Non-California US Privacy Notice and Privacy Policy
Scope of Notice
This Non-California US Privacy Notice and Privacy Policy ("Notice") describes how Yahoo collects, uses, and discloses your personal data (e.g., human resources information) in the context of our operations pursuant to the applicable United States laws. As used in this Notice, "Yahoo," "Company," "we," and "us" means College Top Holdings, Inc. and any entity directly or indirectly controlled by it.
Unless otherwise expressly stated herein, this Notice applies to the following individuals who are based in the United States, but are not residents of California: (i) all of our current and former employees (together "Employees"); (ii) non-employee consultants, contractors, agents, selected service providers, and contingent workers (together, "Contractors") with whom Yahoo has contracted directly (e.g., 1099 relationship). This Notice also applies to job applicants applying for a role at Yahoo and beneficiaries of our benefit plans (as applicable) (together, "Applicants"). This Notice does not form part of any employment contract or contract to provide services. If you provide services to us through or in connection with another company, we are not responsible for that company's privacy practices. If you provide your information to a third party directly, that company's privacy policy may apply.
For clarity, if you are an Employee, Contractor, or Applicant located in any of the following regions, countries, or state, this Notice does not apply to you. Please refer to the applicable notice for your location: (i) California; (ii) the EEA and/or UK; (iii) Brazil; or (iv) Japan. If you are an Applicant applying for a role at Yahoo in one of the following locations, this Notice does not apply to you, please refer to the applicable notice for your location : (i) the EEA and/or UK; (ii) California; (iii) Brazil; (iv) Japan; or (v) other locations outside the United States.
This Notice also does not address our information practices with respect to your interactions with Yahoo as a consumer or customer. When you interact with us as a consumer or customer, the privacy policy associated with that product or service applies.
There may be certain other circumstances in which we may also provide you a separate privacy notice regarding the processing of personal data. This Notice does not apply to information subject to the Health Insurance Portability and Accountability Act of 1996, including information that our health plans collect. Such information is subject to our HIPAA Notice of Privacy Practices, available on The Street.
Information we collect
We may collect the following categories of personal data:
Identification and contact information and related identifiers, such as full name, alias, date and place of birth, Social Security number, tax ID, citizenship and permanent residence, home and business addresses, telephone numbers, email addresses and unique personal identifiers. Professional or employment-related information, including:
- Recruitment, employment, or engagement information, such as application forms and information included in a resume, cover letter or other information provided through the application or engagement process; copies of identification documents, such as driver's licenses, passports and visas; and background screening results and references.
- Career information, such as job titles; work history; start and end dates; work locations; employment, service or engagement agreements or any other contract we have signed with you; appraisal and performance information; information about skills and qualifications, experience and preferences, and training; absence and leave records; professional memberships; disciplinary and grievance information; termination details; and other information you may provide in an interview or as part of our hiring application process.
- Financial information, such as salary, bank account details, payroll records and tax information.
- Business travel and expense information, such as travel itineraries, expense reports, and corporate credit card usage.
Internet, electronic network, and device activity and device information and related identifiers, such as information about your use of Yahoo network, information, and communication systems and Yahoo devices, including user IDs, passwords, IP addresses, device IDs, web logs, audit trails of system access, call and text usage, email and text content, destination IP addresses, and location information. Audio or visual, and security-related information, such as photos, interview recordings, and CCTV footage, badge swipe data, as well as other information relating to the application process and security of our premises. Location, such as your VPN location. Legally protected classification information, such as race/color, age, sex, pregnancy, sexual orientation, gender identity and expression, national origin, disability, marital status, citizenship status, veteran status, military service status, medical condition, religious beliefs, or any other protected category under applicable law. Health-related information, such as disability status, health and safety incidents or accidents, sickness records, and health issues requiring adaptations to your working environment or working practices. Information about your partner, spouse, beneficiaries and dependents, such as name, address, Social Security number, date of birth, and relationship status. Sensitive personal data, such as: (a) Social Security number and other government identifiers (e.g., as part of the application and verification process); (b) racial or ethnic origin or sexual orientation (e.g., on a voluntary basis to support our equal opportunity and diversity and inclusion efforts and reporting obligations, or where otherwise required by law, or union membership); (c) citizenship and permanent residence (e.g., to understand our legal obligations when sponsoring your employment); (d) religious beliefs (e.g., when requesting a religious exemption); and (e) health (e.g., as necessary to provide reasonable accommodations). Sources of personal data
In general, we may collect the categories of personal data identified in the table above from the following categories of sources:
- Directly from the individual
- From third parties such as references or coworkers
- Our service providers, representatives, and agents
- Publicly available sources, such as professional networking platforms and public profile data
Employee monitoring information
We may use tools that automatically monitor Employees', Contractors', and Applicants use of different workplace applications and tools, such as phone, email, and internet usage, which may be considered electronic monitoring under certain state laws, such as those in Delaware and New York. This may include monitoring communications that take place through these tools. The use of Yahoo computing devices and network resources is subject to monitoring and access by Yahoo to the fullest extent permitted by applicable laws, and Employee and/or Contractor use of Yahoo computer assets, networks, and systems constitute full consent to such monitoring at any time consistent with applicable laws and this Notice. Employees and Contractors are also subject to monitoring when using the Yahoo network, assets, and personal devices enrolled in the Intelligent Hub Program; this monitoring is in accordance with applicable laws, the Yahoo Acceptable Use Policy, and the Yahoo Mobile Device Policy. To the extent Applicants use Yahoo computing devices or network resources (for example, before, during, as part of, or after the interview process), such use may be monitored as set forth in this Notice and governed by the terms set forth in this Notice.
Such monitoring may take place manually through human review or by using algorithms or automated decision-making technology (e.g., artificial intelligence). In connection with such monitoring, Yahoo may collect and process personal data in accordance with this Notice.
Items that Yahoo may monitor include, but are not limited to, the following: incoming and outgoing email usage; use of Yahoo network and Internet-based communication through computer assets (e.g., Internet browsing, communications between internal and external servers and file-sharing or file transfer); installed software and applications; incoming and outgoing phone call usage; mobile device text and data usage; external and internal areas of its offices via CCTV cameras; and secured facility access.
How we use personal data
We use personal data for our and our service providers' business purposes, to the extent permitted by and in compliance with applicable law, which include, where applicable:
Workforce recruitment, management, and administration, including job advertising, interviewing, and selecting and hiring new staff, training, compensation, and benefits, approving and managing invoices and leave, scheduling, feedback surveys, career development, performance appraisals and recognition, diversity programs, investigating and resolving queries and complaints, providing references, succession planning, planning changes in organization structure, investigating and preventing fraud, verifying the authenticity of information provided during the application process, ensuring you are paid and taxed correctly and preparing analyses and reports, and providing you with health benefits and wellness programs. Performance of business operations, including providing, managing, supporting, and improving information and communication systems (such as laptops, phones and corporate email, intranet, collaboration, and storage systems) and processes; maintaining accounts and internal directories, crisis management, managing the environmental impacts associated with business operations; protecting and monitoring workforce occupational health and safety; participating in business-related due diligence activities; business succession planning; building or using algorithms or automated decision making technology (e.g., artificial intelligence) to help with our internal processes; and conducting internal analyses, audits, research, and reports. Security, health, and safety management, such as to help ensure physical and network and information security (including detecting security incidents, debugging and repairing errors, preventing unauthorized access to our computer and electronic communications systems, and preventing malicious software distribution); monitoring and controlling access to Yahoo premises and locations; monitoring your use of our information, communications, and collaboration systems to ensure compliance with Yahoo policies; preventing data loss and corporate device management; and to ensure the health and safety of our personnel. Legal compliance, such as complying with applicable legal and regulatory requirements and responding to and cooperating with legal or regulatory requests and investigations. Charitable and volunteer programs, including processing, tracking, and reporting of your charitable donations, volunteer work, and other such contributions. Workforce updates, such as communicating with our workforce about updates and other changes to any of the above (e.g., changes to benefits packages or security protocols); informing our workforce about perks, benefits and discounts, including those offered by Yahoo or our business partners; and notifying our workforce about updates and other changes to Yahoo products and services. M&A and other business transactions, for planning, due diligence, and implementation of commercial transactions, for example mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization, or other similar business transactions. Defending and protecting rights, to protect and defend our rights and interests and those of third parties, including to manage and respond to employee and other legal disputes, to respond to legal claims or disputes, and to otherwise establish, defend, or protect our rights or interests, or the rights, interests, health, or safety of others, including in the context of anticipated or actual litigation with third parties. With your consent, or otherwise at your direction. Sensitive personal data. We do not collect, use or disclose sensitive personal data beyond the purposes as set forth in this Notice or authorized by the applicable laws. Accordingly, we only use and disclose sensitive personal data as reasonably necessary and proportionate: (i) to perform tasks associated with your employment as set forth in this Notice for which you have provided the sensitive personal data (e.g., employment verification, managing payroll); (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent, and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our services; (v) for compliance with our legal obligations; and (vi) to our service providers who perform services on our behalf.
Artificial Intelligence. We may use artificial intelligence tools or automated decision making technology ("AI Tools") to process your personal information for purposes of, including but not limited to, recruitment, identity verification, hiring, promotion, renewal of employment, selection for training or apprenticeship, discharge, discipline, tenure, or the terms, privileges, or conditions of employment. We do not use AI Tools that have the effect of subjecting Illinois residents to discrimination on the basis of protected classes under the Illinois Human Rights Act.
Verifying Applicant Identity and Detecting Fraud. Yahoo may use AI Tools to analyze applicant-provided and publicly available information to generate a fraud risk classification assessing whether an applicant’s identity and application materials appear authentic. The output is a risk classification (e.g., clear, low risk, medium risk, or high risk) that is used to help determine whether an applicant’s identity appears legitimate as part of the pre-screening process. Human review is part of this process. For example, a Yahoo recruiter will review a medium or high risk classification before a determination is made regarding the applicant’s advancement in the hiring process. A summary of the latest bias audit of the AI Tool used for this purpose may be viewed here.
Illinois Artificial Intelligence Video Interviewing Act. If you are an Applicant who is an Illinois resident and who engages with us by way of video, such as for screening calls or interviews (together, "Interviews"), if we record such Interviews and we use artificial intelligence to analyze such recordings, we will provide notice of and obtain consent regarding the use of such technology as required under applicable law.
How we may disclose personal data
We may disclose your personal data to the following categories of third parties: service providers, advisors and agents, benefit(s) providers and administrators, corporate affiliates, regulators, government entities, and law enforcement, and others as required by law.
Data retention
We retain the personal data we collect only as: (i) reasonably necessary for the purposes described in this Notice; (ii) as authorized by the applicable laws; or (iii) otherwise disclosed to you at the time of collection. For example, we will retain your information as necessary to comply with our tax, accounting and record keeping obligations, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and comply with our legal obligations.
Your Rights
You may have rights under the applicable laws with respect to your personal data processed by us, subject to certain limitations and exceptions. We will carry out your request to exercise any such rights you may have in accordance with the applicable laws, subject to certain limitations and exceptions.
For applicants for positions based in New York City, pursuant to New York City Local Law 144, you may request an alternative fraud detection process before our automated screening tool is applied to your application by emailing us at hranswers@yahooinc.com before submitting your application. When emailing us, please include the following information: (i) your full name; (ii) the position you are applying for; and (iii) a statement indicating you are a prospective job applicant and your request to opt out of automated screening for fraud detection.
How to contact us about this Notice
If you have any questions about this Notice, or if you require further information about our use of your personal data or you wish to avail of any rights you may have under the applicable law, please contact us at privacy-inquiries@yahooinc.com.
Changes to this Notice or our data collection or processing practices
We may update this Notice, including when we make changes to our data processing practices. We recommend reviewing this notice regularly. If we make material changes, we will notify you in accordance with legal requirements.
Updated April 2026