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Prometheus Real Estate Group, Inc.

Employee Privacy Notice For California Residents

Employee Privacy Notice for California Residents

Effective Date: January 1, 2023

This Employee Privacy Notice for California Residents is to inform our personnel (including employees, temporary workers, interns, volunteers, job applicants, and contractors) who reside in the State of California (referred to herein as “you” or “individual”) about the categories of personal information to be collected by Prometheus Real Estate Group, Inc. (“Prometheus”) and the purposes for which the categories of personal information will be used. We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (“CPRA”) and any terms defined in the CPRA have the same meaning when used in this notice.

I. Data Collection Notice

Prometheus collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household (“Personal Information”). In particular, we collect, use and disclose the categories of Personal Information specified below. Prometheus may collect, use, disclose, sell or share these categories of personal information for one or more of the indicated business or commercial purposes:

CategoriesDescriptionDisclosed for a Business Purpose?Categories of Third Parties to whom the Personal Information is Disclosed
IdentifiersA real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, or other similar identifiers. Yes
  • Third-party service providers who perform services on Prometheus's behalf including, but not limited to, those who help manage the recruitment and onboarding process, provide applicant tracking systems and recruiting software, conduct background checks and provide data storage or hosting services
  • Government agencies or law enforcement to comply with legal obligations or valid legal processes such as search warrants, subpoenas or court orders and to protect our rights and property or protect the rights, property or safety of others
  • Buyers/acquirors in the event of a corporate transaction, including but not limited to a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy
Categories listed in the California Customer Records statuteA name, signature, Social Security number, physical characteristics or description, address, telephone 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. Cal. Civ. Code § 1798.80(e).Yes
Protected classification characteristics 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, and veteran or military status.Yes
Commercial informationRecords of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.Yes
Internet or similar network activityBrowsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.Yes
Professional or employment-related informationCurrent or past job history or performance valuations.Yes

We collect, use and disclose the following categories of Sensitive Personal Information (as defined under the CPRA) regarding our personnel:

Categories of Sensitive Personal Information CollectedDisclosed for a Business Purpose?Categories of Third Parties to whom the Personal Information is “Sold” or “Shared”
Personal information that reveals Social Security, driver's license, state identification card, or passport numberYes
  • Third-party service providers who perform services on Prometheus's behalf including, but not limited to, those who help manage the recruitment and onboarding process, provide applicant tracking systems and recruiting software, conduct background checks and provide data storage or hosting services
  • Government agencies or law enforcement to comply with legal obligations or valid legal processes such as search warrants, subpoenas or court orders and to protect our rights and property or protect the rights, property or safety of others
  • Buyers/acquirors in the event of a corporate transaction, including but not limited to a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy
Personal information that reveals account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an accountYes
Personal information that reveals racial or ethnic origin, religious or philosophical beliefs or union membershipYes
Personal information collected and analyzed concerning a consumer's healthYes

Prometheus does not use or disclose the above Sensitive Personal Information for any purpose other than those permitted under the CPRA.


The Personal Information, including the Sensitive Personal Information, described above are collected directly from you when you apply for employment or from other sources such as third parties for reference checks (e.g., past employers), recruitment agencies, background check agencies, public agencies (e.g., tax authorities, the California Department of Fair Employment and Housing, the California Labor Commissioner, the California Occupational Safety Administration, etc.), and law enforcement agencies.


With the limited exception of internet or other network activity that may be collected and shared with our third-party website analytics and digital advertising service providers if you visit our websites, such information is not sold or shared as such terms are defined under the CPRA. See the Section of this privacy notice, below, entitled “CPRA Rights” for more information about how to opt-out of the sale or sharing of Personal Information. Prometheus does not have actual knowledge that it sells or shares such information of children under 18 years of age


We use the Personal Information, including the Sensitive Personal Information, described above for business purposes related to your application for employment. Those purposes may include:


• Workforce Planning and Recruitment1
• General Human Resources Management/ Administration2
• Performance of our Business Operations3
• Security Management4
• Legal and Regulatory Compliance5
• As described to you when collecting your personal information.
• Business transactions6

1 Workforce Planning and Recruitment (for example: for business forecasting, employee assignment planning and budgeting, job advertising, interviewing, conducting background and criminal history checks, performing drug testing, selecting and hiring and terminating staff).

2 General Human Resources Management and Administration (for example: for career development, performance management, compensation and benefits management and benchmarking, administering payroll, reimbursing expenses, managing stock options, obtaining employee satisfaction feedback, managing absences, general headcount reporting, disaster recovery and emergency response planning, equal opportunities monitoring, training employees, and carrying out disciplinary or grievance procedures.)

3 Performance of our Business Operations (for example: to carry out day-to-day business activities, to allow us to work together and collaborate, to provide our services, to ensure business continuity, to enforce our rights and protect our operations and those of our affiliates, and to pursue available remedies and limit damages we may sustain.)

4 Security Management (for example: to ensure the security of our premises, assets, information, employees and other personnel.)

5 Legal and Regulatory Compliance (for example, to respond to law enforcement requests; as required by applicable law, court order, or governmental regulations; to ensure compliance with health & safety requirements and other legal or fiscal obligations, or in connection with litigation or an internal investigation or audit and to ensure compliance with our policies regarding anti-money laundering, bribery and corruption.)

6 Business Transactions (for example, to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Prometheus’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Prometheus about you is among the assets transferred.)


We will retain the personal information, including sensitive personal information, described above as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulations. For applicants who do not become employees, records will generally not be kept longer than 4 years, and for some records a lesser amount of time, provided such records are not subject to any litigation holds or other applicable laws or regulations that require a longer retention period; for employees, records will generally not be kept longer than their duration of employment plus 6 years, and for some records a lesser amount of time provided such records are not subject to any litigation holds or other applicable laws or regulations that require a longer retention period.

II. CPRA Rights

As a California resident, you have the following rights under the CPRA:


Right to Know: You have the right to request that we disclose certain information to you about our collection and use of certain Personal Information, including Sensitive Personal Information, about you as described below:
  • The specific pieces of Personal Information collected;
  • The categories of Personal Information collected;
  • The categories of sources from whom the Personal Information is collected;
  • The purpose for collecting, selling or sharing the Personal Information;
  • The categories of third parties with whom we have disclosed the Personal Information;
  • The categories of Personal Information that we have sold or shared, and the categories of third parties to whom the Personal Information was sold or shared, by category or categories of Personal Information for each third party to whom the Personal Information was sold or shared;
  • The categories of Personal Information that we disclosed for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
Right to Delete: You have the right to request that we delete your Personal Information, subject to certain exceptions.

Right to Correct Inaccurate Personal Information: You have the right to request that we correct inaccurate Personal Information we maintain about you, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information.

Right to Opt-Out of Sale or Sharing:Prometheus does not sell Personal Information to third parties for monetary consideration. However, certain sharing of information with our third-party analytics and digital advertising vendors may qualify as a “sale” and is considered “sharing” under the CPRA. This data collection is not directly related to your relationship to Prometheus as our personnel but may be collected from any user of our websites generally. To opt-out of certain sharing of information with our third-party analytics and digital advertising service providers, you may set your preferences to reject analytics and advertising cookies by clicking the “Do Not Sell or Share My Personal Information” link at the bottom of the applicable Prometheus brand web page.

Right to Limit the Use and Disclosure of Sensitive Personal Information for Certain Purposes: As stated above, we do not use or disclose your Sensitive Personal Information for any purpose other than those permitted under the CPRA.

Freedom from Discrimination: You have the right not to receive discriminatory treatment for exercising your rights above, including not to be retaliated against for exercising such rights.

To exercise the rights above, you must submit a verifiable request to us by calling us at 1-888-977-1383 or submitting a request online at https://prometheusapartments.com/privacy/online-privacy-policy-portal. To submit a verifiable request, you will be asked to provide certain information to help us verify your identity. 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.


You may designate an authorized agent to make a request on your behalf by providing the agent with signed written permission to do so.

III. Changes to the Notice

Prometheus reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on Prometheus’s intranet site and on our notice boards, noting the notice’s effective date.

IV. Contact Information

If you have any questions or comments about this notice, including the ways in which Prometheus collects and uses your information, please do not hesitate to contact us at [email protected].