Legal

California Job Applicant Privacy Notice

In compliance with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”), Ooma, Inc. (“Ooma”) is providing you with this Job Applicant California Privacy Notice (“Notice”) to inform you about:

The categories and types of Personal Information Ooma collects about applicants who reside in California; and
The purposes for which Ooma uses your Personal Information.

“Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonable be linked, directly or indirectly, with a natural person that Ooma collects about its applicants, who reside in California, in their capacity as applicants for positions with Ooma.

Persons with disabilities may obtain this Notice in an alternative format upon request by contacting us at privacy@ooma.com. This Notice supplements the information contained in Ooma’s Privacy Policy.

Personal Information We Collect

In the course of applying for a position with Ooma, we may collect the following categories and types of Performance Information. This information may be used for the following identified purposes during the application process, prior to onboarding as an employee:

Category	Personal Information	Purposes
Identifiers and Professional or Employment-Related Information	Identifiers: real name, former name, nickname or alias, postal address, social media address, telephone number, e-mail address, signature, Internet Protocol address, Social Security number, online identifier, driver’s license number or passport number. Professional or Employment Related Information: membership in professional organizations, professional certifications, licensure information, and employment history.	To evaluate applicants’ qualifications for employment with Ooma. To administer background, clearance, and driving record checks, and other investigative consumer reports, as applicable. To determine eligibility for employment, including confirming and ensuring compliance of California employees’ ability to work in the United States. To communicate with applicants. To create a talent pool for future job openings. For recordkeeping purposes. To demonstrate applicants’ agreement to, or acceptance of documents presented to them (e.g., pre-employment arbitration, acknowledgement for employment application, offer letter). To evaluate and improve the recruiting process.
Personal Information Categories Listed in the California Customer Records Statute	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. Some Personal Information included in this category may overlap with other categories.	To evaluate applicants’ qualifications for employment with Ooma. To administer background, clearance, and driving record checks, and other investigative consumer reports, as applicable. To determine eligibility for employment, including confirming and ensuring compliance of California employees’ ability to work in the United States. To communicate with applicants. To create a talent pool for future job openings. For recordkeeping purposes. To demonstrate applicants’ agreement to, or acceptance of documents presented to them (e.g., pre-employment arbitration, acknowledgement for employment application, offer letter). To evaluate and improve the recruiting process.
Protected Classifications under California or Federal Law * Ooma collects this category of Personal Information on a purely voluntary basis, except where collection is required by law, and uses the information online in compliance with applicable laws and regulations.	Race, color, ancestry, national origin, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, and pregnancy or childbirth and related medical conditions), sexual orientation, veteran, or military status.	As necessary to comply with legal obligations, including but not limited to, the reporting requirements of the federal Equal Employment Opportunity Act (“EEOC”), and California’s Fair Employment and Housing Act. Ooma also uses this Personal Information to report on diversity and inclusion.
Internet or Other Electronic Network Activity Information	If you apply on Ooma’s career page, Ooma may collect your IP address or other unique device identifiers, information collected by cookies on your usage of our career page, mobile carrier (if applicable), time zone setting, operating system and platform, browser software, and information regarding your use of the portal or website including date and time of visit.	Ooma may collect certain internet information automatically when you submit an application on our career page, as necessary to transmit your information electronically for consideration as well as monitor, detect, investigate and prevent prohibited or illegal behaviors, to combat spam and other security risks.
Geolocation	If you apply on Ooma’s career page, cookies on our career website may collect geolocation data.	Ooma’s career page may capture your geolocation automatically when you submit an application as necessary to transmit your information electronically for consideration. You may also choose to provide your location when submitting an application, or within your Resume/CV.
Sensory or Surveillance Data	Footage from video surveillance cameras and voicemail recordings and other audio or visual information.	To protect the safety and security of Ooma’s facilities and personnel through video surveillance. To communicate and receive messages with applicants.
Education Information	Academic transcripts and current or past job history.	To evaluate applicants’ qualifications for employment with Ooma. Pre-employment background checks.
Inferences	Inferences drawn from Personal Information to create a profile about applicant reflecting applicant’s: Intelligence Abilities Aptitudes	To evaluate applicants’ qualifications for employment with Ooma.

Other Purposes Potentially Applicable to Any Categories of Personal Information Listed Above

Ooma may also use applicants’ Personal Information to facilitate administrative functions, information technology operations, and corporate transactions, and for legal reasons. These functions may include:

To manage litigation and other legal disputes and inquiries involving Ooma, and to meet legal and regulatory requirements;
In connections with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other change of control or financial status of Ooma or any of its subsidiaries or affiliates; and
To manage licenses, permits, and authorizations applicable to Ooma’s business operations.

Information Provided About Other Individuals

If you provide us with Personal Information of a reference or any other individual as a part of your application, it is your responsibility to inform them of this Notice and obtain consent from that individual prior to providing information to Ooma.

Data Sharing

We do not sell, rent, or otherwise disclose Personal Information we collect to third parties for monetary or other valuable considerations. We will only disclose job applicants’ Personal Information to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the recruitment process, including third-party service providers who provide services to us or on our behalf. We may use third-party service providers for various purposes, including, but not limited to, obtaining employment verification and background checks.

We require all our third-party service providers, by written contract, to implement appropriate security measures to protect job applicants’ Personal Information consistent with our policies and any data security obligations applicable to us. We do not permit our third-party service providers to use job applicants’ Personal Information for their own purposes. We only permit them to process job applicants’ Personal Information for specified purposes in accordance with our instructions.

We may also disclose your Personal Information for the following additional purposes, where permitted or required by applicable law:

To a recruiting firm to assist in our recruiting efforts.
To subsidiaries or affiliates of Ooma for the purposes set out in this Notice and as necessary to administer the application and recruitment process.
To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose job applicants’ Personal Information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum Personal Information necessary for the specific purpose and circumstances.
To protect the rights and property of Ooma.
During emergency situations or where necessary to protect the safety of persons.
Where the personal Information is publicly available.
For additional purposes with the job applicant’s consent where such consent is required by law.

Data Security

We have implemented appropriate physical, technical, and organizational security measures designed to secure job applicants’ Personal Information against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to Personal Information to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain job applicants’ Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize the Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

If you are offered and accept employment with Ooma, the Personal Information we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our employee Personal Information policies. If you do not become an employee, or, once you are no longer an employee of Ooma, we will retain and securely destroy your Personal Information in accordance with our document retention policy and applicable laws and regulations.

Changes to this Notice

Ooma reserves the right to amend this Notice in its discretion and at any time. As required by the CCPA and CPRA, Ooma will review and revise this Notice on an annual basis. Updates to this Notice will be posted on the careers section of Ooma’s website.

Contact Information

If you have any questions about this Privacy Notice or concerns about how we manage your personal information, please email privacy@ooma.com. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you.

Effective Date and Updates

Effective Date: January 1, 2023

Last Updated: December 19, 2023