Privacy Notice To California Employees, Contractors And Job Applicants Regarding The Collection Of Personal Information

Last Reviewed and Updated: 1/1/2022

Grid Dynamics, Holdings, Inc (the “Company” or “we”) collects personal information of our current and former employees, job applicants, officers, directors, contractors and agents (collectively, “Employees” or “you”) and their emergency contacts and beneficiaries in connection with its human resources activities. The Company does not sell or otherwise disclose this personal information for monetary consideration.

Employees, emergency contacts and beneficiaries with disabilities may access this notice in an alternative format by contacting Shannon LeBaron at slebaron@griddynamics.com or (214) 733-0435.

What Categories Of Employee Information Do We Collect And How Do We Use This Information?

We collect the following categories of personal information for the purposes described below:

Category of Personal Data Examples of Personal Information Collected Purpose
A. Personal identifiers Real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver's license number, passport number or other similar identifiers, age, date of birth.

The Company collects personal identifiers to process job applications; onboard new Employees, enroll and administer benefits, enter into contracts, and general human resource purposes.

The Company collects Employees’ age and date of birth to onboard new Employees, enroll and administer benefits, and general human resource purposes.

B. Records identified by state law (including the California Customer Records statute (Cal. Civ. Code § 1798.80(e))) Name, signature, Social Security number, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card information, or any other financial information, medical information or health insurance information. The Company collects this information to process job applications; onboard new Employees, enroll and administer benefits, enter into contracts, and general human resource purposes.
The Company collects pay information, such as pay rate, payroll deduction information; banking information for direct deposit, and credit card information for expense reimbursement. The Company collects this information to pay its Employees and comply with applicable laws.
C. Protected classification characteristics under state or federal law Age (40 years or older), race, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status. The Company collects equality and diversity information, such as minority, veteran and disability status, through voluntary self-disclosure and other means to report to government agencies as needed, implement the Company’s diversity programs and comply with applicable laws.
The Company collects health and safety information to maintain a safe workplace, assess your working capacity, administer health and Workers’ Compensation insurance programs, and comply with applicable laws.
The Company also collects information necessary for benefits enrollment and administration purposes.
D. Commercial information Records of products or services purchased or obtained, or other purchasing or consuming histories or tendencies. The Company collects records of products purchased and purchasing histories to reimburse its Employees for business and work-related travel expenses.
E. Internet or other similar network activity information Email, computer, internet, telephone, and mobile device usage; IP address; log-in information; and location information, browsing history, search history, or information regarding your interaction with a website, application or advertisement. The Company collects this information to protect Company, customer, and employee property, equipment and confidential information; monitor employee performance; enforce the Company’s electronic communications acceptable use policies; and monitor employee logs to maintain and protect the security of Company’s portals.
F. Sensory data Audio and visual information. The Company may collect audio and visual information of Employees through photographs used for identification purposes and to promote the Company. The may Company collects audio and video recordings of meetings or training sessions.
G. Professional or employment-related information Examples: Current or past job history or performance evaluations Performance Management Information such as employment status (full-time or part-time, regular or temporary); work schedule; job assignments’ hours worked; accomplishments and awards; training and development information; performance evaluation information; and employment termination information. The Company collects professional and employment- related information to manage our employment relationship with Employees.
H. Education information (per The Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) Education records such as grades, transcripts, and class lists. The Company collects education information in connection with the job application process, to evaluate job applicants, and to feature Employees in marketing materials and on the Company’s website.
I. Inferences drawn from Personal Data Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. The Company collects performance reviews, evaluations, background check information, and resume information in Employee files as part of the Company’s HR operations.
J. Personal Data about children under the age of 16 Personal information about your dependents under the age of 16. The Company collects information about Employees’ dependents under the age of 16 if Employees voluntarily provide such information in connection with the enrollment and administration of benefits and other human resource purposes that involve such dependents.

The Company also collects legal and contractual information, such as information necessary to respond to law enforcement and governmental agency requests, comply with legal and contractual obligations, exercise legal and contractual rights; and initiate or respond to legal claims. The Company collects this information to comply with legal and contractual requirements and to establish, exercise and defend legal and contractual rights and claims. The Company may also use information that it collects for other purposes that you would reasonably expect from an employer, or for which we provide specific notice at the time the information is collected.

What Categories Of Emergency Contact Information Do We Collect And How Do We Use This Information?

We collect the following categories of personal information for the purposes described below:

  • Name and contact information; and
  • Relationship to Employee.

The Company collects this information to contact the Employee’s designated emergency contact persons in the event of an emergency.

What Categories Of Beneficiary Information Do We Collect And How Do We Use This Information?

We collect the following categories of personal information for the purposes described below:

  • Name and contact information;
  • Relationship to the Employee;
  • Birth date;
  • Social Security Number; and
  • Information necessary to process benefits claims

The Company collects this information to enroll and administer benefits programs for beneficiaries of Employees.

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