Grid Dynamics California Resident Job Applicant Privacy Notice
Last Updated: 5/9/2024
Grid Dynamics Holdings, Inc. and its affiliates (collectively, “Grid Dynamics,” “we,” “us,” or “our”) respect your privacy. This California Job Applicant Privacy Notice (“Notice”) applies to Personal Information that we collect as a Business from or about job applicants who are California residents (collectively, “you,” or “job applicants”). Please see our California Resident Privacy Notice for information about the information we process when you visit our website.
For the purposes of this notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).
Personal Information does not include information that is:
- Lawfully made available from government records.
- Deidentified or aggregated.
- Otherwise excluded from the scope of the CCPA.
1. Sources of Personal Information We Collect
We collect Personal Information from you when you provide it to us or automatically through your devices. We may also obtain information about you from other sources, such as former employers, including managers and colleagues, background check providers, social media services, recruitment agencies, affiliates, consumer data brokers, and publicly available databases.
2. Personal Information Collection, Disclosure
The chart below provides the categories of Personal Information from job applicants for a Business Purpose.
Category | Categories of Third Parties to Whom We Disclosed Personal Information |
A. Identifiers Examples: Name, address, email address, and government-issued IDs (social security number, driver’s license number, passport number, or other similar identifiers). | • Affiliates • Service providers and vendors |
B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e) Examples: Name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, education, employment, and employment history. | • Affiliates • Service providers and vendors |
C. Characteristics of Protected Classifications under California or Federal Law Examples: Age (over 40), race or color, ancestry or national origin, mental or physical disability, sexual orientation, sex (including gender), gender identity or expression, marital status, military and veteran status | • Affiliates • Service providers and vendors |
D. Internet or Other Electronic Network Activity Information Examples: Usage metrics and information regarding your interaction with an internet website, application or advertisement. | • Affiliates • Service providers and vendors |
E. Audio and Visual Information | |
F. Biometric Information | |
G. Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99) Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution. | • Affiliates • Service providers and vendors |
H. Inferences Drawn from Personal Information | |
I. Sensitive Personal Information Examples: Government-issued IDs (Social Security numbers, visa and passport information), and ethnicity | • Affiliates • Service providers and vendors |
Over the past 12 months, we have collected and disclosed each of the categories of Personal Information as described in the chart above.
3. Use of Personal Information
We collect your Personal Information for the following specific business and commercial purposes:
- Diversity and Inclusion-Related Purposes: Monitor equal employment opportunities and uphold our commitment to diversity and inclusion.
- Recruitment Purposes: Undertake activities related to recruitment and processing your job application, such as evaluating job applications, determining qualifications for employment and reaching a hiring decision, contacting references, verifying your identity or other information related to your application, protecting against fraud, and communicating with you.
- Health, Safety, and Security Purposes: Protect the health and safety of our job applicants, employees, and other personnel, and to assess and maintain the security of our offices, facilities, and online services.
- Analytics Purposes: Analyzing your interactions with our services.
- Marketing Purposes: Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you.
- Law-Related Purposes: Comply with laws and regulations, including collecting and disclosing job applicants’ Personal Information as required by law, under judicial authorization, or in exercising or defending our legal rights.
- Notified Purposes: For other purposes for which we provide specific notice at the time the information is collected.
4. Data Retention
- We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods for each category of Personal Information include:
- The length of time we have an ongoing relationship with you and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
- Whether there is a legal obligation to which we are subject that requires us to retain information for, or delete information after, a certain period of time;
- The length of time we use the information to detect and prevent fraud and security incidents.
5. Your California Privacy Rights
If you are a California resident, you may exercise the following rights.
- The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, and the categories of third parties to whom we disclose Personal Information.
- The right to access the specific pieces of Personal Information we have collected about you in a portable and, to the extent technically feasible, readily usable format.
- The right to correct inaccurate Personal Information that we maintain about you.
- The right to request deletion of the Personal Information that we have collected about you.
- The right to opt out of the sale of Personal Information, or the sharing of Personal Information for cross-context behavioral advertising. We do not sell or share (for cross-context behavioral advertising purposes) your Personal Information, including if you are under 16 years old.
- The right to limit our use or disclosure of your sensitive Personal Information. We do not use or disclose your Sensitive Personal Information for purposes other than the limited purposes permitted by the CCPA.
- The right to be free from discriminatory treatment for the exercise of your privacy rights.
To submit a request to access, correct, or delete your information, you may email us at dpo@griddynamics.com. Such requests are subject to our ability to reasonably verify your identity. To verify your request, please follow the instructions provided in our response to your request. After we validate your request, we will process your request in the timeline set forth in the CCPA.
If you are acting as an authorized agent to make a request to know, delete, correct, or opt out on behalf of a California resident, please provide us with written authorization signed by the resident, and we will contact you and the resident with further steps required to verify the resident’s identity.
6. Contact for Questions
If you have any questions, comments, or concerns about our processing activities, please contact:
Grid Dynamics
5000 Executive Parkway, Suite 520
San Ramon, CA 94583.
dpo@griddynamics.com
+1 (214) 733-0435
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