Candidate Privacy Policy

Activehours, Inc. dba Earnin and our affiliates and subsidiaries (referred together as “Earnin,” “we,” “our,” or “us”) respect individual privacy and take the privacy of your Personal Information seriously. 

When we refer to “Personal Information” we mean any information that relates to you as a particular individual. This includes information that directly identifies you (e.g., your name, social security number or other government-issued identifier, or employee ID number). 

This Candidate Privacy Policy (“Privacy Policy”) explains what types of Personal Information Earnin collects about job applicants and candidates (collectively “you” or “your”) and how such Personal Information may be used. 

1. What Personal Information Does Earnin Collect or Process?

In order to manage your application to Earnin, Earnin collects certain Personal Information from you.  The Personal Information that Earnin collects and uses about you includes: 

  • Application information (e.g., your resume, LinkedIn profile, references and information provided by your references) provided to Earnin or a third party site such as Greenhouse or Coderpad. 

  • Information from interviews and any phone-screenings you may have had, if any. 

  • Basic personal details (e.g., name, date of birth). If you are a family member of an employee, former employee or contractor, we may collect this information from the relevant individual you are related to.

  • Contact details (e.g.,telephone number, email address, postal address). If you are a family member of an employee, former employee or contractor, we may collect this information from the relevant individual you are related to.

  • Residency and work permit status, nationality and passport information. 

  • Information related to gender, race or ethnic origin for purposes of complying with applicable anti-discrimination or diversity legislation.

  • Where permitted by law and applicable we may collect the results of credit and criminal background checks, the results of drug and alcohol testing, screening, health certifications, driving license number, vehicle registration and driving history.

  • Information captured on security systems, including Closed Circuit Television (“CCTV”) and entry systems.

  • Information relating to any previous applications you may have made to Earnin and/or any previous employment history with Earnin. 

  • Any other information that you provide directly to us.

2. How Does Earnin Collect Personal Information?

Generally, we collect Personal Information directly from you in the circumstances where you provide Personal Information (e.g., submitting an Application). However, in some instances, the Personal Information we collect has been inferred about you based on other information you provide us, through your interactions with us, or from third parties.  When Earnin collects your Personal Information from third parties, it is either because you have given us express permission to do so, your permission was implied by your actions (e.g., providing references for Earnin to contact), or because you provided explicit or implicit permission to the third party to provide the personal information to us).

3. What Does Earnin Do With Your Personal Information and Why Is It Processed?

We use your Personal Information to manage the application process, including but not limited to: 

  • To manage all aspects of your employment application. Examples of activities related to this include: determining eligibility for initial employment, verification of references and qualifications; and managing required travel if any. 

  • Assisting you with obtaining an immigration visa or work permit where required.

  • For use in video conferencing.

  • For applicant satisfaction programs, including surveys.

  • To protect the safety and security of our workforce, guests, property, and assets.

  • If applicable, to investigate and respond to claims against us.

  • Carry out any additional purposes that we advise you of (if applicable law requires your express consent for such additional use or disclosure we will obtain it from you).

4. Sensitive Personal Information and Why Earnin Processes It 

Sensitive Personal Information is a subset of personal information that may be more sensitive in nature for the individual concerned and includes:

  • Race and ethnic information.

  • Sexual orientation.

  • Gender Identity.

  • Political/religious beliefs.

  • Social security or other taxpayer/government issued identification numbers.

  • Financial information.

  • Health or medical information.

  • Criminal records.

  • Credit Reports.

When applicable, we collect and use these types of information in some limited circumstances where it is necessary for us the application process (e.g., background checks), where we need to do so to comply with specific legal obligations (e.g., equal opportunity or anti-discrimination legislation), or where we have your explicit consent to use it.  Some of the purposes for which Sensitive Personal Information may be used include the following:

  • Compliance with equal opportunity or anti-discrimination legislation or regulations(where applicable).

  • Background checks for employment or client engagement purposes, where permitted by applicable laws.

5. What Does Earnin Do With Aggregated Data And Why Is It Processed?

Earnin may also collect and/or generate information from your use of Earnin Wi-Fi, applications, systems, and websites. Such anonymized or aggregated information is not Personal Information since we are not able to re-identify you by using any available means to us. For further information, please see the Earnin Privacy Policy. 

6. How Do We Share Information with Third Parties?

Your personal information may be shared, including our affiliates, subsidiaries, and other third parties, as follows:

  • Where you request us or provide your consent to us.

  • In order to carry out the uses of Personal Information described above (see Sections 3 and 4).

  • When using or collaborating with third parties in the application process (e.g. your submission of an application on a third party site or Earnin’s use of such sites to track and manage the application process). 

  • Where required by law, by order or requirement of a court, administrative agency, or government tribunal, which includes in response to a lawful request by public authorities, including to meet national security or law enforcement requirements or in response to legal process.

  • As necessary to protect the rights, privacy, safety, or property of an identifiable person or group or to detect, prevent or otherwise address fraud, security or technical issues, or to protect against harm to the rights, property or safety of Earnin, our users, applicants, candidates, employees or the public or as otherwise required by law.

  • Where the personal information is public.

  • Where appropriate, to speak with Earnin’s professional advisers (e.g. bankers, lawyers, accountants) and potential buyers and vendors.

We will endeavor to obtain assurances from each third party with whom we share your Personal Information that it will safeguard your Personal Information consistently with this Privacy Policy and will notify Earnin if it makes a determination it can no longer meet this obligation. 

7. Correction of Collected Personal Information

We endeavor to ensure that Personal Information in our possession is accurate, current and complete. If an individual believes that the Personal Information about them is incorrect, incomplete or outdated, they may request the revision or correction of that information. We reserve the right not to change any personal information we consider is accurate.

If it is determined that Personal Information is inaccurate, incomplete or outdated, we will use reasonable efforts to revise it and, if necessary, use reasonable efforts to inform agents, service providers or other third parties, which were provided with inaccurate information, so records in their possession may be corrected or updated.

8. Retention of Collected Information The length of time we retain your Personal Information depends on the status of our relationship with you and the requirements of any applicable laws. Earnin will retain your Personal Information for a certain period after your application has been received. 

To determine that period, we take into account our legal and regulatory obligations (such as financial reporting obligations and equal opportunity or anti-discrimination reporting obligations) and whether we may need to retain personal information to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes and/or enforce our agreements.

9. Resolving Concerns Regarding Personal InformationIf you have questions or concerns regarding the handling of your Personal Information please contact HR@earnin.com. Alternatively, you may report concerns or complaints, including information about potential data breaches involving Personal Information to the Legal Department at privacy@earnin.com.

10. Changes to Privacy PolicyThis Privacy Policy is reviewed periodically to ensure it accurately captures all types of data collected or any additional or different processing of such data. We may, therefore, change this Privacy Policy at any time. The effective date of each version of this Privacy Policy is identified below.

11. Security of Collected Information We are committed to protecting the security of the Personal Information collected, and we take reasonable physical, electronic, and administrative safeguards to help protect the information from unauthorized or inappropriate access or use.