Your browser is not supported!

Please try one of these browsers:

Chrome, Firefox, IE10+

CALIFORNIA PRIVACY NOTICE

This California Privacy Notice (the "Notice") supplements the California Privacy Policy and the Online Privacy Policies of Headlands Technologies LLC ("HT") and Headlands Tech Global Markets, LLC ("HTGM") and their affiliates (collectively, "we," "us," or "our") and applies solely to users, visitors, business partners, employees, candidates, and others who reside in the State of California ("consumers" or "you"). This Notice has been adopted to comply with the California Consumer Privacy Act of 2018 (the "CCPA") and other California Privacy laws. Any terms defined in the CCPA have the same meaning when used in this Policy.

Information We Collect

We collect information that identifies, relates to, describes, is capable of being associated with, or may reasonably be linked, directly or indirectly, with a particular consumer or household ("Personal Information"). In particular, we collect the following categories of Personal Information from consumers:

Category Title Examples Purpose

A

Identifiers

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.

  • To provide you with information, products, or services that you request from us
  • To maintain an accurate and up to date personnel file
  • To evaluate and identify candidates for recruitment
  • To conduct due diligence and KYC procedures
  • To improve our websites and present their contents to you
  • As necessary or appropriate to protect the rights, property, or safety of us or others
  • To respond to law enforcement requests and as required by applicable law, court order, or government regulations

B

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e))

A name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

  • To provide you with information, products, or services that you request from us
  • To maintain an accurate and up to date personnel file
  • To evaluate and identify candidates for recruitment
  • To conduct due diligence and KYC procedures
  • To meet our financial obligations
  • As necessary or appropriate to protect the rights, property, or safety of us or others
  • To respond to law enforcement requests and as required by applicable law, court order, or government regulations

C

Characteristics of protected classifications under California or federal law

Age (40 years or older), 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).

  • To facilitate employee background checks
  • To verify employment eligibility
  • To determine benefits eligibility
  • To maintain an accurate and up to date personnel file
  • As necessary or appropriate to protect the rights, property, or safety of us or others
  • To respond to law enforcement requests and as required by applicable law, court order, or government regulations

D

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  • To facilitate employee expense reimbursement
  • To maintain financial records
  • As necessary or appropriate to protect the rights, property, or safety of us or others
  • To respond to law enforcement requests and as required by applicable law, court order, or government regulations

E

Biometric information

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.

  • To comply with regulatory requirements (e.g., fingerprinting)
  • As necessary or appropriate to protect the rights, property, or safety of us or others
  • To respond to law enforcement requests and as required by applicable law, court order, or government regulations

F

Internet or other similar network activity

Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.

  • To provide you with information, products, or services that you request from us
  • To improve our websites and present their contents to you
  • As necessary or appropriate to protect the rights, property, or safety of us or others
  • To respond to law enforcement requests and as required by applicable law, court order, or government regulations

G

Geolocation data

Physical location or movements.

  • To provide access to office locations
  • As necessary or appropriate to protect the rights, property, or safety of us or others
  • To respond to law enforcement requests and as required by applicable law, court order, or government regulations

I

Professional or employment-related information

Current or past employment history, performance evaluations, or professional references.

  • To facilitate new hire background checks
  • To verify employment eligibility
  • To maintain an accurate and up to date personnel file
  • To conduct due diligence and KYC procedures
  • As necessary or appropriate to protect the rights, property, or safety of us or others
  • To respond to law enforcement requests and as required by applicable law, court order, or government regulations

Personal Information does not include:

  • Publicly available information that is lawfully made available from federal, state, or local government records.
  • Deidentified or aggregate consumer information.
  • Information specifically excluded from the CCPA’s scope, including:
    • protected health or medical information collected by a covered entity under the Confidentiality of Medical Information Act or governed by the privacy, security, and breach notification rules under the Health Insurance Portability and Availability Act of 1996 ("HIPAA");
    • personal information covered by certain other privacy laws, including the Fair Credit Reporting Act ("FCRA"), the Gramm-Leach-Bliley Act ("GLBA"), California Financial information Privacy Act ("FIPA"), and the Driver’s Privacy Protection Act of 1994.

We do not and will not knowingly collect, disclose, or sell data relating to children, that is, individuals under the age of 16 years.

Privacy Policy

For additional information regarding our privacy practices, please see our California Privacy Policy (spotlight.htglobalmarkets.com/ca-privacy-policy) or use the contact information below to request a copy. We reserve the right to amend the policy and this Notice at our discretion and at any time. When we make changes to this Notice or the privacy policy, we will post a notice on our website.

Contact Information

If you have any questions or comments about this Notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone:

(888) 611-4611

Website:

www.headlandstech.com or www.htglobalmarkets.com

Email:

dataprotection@headlandstech.com

Postal Address:

Headlands Technologies LLC

Attn: Adam Long, Data Protection Officer

444 W. Lake St., Suite 4650

Chicago, IL 60606

Updated: December 2019