California Personnel and Job Applicant Notice

Last Updated: December 19, 2024

Employee, Contractor, and Applicant Privacy Notice

This Employee, Contractor, and Applicant Privacy Notice (this “Notice”) explains how GoodRx and its affiliates (collectively, “GoodRx, “we,” “us,” or “our”) processes personal information about our California-based employees, contractors, and job applicants (collectively, “personnel” or “you” or “your”) and their family members or other individuals about whom we process personal information as a result of the relationships those individuals have with such personnel.

For purposes of this Notice, “personal information” has the meaning given in the CCPA. It does not include, and this Notice does not cover, information that is deidentified or aggregated such that it cannot reasonably be used to infer information about, or otherwise be linked to, a particular individual. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.

This Notice applies to GoodRx’s processing of your personal information as an employee, contractor, or job applicant and does not cover your use of GoodRx’s products and services as a consumer or outside of your regular employment or of the job application process.

If you use the GoodRx website and services, please see the GoodRx privacy policy (goodrx.com/privacy-policy) for additional information.

Categories of Personal Information we Collect: For each category of personal information, the list of examples is intended to be illustrative and not exhaustive. In connection with an individual’s role as a member of our personnel, we may not collect every example listed within a category nor use every example for each business purpose identified within each category. Please note, in addition to the business purposes defined below, GoodRx processes the following categories of personal information for compliance with legal and/or regulatory obligations.

Categories of Personal Information Collected	Examples	Business Purposes
Identifiers	Name Email address Home address Business address IP address Phone number Social Security Number Online identifiers Personnel ID (e.g., government or state-issued identification)	HR administration, such as benefits, payroll, and other employment-related purposes. Job Application Process Performing services on behalf of the company Auditing
Protected classification information	Marital or Domestic Partner Status Age Disability or medical information (if/as needed for accommodations, leaves of absence, or other benefits reasons) Veteran or military status Race Sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions or events) National Origin Citizenship Sexual Orientation	HR administration, such as benefits, payroll, and other employment-related purposes Job Application Process Auditing
Internet or electronic activity	Website interactions during application process, use of internal networks Geolocation information, such as general geographic location based on the log data we or third-party providers collect	HR administration, such as benefits, payroll, and other employment-related purposes, such as employee investigations, discipline, and cybersecurity Job Application Process Auditing Performing services on behalf of the company
Surveillance Data	Company building, assets, and physical security information via access control systems and video surveillance (CCTV)	Personnel and third party security, safety, and loss prevention Employment-related purposes, such as employee investigations Auditing Compliance with health and safety policies and laws
Professional or employment related information	Resumes/CVs References Background Checks Emergency contacts Dependents GoodRx employment information such as hire date, location, business unit, department, job title, salary, restrictions or accommodations, and other related information Performance-related information, such as performance reviews and disciplinary records Employment eligibility information, such as visa information Work-related accounts and passwords, and financial account information	HR administration, such as benefits, payroll, and other employment-related purposes Job Application Process Auditing
California Customer Records (Cal. Civ. Code § 1798.80(e))	Social Security Number Home address Business address Phone number	See business purposes defined for these categories of data.
Inferences drawn from personal information	Performance reviews, job application vetting	HR administration, such as benefits, payroll, and other employment-related purposes Job Application Process Auditing

Sensitive Information: The following personal information elements, which are also identified above, may be classified as “sensitive” under the CCPA (“sensitive information”): Social Security number, government or state-issued identification, work-related accounts and passwords, race, national origin, ethnicity, disability or medical information, sexual orientation, and financial account information. We may use this sensitive information for the purposes set forth regarding personal information.

In addition to the business purposes set forth above, we may use these categories of personal information:

To fulfill or meet the reason you provided the personal information;
To comply with our health, safety, compliance, and fraud-prevention obligations;
To create anonymous, aggregated or de-identified data that we use and share to analyze our application and recruitment activities, business and for other lawful business purposes;
To authorize, grant, administer, monitor, and terminate access to or use of company systems, facilities, records, property, and infrastructure
To manage business travel (e.g., car service/rentals, flights, hotels) and personnel expenses (e.g., reimbursement, corporate credit card).
To facilitate personnel compensation, payroll, and benefit planning and administration (e.g., salary, tax withholding, insurance);
To carry out discipline and investigations as necessary;
To facilitate personnel and third party safety and loss prevention;
To establish, exercise, or defend legal claims;
To comply with applicable law, court orders, subpoenas, and governmental regulations or investigations;
To respond to requests by public authorities, including for the purpose of meeting national security or law enforcement requirements;
In the event of a merger, acquisition, disposition of all or substantially all of the relevant assets of the business, bankruptcy, or similar event (including due diligence related thereto);
As described to you when collecting your personal information; or
As otherwise authorized or required by applicable law.

We may use de-identified Personal Information in accordance with applicable law.

Disclosure of Personal Information: We may share your personal information with other parties as necessary for the purposes described above. For example, we may disclose your personal information with:

Affiliates. Our subsidiaries, and other affiliates for purposes consistent with this Notice or to operate shared infrastructure, systems, and technology.
Company service providers. Companies that provide us with services that help us manage the recruiting process and operate our business, such as job boards, recruiters, interviewing and testing, pre-employment screening, interview travel booking and expense reimbursement (where applicable), relocation (where applicable), recruitment analytics, benefit administrators, compensation, payroll, and tax providers.
Government authorities, law enforcement and others. Government authorities, law enforcement, courts, and others as described in the compliance, safety and fraud prevention section above.
Business transfers. Parties to transactions and potential transactions whereby we sell, transfer, or otherwise share some or all of our business or assets, including your personal information, such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
Professional advisors. Lawyers, immigration advisors, and other outside professional advisors.
Customers and business partners. Customers, other companies, and individuals with whom the Company does business or is exploring a business relationship.

We do not sell or share any information regarding employment-related personal information to third parties for monetary or other valuable consideration. However, as stated above, in the event of a merger to, acquisition by, or similar event relating to a third party, we may transfer your personal information to the new owners/entities pursuant to such event.

Finally, we may also use and share de-identified information in accordance with applicable law. Once de-identified, we will not attempt to re-identify your information except to ensure de-identification is working as expected. When we do so, we have reasonable measures in place to prevent the information from being reassociated with you. And, we obligate recipients of de-identified information to maintain and use such de-identified in accordance with applicable law.

Retention of Personal Information: We retain the categories of personal information listed above as reasonably necessary to fulfill the purposes outlined in this notice, unless a longer retention period is required or permitted by law. In many situations, we must retain all, or a portion, of your personal information to comply with legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes.

Relatedly, we may retain application information for unsuccessful applicants beyond consideration of the immediate position for which the application is submitted as a reference in case future positions become available and are of interest. Application information for successful applicants becomes part of the applicant’s employment file and is treated accordingly.

Sources of Personal Information: We may collect Personal Information from a variety of sources, including as follows:

Directly or automatically collected from you
Inferences we may derive from information we have collected
References provided by you, including former and current employer
Service providers (e.g., expense reimbursement services, recruiters, cookies and similar technologies related to our providers’ services)
Insurance and benefits providers
Travel partners (e.g., travel agents and portals, car service, and ride share companies)
Background check services
Online sources including social networks and recruiting sites (e.g., LinkedIn)
Open government databases and other public sources

Your Privacy Rights:

We will get consent from you for the collection, use, and disclosure of Personal Information where such consent is required by applicable law. Failure to provide necessary Personal Information may disqualify you from employment or contract or restrict participation in certain plans or programs.

For California residents, under the CCPA, you have the following rights with respect to Personal Information we process about you, subject to permitted exemptions and limitations under applicable law.

Right to Limit Use and Disclosure of Sensitive Personal Information. Where we use or disclose Sensitive Personal Information to infer individual characteristics or for purposes other than those permitted by CCPA, you have a right to request that we limit our use and disclosure of such Sensitive Personal Information. Note that we do not use or disclose Sensitive Personal Information to infer individual characteristics or for additional purposes.

Right to Know. You have a right to request that we disclose the Personal Information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, sale, or sharing of Personal Information. Note that we have provided much of this information in this Notice.

Right to Request Correction. You have the right to request the correction of inaccurate Personal Information.

Right to Request Deletion. You also have a right to request that we delete Personal Information under certain circumstances, subject to lawful exceptions.

Right to Notice. You have a right to receive notice of our Personal Information collection, use, retention, and disclosure practices at or before the collection of Personal Information.

Right to Non-Discrimination. You have a right not to be discriminated against for exercising these rights set out in the CCPA.

Exercising Your Rights: If you are a California resident, you can submit a GoodRx Employee Data Deletion Request form for the right to delete and the GoodRx Employee Data Access Request form for the right to know or correct. You may also contact us at datarequest@goodrx.com for any other privacy rights requests or questions.

Further, to process your privacy rights requests, such as to provide, correct, or delete specific pieces of Personal Information, we will need to verify your identity to the degree of certainty required by law. We will verify requests by asking you to send the request from the email address associated with your request or by requiring you to provide additional information reasonably necessary to verify your identity.

If you have any questions, please contact legal@goodrx.com.

Submitting Authorized Agent Requests: In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Changes to this Notice: We may occasionally update this Notice to reflect changes required by law or our practices or procedures. If we make material changes to this Statement, or in how we use Personal Information, we will provide notice (or obtain consent) regarding such modifications as may be required by law.

Contact:

Please address comments or questions to us about this Privacy Notice via phone by calling 1-855-268-2822. We are available every day (excluding holidays), from 8AM to 7PM (CT).

GoodRx, Inc.
2701 Olympic Blvd.
West Building Suite 200
Santa Monica, CA 90404
USA

E-Mail: datarequest@goodrx.com

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California Personnel and Job Applicant Notice

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