01 About this notice
This Your Privacy Choices page is made available to California residents pursuant to the California Consumer Privacy Act ("CCPA") as amended by the California Privacy Rights Act ("CPRA"). It supplements our general Privacy Policy with rights and disclosures that apply specifically to California residents.
Hartwell Search LLC is a Delaware-registered company operating recruiting and staffing services in California (with an office at 235 Montgomery Street, Suite 1040, San Francisco, CA 94104) and across the United States. We are the "business" for purposes of the CCPA.
02 What we collect
Over the preceding twelve (12) months, we have gathered the following categories of personal information from California residents:
| Category | Examples | Sources |
|---|---|---|
| A. Identifiers | Name, postal address, email, phone, IP address | You, our clients, public sources |
| B. Personal records (Cal. Civil Code § 1798.80) | Employment history, education, signatures, work authorization | You, references |
| C. Protected classifications | Age, gender, veteran status (only if you voluntarily disclose for EEO) | You |
| D. Commercial information | Records of services purchased (career coaching only) | You |
| E. Internet activity | Browsing history on our Site, time on page | Cookies & analytics |
| F. Geolocation | City-level only (from IP), used for office routing | Automatic |
| G. Professional information | Résumé, references, current/target compensation, performance history | You, references, our clients |
| H. Sensory data | Audio/video recordings of consented interviews | You (with consent) |
| I. Inferences | Suitability for specific roles based on profile analysis | Internal processing |
| J. Sensitive PI | Social Security Number (only for FCRA-compliant background checks) | You (with consent) |
We retain each category according to the schedule in Privacy Policy § 6.
03 Sale & sharing
Under the CPRA, a "sale" encompasses selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating personal information in exchange for monetary or other valuable consideration. "Sharing" refers to disclosure for the purpose of cross-context behavioral advertising.
Hartwell Search does not sell personal information. We do not share personal information for cross-context behavioral advertising. We have neither sold nor shared personal information during the preceding 12 months and have no plans to begin doing so.
Disclosures of personal information to service providers and contractors (such as our ATS, email infrastructure, and background-check vendor) governed by written confidentiality agreements do not constitute "sales" or "shares" under the CPRA.
04 Your California rights
If you are a California resident, you are entitled to the following rights:
- Right to know: Request disclosure of the categories of personal information we have collected, the sources, the purposes, and the categories of third parties to whom we disclose, in the previous 12 months (or longer at your election, subject to feasibility).
- Right to access: Receive a copy of the specific pieces of personal information we hold about you.
- Right to delete: Request that we delete personal information we have collected from you, subject to legal exceptions (e.g. records we must retain for EEO or tax compliance).
- Right to correct: Request correction of inaccurate personal information.
- Right to opt out of sale/sharing: Although we do not currently sell or share personal information, you have a standing right to opt out should our practices ever change.
- Right to limit use of sensitive PI: Direct us to use sensitive personal information only for specified, authorized purposes.
- Right to non-discrimination: We will not discriminate against you for exercising any of these rights (see Section 8).
- Right of portability: Receive your personal information in a structured, machine-readable format.
05 How to submit a request
You may exercise any of the rights listed above through three channels:
5.1 — Online
Email privacy@hartwellsearch.com with subject line "CCPA Request – [type of request]" and a description of which right you wish to exercise.
5.2 — By phone
Call our toll-free privacy line at +1 (833) 261-4087 and select option "Privacy & Compliance" or ask for the Privacy Officer directly.
5.3 — By mail
Send a written request to:
Hartwell Search LLC · Attn: Privacy Officer
485 Lexington Avenue, 26th Floor
New York, NY 10017
5.4 — "Do Not Sell or Share My Personal Information"
We do not currently engage in the sale or sharing of personal information as defined by the CPRA. The Global Privacy Control (GPC) signal transmitted by your browser will be treated as a confirmed opt-out request should our practices change in the future.
06 Verification & timing
To safeguard your information, we will confirm your identity before processing a request. We will ask for details sufficient to match against our records — typically your full name, email address, and the approximate date of your most recent interaction with us. For sensitive requests (such as deletion or access to sensitive PI), we may require additional verification, including a signed declaration under penalty of perjury.
We will respond to verifiable requests within forty-five (45) days. If additional time is needed, we will inform you within the initial 45-day period and may extend the deadline by an additional 45 days, for a maximum of 90 days.
You are entitled to two free requests per twelve-month period. Requests beyond that limit, or those that are manifestly unfounded, may be subject to a reasonable fee or may be declined, in which case we will provide an explanation.
07 Authorized agents
You may appoint an authorized agent to submit a request on your behalf. The agent must supply:
- Written, signed permission from you authorizing the agent to act;
- Proof of the agent’s identity (government ID);
- Verification of your identity directly with us.
08 Non-discrimination
We will not penalize you for exercising any CCPA/CPRA right. Specifically, we will not:
- Deny you services or refuse to consider you for placements;
- Charge you a different price or rate for services;
- Provide a different level or quality of services;
- Suggest that you will receive different prices or quality of services.
09 California "Shine the Light"
California Civil Code § 1798.83 grants California residents the right to request a notice identifying the categories of personal information we share with third parties for their direct marketing purposes. As stated above, we do not share personal information for third-party direct marketing. Should this practice change, we will update this section and provide appropriate notice.
10 Contact us
For questions related to the CCPA/CPRA or to submit a request, please contact:
Hartwell Search LLC · Privacy Officer
485 Lexington Avenue, 26th Floor
New York, NY 10017
Email: privacy@hartwellsearch.com
Toll-free: +1 (833) 261-4087
San Francisco office: 235 Montgomery Street, Suite 1040
If you are not satisfied with our response, you may file a complaint with the California Privacy Protection Agency at cppa.ca.gov or with the California Attorney General’s office.