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Mariner Employee & Applicant Privacy Notice

Table of Contents

Introduction

Mariner Wealth Advisors, LLC (“Mariner”, “we”, “our” or “us”) is committed to safeguarding your privacy. This Employee & Applicant Privacy Notice (“Notice”) describes the personal information that Mariner collects and processes about you as an applicant, as well as during and after your employment.

Pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), we are required to provide California employees and job applicants with a Notice that contains a comprehensive description of our online and offline practices regarding our collection, use, sale, sharing, and retention of their personal information as well as a description of the rights they have regarding their personal information. This Notice provides the information the CCPA requires as well as other useful information regarding our collection and use of personal information.

Please review this Notice carefully. From time to time, we may change this Notice. If we do, we will post an amended version on our webpage and on our internal employee communication platform. You also may receive a copy at any time by contacting us at [email protected]. 

Accessibility

We are committed to ensuring this Notice is accessible to individuals with disabilities. If you wish to access this Notice in an alternative format, please contact us as at [email protected]. 

Scope

When This Notice Applies

This Notice is intended solely for, and is applicable only to, current and former California employees. Where relevant, it also applies to California resident job applicants, interns, agency workers, contractors, consultants, directors, and other individuals whose information we collect in connection with providing employment (such as dependents, family members, beneficiaries, and emergency contacts of employees). For ease of reference, this Notice generally refers to employee data, but this does not indicate in any way that an individual is our employee.

When This Policy Does Not Apply

This policy applies only to California residents who are Employees or Job Applicants. If you are a California resident interacting with us in any other capacity (such as a website visitor, customer, supplier, or candidate), please refer to Mariner Privacy Policy. 

This Notice also does not apply to our collection and use of your personal information in a consumer or business-to-business capacity, such as your interaction with our website. For more information on our collection and use of your personal information in that capacity, including how we process opt-out preference signals, please see the Mariner Privacy Policy.

Certain Company services and website features may be supported by third party vendors that utilize AI technology. When utilizing the website chatbot and utilizing our candidate screening assessment, our AI vendor(s) Humanly may record and transcribe information and may access the information in real-time and use the information for providing the services. By using the chatbot feature and by submitting a job application, you consent to the collection and analysis of any Personal Information provided. If you do not consent to such use and disclosure, please do NOT use the chatbot feature and ensure you select the opt out for artificial intelligence in your application. For more information on how Humanly may use or disclose Personal Information, please review their privacy policy HERE.

California Notice at Collection of Personal Information

Personal Information We Collect

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified, or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this Notice, we will refer to this information as “Personal Information.” 

While we provide this California Notice at Collection as part of this Notice, you may also view the California Notice at Collection for Employees and Job Applicants as a stand-alone document.

We currently collect and, in the 12 months prior to the Effective Date of this Notice, have collected the following categories of Personal Information from you (what we specifically collect will depend on where you are in the job applicant to employment lifecycle). The examples provided in each category are not intended to be an exhaustive list or an indication of all specific pieces of information we collect from or about you in each category, but rather the examples are to provide a meaningful understanding of the types of information that may be collected within each category.

  • Identifying Information: such as your full name, gender, date of birth, marital status, employee ID number, signatures
  • Contact Information: such as your Email address, telephone number, postal address, and contact information for you and for your referrals, references, or emergency contacts.
  • National Identifiers: such as your SSN, Driver’s License Number, passport and visa information and immigration status and documentation
  • Dependents’ Information: such as your dependents’ and their respective names, address, date of birth and Social Security Number (SSN)
  • Educational and Professional Background: such as your work history, resume/CV, academic and professional qualifications and history, certifications, language proficiencies, awards, security clearance information, and other work-related skills
  • Employment Details: such as your job title, position, hire dates, base pay, bonus, commission, expense reimbursement, incentive pay and any other wage related information; performance and disciplinary records; timekeeping records including vacation and sick leave records; training records; and personality assessment information that you may take as part of the interview process or while you are an employee 
  • Background Check Information: such as your background check, credit check, education verification, employment verification, and/or drug testing results (where you have provided consent for such screenings)
  • Benefits Administration Information: such as your benefits enrollment information, including Dependents’ Information you provide
  • Career Planning Information: such as your career interests, desired compensation and benefits, desired work location and willingness to relocate, family information you provide as it relates to your career goals or plans, hobbies and interests
  • Financial Information: such as your bank account routing and account information, tax information, payroll information and withholdings, and credit card information (for example if you choose to provide it for booking a hotel for work travel)
  • Health and Safety Information:  such as your absence or leave records that contain health-related information (for example information about pregnancy, illness or other medical leaves of absence); information about your health as part of required occupational health screenings or related to a workplace injury; health information related to disability or other accommodation requests; health information related to COVID-19 symptoms, COVID-19 testing results, or COVID-19 vaccination status. Health information we hold about employees related to our self-funded medical plans is covered by our HIPAA Privacy Notice and not this Notice. You can obtain a copy of our HIPAA Privacy Notice from our intranet, our benefits website or by sending an email to [email protected].
  • Geolocation Information: such as time and physical location related to your logging into our network or applications or using your badge to enter one of our office locations.
  • Biometric Information: We do not collect biometric information.
  • Characteristics of Protected Classifications under California or Federal Law: Your race and national or ethnic origin, gender, and veteran status (for example in order to complete legally required EEO-1 or OFCCP reporting or other DEI company initiatives); disability status, information about religion (including religious dress and grooming practices and sincerely held religious belief, practice or observance), for example as part of a request for an accommodation; pregnancy and childbirth information (for example when you request FMLA leave or short-term disability); status as a victim of domestic violence, assault or stalking (if you request time off or an accommodation as allowed under law); union membership (if as part of working for one of our clients you are part of a union).
  • Physical Characteristics or Descriptions: Information on your driver’s license (such as eye color, hair color, height, weight), as well as information collected to the extent relevant for workplace investigations or for enforcement of Mariner policies on appearance and grooming (such as tattoos, piercings).
  • Audio, Visual or Similar Information: Photographs (for example your photo for our intranet or photos of you at company events), video interviews, help desk phone call recordings, WebEx/Teams video and audio recordings and video captured by our security systems.
  • Device Information: Your IP address, browser type and version, browser plug-in types and versions, operating system and platforms of the Mariner Electronic Resources (e.g., computers and other devices) you operate.
  • Internet, Network, and Computer Activity: Internet or other electronic network activity information related to usage of Mariner networks, servers, intranet, shared drives, or Mariner-issued computers and electronic devices, including system and file access logs, security clearance level, browsing history, search history, and usage history; data from employee devices identifying which devices access Mariner networks and systems, including cell phone make, model, and serial number, cell phone number, and cell phone provider.
  • Inferences: based on the analysis of the Personal Information collected, the Company may develop inferences regarding your predispositions, behavior, attitudes, intelligence, abilities, and aptitudes for purposes of recruiting and hiring assessments and decisions.
  • Other Information You Provide: including any other Personal Information you may elect to provide to us. If you use Company email, phones, computers, online chat applications (Slack, Teams, Zoom, etc.) or other Company systems for personal communications where the Company is not the intended recipient of the communication, the Company retains these communications in the ordinary course of managing its communication and computer systems and pursuant to the Company’s data retention policy. Employees have no expectation of privacy with respect to any communications or data they send, receive, access or store on any Company computer or system, including any personal communications. The Company may monitor, access, review and use all such communications and data for lawful business purposes detailed below, including to manage and evaluate employee performance and make employment decisions.

What Sensitive Personal Information We Collect

Of the above categories of Personal Information, the following are categories of Sensitive Personal Information we plan to collect and have collected in the 12 months prior to the Effective Date of this Notice:

  • Personal Identifiers (social security, driver’s license, state identification card, or passport number)
  • Account Information (your Company account log-in, in combination with any required security or access code, password, or credentials allowing access to the account)
  • Protected Classifications (racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, union membership, or sexual orientation)
  • Medical and Health Information
  • Geolocation Data (IP address)
  • Contents of Personal Communications (contents of mail, email, and text messages where the Company is not the intended recipient)
  • Data of a Known Child (under 16 years of age) such as dependents of employees

Sources of Personal Information

  • Information you submit to us: Where we request information from you, we will inform you prior to collection whether the provision of the Personal Information may be provided on a voluntary basis, and the consequences of not providing the information, which may include being unable to properly provide you with Services.
  • Information we obtain from other parties: We may receive or acquire information about you from other parties such as: 
  • Websites and services like job boards and professional network sites (for example LinkedIn) and social media platforms and websites where you post information;
  • Clients (for example a client may provide current or prospective candidates for us to consider for a job they have asked us to fill);
  • Mariner Employees (for example an existing employee may provide current or prospective candidates for us to consider for a job)
  • Business intelligence sources, including data aggregators and list providers;
  • Your referrals and references (for example a referral who refers you to us for a potential job opportunity or a reference you provide to us);
  • Trade journals and news sources (for example industry publications); and
  • Mariner affiliates, which are companies that have ownership in Mariner, that are owned by Mariner, or are under common control with Mariner. 
  • Information we collect or create through our own observations: For example, through company systems, networks, software applicants, and databases you log into or use in the course of applying for a position with the Company, including vendors the Company engages to manage or host such systems, networks, applications, or databases; as well as through surveillance cameras at our physical locations. Inferences (as described above) also fall in this source category.

Any Personal Information you provide to a third party will be subject to that third party’s privacy notice and our use of the Personal Information we obtain from such third parties will be subject to this Privacy Notice. 

We do not collect all categories of Personal Information from each source.

Reasons Why We Collect, Use, Retain, and Disclose Personal Information

We currently collect and have collected, and we may use and disclose, the above categories of Personal Information for any of the following business purposes:

  • Contact you for the purposes listed below. We may contact you by telephone, email, text messaging, or otherwise (note that messaging and data rates may apply for any SMS, MMS, and other electronic communications (typically, this is based on your carrier and service plan)); 
  • Comply with applicable local, state and federal laws and regulations;
  • Evaluate job applicants and candidates for employment;
  • Evaluate suitability for temporary assignments with our clients, to facilitate such assignments and address any issues that may arise from them;
  • Process payroll and/or travel and expenses;
  • Obtain and verify background, credit and education checks and/or drug testing as well as employment references;
  • Verify your ability to work in this country;
  • Track time and attendance at work;
  • Communicate with you regarding employment-related matters;
  • Communicate with your family or other contacts in case of emergency or other necessary circumstance;
  • Arrange business travel;
  • Establish and manage training, professional development and employee recognition programs;
  • Evaluate, make and communicate decisions regarding your employment, including decisions to hire, terminate, promote, demote, transfer, suspend or discipline;
  • Administer, manage and maintain benefits, including group health insurance, retirement accounts, short-term disability, and other Company benefits and perks;
  • Manage your job-related performance and/or employee conduct, including by engaging in lawful monitoring of your activities and communications;
  • Investigate and handle workplace investigations (such as investigations of workplace accidents or injuries, harassment or other misconduct), disciplinary actions or termination;
  • Administer and maintain our operations for safety purposes, including preventing the spread of illness and administer programs during a pandemic (e.g., COVID-19);
  • Implement, monitor and manage electronic security measures (including detection of security incidents);
  • Grant and monitor your access to secure company facilities;
  • Verify and respond to consumer requests under applicable consumer privacy laws;
  • Promote and foster diversity, equity and inclusion in the workplace;
  • Perform workforce analytics, data analytics and benchmarking;
  • Perform company audits;
  • Engage in corporate transactions requiring review of employee records and information, such as for evaluating potential mergers and acquisitions;
  • Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance, including managing workers’ compensation claims;
  • Evaluate, assess and manage Mariner’s business relationship with vendors, service providers and contractors that provide services to Mariner;
  • Improve user experience on Company computers, networks, devices, software applications or systems, and to debug, identify and repair errors that impair existing intended functionality of our systems; and 
  • Exercise or defend our legal rights.

To Whom We Disclose Personal Information

The following identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Effective Date of this Notice and, for each category, categories of recipients to whom we disclosed Personal Information. For all of the Personal Information categories below, we may disclose, as appropriate under the circumstances, to government or law enforcement entities and lawyers.  

  • Identifying Information and Contact Information: Clients and potential clients; vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as applicant tracking, back-office solutions, security vendors, data analytics providers, insurance vendors, company banks, benefits providers); Mariner affiliates; auditors, consultants and other professional advisors
  • National Identifiers: Clients and potential clients; vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as applicant tracking and back-office solutions, security vendors, data analytics providers, insurance vendors, company banks, benefits providers); Mariner affiliates; auditors, consultants and other professional advisors
  • Dependents’ Information and Benefits Administration Information: Vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as human capital solutions and back-office solutions, security vendors, insurance vendors, company banks, benefits providers); Mariner affiliates; auditors, consultants and other professional advisors
  • Education and Professional Background: Clients and potential clients; vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as applicant tracking and back-office solutions, security vendors); Mariner affiliates; auditors, consultants and other professional advisors
  • Employment Details and Career Planning Information: Clients and potential clients; vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as applicant tracking, human capital solutions and back-office solutions, security vendors); Mariner affiliates; auditors, consultants and other professional advisors 
  • Background Check Information: Clients and potential clients (where employees have authorized release, however background information of applicants is not shared); vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as applicant tracking, human capital solutions and back-office solutions, security vendors); Mariner affiliates; auditors, consultants and other professional advisors
  • Financial Information: Vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as human capital solutions and back-office solutions, security vendors); Mariner affiliates; auditors, consultants, and lawyers
  • Health and Safety Information: Vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as human capital solutions, security vendors); Mariner affiliates; auditors, consultants and other professional advisors
  • Geolocation Information: Vendors, contractor and other service providers (e.g., badge entry information systems, security vendors); auditors, consultants and other professional advisors
  • Characteristics of Protected Classifications under California or Federal Law and Physical Characteristics or Descriptions: Vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as human capital solutions, security vendors); Mariner affiliates; auditors, consultants and other professional advisors
  • Audio, Visual or Similar Information: Vendors, contractors and other service providers (e.g., Company intranet system (for photos), video conferencing providers, security providers); auditors, consultants and other professional advisors
  • Device Information and Internet, Network, and Computer Information: Vendors, contractors and other service providers (e.g., IT operating and system and platform vendors; networking monitoring systems; security providers); auditors, consultants and other professional advisors

We disclosed Personal Information to the above categories of recipients for all of the business or commercial purposes identified in the above “Reasons Why We Collect, Use, Retain, and Disclose” section.

We do not sell your Personal Information in exchange for monetary consideration. Other than data collected and shared through cookies, pixels and similar technology about website users (which is not addressed here in this policy as it is subject to our website Privacy Policy), we do not sell your Personal Information in exchange for other valuable consideration or share it for cross-context behavioral advertising, and we have not done so in the twelve (12) months preceding the Effective Date of this Notice.

We do not knowingly collect, sell, or share the Personal Information of job applicants under 16 years of age. We collect certain information of individuals under the age of 16 when provided to us by their parents, guardians, or other authorized representatives in connection with employment.  If you believe we have collected or otherwise processed information for a child under the age of 16 without authorization, please contact us right away.

We do not use or disclose Sensitive Personal Information for any purpose that gives rise to a right to limit the use or disclosure of your Sensitive Personal Information under the CCPA.

Retention of Personal Information

We will retain each category of Personal Information for as long as we continue to have a legal or business need to retain it consistent with the purposes for which the information was collected. Your Personal Information may be stored or maintained in a variety of different records, files, databases, and information systems some of which are controlled or managed by vendors. As a result, we are unable to predict at the point of collection of your information how long the information will be retained, as it depends on many factors. In deciding how long to retain each category of Personal Information that we collect, we consider many criteria, including, but not limited to: the business purposes for which the Personal Information was collected; relevant federal, state and local recordkeeping laws; applicable statute of limitations for claims to which the information may be relevant; and legal preservation of evidence obligations.

Because the law prescribes minimum periods for retention of certain records, some records will be retained for at least the duration of the required period plus a certain number of years. Retention is often measured from occurrence of a triggering event but we may also measure the retention period from either (1) the date the record or data was collected, created, or last modified, (2) the date of the particular transaction to which the record or data pertains, or (3) another triggering event that is determined to be reasonable and appropriate based on the nature of the data and the legal/business needs for its continued use.

If the business purposes for collecting the Personal Information, and legal reasons for retaining the Personal Information, have both expired, we will purge the information in a secure manner. Please contact us as described in the “How to Contact Us” section below for more information on our employee data retention schedule.

Your Rights

You have the following rights with respect to your Personal Information:

  1. Right to Know. The right to request, up to 2 times in a 12-month period, that we identify to you (1) the categories of Personal Information we have collected, shared or sold about you, (2) the categories of sources from which the Personal Information was collected, (3) the business purpose for which we use this information, and (4) the categories of third parties with whom we disclose or have disclosed your Personal Information
  2. Right to Access. The right to request, up to 2 times in a 12-month period, that we provide you access to or disclose to you the specific pieces of Personal Information we have collected about you;
  3. Right to Delete. The right to delete Personal Information that we collected from you, subject to certain exceptions;
  4. Right to Correct. The right to correct inaccurate Personal Information that we maintain about you;
  5. Right to Opt-Out of ADMT. The right to opt-out of the use of Automated Decision-Making Technology (ADMT) to make a significant decision about you;
  6. Right to Access ADMT. The right to access information about the use of ADMT to make a significant decision about you;
  7. The right to designate an authorized agent to submit one of the above requests on your behalf. See below for how you can designate an authorized agent; and
  8. The right not to be retaliated against for exercising any of the above rights.

How to Exercise Your Rights

You may submit a request to exercise the rights listed above through our interactive webform available here or by calling us at 1-866-673-7795. If you experience any issues with the web form or phone number, please contact [email protected].

If you are submitting a request on behalf of a California employee, please submit the request through one of the designated methods discussed above.

For all requests, after submitting the request, we will require additional information to reasonably verify your identity.

If you would like to update your personal information, such as to notify us of a change of name or address, or if you have questions about your employment, please contact your local Human Resources contact.

Our Verification Process for Exercise of Your Rights

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California employee on whose behalf you are making such request.

We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information involved in the request and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. 

For requests to access categories of Personal Information and for requests to delete or correct Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

For requests to access specific pieces of Personal Information or for requests to delete or correct Personal Information that is sensitive and poses a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Use of Automated Decision-Making Technology (ADMT)

What Does This Notice Cover?

This notice explains how Mariner uses automated decision-making technology (“ADMT”) for certain employment-related decision that may produce legal or similarly significant effects for job candidates or employees. This notice applies to our use of Humanly platform(s) and/or tool(s) for our candidate screening assessment, and to assist with hiring decisions.

What ADMT Do We Use?

We use the Humanly artificial intelligence platform (more information available at https://www.humanly.io/) to assist in employment-related decisions. This technology processes personal information and uses computation to assist in some aspects of the hiring process, including: job candidate screening and matching; resume scoring; and skills assessment.  

Why Do We Use This Technology?

We use Humanly’s ADMT to:

  • Improve the efficiency and effectiveness of our hiring process
  • Reduce time-to-hire and enhance the candidate experience
  • Match candidates with positions based on skills, experience, and qualifications
  • Support employee career development and internal mobility
  • Automate routine screening tasks so our recruiters can focus on human interactions

ADMT Output

Our ADMTs analyze this information using machine learning algorithms to generate outputs, including: compatibility scores between candidates and job requirements; analyze skill gaps analysis; candidate ranking and prioritization; and automated screening outputs.

These outputs may be considered in producing legal or similarly significant effects, such as the evaluation of job candidates, hiring decisions, routine screening, and skills assessments. 

What is Human Involvement in Hiring Decisions?

While our ADMT provides recommendations and scores, final employment decisions are made by qualified human reviewers who review ADMT outputs and recommendations; may overturn or modify automated recommendations; consider additional factors not captured by the technology; and make the ultimate hiring decisions.

What Are Your Rights?

Depending on your state of residence, you may have the following rights regarding our use of ADMT:

  • You may opt out of our use of ADMT when it is used to make decisions that produce legal or similarly significant effects, such as hiring, promotion, or termination. If you exercise this right, we will use alternative evaluation methods that do not rely on automated decision-making technology.
  • You may request specific information about how ADMT was used in decisions affecting you, including the purpose for using ADMT in your case; the output or score generated for you by the ADMT; how that output influenced the final decision; and key factors considered by the ADMT in analyzing your information.

We will not retaliate against you for exercising any of these rights.

How to Exercise Your Rights

To opt out of ADMT use or request access to ADMT information, you may:

  1. Email us: send your request to [email protected] with “ADMT Request” in the subject line
  2. Online Form: Submit a request through our privacy portal at Opt Out Form
  3. Call our phone number: 1-866-673-7795

You must provide enough information to verify your identity. We will respond to verified requests within 45 days.

Alternative Decision-Making Process

If you request an accommodation or opt out of ADMT use for significant employment decisions, we will evaluate your application or employment matters by manual recruiter review.

Questions or Concerns

If you have questions or concerns about Mariner’s use of ADMT or this Pre-Use Notice, please contact:

Dave Muller, Vice President, Talent Acquisition, [email protected], Ph. 913-365-2709, 5700 W. 112th St. Suite 500 | Overland Park, KS 66211

Other Relevant Policies, Including Monitoring

When we hire you, we provide you with other policies and procedures that govern your use of our offices, networks, computers, and other devices. We have the right to monitor your use of our offices and electronic resources in accordance with those policies and procedures. 

How to Contact Us

To contact us for questions or concerns about our privacy policies or practices please email [email protected].

Changes to this Notice and Effective Date

If we change this Notice, we will post the revised Notice on our Sites, with an updated revision date and distribute the new version to all employees upon hire. The Effective Date of this Notice is April 23, 2026.

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