Employee & Applicant Privacy Policy

This Notice of Privacy Practices for Job Applicants (“Applicant Notice”) explains how Buffalo Exchange, Ltd. (“Buffalo Exchange,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information in connection with our recruiting and hiring activities.

This Applicant Notice applies to individuals who apply for employment with Buffalo Exchange, whether online, in person, or through third parties. If you use our websites or other services outside of the application process, additional privacy notices may apply.

This Privacy Policy is intended to be reasonably accessible to people with disabilities. If you experience any difficulty accessing this information, please email us at [email protected] or write to us at PO Box 40488, Tucson, AZ 85717.

When you apply for a job with Buffalo Exchange, we may collect personal information to evaluate and manage your application, including:

• Contact information: name, mailing address, email address and telephone number.
• Employment and background information: work/volunteer history, job titles, education, degrees, certifications, language skills, hobbies, and other qualifications;
• References: names and contact details of references and information they provide;
  Work authorization information: eligibility to work in the applicable country;
• Recruitment-related communications: correspondence with you and notes from interviews;
• Online activity: information about your interaction with our career sites or application platforms, including device and usage data, as described in our Privacy Policy and Terms of Use (where applicable);
• Social media information: information from professional or social networking sites if you choose to provide it or link your application; and
• Other information you voluntarily provide: such as employment preferences, availability, willingness to relocate, or desired compensation.
• Sensitive Personal Information: As part of a background check, we may collect Sensitive Personal Information. See below for more information.

Sensitive Personal Information

Certain information may be considered “sensitive personal information” or “special category data” under applicable laws. This may include, where permitted and required by law:

• Race, ethnicity, nationality, or national origin (typically only if voluntarily disclosed);
• Age, gender, gender identity, sex, sexual orientation, or marital status ((typically only if voluntarily disclosed);
• Veteran or military status (typically only if voluntarily disclosed);
• Disability or health-related information (for accommodation or compliance purposes);
• Criminal history or background check information (where legally permitted);
• Religious, philosophical, political, or trade union information (typically only if voluntarily disclosed).

Under the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), sensitive personal information may also include identifiers such as Social Security numbers, driver’s license or passport numbers, and account login credentials.

We use Sensitive Personal Information only for purposes permitted under the California Privacy Rights Act, including to provide requested services, verify identity, prevent fraud, ensure security, and comply with legal obligations. We do not use Sensitive Personal Information to infer characteristics about individuals.

Because we use Sensitive Personal Information solely for these limited and permitted purposes, Buffalo Exchange does not use or disclose Sensitive Personal Information in a manner that requires offering a separate “Limit the Use of My Sensitive Personal Information” link under California law. California residents may nonetheless submit questions or requests regarding Sensitive Personal Information using the methods described in the “California Privacy Notice” section below.

Depending on the role and stage of the hiring process, we may also receive information from third parties such as recruiting platforms, background check providers, references, former employers, or public sources, where permitted by law.

We use applicant information for human resources and business purposes, including to:

• Evaluate your qualifications, skills, and suitability for the role you applied for or other open positions within Buffalo Exchange;
• Communicate with you about your application, interviews, offers, or other opportunities;
• Conduct background checks, employment verification, or reference checks, where permitted by law;
• Maintain recruiting records and manage hiring operations;
• Protect the security and integrity of our recruitment systems; and
• Comply with applicable legal, regulatory, and reporting obligations.

We may aggregate or de-identify applicant information and use it for analytics, reporting, and improvement of our recruitment processes.

You are responsible for ensuring that the information you provide during the application process is accurate, complete, and not misleading.

We may share applicant information in the following circumstances:

• Service providers and vendors: with third parties that assist us with recruiting, application processing, background checks, technology services, analytics, or communications, under contractual obligations to protect your data;
• Affiliates: with entities under common ownership or control with Buffalo Exchange for business and Human Resources purposes;
• Legal and compliance purposes: where required or permitted by law, such as responding to lawful requests from government authorities, enforcing our policies, or protecting our rights, employees, and applicants.

We do not sell applicant personal information.

Our career websites and application platforms may use cookies and similar technologies to operate effectively and improve the applicant experience. For more information, please review our applicable Cookie Notice.

We retain applicant personal information for as long as reasonably necessary to fulfill recruitment and hiring purposes, comply with legal obligations, resolve disputes, and enforce our policies. Retention periods may vary depending on the role, location, and applicable law.

When applicant information is no longer required, we securely dispose of it through physical destruction, electronic deletion, or anonymization.

Buffalo Exchange implements appropriate administrative, technical, and physical safeguards designed to protect applicant personal information against unauthorized access, loss, misuse, or disclosure. While we take reasonable steps to protect your information, no system can be guaranteed to be completely secure.

If you believe your interaction with us is no longer secure, please contact us promptly using the details below.

For California residents, Buffalo Exchange collects the categories of personal information described in this Applicant Notice for the purposes outlined in Section 2. Categories may include identifiers, professional or employment-related information, education information, internet activity related to our recruiting systems, and sensitive personal information where permitted by law.

We do not sell applicant personal information for cross-context behavioral advertising.

California residents have rights under the CCPA/CPRA, including the right to access, correct, or delete personal information, subject to certain exceptions, and the right to non-discrimination for exercising those rights.

Buffalo Exchange is headquartered in the United States. If you apply from outside the U.S., your personal information may be transferred to, stored, and processed in the United States or other countries where we or our service providers operate. We take steps to ensure appropriate safeguards are in place for such transfers as required by applicable law.

We may update this Applicant Notice from time to time. Any changes will be posted with an updated “Last Updated” date. Changes are effective upon posting.

If you have questions about this Applicant Notice or our handling of applicant personal information, please contact:

• Online: https://buffaloexchange.com/contact-us/
• Phone: (520) 622-2711
• Mail: Buffalo Exchange, PO Box 40488, Tucson, AZ 85717