Grimes & Company Applicant Privacy Policy
 

1. Collection of Personal Information

Grimes & Company (“Grimes,” “we,” or “us”) takes the privacy and security of your personal data seriously and is committed to complying with applicable legal requirements. This privacy policy for applicants for employment with Grimes (the “Policy”) explains how Grimes uses and manages the personal information of applicants for employment. 


Grimes uses a third-party service, Paylocity Corporation (“Paylocity”), for our applicant recruiting. When you use the applicant portal on Paylocity, Paylocity collects both personal and non-personal information on behalf of Grimes relating to your application for employment. 


Please note that Grimes does not control the privacy practices of Paylocity. Please refer to Paylocity’s Client Employees Privacy Statement for additional information. 


2. Personal Information Required by Applicant Portal & Use of Personal Information

When you apply for a job with Grimes, we, through the Paylocity platform, ask for certain personal information from you including your name, home address, personal email address, home telephone number and mobile telephone number, skills, education and work history, references, desired salary, how you heard about Grimes, and information obtained from documents you may be required to provide as part of the application process.


The personal information you submit through the Paylocity platform will be used for Grimes’ personnel recruitment, management, and planning purposes, including to: (i) process your application; (ii) assess your capabilities and qualifications for a job; (iii) conduct reference checks; (iv) respond to your inquiries and communicate with you about your application; (v) comply with or monitor compliance with any applicable law or regulation; (vi) conduct background checks if we offer you a position; and (vii) preserve our other legitimate business interests. 


If we hire you, personal information we collect in connection with your application may be incorporated into our human resources system and may be used to manage the new-hire process. Any such personal information may become part of your employee file and may be used for other employment-related purposes. 


We may also use the information as we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities including public and government authorities; (iv) to protect our legal rights and operations or the rights, privacy, safety or property, and/or of us, you, or others; and (v) to allow us to pursue available remedies or limit the damages that we may sustain.


3. Disclosure of Personal Information

We may share personal information with affiliates and/or partners that are involved in evaluating candidates for a given position. We will make the information available to personnel with a business need to know the information, including personnel in the recruiting, human resources, and information technology departments, and in the department responsible for the position for which you are applying.
 

We may share personal information with third-party service providers who provide services such as recruiting assistance, background check processing, and similar services. 


We also may share personal information as we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to protect our legal rights and operations or the rights, privacy, safety or property, and/or of us, you, or others; and (v) to allow us to pursue available remedies or limit the damages that we may sustain.


We may transfer information in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Grimes does not, and will not, sell or share your personal information for commercial purposes.
 

4. Passive Information Collection: Cookies and Similar Technology

Paylocity may collect information automatically as you navigate the applicant portal. Please refer to Paylocity’s Cookie Notice for detailed information about the cookies and other tracking technologies that are used in the applicant portal. The Cookie Notice includes information on how you may deactivate or delete cookies.
 

5. Retention and Deletion of Your Personal Information

Grimes will keep your personal information for as long as needed or permitted considering the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you (such as an application process); (ii) as required by a legal obligation to which we are subject; or (iii) as advisable considering our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations). 


  Grimes uses reasonable organizational, technical and administrative measures to protect personal information within our organization. If you are concerned about the security of your personal information with Grimes, please contact us in accordance with the “Contact Us” section below.  

 

Grimes does not control Paylocity’s retention of your personal information. Please direct your inquiries concerning Paylocity’s retention of your personal information to Paylocity directly at privacy@paylocity.com. Please review Paylocity’s Retention & Disposal policy for more information.  
 

6. California Notice Collection

If you are a resident of California applying for employment with Grimes, you may have certain rights concerning your personal information. The California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (“CPRA”), provides California residents with rights to receive some disclosures regarding the collection, use, and sharing of information about them, as well as rights to know/access, delete, and limit sharing of personal information. You have the right to be free from discrimination based on your exercise of your CCPA rights. If you are a California resident and receive our services solely as a private individual – in other words, not as a member or representative of a company or other organization – you are entitled to the privacy rights listed below:


Right to Know/Access - You have the right to know:

  • The specific pieces of personal information we have about you;
  • The categories of sources from which that personal information was collected;
  • The categories of your personal information that we sold or shared, or disclosed to a third party for a business purpose; 
  • The categories of third parties to whom your personal information was sold or shared (and the categories of personal information sold or shared with each category of third parties), or disclosed for a business purpose; and 
  • The business or commercial purpose for collecting, selling, or sharing your personal information. 

Right to Opt-out of Sale or Sharing of Personal Information

  • Grimes does not sell or share your personal information for commercial purposes, except when required by law or compelled by judicial process. 

Right to Deletion

  • You have the right to request that Grimes delete the personal information collected or maintained about you. Grimes may deny your request under certain circumstances, such as if we need that personal information to comply with legal obligations or complete a transaction for which your personal information was collected. If Grimes denies your request for deletion, we will notify you of the reason for the denial.

Right to No Retaliation

  • If you choose to exercise any of these rights, Grimes will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to proceed with an employment application to Grimes through the applicant portal on the Paylocity website.

7. Applicant Notices 

Grimes reserves the right to amend this Policy at any time. When we make changes to this Policy, we will post it on our website and update the Policy’s last updated date so you can identify when the Policy was last updated. Any changes will become effective upon the posting of the revised Policy. By continuing to use the applicant portal on the Paylocity website for your employment application to Grimes, you will be deemed to have agreed to such changes.


If you do not agree with the terms of this Policy, in whole or in part, you can choose to not use or continue to use the applicant portal on the Paylocity website for your employment application to Grimes.  
 

8. Contact Us

We welcome any questions, comments, or concerns you may have regarding this Policy. Please direct any inquiries to Grimes’ Chief Compliance Officer at One Technology Drive Suite 100, Westborough, MA 01581, with a phone number of (508) 366-3883.