Overview

This Notice explains your rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CPRA”) (Cal. Civ. Code § 1798.100 et seq.). It helps you understand how Ono Management LLC, dba Ono Hawaiian BBQ, collects and uses your Personal Information in compliance with the CPRA. In this Notice, the terms “Company,” ”us,” “we,” “Ono,” and “our” refer to Ono Management LLC and its affiliates and subsidiaries. “Applicant” or “you” refer to job applicants or candidates for employment with Ono.

Who This Notice Applies To

The CPRA provides a right to notice at collection for certain California residents, including those applying to work at Ono.

This Notice does not cover:

• Your interactions with Ono outside the job application and recruiting context, such as browsing Ono’s website or dining at one of our restaurants. To learn more about how we collect and use information related to those types of interactions, please see our Ono Privacy Policy.

What We Collect

As further described below, Ono collects your Personal Information in connection with your application to work at Ono. Your “Personal Information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. Personal Information does not include publicly available information from government records, de-identified information, or aggregated data.

As described in greater detail below, we collect Personal Information in the following ways:

• Directly from You. We may collect Personal Information directly from you as part of the application and recruiting process, such as when you submit a job application and resume (whether directly to Ono or through a job search service or referral), are interviewed by us, or when you inquire about opportunities with us.
• From Third Parties. We may collect certain Personal Information about you from third parties. For example, this includes from vendors that run background checks and references you provide to us. Our employees may provide us with information about you in connection with your application to work for us. We may combine information that we collect from different sources.

The following discusses the categories of Personal Information we collected in the last twelve (12) months. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different purposes without first providing you notice.

•Personal Identifiers. We collect your name, address, telephone number, social media handle(s), online identifiers (i.e., username and/or password), signature, and email address from you during our recruitment processes.

• Characteristics of Protected Classifications Under California or Federal Law. If you receive a conditional offer of employment, we may collect information concerning your race, national origin, disability, marital status, sex, age, citizenship, or immigration status to establish your authorization to work in the United States and veteran or military status if you provide this information to us
• Professional or Employment-Related Information. During the recruitment process, we collect information about your employment history (i.e., your prior dates of employment, where you worked, and what jobs you previously held), including your resume.
• Education Information. We collect your education history from you as part of your application.

The following forms of data listed above constitute “Sensitive Personal Information”: Your race, national origin, citizenship and immigration status, and disability, if provided to us. We do not use or disclose Sensitive Personal Information, as defined by California law, for inferring characteristics or purposes other than those permitted by law.

How We Use the Information We Collect

We use the Personal Information we collect for the following purposes:

• Recruiting and Hiring. We use the personal information we collect from your application and the interview process to evaluate your qualifications and eligibility for employment. We do not consider any Characteristics of Protected Classifications Under California or Federal Law as part of our determination of whether you are qualified for employment with us.
• Onboarding. If you are given a conditional offer of employment, we may conduct a background check and, as a result, may use Personal Information as part of the background check process.
• Legal Compliance and Protection. We use the personal information we collect to comply with applicable laws, our legal obligations, and our defense of our company, property, and others through legal proceedings.

Please note that some of the internally provided applications and services we make available to you also include integrations, references, or links to services provided by providers whose privacy practices differ from ours. If you provide Personal Information via these integrations, references, or links or allow us to disclose It to them, that information is governed by their privacy statements. Finally, we may share de-identified information in accordance with applicable law.

Additional Rights Under California Law

You may have certain rights under California law. This may include a right to access, correct, or delete your data, subject to applicable exceptions. For example, we may retain your application data to comply with legal obligations. To exercise your rights, contact us as described at the end of this notice or use the webform https://onohawaiianbbq.com/general-inquiry/ on our website to submit a request.

Under California law, we are required to tell Californians if we “sell” or “share” Personal Information as that term is defined by applicable law. Sell is defined under the law as disclosing personal information to a third party for monetary or other valuable consideration. Share is specifically defined under the law as well. Sharing means sharing Personal Information with a third party for cross-context behavioral advertising.

We do not “sell” or “share” applicant data (including Personal Information and Sensitive Personal Information) based on our understanding of those terms. You may have different rights if you interact with the Company in other ways. For example, if you use our website, visit our privacy policy for information collection and rights for website users. If you are also an Ono customer or consumer, the privacy policy on our website applies to our interactions with you as a customer or consumer.

This notice does not affect other rights you may have under the California Labor Code or similar laws.

How We Retain Your Personal Information

To the extent permitted by applicable law, Ono will retain your Personal Information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to meet any legal, accounting, or other reporting requirements or obligations. For example, we retain Personal Information in accordance with our obligations under applicable labor and employment law and as necessary to administer and carry out the application and recruiting processes. We use the following criteria to determine retention periods:

• How long the information is needed to provide our services and operate our business;
• Whether there are contractual or legal obligations that exist that require us to retain the information for a period of time;
• Whether any law, statute, or regulation allows for a specific retention period;
• Whether an individual has agreed to a longer retention period;
• Whether the data is considered to be sensitive data; and
• What was the expectation for retention at the time the data was provided to us?

How You Are Protected Against Discrimination

Ono will not unlawfully discriminate against you for exercising your rights under the CPRA. This commitment applies to all persons involved in our operations and prohibits unlawful discrimination by any company employee.

Disclaimer

Nothing in this Notice restricts Ono’s ability to:

• Comply with federal, state, or local laws;
• Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
• Cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local law;
• Exercise or defend legal claims;
• Detect security incidents and protect against fraudulent or illegal activity and prosecute those responsible for such activity; or
• Transfer Personal Information as part of a merger or acquisition, dissolution, bankruptcy, or any other transaction in which a third party assumes control of all or part of the Company.

Changes To This Notice

This Notice is reviewed and updated annually to ensure it accurately captures our practices and procedures. In addition, from time to time, we may update this Notice to reflect changes required by law or our privacy practices or procedures. The effective date for this version is posted in the footer below.

Privacy Policy

Our Privacy Policy for applicants may be found here: https://onohawaiianbbq.com/Applicant-privacy-policy

Contact us

If you have any questions about this Notice or our handling of your Personal Information, please email us at [email protected] or 877-236-9081.