification of references and qualifications.
Processing background checks of new applicants and existing Employees.
Managing the terms and conditions of employment, such as payment of wages/salary, direct deposit authorization, the provision and administration of benefits and leaves of absence, and maintenance of emergency and beneficiary contact information.
Processing Employee work-related claims (e.g., worker compensation, insurance claims, etc.).
Conducting training, taking disciplinary action, addressing injuries, and other employment related incidents.
Providing a safe work environment.
Administering our occupational safety and health programs.
Assisting you with obtaining immigration or work documentation, when required.
Maintaining directories of Employees.
For employee-related programs, including surveys and voluntary programs.
Investigating and responding to claims against us.
For corporation transactions, such as transferring personal information in the event we sell or transfer, or are considering selling or transferring, all or a portion of our business or assets.
Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.
Helping to ensure security and integrity to the extent the use of the Employee’s personal information is reasonably necessary and proportionate for these purposes.
Debugging to identify and repair errors that impair existing intended functionality.
Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of an Employee’s current interaction with College Ave, provided that the Employee’s personal information is not disclosed to another third party and is not used to build a profile about the Employee or otherwise alter the Employee’s experience outside the current interaction with College Ave.
Performing services on behalf of College Ave, including maintaining or servicing accounts, providing services, verifying information, processing payments, providing storage, or providing similar services on behalf of College Ave.
Providing advertising and marketing services, except for cross-context behavioral advertising, to the Employee provided that, for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out Employees that the service provider or contractor receives from, or on behalf of, College Ave with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with Employees.
Undertaking internal research for technological development and demonstration.
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the College Ave, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the College Ave.
Comply with federal, state, or local laws or comply with a court order or subpoena to provide information.
Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities.
Cooperate with law enforcement agencies concerning conduct or activity that the College Ave, service providers, or third parties reasonably and in good faith believe may violate federal, state, or local law.
Cooperate with a government agency request for emergency access to an Employee’s personal information if a natural person is at risk or danger of death or serious physical injury.
Exercise or defend legal claims.

How we disclose personal information about Employees

For any of the above business purposes, we may disclose any of the categories of personal information that we collect about Employees to service providers, contractors, affiliates, and other third parties.

Employee Rights

This section describes your rights under the CCPA. For information on how you may contact College Ave to exercise these rights, please see the section below entitled, “How to Submit a Request.”

Right to Know: You have the right to request that a business disclose what personal information it collects, uses, discloses, or sells. Specifically, you may request that a business that collects personal information about you disclose to you the following:
- (1) The categories of personal information it has collected about you in the preceding 12 months.
- (2) The categories of sources from which the personal information is collected.
- (3) The business or commercial purpose for collecting or selling personal information.
- (4) The categories of third parties with whom the business shares personal information.
- (5) The specific pieces of personal information it has collected about you in the preceding 12 months.
You may also request that a business that sells your personal information, or that discloses it for a business purpose, disclose to you:
- The categories of personal information that the business collected about you in the preceding 12 months.
- The categories of personal information that the business sold about you and the categories of third parties to whom the personal information was sold in the preceding 12 months, by category or categories of personal information for each third party to whom the personal information was sold.
- The categories of personal information that the business disclosed about you for a business purpose in the preceding 12 months.
Right to Correct Inaccurate Personal Information: You have the right to request that a business correct any inaccurate personal information about you which the business has collected from you. If we determine that we cannot comply with your request when you request us to do so, we will inform you and tell you why we are not correcting it.
Right to Request Deletion: You have the right to request that a business delete any personal information about you which the business has collected from you. If it is necessary for College Ave to maintain the personal information for certain purposes, College Ave is not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it.
Right to Opt-Out of Sale of Personal Information: You have the right to opt-out of the sale of your personal information. However, College Ave does not and will not sell your personal information. College Ave has no actual knowledge that it sells the personal information of anyone under 16 years of age.
Right to Opt-Out of Sharing of Personal Information: You have the right to opt-out of the sharing of your personal information. However, College Ave does not share our Employees’ personal information for cross-context behavioral advertising.
Right to Opt-Out of Use and Disclosure of Sensitive Personal Information: You have the right to opt-out of the use and disclosure of your sensitive personal information. If College Ave collects or processes sensitive personal information with the purpose of inferring characteristics about Employees, College Ave will respond to such requests by restricting any further use of the Employee’s sensitive personal information to those uses which are necessary to continue the Employee relationship as reasonably expected by an average Employee and to perform the services permitted by applicable law.
No Discrimination: You have the right not to be discriminated against because you exercised any of you Employee rights under the CCPA.

How to Submit a Request

To exercise the rights described above, you must submit a verifiable Employee request to us by contacting College Ave at 844-422-7502 or by mailing a request to College Ave, LLC, 233 N. King St., Ste 400 ATTN: Human Resources, Wilmington, DE 19801. You may submit a request as frequently as you would like, but we are not required to respond to requests to provide personal information to you more than twice in any 12-month period.

Verification

To protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, or to answer questions regarding your employment. The information we ask you to provide to initiate a request may differ depending upon the type of request; the type, sensitivity, and value of the personal information that is the subject of the request; and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors. We may also require you to provide a written declaration that you are who you say you are.

If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal information provided in a verifiable Employee request to verify the requestor’s identity or authority to make the request.

Authorized Agent

Only you, or someone legally authorized to act on your behalf, may make a verifiable Employee request related to your personal information. You may also make a verifiable Employee request on behalf of your minor child if the minor child is an Employee of College Ave. To authorize an agent, provide written authorization signed by you and your designated agent and contact us as set forth below.

Security

We use data storage and security techniques to protect your personal information from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss. However, it is important to remember that no website can be 100% secure and we cannot be held responsible for unauthorized or unintended access that is beyond our control.

Retention of your Information

We apply a general rule of keeping personal information only for as long as required to fulfil the purposes for which it was collected. However, in some circumstances we may retain personal information for longer periods of time, for instance when we are required to do so in accordance with legal, tax, and accounting requirements.

In specific circumstances, we may also retain your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

Contact for More Information

If you have any questions or concerns about College Ave’s privacy policy or practices, please contact us at 844-422-7502.

If you have a disability that prevents or limits your ability to access these privacy disclosures, please contact us so we can work with you to provide these disclosures in an alternative format.

This Employment Privacy Policy was last updated on: November 6, 2023