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Griffis Residential Job Applicant Privacy Notice

Last Updated: June 19th, 2025

Griffis Residential (“the “Company”, “we”, “us”, “our”) takes your privacy seriously. Because we gather certain types of information about applicants during the recruitment process, we want to help you understand our practices surrounding the collection, use, disclosure, and other handling (collectively, “process”) of your personal information.

EEO Statement

Griffis Residential is an Equal Opportunity Employer that does not discriminate on the basis of actual or perceived race (including hair texture, hair type, or protective hairstyles commonly or historically associated with race), creed, color, religion, alienage or national origin, ancestry, citizenship status, immigration status, age, physical or mental disability, sex (including pregnancy, childbirth, breastfeeding or related medical conditions), marital status, military or veteran status, sexual orientation, genetic information, gender, gender identity and gender expression, AIDS/HIV/Hepatitis C status, arrest record, or any other characteristic protected by applicable federal, state or local laws. Our management team is dedicated to this policy with respect to recruitment, hiring, placement, promotion, transfer, training, compensation, benefits, Associate activities and general treatment during employment.

Griffis Residential complies with the ADA, the ADAAA and applicable state law and considers reasonable accommodation measures that may be necessary for qualified applicants/employees to perform the essential functions of the job. Hire may be contingent upon a post-offer medical examination, and to skill and agility tests, as appropriate for the position.

Assistance For The Disabled

Alternative formats of this Notice are available to individuals with a disability. Please contact ccparequests@griffisresidential.com for assistance.

1. Scope of this Notice

This Privacy Policy applies to the personal information of individuals in their role as job applicants to the Company (“Applicants”). 

Except with respect to Applicants, this Notice does not apply with respect to the personal information processed by the Company in our capacity as an employer, including the personal information of the Company’s current or former employees. Griffis Residential maintains separate policies, if and to the extent required by law, with respect to the Company’s processing of personal information in its capacity as employer.

The term “personal information” as used in this Notice 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 Applicant. However, personal information does not include: (a) information publicly available from government records or made publicly available by you or with your permission; (b) protected health information covered by the Health Insurance Portability and Accountability Act (“HIPAA”) or medical information covered by California Confidentiality of Medical Information Act (“CMIA”); or (c) personal information covered by certain sector-specific privacy laws, such as the Fair Credit Reporting Act (“FCRA”).

2. Personal information we collect

We may collect the following categories of personal information. Not all categories may be collected about every Applicant.

  • Identifiers: such as your name, nickname(s), telephone number, mailing address, e-mail address, Internet Protocol (IP) address, and signature.
  • Professional or Employment-Related Information: such as educational institutions attended, degrees and certifications, licenses, work experience and previous employers, professional memberships and affiliations, and any information you disclose through your LinkedIn profile.
  • Commercial Information: For example, if you travel to a Griffis Residential office for an in-person interview during the recruitment process, we may collect information related to your travel and lodging arrangements.
  • Internet or Other Similar Network Activity: We may collect information regarding your interaction with the Company's website, including through the use of cookies. Please review our Privacy Policy to learn about the information we collect automatically using cookies when you visit our website. If you visit our offices during the recruitment process and use our guest WiFi, we may collect information about that use, such as type of device used and start/stop time.
  • Audio, electronic, visual, or similar information: such as voicemails, , and footage from video surveillance cameras.
  • Medical information: If you request an accommodation in connection with the hiring process, we may collect medical information about you.
  • Characteristics of Protected Classifications Under State or Federal Law for Applicants, We may collect—on a purely voluntary basis—information about your protected classification, i.e., gender, race/ethnic origin and/or veteran status in order for us to conduct equal opportunity monitoring only in compliance with applicable laws and regulations. If you decline to provide this information, your application(s) will not be affected in any way.
  • Other information you provide with your application: We may also collect other personal information submitted within your resume, cover letter, or in an interview, for example, hobbies and leisure activities or membership in voluntary/charitable/public organizations.

3. Sources of personal information

We collect personal information from the following categories of sources. Not all categories apply to every Applicant.

  • You: in your job application, forms you fill out for us, assessments you complete, surveys you complete, and any information you provide us during the course of your application and interview process.
  • Vendors and service providers: for example, from recruiters.
  • Third parties: for example, from job references, affiliated companies, professional employer organizations or staffing agencies.
  • Public internet sources: for example, from social media, job boards, public profiles, and other public online sources.
  • Automated technologies: for example, on the Company's website or careers page, video surveillance in common areas of Company facilities, voicemail technologies, webcams, and audio/video recording technologies with consent to the extent required by law.

4. How we use personal information

We may use the personal information we collect for one or more of the following purposes:

A. Generally applicable purposes

Unless stated otherwise in section 4.B, below, we may use Applicants’ personal information for the following purposes:

Recruiting:

  • To evaluate your qualifications or suitability for employment with the Company
  • To communicate with you
  • To check your references
  • To conduct a pre-employment or criminal history background check
  • For identification purposes
  • For diversity and inclusion purposes where permitted by applicable law
  • For recordkeeping purposes
  • To demonstrate your agreement to, or acceptance of, documents presented to you, e.g., pre-employment arbitration agreement, acknowledgment of employment application, offer letter
  • To evaluate and improve the recruiting process

If you visit our facilities:

  • To make travel arrangements
  • To reimburse travel expenses
  • To managed access to the facility
  • To issue a security badge
  • To monitor your use of the corporate Internet access if you connect to our guest WiFi during a visit to our offices

Other purposes to conduct our business:

  • To manage and operate information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, strategic planning
  • To manage litigation involving the Company, and other legal disputes and inquiries, and to meet legal and regulatory requirements
  • In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of the Company.
  • To protect the rights, property, or safety of the Company, Applicants, residents or others

B. Purposes specific to certain categories of personal information

We may use the categories of Applicants’ personal information listed in this Section 3.B for the purposes stated below:

Purposes for using medical information:

  • To the extent necessary to comply with the Company's legal obligations, such as to accommodate disabilities
  • For occupational health and safety compliance and record-keeping
  • To conduct pre-employment medical examinations
  • To respond to an Applicant's medical emergency

Purposes for using protected classifications under state or federal law:

The Company collects information about race, age, national origin, disability, sex, and veteran status as necessary to comply with legal obligations, including the reporting requirements of the federal Equal Employment Opportunity Act, The Office of Federal Contracting Compliance Programs (applicable to government contractors), and state laws, and for purposes of diversity analytics.

The Company also uses this personal information for purposes including: (a) with respect to disability and/or medical condition, as necessary, to comply with federal and state law related to accommodation; and (b) with respect to age, incidentally to the use of birth date for identity verification.

C. Recruiting Text Messages

If you opt-in when submitting your application, the Company, or trusted service providers on our behalf, may send automated text messages relating to your application and other similar recruiting-related text messages that may be of interest to you. For example, messages about the status of your application, invitations to schedule an interview, to notify you about hiring events, or about other openings or job opportunities you may be interested in.

If you no longer wish to receive these communications from us, you can opt out at any time by replying “STOP” to any message, or by contacting the Company directly using the information listed in Section 10 (Contact us), below.

Carriers are not liable for delayed or undelivered messages. Message and data rates may apply for any messages sent to you from Griffis Residential, and to Griffis Residential from you. Message frequency varies. If you have any questions about your text plan or data plan, please contact your wireless provider.

5. How we disclose personal information

We generally maintain personal information related to Applicants as confidential, and we will not sell, lease, or license your personal information to any third party. There are limited circumstances when the Company may disclose the personal information we collect about you to third parties, most notably:

  • Your direction: We may disclose your personal information to third parties at your direction.
  • Service providers and contractors: We disclose your personal information to service providers and contractors for the purposes above to assist us in our recruiting efforts and in meeting our business needs and legal obligations.
    • The Company only discloses your personal information to service providers and contractors subject to written contracts as required by applicable law.
    • Service providers and contractors include recruiters, law firms, travel agencies, and any other entity providing services to the Company.
  • Government or administrative agencies: These may include, for example the
    • Equal Employment Opportunity Commission as required for reporting.
    • State equal employment agencies as required to respond to employment claims and charges.
    • Law enforcement in the event of criminal investigations.
  • Required Disclosures: We may be required to disclose personal information in a court proceeding, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.
  • Legal Compliance and Protections: We may disclose personal information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Company, Applicants, or others.

6. How we secure personal information

We want you to feel confident about providing your personal information through the online application page, so we have implemented a security program to keep information that is transmitted to our systems protected from unauthorized access. Your submissions of information to our secure server are protected by Hypertext Transfer Protocol Secure (“HTTPS”) and Transport Layer Security (TLS) technology, utilized by many popular browsers to safeguard transmissions. This technology allows us to use encryption tools to protect information transmitted between your computer and our server. After we have received your information, access to it is limited to employees with a need to know.

While we strive to protect your personal information, we cannot guarantee the security of any information that you submit through the online application, and you do so at your own risk. We urge you to keep your username, password and any other log-in credentials in a safe place as you share responsibility for maintaining the confidentiality of the information that you submit to us.

7. How long we retain personal information

If the Company hires you, the information collected about you during the job application process may become part of your personnel file, which may be used to administer the employment relationship and for related reporting and recordkeeping purposes. In that case, the Company will retain application information for the entire duration of your employment relationship with Company and for as long thereafter as permitted or required by applicable law. The Company makes its document retention schedule available to employees for review.

The Company will retain information of applicants who are not hired for at least one year and longer if required by applicable law (for example, for four years for California residents). These records will be retained for our internal recordkeeping and reporting purposes. During this retention period, we may use your information to consider you for positions in addition to the position(s) for which you initially applied.

8. Additional information for California Applicants

This section applies only to Applicants who reside in the state of California (“California Applicants”), to the extent that Griffis Residential’s processing of their personal information is subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act, (the “CCPA”).

California Notice at Collection:

The Company collects the categories of personal information identified in Section 2 (Personal information we collect), for the purposes identified in Section 4 (How we use personal information), and retains personal information for the period described in Section 7 (How long we retain personal information). We do not, and will not, sell your personal information or disclose it to third parties for cross-context behavioral advertising (“sharing”). In addition, we have no actual knowledge that we sell or share the personal information of individuals of any age, including the personal information of children under 16. We also do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

Additional Information Regarding Disclosures of Personal Information

We may disclose your personal information to third parties for the following “business purposes” as that term is defined in the CCPA and as a supplement to the disclosure described in Section 5 (How we disclose personal information), above:

  • Service providers: We may disclose any of the categories of personal information listed above to service providers for the business purpose of performing services on the Company’s behalf, as well as (a) helping to ensure security and integrity, (b) debugging, (c) short-term transient use, and (d) internal research.
  • Auditors, lawyers, consultants, and accountants engaged by the Company: We may disclose any of the categories of personal information listed above to these service providers or contractors for the business purpose of auditing compliance with policies and applicable laws, in addition to performing services on the Company’s behalf.

Note on Deidentified Information

At times, the Company converts personal information into deidentified information using reasonable measures to ensure that the deidentified information cannot be associated with the individual (“Deidentified Information”). The Company maintains Deidentified Information in a deidentified form and does not attempt to reidentify it, except that we may attempt to reidentify the information solely for the purpose of determining whether its deidentification processes ensure that the information cannot be associated with the individual. The Company prohibits vendors, by contract, from attempting to reidentify this Deidentified Information.

Your California Privacy Rights

Subject to applicable limitations and exceptions, California Applicants have the following rights under the CCPA:

  • Right to Know: You have the right to submit a verifiable request for specific pieces of your personal information obtained from you and for information about the Company’s collection, use, and disclosure of categories of your personal information.
  • Right to Delete: You have the right to submit a verifiable request to delete personal information that the Company has collected from or about you.
  • Right to Correct: You have the right to submit a verifiable request to correct inaccurate personal information about you maintained by the Company, taking into account the nature of the personal information and the purposes of processing the personal information.
  • Non-Discrimination: The Company will not unlawfully discriminate against you for exercising your privacy rights under the CCPA

How to Exercise Your California Privacy Rights

You can exercise these rights in the following ways:

How We Will Verify Your Request

If you submit a request, we match personal information that you provide us against personal information we maintain in our files. The more risk entailed by the request (e.g., a request for specific pieces of personal information), the more items of personal information we may request to verify your identity. If we cannot verify your identity to a sufficient level of certainty to respond securely to your request, we will let you know promptly and explain why we cannot verify your identity.

Authorized Agent

If an authorized agent submits a request to know, correct, or delete on your behalf, the authorized agent must submit with the request a document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you to follow the applicable process described above for verifying your identity. You can obtain an “Authorized Agent Designation” form by contacting us at ccparequests@griffisresidential.com.

9. Changes to this Notice

If we change this Privacy Notice, we will post those changes on this page and update the Notice’s modification date above. If we materially change this Privacy Notice in a way that affects how we use or disclose your personal information, we will provide a prominent notice of such changes and the effective date of the changes before making them.

10. Contact us

For questions or concerns about Company’s privacy policies and practices, please contact us using any of the following methods:

4898-8026-9381.1 / 096397.1007