Notice at Collection and Privacy Policy for California Job Applicants

Blend Labs, Inc. and its subsidiaries and affiliates (collectively, “Blend”) take your privacy seriously.  We want you to know how we collect, use, and disclose your personal information.  

This Privacy Policy explains: 

1. The categories of personal information we collect about you
2. The categories of sources from which we collect your personal information
3. The purposes for which we use your personal information  
4. How we may disclose your personal information
5. How long we keep your personal information
6. Your privacy rights and how to exercise them
7. Changes to this Privacy Policy 

Scope:

This Privacy Policy applies to the personal information of California residents in their role as job applicants to Blend (“Applicants”). 

“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Applicant.

THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT ABOUT YOU

• Identifiers, for example: real name, nickname, telephone number, postal address, e-mail address, and signature. 
• Professional, Employment or Education Related Information, for example: resumes/cover letters, educational institutions attended, academic transcripts, degrees and certifications, licenses, work experience and previous employers, and professional memberships and affiliations.
• Work authorization status 
• Internet Activity Information, for example: interactions with Blend’s website, job application, or job advertisement, and publicly available social media activity. 
• Job preferences, for example:  desired compensation, willingness to relocate, positions for which you are interested 
• Sensory or Surveillance Data, for example: voice-mails, audio/visual recordings of interviews, and footage from video surveillance cameras. 
• § 1798.80: personal information described under Cal. Civ. Code § 1798.80 to the extent not already included in other categories in this section, such as a photograph or health information, for example, to conduct pre-employment physical examinations.  
• Characteristics of Protected Classifications Under California or Federal Law for Applicants, collected on a purely voluntary basis, except where collection is required by law, and used only in compliance with applicable laws and regulations, for diversity and inclusion reporting and related purposes.
• Other details, for example, hobbies and leisure activities or membership in voluntary/charitable/public organizations, for example, as stated on the Applicant’s resume.
• Reference names and contact information 
• Information submitted in connection with any assessment you may take as part of the interview process
  

THE CATEGORIES OF SOURCES FROM WHICH WE COLLECT YOUR PERSONAL INFORMATION

• You, for example, in your job application, forms you fill out for us, assessments you complete, surveys you complete, and any information you provide us during the course of your application and interview process.
• Vendors and service providers, for example, recruiting agencies. 
• Third parties, for example, job references, affiliated companies, professional employer organizations or staffing agencies.
• Public internet sources, for example, social media, job boards, public profiles, and other public online sources.
• Public records, for example, court records, and credentialing and licensing organizations.
• Automated technologies on Blend’s electronic resources, for example, to track logins and activity on our careers page.
• Surveillance/recording technologies installed by Blend  for example, video surveillance in common areas of Blend facilities and audio/video recording technologies with consent to the extent required by law. 
• Government or administrative agencies, for example, law enforcement or public health authorities.  

THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION

We use Applicants’ personal information for the following purposes:

• Recruiting, including: 
  • To review and process applications
  • To assess Applicants’ qualifications or suitability for employment with Blend
  • To communicate with Applicants during the recruitment process 
  • To verify the information you provide and carry out reference checks 
  • To assist Applicants obtain an immigration visa or work permit if requested 
  • To prepare offers of employment and demonstrate Applicants’ agreement to, or acceptance of, documents presented to them (e.g., pre-employment arbitration agreement and offer letter)
  • To conduct pre-employment or criminal history background checks
  • To evaluate and improve our recruiting processes, including analyzing recruiting metrics and facilitating diversity and inclusion efforts 
  • To create a talent pool for future job openings 
  • Where we have identified you as a potential candidate from information that we’ve collected from public sources, in order to suggest suitable opportunities for you at Blend 
    
• Monitoring, Security, and Compliance, including: 
  • To monitor use of Blend facilities and information systems 
  • To ensure compliance with applicable laws and Blend policies
  • To create and submit reports as required by applicable laws and regulations
  • To conduct internal audits and investigations
  • To protect the safety and security of Blend’s facilities
  • To exercise Blend’s rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel
    
• Conducting Our Business, including: 
  • To manage and operate information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, strategic planning
  • In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of Blend or any of its subsidiaries or affiliates
  • To manage licenses, permits and authorizations applicable to Blend’s business operations
  • To protect the rights, property, or safety of Company, HR Individuals, customers or others

Purposes for Using Applicants’ Personal Health Information: 

• To the extent necessary to comply with Blend’s legal obligations, such as to accommodate disabilities
• For occupational health and safety compliance and record-keeping
• To conduct pre-employment medical examinations 
• To respond to an Applicant’s medical emergency

Purpose For Using Applicants’ Protected Categories Of Information:

Blend collects information about race, age, national origin, disability, gender identity, sexual orientation, sex, and veteran status as necessary to comply with legal obligations, including the reporting requirements of the federal Equal Employment Opportunity Act and California’s Fair Employment and Housing Act, and for purposes of diversity analytics.  We also use this personal information for purposes including: (a) with respect to disability and/or medical condition, as necessary, to comply with federal and California law related to accommodation; and (b) with respect to age, incidentally to the use of birth date for identity verification.

We collect protected categories of Personal Information on a purely voluntary basis, except where required by law, and use the information only in compliance with applicable laws and regulations.

This Privacy Policy does not cover background screening conducted by our third-party background check vendor subject to the federal Fair Credit Reporting Act.  There is a separate disclosure for such screening.

HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION 

Blend generally maintains information related to Applicants as confidential.  However, from time to time, Blend may have a legitimate business need to disclose Applicants’ personal information for one of the purposes listed in Section 3, above, to one or more of the categories of external recipients listed below.  In that event, Blend discloses your personal information only to the minimum extent necessary to achieve the purpose of the disclosure and only if the disclosure is permitted by the CPRA and other applicable laws.

• Service providers and contractors: Blend discloses your personal information to service providers and contractors for the purposes above to assist us in our recruiting efforts and in meeting our business needs and legal obligations. 
  • Blend only discloses your personal information to service providers and contractors subject to written contracts as required by applicable law.  
  • Service providers and contractors include recruiters, staffing agencies, and any other entity providing services to Blend.
• Affiliated companies: Other companies within the Blend family of companies. 
• Government or administrative agencies: These may include, for example: 
  • Equal Employment Opportunity Commission as required for reporting. 
  • California Department of Fair Employment and Housing as required to respond to employment claims and charges.
  • Law enforcement in the event of criminal investigations.
• Required Disclosures: We may be required to disclose personal information in a court proceeding, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law. 
• Legal Compliance and Protections: We may disclose personal information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Blend, our users, or others. 
• Corporate Transactions: We may disclose your personal information in connection with a corporate merger, consolidation, bankruptcy, the sale of all, or substantially all, of our membership interests and/or assets or other corporate change, including to any prospective purchasers. 

No sales and no “sharing”, i.e., disclosure for cross-context behavioral advertising:

Blend does not sell the personal information of any Applicants nor share their personal information for cross-context behavioral advertising.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

If Blend hires you, the information collected about you during the job application process may become part of your personnel file and may be used to administer the employment relationship and for related reporting and recordkeeping purposes.  Blend will retain this application information for the entire duration of your employment relationship with Blend and for as long thereafter as permitted or required by applicable law.  

Blend will retain information of applicants who are not hired for four (4) years after the record is collected.  These records will be retained for our internal recordkeeping and reporting purposes in compliance with California Government Code § 12946.  During that time, we may use your information to consider you for positions in addition to the position(s) for which you initially applied.

YOUR PRIVACY RIGHTS AND HOW TO EXERCISE THEM

Your California Privacy Rights

• Right to Know: You have the right to submit a verifiable request for copies of specific pieces of your personal information obtained from you and for information about Blend’s collection, use, and disclosure of your personal information.
• Right to Delete: You have the right to submit a verifiable request for the deletion of personal information that you have provided to Blend. 
• Right to Correct: You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by Blend, 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, Blend does not sell personal information or disclose personal information for cross-context advertising, and therefore this right does not apply.
• Right to Restrict Use and Disclosure of Sensitive Personal Information: You have the right to restrict Blend’s use and disclosure of your sensitive personal information to purposes permitted under the CPRA, such as security, quality control, uses required by law, and disclosures to vendors in support of the permitted purposes. This right only applies to sensitive personal information collected or processed by Blend for the purpose of inferring characteristics about you. As noted above, Blend does not collect or process your sensitive personal information for the purpose inferring characteristics, and therefore this right does not apply.

How to Exercise Your Rights

Blend will respond to requests to know, delete, and correct in accordance with applicable law if it can verify the identity of the individual submitting the request. You can exercise these rights in the following ways:

• Call: 866-735-2140
• Email: peopleopshelp@blend.com 

How We will Verify Your Request

The processes that we follow to verify your identity depends on how and why the request is submitted. When you make a request to know, correct, or delete, we will verify your identity as described below: 

• Requests To Know Categories or Purposes:  If you request to know how we collect and handle your personal information, we will match at least two data points that you provide with your request, or in response to your verification request, against information about you that we already have in our records and that we have determined to be reliable for purposes of verifying your identity.  Examples of relevant data points include your mobile phone number, your zip code, and the month and year you submitted a job application to us.
• Requests To Know Specific Pieces of Personal Information:  We will match at least three data points that you provide with your request to know, or in response to our request for verification information, against information that we already have about you in our records and that we have determined to be reliable for purposes of verifying your identity. In addition, we may require you to sign a declaration under penalty of perjury that you are the individual whose personal information is the subject of the request. 
• Requests To Correct or Delete Personal Information:  Our process for verifying your identity will depend on the risk level (as determined by Blend)  associated with the personal information that you ask us to correct or delete. For low risk personal information, we will require a match of two data points as described above. For higher risk personal information, we will require a match of three data points and a signed declaration as described above.

If we cannot verify your identity based on the processes described above, we may ask you for additional verification information.  If we do so, we will not use that information for any purpose other than verification.

If we cannot verify your identity to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot verify your identity.

Authorized Agents 

If an authorized agent submits a request to know, correct, or delete on your behalf, the authorized agent must submit with the request a document signed by you that authorizes the authorized agent to submit the request on your behalf (this does not apply when a consumer has provided the authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465).  In addition, we may ask you or your authorized agent to follow the applicable process described above for verifying your identity.

Blend’s Non-Discrimination and Non-Retaliation Policy 

Blend will not discriminate or retaliate against you for exercising your privacy rights under the California Privacy Rights Act.

CHANGES TO THIS PRIVACY POLICY

If we change this Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date above. If we materially change this Privacy Policy in a way that affects how we use or disclose your personal information, we will provide a prominent notice of such changes and the effective date of the changes before making them.