Grid Dynamics California Resident Privacy Notice

Last Updated: 5/9/2024

This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under the CCPA. If you are a California resident job applicant, please see our California Resident Job Applicant Privacy Notice.

Personal Information Collection, Disclosure, and Sale

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Rights Act of 2020 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).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:

Publicly available or lawfully obtained, truthful information that is a matter of public concern.
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 our services. We may also obtain information about you from other sources, such as social media and databases.

2. Categories of Personal Information We Collect and Disclose to Third Parties

The chart below provides the categories of Personal Information (as defined by the CCPA) that we collect and disclose for a business purpose.

Categories of Personal Information Collected	Categories of Third Parties to Whom We Disclosed Personal Information for a Business Purpose
A. Identifiers Examples: Name, online identifier, internet protocol address, email address, and other similar identifiers.	• Affiliates • Service Providers • Advertising Networks • Analytics Providers
B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e) Examples: Name and telephone number.	• Affiliates • Service Providers
C. Internet or Other Electronic Network Activity Information Examples: Browsing history, search history, and information regarding your interaction with our website or advertisement.	• Affiliates • Service Providers • Advertising Networks • Analytics Providers
D. Inferences Drawn from Personal Information

Over the past 12 months, we have collected and disclosed each of the categories of Personal Information as described in the chart above. As described in that chart, we have disclosed Identifiers and Internet or Other Electronic Network Activity Information to advertising networks. Under the CCPA, some of these data disclosures may broadly be considered a “sale” of information and “sharing” of Personal Information for cross-context behavioral advertising. Over the past 12 months, we have not collected Sensitive Personal Information in our capacity as a Business and therefore did not disclose Sensitive Personal Information for purposes other than those permitted by the CCPA. We do not have actual knowledge that we sell Personal Information or shares for cross-context behavioral advertising the Personal Information of consumers under 16 years of age.

3. Use of Personal Information

We collect, sell, share, or disclose your Personal Information for the following specific business and commercial purposes:

To provide, maintain, improve, and enhance our services;
To communicate with you, provide you with updates and other information relating to our services, provide information that you request, respond to questions, and otherwise provide customer support;
To understand and analyze how you use our services and develop new products, services, features, and functionality;
For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you;
To de-identify and aggregate information collected through our services and use it for our business purposes;
To find and prevent fraud, and respond to trust and safety issues that may arise;
For compliance purposes, including enforcing our legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
For other purposes for which we provide specific notice at the time the personal information is collected.

4. Retention

We collect the following categories of personal information for the pWe will retain Personal Information for a time period required or allowed by applicable regulations or laws and as needed to fulfill legitimate business purposes outlined in Section 3, including providing you products and services, complying with our legal obligations, resolving disputes, and enforcing our agreements, or for other purposes described in this California Resident Privacy Notice. Our retention of information is based on many factors such as your relationship with Grid Dynamics, the nature of the information, compliance with our legal obligations, and defending or resolving actual or anticipated legal claims.

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.
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, please send an email to dpo@griddynamics.com. Such requests are subject to our ability to reasonably verify your identity. To verify your request, we will ask you for your name, address, email address, and potentially other information about you that you have previously provided to us to respond to your access or deletion requests. 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, you may submit a request through the methods described above. Your Authorized Agent should submit proof that you gave the agent signed permission to submit the request. We may still require you to directly verify your identity and directly confirm that you have provided the Authorized Agent permission to submit the request.

You can exercise your right to opt out of the “sale” of your Personal Information, or the “sharing” of your Personal Information for cross-context behavioral advertising by clicking the “Do Not Sell or Share My Personal Information” link in our website footer or by visiting this link. If you are visiting our website using a web browser with the Global Privacy Control (“GPC”) signal enabled, we will treat the GPC signal as a “sale” and “sharing” opt-out request.

6. Contact Information

If you have any questions, comments, or concerns about this notice or our processing activities, please email us at dpo@griddynamics.com or write to us at:

Grid Dynamics
5000 Executive Parkway, Suite 520
San Ramon, CA 94583.