CCPA/CPRA notice for candidates applying to jobs at Xsolis

California law requires that we provide you this notice about the collection and use of your personal information. We encourage you to read it carefully.

Effective Date: June 1, 2026 

1. Introduction
This notice (“Notice”) describes the categories of personal information that Xsolis, Inc. (“Company”, “we”, “us” and “our”) collects about California residents who apply or are recruited for a job with us (“candidates”), and the purposes for which we use that information. 

For purposes of this Notice, “personal information” has the meaning given in the California Consumer Privacy Act of 2018 (the “CCPA”), as amended by the California Privacy Rights Act of 2020, but excludes information exempted from the CCPA’s scope. Further, per California law, Xsolis is the “business” that determines the purposes and means of processing your personal information. Greenhouse acts as a ‘service provider’ (or ‘contractor’) in providing recruitment technology services. The sharing of information is additionally covered in section 3.2 and rights under California law are covered in Section 4. 

This Notice does not create or form part of any contract for employment or otherwise. 

If you have questions about this Notice, please contact the People Operations, using the contact information set forth below: 

Xsolis, Inc. 
4031 Aspen Grove Dr. Ste. 500 
Franklin, TN 37067 
 
2. Information we collect about candidates 
 
2.1 Categories of personal information
The categories of personal information we may collect and process during the application and recruitment process include:

• Contact information, such as home address, telephone number, and email address;
• Information from job application materials or recruiters, such as your job application, resume or CV, cover letter, references, education history, work history, whether you are subject to prior employer obligations, and information that referrers provide about you;
• Professional qualifications, such as licenses, permits, memberships, and certifications;
• Information from the application process, such as any phone-screens, interviews, evaluations and outcomes of take home tests and other recruiting exercises;
• Immigration status and other information that would allow us to verify your employment eligibility;
• Biographical information, such as name, gender, date of birth, professional history, references, language proficiencies, education details, and information you make publicly available through job search or career networking sites;
• Job preferences, such as desired position and compensation, location preferences and willingness to relocate;
• Employment history;
• Background check information, such as information necessary to complete background, credit, and/or other checks when permitted by law, and information received during these checks;
• Information needed to understand and assess accommodation requests regarding potential disabilities or other health conditions; and
• Other information you provide to us. 

Providing personal information to us is voluntary. However, if you do not provide sufficient information, we may be unable to consider your application or, if you are hired, your subsequent promotion, transfer or relocation. 

In certain cases we may ask you for additional information for purposes of complying with applicable laws. We may also inquire about criminal records. We will do so only where permitted by applicable law. 
 
2.2 Sources of personal information
We collect personal information from you when you apply for a job and throughout the job application or recruitment process. We may also collect your personal information from other sources and combine it with the personal information you provide us. For example, we may collect your personal information from: 

• Job board websites you may use to apply for a job with us;
• Prior employers that provide us with employment references;
• Professional references that you authorize us to contact;
• Pre-employment screening services, such as background check providers (where permitted by law);
• Employment agencies and recruiters;
• Your educational institutions;
• Your public social media profile or other publicly-available sources;
• Online activity information that we and our service providers collect using server logs, “cookies” and similar technologies on the Careers Site. Please see our Privacy Policy for more information.
• Other Company personnel. 

3. How we use personal information about candidates 
 
3.1 Purposes for which we use personal information
We may use the categories of personal information above for the following purposes: 
 
Recruitment management. Managing recruitment generally, such as: 

• operating the careers website we maintain at https://www.xsolis.com/about/careers  or any other site to which this Notice is posted (“Careers Site”);
• recruiting, interviewing and evaluating job candidates;
• conducting background checks and other pre-employment screening (where permitted by law);
• analyzing and improving our application and recruitment processes;
• accommodating disabilities or health conditions;
• communicating with you regarding your candidacy, opportunities with the Company or about the Careers Site and any changes to applicable terms or policies; and
• other business operations.  

Compliance, safety and fraud prevention, such as: 

• complying with or monitoring compliance with legal and other requirements, such as reporting and equal opportunities monitoring requirements, where applicable;
• complying with internal policies and procedures;
• complying with lawful requests and legal process, such as responding to subpoenas or requests from government authorities;
• protecting our, your or others’ rights, safety and property;
• investigating and deterring against fraudulent, harmful, unauthorized, unethical or illegal activity, or conduct in violation of our policies or procedures; and
• sharing information with government authorities, law enforcement, courts or private parties where we have a good-faith belief it is necessary for the foregoing purposes. 

Analytics. Creating anonymous, aggregated or de-identified data that we use and share to analyze our application and recruitment activities, business and for other lawful business purposes. 

3.2 Sharing personal information
We may share your personal information with other parties as necessary for the purposes described above. For example, we may share your personal information with: 

• Affiliates. Our corporate parent, subsidiaries, and other affiliates under the control of our corporate parent, for purposes consistent with this Notice or to operate shared infrastructure, systems and technology.
• Company service providers. Companies that provide us with services that help us manage the recruiting process and operate our business, such as job boards, recruiters, interviewing and testing, pre-employment screening, interview travel booking and expense reimbursement (where applicable), relocation (where applicable), and recruitment analytics.
• Government authorities, law enforcement, courts, and others as described in the compliance, safety and fraud prevention section above.
• Business transfers. Parties to transactions and potential transactions whereby we sell, transfer or otherwise share some or all of our business or assets, including your personal information, such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
• Professional advisors. Lawyers, immigration advisors, and other outside professional advisors.
• Customers and business partners. Customers, other companies and individuals with whom the Company does business or is exploring a business relationship. 

4. Your California Privacy Rights
As a California resident applying for employment, you have the following rights under the California Consumer Privacy Act (CCPA): 

4.1 Right to Know
You have the right to request that we disclose to you: 

• The categories of personal information we have collected about you
• The categories of sources from which we collected your personal information
• The business or commercial purpose for collecting your personal information
• The categories of third parties with whom we share your personal information
• The specific pieces of personal information we have collected about you 

4.2 Right to Delete 
You have the right to request that we delete any personal information about you that we have collected, subject to certain exceptions under the law.

4.3 Right to Correct
You have the right to request that we correct inaccurate personal information that we maintain about you. 

4.4 Right to Opt-Out
Xsolis does not “sell” or “share” its candidates’ personal information for cross-context behavioral advertising purposes, as those terms are defined under California law. Because Xsolis does not sell or share candidate personal information (as defined by CA law), the right to opt-out of sale or sharing does not apply in this context.

4.5 Right to Non-Discrimination 
We will not discriminate against you for exercising any of your CCPA rights, including by: 

• Denying you employment or consideration for employment
• Providing a different level or quality of employment-related services
• Suggesting that you will receive a different level of consideration or employment opportunity
• Retaliating against you as an applicant or employee 

4.6 How to Exercise Your Rights
To submit a request to know, delete, or correct your personal information: 

Email us at PeopleOperations@xsolis.com with “CCPA Request” in the subject line

Mail us at:  
Xsolis, Inc. 
Attn: Privacy – CCPA Request 
4031 Aspen Grove Dr. Ste 500 
Franklin, TN  37067 
‍ 
Opting-out of sale/sharing:
As noted above, Xsolis does not “sell” or “share” its candidates’ personal information for cross-context behavioral advertising purposes, as those terms are defined under California law. 

4.7 Verification Process
To protect your privacy, we will verify your identity before processing your request. We may ask you to provide information such as your name, email address, and details about your application to confirm your identity. 

4.8 Response Timeframes
We will respond to your requests within 45 days of receipt. If we need additional time (up to 90 days total), we will inform you of the reason and extension period in writing. 

4.9 Authorized Agents
You may designate an authorized agent to make requests on your behalf. We will require proof of authorization and may still ask you to verify your identity directly with us. 

4.10 Data Retention
We retain personal information collected during the recruitment process for as long as necessary to fulfill the purposes described in this Notice, comply with our legal obligations, resolve disputes, and enforce our agreements. The specific retention periods depend on the nature of the information and the outcome of your application. 

How We Determine Retention Periods
We consider the following criteria when establishing retention periods: 

• Legal and regulatory obligations – Requirements under federal and state employment laws, including recordkeeping obligations under Title VII, EEOC regulations, and applicable California law
• Statutes of limitations – Retention sufficient to defend against potential legal claims arising from the recruitment process
• Business necessity – Operational needs related to workforce planning, auditing, and reporting
• Security and fraud prevention – Protection against unauthorized access or misuse of personal information 

Unsuccessful Candidates
If your application does not result in an offer of employment, or if you withdraw your application, we will generally retain your personal information for up to 2 years from the date your application is closed or the position is filled, whichever is later. 

We retain this information to: 

• Comply with EEOC and OFCCP recordkeeping requirements (typically a minimum of 1–2 years)
• Consider you for future openings, where you have consented to such consideration
• Defend against potential legal claims related to the recruitment process 

After this period, your personal information will be securely deleted or de-identified in accordance with our data disposal procedures, unless a longer retention period is required or permitted by applicable law. 

Successful Candidates (New Hires)
If your application results in an offer of employment that you accept, the personal information collected during the recruitment process will be transferred to and retained as part of your employee record in our human resources information systems.

Your personal information will then be subject to our employee privacy notice, which governs how we collect, use, and retain personal information throughout the employment relationship. You will receive a copy of the Employee Privacy Notice upon hire.

Recruitment records that are no longer needed for HR purposes will be retained in accordance with our standard employment recordkeeping schedule and applicable law, and securely disposed of thereafter. 

Special Categories of Information
Certain sensitive personal information collected during recruitment — such as background check results, drug screening records, or medical/disability-related information — may be subject to separate or longer retention periods as required by applicable federal or state law. Such records are maintained separately and with appropriate access controls. 

Your Rights Regarding Retained Data
You may have the right to request access to or deletion of your personal information, subject to certain legal exceptions. Please refer to Section 4.6 How to Exercise Your Rights section of this Notice for more information on how to submit a request. 

5. Other information about this Notice 
 
5.1 Third parties
This Notice does not address, and we are not responsible for, the practices of any third parties, which have their own rules for how they collect and use your personal information. Our links to third party websites or services are not endorsements. 

5.2 Changes to this Notice
We reserve the right to change this Notice at any time. The “Effective Date” heading at the top of this Notice indicates when it was last revised. Any changes will become effective when we post the revised notice on our Careers Site. 

5.3 Children
The Careers Site is not intended for minors under the age of 18. 
 
6. Your obligations
Among other obligations, including without limitation the obligation to provide complete and accurate information in recruiting documents and processes, it is your responsibility to ensure that information you submit does not violate any third party’s rights. 

You should keep your personal information on file with the Company up to date and inform us of any significant changes to it. 
 

 

 

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