California Privacy Notice to Employees and Job Applicants

Effective Date: June 5, 2023        Updated: December 4, 2023


This California Employee Privacy Notice (the “Employee Privacy Notice”) is applicable to all California employees, owners, directors, officers, interns, contractors, volunteers, and applicants of, Inc. (“Pony,” “Company,” “we,” “us,” or “our”). The Employee Privacy Notice supplements Pony’s Privacy Notice and applies to personal information of California employees, owners, directors, officers, interns, contractors, volunteers, and applicants collected by Pony for employment purposes. This Employee Privacy Notice also applies to information provided to Pony about employees’ relatives or other persons used for emergency contact or benefits administration.

Please read this Employee Privacy Notice to learn how Pony collects and processes your personal information while you are employed by Pony, engaged to provide services to Pony, or apply for a job with Pony. Under the California Consumer Privacy Act of 2018, Cal. Civ. Code § 1798.100 et seq. and its implementing regulations (the “CCPA”), as modified by the California Privacy Rights Act (the “CPRA”), you have the right to know and understand the categories of personal information Pony collects about you and purposes for which Pony uses such personal information unless preempted by a superseding law. Certain terms used in this Employee Privacy Notice are given their meanings as defined in the CCPA or the CPRA. This Employee Privacy Notice only applies to employees, owners, directors, officers, interns, contractors, and applicants who are residents of the State of California. Pony does not sell or, for cross-contextual behavior advertising, share this personal information with any third parties.


Categories of Personal Information

As permitted by applicable law, Pony collects following categories of personal information, including sensitive personal information, for purposes described below:

  • Personal identifiers, such as your given name, preferred name, postal address, unique device identifiers (such as device identifiers, cookies, beacons, pixel tags, mobile ad identifiers, and similar technology), telephone numbers, online identifiers, Internet Protocol (IP) addresses, email addresses, social security numbers, driver’s license number, passport number, date of birth, signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, other financial information, medical information, and health insurance information.
  • Characteristics of protected classifications, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military or veteran status. Pony only collects this information if you voluntarily disclose it and as permitted by applicable law. Pony will not use this information to make hiring decisions.
  • Biometric information, such as your physiological, biological or behavioral characteristics that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information can include, but is not limited to, imagery of face, fingerprints, and voice recordings.
  • Online activity on Company issued or authorized devices, such as your browsing history, search history, and information relating to interactions with websites or applications (i.e., programs or “apps”).
  • Geolocation data, including geolocation data of Company vehicles, that can indicate your precise location.
  • Sensory data, such as audio and visual information. If you visit, work, or perform services in Pony’s facilities or in facilities operated by Pony, or operate or is a passenger on vehicles operated by Pony, your activities and actions in or around those facilities or vehicles may be monitored by closed-circuit television or related technology.
  • Professional or employment-related information, such as your employment history, job application or resume, employment contract, references, information about skills and abilities, accomplishments and awards, training and development information, performance evaluation information, and employment termination information.
  • Education information, such as your education history, education records (such as grades, transcripts, etc.) and other information included in your resume or cover letter.
  • Inferences drawn from other personal information excluding sensitive personal information, including any information referenced above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Pony also may collect personal information included in job interview notes, responses to screening questions, assessment results, and any other information you provide in connection with recruitment process.

Retention.  We generally retain personal information to fulfill various obligations and for business purposes.  Obligations can include, for example, satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.  Business purposes can include, for example, retaining personal information that is reasonably necessary to manage our operations, to manage your relationship with us, to satisfy another purpose for which the personal information is collected, or to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information is collected.  Where personal information is used for more than one purpose, we may retain it until the purpose with which the latest period expires.  To determine appropriate retention period for personal information, we may consider factors such as amount, nature, and sensitivity of your personal information, potential risk of harm from unauthorized use or disclosure of your personal information, purposes for which we process your personal information and whether we can achieve those purposes through other means, and applicable legal requirements.

When we no longer require to retain your personal information, we will either delete it or anonymize it.


Sources of Personal Information

Pony collects personal information you voluntarily provide to Pony during recruitment process. Further, Pony may automatically collect certain information, such as IP addresses and device identifiers from Company issued or authorized devices that may be tied to employees.

Pony may combine personal information you voluntarily provide with information Pony collect from other sources, such as:

  • Recruiters or Temporary Employment Agencies;
  • Prior employers and professional references;
  • Educational institutions;
  • Pre-employment screening and background check services;
  • Credentialing and licensing organizations;
  • Publicly available sources, such as public social media profiles on LinkedIn, Twitter or Facebook; and
  • Other sources as directed by you.


Business Purposes for Collecting Personal Information

Pony uses the categories of personal information described above for following business purposes:

  • Recruitment of employees. Pony uses your personal information to process your job application, create an applicant profile, evaluate your qualifications, schedule and conduct interviews and communicate with you.
  • Conducting pre-employment screening and background checks. In accordance with applicable law, Pony uses your personal information to conduct employment screening and background checks.
  • Compensation and expense management. Pony uses your personal information to conduct payroll processing, salary administration, expense reimbursement, and for other compensation purposes such as determining bonuses, equity, and other employee compensation.
  • Benefits administration. Pony uses your personal information to administer benefits, such as medical, dental, vision, disability insurance, retirement benefits, and other employee benefits.
  • Human Resources (HR) management. Pony uses your personal information to administer HR management services, including managing employee on-boarding, termination and separation, travel administration, and return-to-work screening (including any medical screening as required or permitted by applicable law).
  • Training and professional development. Pony uses your personal information to provide employment-related training, assisting with professional licensing and development.
  • Internal employment purposes. Pony uses your personal information to conduct internal investigations, conduct surveys, resolve disputes, prevent or detect fraud or security incidents, conduct employee performance reviews, enforce Company’s policies and code of conduct, protect rights and safety of employees or others.
  • Compliance with legal requirements. Pony uses your personal information to comply with applicable laws, regulations, and legal processes (such as responding to subpoenas or court orders), and to respond to legal claims, resolve disputes, enforce Pony’s legal rights contained in employment or other contracts, and comply with legal or regulatory recordkeeping requirements.


Disclosure of Personal Information

Pony may disclose your personal information for business purposes with following parties:

  • Affiliates and subsidiaries. Pony may disclose your personal information with Pony’s affiliates and subsidiaries.
  • Service providers. Pony may disclose your personal information with service providers, such as recruiters, pre-employment screening services, third-party benefits administrators, payroll processors, background check providers, and others.
  • Governmental authorities. Pony may disclose your personal information with federal or state regulatory agencies, law enforcement, courts, and other governmental authorities as required by law or legal process.
  • Professional advisors. Pony may disclose your personal information with professional advisors, such as auditors and law firms.
  • Parties involved with business transfers. Pony may disclose your personal information to third parties in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation).

In accordance with Company’s policies and procedures, Pony will not discriminate or retaliate against you if you choose to exercise any of your rights under the CCPA or the CPRA.

We have disclosed personal information enumerated in Categories of Personal Information to some or all of the third parties listed above in the preceding 12 months.

We have not sold or, for cross-context behavior advertising, shared your personal information in the preceding 12 months.


Your California Privacy Rights. 

You have the rights listed below and may exercise the rights by submitting a verifiable consumer request. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

  • Know/Access.  You can request the following information about how we have collected and used your Personal Information during the past 12 months:
    • Categories of Personal Information that we have collected.
    • Categories of sources from which we collected Personal Information.
    • Categories of Personal Information we have disclosed about you for a business purpose and categories of recipients to which it was disclosed.
    • Categories of Personal Information that we sold or, for cross-context behavior advertising, shared and categories of third parties to whom Personal Information was sold or, for cross-context behavior advertising, shared.
    • Categories of third parties to whom Personal Information was disclosed for a business purpose.
    • Business or commercial purposes for collecting, selling, or, for cross-context behavior advertising, sharing Personal Information.
    • Specific pieces of Personal Information collected.
  • Correct.  You can ask us to correct inaccurate Personal Information we have collected about you.
  • Delete.  You can ask us to delete Personal Information we have collected from you.  Please be aware that certain information we have collected from you may still be retained for legal, accounting, security, information technology backup, anti-fraud reasons, as well as for solely internal uses reasonably aligned with your expectation based on your relationship with Pony and compatible with the context in which you provided the information.
  • Nondiscrimination.  You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.


How to Exercise Your Rights  

You may submit requests to exercise your California privacy rights described above as follows:

  • Request to know/access, correct, and delete. You may submit requests to:

These requests can be made for personal information of a consumer but not of a household.