Grindr Employee, Contractor, Vendor and Applicant Privacy Policy

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<div>Effective Date: The earlier of 2023-06-21 or individual acknowledgment. Welcome to Grindr's Employee, Contractor, Vendor and Applicant Privacy Policy ("Policy"). All references in this policy to "Grindr", "we", "us", or "our", refer to Grindr LLC, its parent companies, and its subsidiaries such as Grindr Canada Inc. This Policy explains how Grindr processes Personal Information with respect to current and former employees, contractors, vendors and applicants ("In-Scope Individuals"). "Personal Information" means any information that allows someone to identify, or reasonably link to, you directly or indirectly. When we describe "processing" of Personal Information, we mean how we collect, use, share, and retain Personal Information. By being transparent with how we collect and use your Personal Information, we hope you will be confident about the reasonable efforts Grindr is taking to safeguard your privacy.California Residents. Please see Your California Privacy Rights to learn about the specific rights you are afforded under California privacy laws.<h3>PERSONAL INFORMATION WE COLLECT</h3> We start to collect Personal Information from In-Scope Individuals during the recruitment or onboarding process and throughout and post the duration of your employment or your engagement with Grindr. We may collect Personal Information directly from you, directly from the devices you use to support the work you do for Grindr, or from third-parties. We have to collect some Personal Information from you in order to pay you, reimburse you for expenses, provide you with benefits, and fulfill legal obligations (e.g., tax reporting). Sometimes providing Personal Information is optional (e.g., for optional company events). Examples of Personal Information that Grindr collects about you include (without limitation):<ul><li>Legal name or alias;</li><li>Date of birth;</li><li>Primary address;</li><li>Email address;</li><li>Government identifiers (e.g., social security number, driver's license number, passport);</li><li>Employment and education history;</li><li>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 (e.g., for same sex benefits), veteran or military status;</li><li>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;</li><li>Performance evaluations; and</li><li>Compensation information and tax withholding information.</li></ul><h3>SOURCES OF PERSONAL INFORMATION</h3> We may collect Personal Information about you in various ways, including through:<ul><li>Personal Information provided directly by you;</li><li>Payroll information including but not limited to social security or insurance number, tax details, and paycheck deposit information;</li><li>Wage and benefit information;</li><li>Beneficiary and emergency contact information;</li><li>Resumes and/or applications;</li><li>Degrees and diplomas;</li><li>References and interview notes;</li><li>Third party candidate sourcing technologies;</li><li>Photographs and video;</li><li>Government ID and related information such as driver's license, and passport;</li><li>Letters of offer and acceptance of employment;</li><li>Mandatory policy acknowledgement sign-off sheets;</li><li>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;</li><li>Family member data such as child's birth certificate, marriage certificate, or family member death certificate;</li><li>Background screening information;</li><li>Internal systems configurations may leverage your full name, title, role, etc. with your account details;</li><li>Grindr Services Setup (limited - see "Grindr Employee Use of Grindr Products and Services" below);</li><li>Your utilization of Grindr's information systems (such as SSO logs, IP address, device IDs, etc.); and</li><li>Internal due diligence processes (e.g., when Grindr engages your organization to complete a vendor review).</li></ul><h3>WHAT WE DO WITH YOUR PERSONAL INFORMATION</h3>We gather the Personal Information listed above for business operations, including for establishing, maintaining, or terminating your employment or your engagement with Grindr. Such use cases include, but are not limited to: <ul><li>Background reports and employment verification, including the verification of references;</li><li>Payroll and benefits processing;</li><li>Conducting performance reviews and determining performance requirements;</li><li>Assessing qualifications for a particular job or task;</li><li>Parking and office access;</li><li>Complying with labor or employment law, including immigration filings;</li><li>Disability, unemployment, or other insurance claims;</li><li>Establishing training and/or development requirements;</li><li>Gathering evidence for disciplinary action, or termination;</li><li>Establishing a contact point in the event of an emergency;</li><li>Maintaining and sharing an organizational chart with roles and responsibilities;</li><li>Contributing to global initiatives such as diversity and inclusion, employee onboarding management, and global headcount management;</li><li>Ensuring the security of company-held information;</li><li>To comply with our legal obligations;</li><li>To identify and implement enhancements of our employee recruitment and retention practices;</li><li>To establish a point of contact for communication with third parties and for vendor payment purposes;</li><li>Other purposes as are reasonably required by Grindr in connection with your employment or engagement; and</li><li>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.</li></ul><h3>EMPLOYEE MONITORING</h3>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 employees' activities, online and within the workplace. For example, we have the capability to monitor all employees' use of workplace hardware, software and tools (e.g., laptop, email, and chat).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.<h3>GRINDR EMPLOYEE USE OF GRINDR PRODUCTS AND SERVICES</h3> Personal use of Grindr Services (as defined in the <a href="https://www.grindr.com/privacy-policy/?lang=en-US">Grindr Privacy and Cookie Policy</a>) 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 Services by employees is governed by the <a href="https://www.grindr.com/privacy-policy/?lang=en-US">Grindr Privacy and Cookie Policy</a>.<h3>HOW WE SHARE YOUR PERSONAL INFORMATION</h3>In some instances (i.e., on a conditional and need-to-know basis), Grindr may provide your Personal Information to employees, contractors, consultants, or service providers 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:<ul><li>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;</li><li>To comply with valid legal processes, such as search warrants, subpoenas or court orders;</li><li>To protect the rights and property of Grindr;</li><li>During emergency situations or where necessary to protect the safety of a person or group of persons;</li><li>Where the Personal Information is publicly available (e.g., speaking at an event); or</li><li>With your consent where such consent is required by law.</li></ul>Grindr does not sell In-Scope Individuals' Personal Information to third-parties. <h3>HOW LONG WE KEEP YOUR PERSONAL INFORMATION</h3>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. <h3>YOUR CHOICES AND RIGHTS</h3>In most cases, you have direct access to the systems Grindr uses to support the processing purposes above. Via such access, generally you'll be able to edit or delete your Personal Information yourself. Where your jurisdiction's law allows, you may also request access, edits, or deletions to your information that you're unable to access, delete or correct on your own by submitting a request through our website <a href="https://help.grindr.com/hc/en-us/requests/new?ticket_form_id=360006692913">here</a>.Please note that requests for access, edits, or deletions are not always guaranteed, and may depend on the applicable laws. In the event we cannot fulfill your Personal Information request, Grindr will aim to provide a justification as to why.<h3>PRIVACY OFFICE CONTACT</h3>If you have questions regarding this Policy, you can submit a request through our website <a href="https://help.grindr.com/hc/en-us/requests/new?ticket_form_id=360006692913">here</a>.<h3>YOUR CALIFORNIA PRIVACY RIGHTS</h3>Below we provide specific information for California residents and describe the specific rights afforded to them in accordance with the California Consumer Privacy Act of 2018 ("CCPA") and the California Privacy Rights Act of 2020 ("CPRA"). Your Rights as a California Resident<ol><li>You can request the following information about how we have collected and used your Personal Information during the past 12 months (a majority of this information can be found in the table below or in the broader section of the Policy):</li><ol type="a"><li>The categories of Personal Information we have collected (see table below);</li><li>The categories of sources from which we collected the Personal Information (see table below);</li><li>The business or commercial purpose for collecting and/or selling Personal Information (see WHAT WE DO WITH YOUR PERSONAL INFORMATION above. Per HOW WE SHARE YOUR PERSONAL INFORMATION above, we do not sell In-Scope Individuals' Personal Information to third-parties for monetary or other valuable consideration (or share Personal Information for cross-contextual behavioral advertising purposes));</li><li>The categories of third parties with whom we share the Personal Information (see table below);</li><li>The categories of Personal Information that we sold or shared for cross-contextual behavioral advertising or disclosed for a business purpose (e.g., Service Providers and Other Partners) (see table below);</li><li>The categories of third parties to whom the Personal Information was sold or shared for cross-contextual behavioral advertising, or disclosed for a business purpose (see table below);</li></ol><li>You can request a copy of the Personal Information that we have collected about you during the past 12 months. You can make these requests twice a year and Grindr has up to 45 days to respond to your request (with an optional additional 45 days that Grindr may inform you about);</li><li>You can ask us to delete the Personal Information that we have collected from you;</li><li>You can correct inaccurate Personal Information;</li><li>Grindr does not sell In-Scope Individuals' Personal Information to third parties for monetary or other valuable consideration (or share Personal Information for cross-contextual behavioral advertising purposes).</li><li>You are entitled to exercise the rights described above free from discrimination.</li></ol>Personal Information Collected, Shared, and SourcesFor ease of reference, the table below describes the categories of personal information we have collected and shared in the preceding 12 months for business purposes:<table><tbody><tr><td>Category of Personal Information Collected</td><td>Source</td><td>Disclosed for a Business Purpose</td><td>Purposes for Collecting, Selling, or Sharing Personal Information</td></tr><tr><td>A. Identifiers and contact information, such as email, phone number, postal address, and identification documents (e.g., driver license, passport)</td><td><ul><li>You</li><li>Service Providers (e.g., sourcers)</li></ul></td><td><ul><li>Service Providers (e.g., benefits providers, expense reimbursement systems, payroll systems)</li><li>Contractors (e.g., accounting consultants)</li></ul></td><td><ol><li>Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business;</li><li>Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes;</li><li>Debugging to identify and repair errors that impair existing intended functionality.</li><li>Undertaking internal research for technological development and demonstration; and</li><li>Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.</li></ol></td></tr><tr><td>B. California customer records (as defined in California Civil Code § 1798.80)</td><td colspan="3">N/A - Grindr does not directly collect this information from In-Scope Individuals</td></tr><tr><td>C. Characteristics of protected classifications under California or federal law, such as age, gender identity, marital status, and medical information</td><td><ul><li>You</li><li>Service Providers (e.g., sourcers)</li></ul></td><td><ul><li>Service Providers (e.g., benefits providers)</li></ul></td><td><ol><li>Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business;</li><li>Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes;</li><li>Debugging to identify and repair errors that impair existing intended functionality.</li><li>Undertaking internal research for technological development and demonstration; and</li><li>Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.</li></ol></td></tr><tr><td>D. Commercial information, such as business expense-related information (e.g., receipts)</td><td><ul><li>You</li></ul></td><td><ul><li>Service Providers (e.g., expense reimbursement systems)</li><li>Contractors (e.g., accounting consultants)</li></ul></td><td><ol><li>Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business;</li><li>Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes;</li><li>Debugging to identify and repair errors that impair existing intended functionality.</li><li>Undertaking internal research for technological development and demonstration; and</li><li>Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.</li></ol></td></tr><tr><td>E. Biometric information</td><td colspan="3">N/A - Grindr does not directly collect this information from In-Scope Individuals</td></tr><tr><td>F. Internet and other electronic network activity information, such 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</td><td><ul><li>You</li><li>Your Device</li></ul></td><td><ul><li>Service Providers (e.g., who provide security monitoring tools)</li></ul></td><td><ol><li>Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business;</li><li>Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes;</li><li>Debugging to identify and repair errors that impair existing intended functionality.</li><li>Undertaking internal research for technological development and demonstration; and</li><li>Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.</li></ol></td></tr><tr><td>G. Geolocation data, such as home address, office visits, or business travel itinerary</td><td><ul><li>You</li><li>Service Providers (e.g., sourcers)</li></ul></td><td><ul><li>Service Providers (e.g., talent acquisition systems, corporate travel portals)</li></ul></td><td><ol><li>Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business;</li><li>Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes;</li><li>Debugging to identify and repair errors that impair existing intended functionality.</li><li>Undertaking internal research for technological development and demonstration; and</li><li>Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.</li></ol></td></tr><tr><td>H. Audio, electronic, visual or similar information, such as audio and video from recorded meetings and presentations, or from security cameras in common spaces (e.g., points of entry into Grindr's offices)</td><td><ul><li>You</li></ul></td><td><ul><li>Service Providers (e.g., video conference vendors)</li></ul></td><td><ol><li>Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business;</li><li>Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes;</li><li>Debugging to identify and repair errors that impair existing intended functionality.</li><li>Undertaking internal research for technological development and demonstration; and</li><li>Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.</li></ol></td></tr><tr><td>I. Professional or employment-related information, such as compensation information, tax withholding information, current or past job history or performance evaluations</td><td><ul><li>You</li><li>Service Providers (e.g., sourcers)</li></ul></td><td><ul><li>Service Providers (e.g., payroll systems)</li></ul></td><td><ol><li>Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business;</li><li>Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes;</li><li>Debugging to identify and repair errors that impair existing intended functionality.</li><li>Undertaking internal research for technological development and demonstration; and</li><li>Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.</li></ol></td></tr><tr><td>J. Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act</td><td colspan="3">N/A - Grindr does not directly collect this information from In-Scope Individuals</td></tr><tr><td>K. Inferences that we derive from the preceding information collected, such as records that may indicate an individual's preferences, characteristics, predispositions, behavior, attitudes, or abilities</td><td><ul><li>Grindr employees</li></ul></td><td><ul><li>Service Providers (e.g., people management platform providers, talent acquisition systems)</li></ul></td><td><ol><li>Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business;</li><li>Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes;</li><li>Debugging to identify and repair errors that impair existing intended functionality.</li><li>Undertaking internal research for technological development and demonstration; and</li><li>Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.</li></ol></td></tr><tr><td>L. Sensitive Personal Information, including certain identifiers listed in the preceding categories A, C and G, account log-in credentials, and the contents of communications where Grindr is not an intended recipient.See note on sensitive Personal Information below.</td><td><ul><li>You</li><li>Your Device</li><li>Service Providers (e.g., sourcers)</li></ul></td><td><ul><li>Service Providers (e.g., benefits providers, expense reimbursement systems, payroll systems, talent acquisition systems)</li><li>Contractors (e.g., accounting consultants)</li></ul></td><td><ol><li>Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business;</li><li>Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes;</li><li>Debugging to identify and repair errors that impair existing intended functionality.</li><li>Undertaking internal research for technological development and demonstration; and</li><li>Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.</li></ol></td></tr></tbody></table> Note on sensitive Personal Information. We limit our use of sensitive Personal Information to only the purposes necessary in connection with your employment or engagement with Grindr.Verification. When submitting a request, Grindr will verify your identity, in order to help protect your privacy and maintain security. You can submit a request through our website <a href="https://help.grindr.com/hc/en-us/requests/new?ticket_form_id=360006692913">here</a>, where we'll require you to provide additional information to authenticate your identity.Authorized Agents. If you are an authorized agent for a California individual, please click <a href="https://help.grindr.com/hc/en-us/requests/new?ticket_form_id=360006692913&tf_360050725894=yes-ca-agent">here</a> to submit a request and attach a signed designation form from the individual that you represent authorizing you to serve as the individual's agent for the purposes of exercising the individual's rights under the applicable California law. Individuals can optionally notarize the document or provide a Power of Attorney document along with the signed designation form. If you do NOT provide the signed designation form, we cannot honor any requests you submit on behalf of the individual.Data Retention. We retain your Personal Information for no longer than is necessary to fulfill the purposes for which the information was collected or as otherwise permitted or required by applicable law or pursuant to <a href="https://www.grindr.com/terms-of-service/">Grindr Terms and Conditions of Service</a> and/or Grindr <a href="https://www.grindr.com/community-guidelines/">Community Guidelines</a> Community Guidelines (the latter applicable to the In-Scope Individual's use of the Grindr Services).For In-Scope Individuals who use the Grindr Services, you can visit our <a href="https://help.grindr.com/hc/en-us/sections/4402729693971-Privacy">Privacy Help Center</a> to learn more about our features that support your privacy and choices. To exercise your choice and rights, click <a href="https://help.grindr.com/hc/en-us/requests/new?ticket_form_id=360006692913">here</a>. Statistics pertaining to Grindr's processing of access, deletion and correction requests (which includes statistics with respect to In-Scope Individuals' use of the Grindr Services) can be found <a href="https://www.grindr.com/privacy-policy/privacy-rights-requests/en-us">here</a>.If you would like to request a copy of information regarding our disclosure to third parties for their direct marketing purposes in the preceding calendar year, or if you have questions about your California privacy rights, you can submit a request through our website <a href="https://help.grindr.com/hc/en-us/requests/new?ticket_form_id=360006692913">here</a> or by postal mail at: Grindr LLC, Attn: Privacy Office, PO Box 69176, West Hollywood, CA 90069.</div>

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