Grindr Employee, Contractor, and Applicant Privacy Policy

Effective Date: June 16, 2021

Welcome to Grindr’s Employee, Contractor, and Applicant Privacy Policy (“Policy”). This Policy explains how Grindr processes Personal Information with respect to current and former employees, contractors, and applicants and provides a straightforward explanation of the following topics:

Who Is Covered By This Policy?
What is Personal Information?
What Personal Information Do We Collect?
Sources of Personal Information
How Do We Use Your Personal Information?
Employee Monitoring
Grindr Employee Use of Grindr Products and Services
To Whom Do We Provide This Information?
Personal Information Retention
Your Personal Information Rights

By being transparent with how we collect and use your information, we hope you will be confident about the reasonable efforts Grindr is taking to safeguard your privacy.

Who Is Covered By This Policy?

All references in this Policy to “Grindr”, “We”, or “Our”, refer to Grindr LLC, its parent companies, and its subsidiaries such as Grindr Canada Inc. All references to “You” and “Your” refer to current, prospective, or former Grindr employees, job applicants, and direct contractors.

What Is Personal Information?

“Personal Information” (sometimes referred to as “Personal Data”) means any information that allows someone to identify you directly. Personal Information does not include anonymous information, publicly-available information that is lawfully made available to the general public from federal, state, or local government records, or information that cannot be affiliated with a specific individual.

What Personal Information Do We Collect?

Grindr collects the following categories of Personal Information about you. Examples include (without limitation):

Category	Examples Of Personal Information That May Be Collected
A. Identifiers	Legal name, alias, date of birth, primary address, unique personal identifier, online identifier, Internet Protocol address, email address, internal employee ID, email account, Social Security number, identification information (driver's license or passport) driver’s license number, passport number, license plate.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, medical information, or health insurance information.
C. Protected classification characteristics under California or federal law	Age, race, color, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation for same sex benefits, veteran or military status.
D. Commercial information	None.
E. Biometric information	None.
F. Internet or other similar network activity	Browsing history, search history, information regarding your interaction with websites, applications, email/chat/social media platforms, or computer or access logs or other activity on any Grindr computer or business information system.
G. Geolocation data	Physical location such as home address, office visits, or business travel itinerary.
H. Sensory data	Audio such as recorded meetings or presentations.
I. Professional or employment-related information	Compensation information, tax withholding information, current or past job history or performance evaluations.
J. Education information, as defined by the Family Educational Rights and Privacy Act	None.
K. Inferences drawn from other Personal Information	Profile reflecting a person's preferences, characteristics, predispositions, behavior, attitudes, or abilities.
L. Video or Audio Recordings	Grindr may utilize security cameras in common spaces (e.g., points of entry into Grindr’s offices).

Sources of Personal Information

We may collect Personal Information about you in various ways, including through:

Payroll information including but not limited to social security or insurance number, tax details, and paycheck deposit information;
Wage and benefit information;
Beneficiary and emergency contact information;
Resumes and/or applications;
Degrees and diplomas;
References and interview notes;
Photographs and video;
Government ID and related information such as driver’s license, and passport;
Letters of offer and acceptance of employment;
Mandatory policy acknowledgement sign-off sheets;
Forms relating to the application for, or in respect of changes to, employee health and welfare benefits; including, short and long term disability, medical, vision, and dental care;
Family member data such as child’s birth certificate, marriage certificate, or family member death certificate;
Background screening information;
Internal systems configurations may leverage your full name, title, role, etc. with your account details;
Grindr App Setup (limited - see “Grindr Employee Use of Grindr Products and Services” below);
Your utilization of Grindr’s information systems (such as SSO logs, IP address, device IDs, etc.).

How Do We Use Your Personal Information?

We gather the Personal Information listed above for business operations, including for establishing, maintaining, or terminating your employment with Grindr. Such use cases include, but are not limited to:

Background reports and employment verification, including the verification of references;
Payroll and benefits processing;
Conducting performance reviews and determining performance requirements;
Assessing qualifications for a particular job or task;
Parking and office access;
Complying with labor or employment law, including immigration filings;
Disability, unemployment, or other insurance claims;
Establishing training and/or development requirements;
Gathering evidence for disciplinary action, or termination;
Establishing a contact point in the event of an emergency;
Maintaining and sharing an organizational chart with roles and responsibilities;
Contributing to global initiatives such as diversity and inclusion, employee onboarding management, and global headcount management;
Ensuring the security of company-held information;
To comply with our legal obligations;
To identify and implement enhancements of our employee recruitment and retention practices;
Other purposes as are reasonably required by Grindr in connection with your employment; and
For any additional purposes that we advise you of and for which we have a legal basis, which may for instance be your consent when such consent is required by law.

Employee Monitoring

The work product of Grindr employees, whether in paper record, computer files, recorded communications, or in any other storage format, belongs to Grindr, and that work product, and the tools used to generate that work product, are always subject to review and monitoring by Grindr.

In the course of conducting our business, we may monitor employee activities, online and within the workplace. For example, we have the capability to monitor all employees' computer, email, and chat use.

This section is not meant to suggest that all employees will in fact be monitored or their actions subject to constant surveillance. We have no duty to monitor. This is meant to bring to your attention that such monitoring may occur and may result in the collection of Personal Information from employees (e.g., through their use of company resources). When using Grindr-specific equipment or Grindr resources, employees should not have any expectation of privacy with respect to their use of such equipment or resources.

Grindr Employee Use of Grindr Products and Services

Personal use of Grindr Services by current employees and contractors is optional, although we welcome everyone to experience the app to better understand its function and features in the context of their employment with Grindr. Current employees or contractors may request upgrades to their personal Grindr accounts (e.g., Grindr Xtra or Grindr Unlimited). Personal Information required for an upgrade is the email address or account identifier associated with the Grindr account. Any normal course use of the Grindr App by employees is governed by the Grindr Privacy Policy.

To Whom Do We Provide This Information?

In some instances (i.e., on a conditional and need-to-know basis), Grindr may provide your Personal Information to employees, contractors, consultants or third party vendors in order to fulfill our business needs or provide assistance or services to you directly. Your Personal Information may also be provided under these specific circumstances:

As permitted or required by applicable law, rule, or regulatory requirements. In such a case, we will endeavor to not disclose more Personal Information than is required or appropriate under the circumstances;
To comply with valid legal processes, such as search warrants, subpoenas or court orders;
To protect the rights and property of Grindr;
During emergency situations or where necessary to protect the safety of a person or group of persons;
Where the Personal Information is publicly available (e.g., speaking at an event); or
With your consent where such consent is required by law.

Grindr does not sell employee data to third party vendors.

Personal Information Retention

Grindr retains your Personal Information for as long as is necessary to perform the business use cases listed in this Policy or to comply with federal, state, or local law.

Your Personal Information Rights

You may request access, edits, or deletions to the Personal Information that we have on file about you. In some cases you may have direct access to do this yourself. To request access, edits, or deletions to your information that you’re unable to access or correct on your own, please contact Grindr’s HR team. You can make these requests twice a year and Grindr has up to 45 days to respond to your request. All requests must be in writing and include the specific information that you would like access to or that you would like to change.

Please note that requests for access, edits, or deletions are not always guaranteed. In the event we cannot fulfill your Personal Information request, Grindr will aim to provide a justification as to why.

We will not discriminate against you for exercising your rights described in this Policy.

Privacy Office Contact

If you have questions regarding this Policy or concerns about how your Personal Information is handled, please contact privacy@grindr.com.