Privacy Policy

Graphite Growth, Inc. HR PRIVACY NOTICE

Effective Date : October 1st, 2022

Welcome to Graphite Growth, Inc.!

Regardless of whether you’re a current Graphite Growth, Inc. team member, or you’re applying to be part of our team, it’s important to us that you’re aware of personal information that we collect, how we use that information, and how you may be able to opt-out, correct, delete, or change that information.

This Privacy Notice applies to all applicants and prospective employees (collectively, “Applicants”) and employees, officers, directors, contractors, and other personnel (collectively, “Team”) of Graphite Growth, Inc., and their emergency contracts and beneficiaries, whose personal information is collected and processed by us in the course of our business. The terms “Graphite Growth” “we,” “us,” and “our” in this policy apply to all companies in the Graphite Growth, Inc. family of companies, which includes Graphite Growth Inc., its affiliates, and subsidiaries.

Applicants, Team members, emergency contacts or beneficiaries with disabilities may access this notice in an alternative format by contacting We do not sell your personal information.




The personal information we collect directly from Team and Applicants may include:  

  • General HR information. This might include your name, alias, postal address, phone number, unique personal identifier, online identifier, email address, date of birth, age, passport number, driver’s license number, Social Security number or other government-issued identification number, employment history, education information and records, professional qualifications, salary information, financial information related to credit checks, bank account number, routing number, and other details required for payroll, information that may be recorded on a resume/CV or application form (such as education history, education records such as grades and transcripts, and employment history), language abilities, records of personal property, business or professional licenses and insurance information and motor vehicle records, and contact information of third parties in case of an emergency.
  • Demographic and Health information. Where required to run our business and ensure the safety of our Team, we may also collect sensitive personal information such as details of health and disability, including details regarding your COVID-19 tests and vaccinations, health insurance information, mental health, medical leave, and maternity leave, national origin, or immigration status. Where permitted by law, we may also ask Applicants and Team for optional information like race, disability, marital status, sex, ethnicity, gender, or military and veteran status to help us achieve our diversity goals.
  • Performance Information. We may also receive or collect other information to help evaluate your application or your performance, such as information you choose to disclose during the interview process (as an Applicant) or provided by you during performance reviews (as a Team member). From Team, we may also collect job assignments, work schedule, hours worked, accomplishments and awards, training and development information, discipline and counseling information, opinions, evaluations, and information provided to us from other Team as part of this review process.
  • Your Communications with Us. If you contact us, for example to inquire about benefits or ask about a job opportunity, we will receive your information, including whatever information you use to contact us.
  • Posting on Intra-Company Sites. We may offer intra-company accessible sites, pages, messaging channels, blogs, or forums for Team to communicate and collaborate with each other, like Discord or Slack (“Intra-Company Sites”). We and other individuals who use the Intra-Company Sites may collect the information you submit or make available through these sites. If you choose to make content available on any public area of the Intra-Company Sites, such content will be visible to other Team and not subject to the privacy protections set forth here in this notice.
  • Surveys and Promotions. From time to time, we may ask Team or Applicants to participate in optional surveys to help inform our decision-making and to ensure that your views are represented and considered. If you decide to participate, you may be asked to provide certain information, which may include personal information. In that same vein of building bonds and community at Graphite Growth, we also frequently run optional Team member promotions and contests. It’s possible that you may be asked to provide certain information to participate, which may include personal information.
  • Legal Information. We also collect contractual information, such as information necessary to comply with legal and contractual obligations, exercise legal and contractual rights, and initiate or respond to legal claims.

Like most companies, Graphite Growth also collects information automatically from Team members throughout the course of their employment when they use our information technology systems and networks. For example:

  • Device Information. We may collect certain information automatically about the devices Team members use on our networks, including  internet protocol (IP) address, your location based on your IP address or activities, identifiers associated with your computer or device, mobile device type and carrier, activity logs, and other information about activities you engage in while working with us, and on our equipment, accounts, systems, and networks.
  • System Monitoring. We may monitor and review Team members’ use of Graphite Growth equipment, accounts, information technology systems and networks, including video conferencing systems, email, phone networks and devices that connect to the Internets. Graphite Growth may review Team members’ electronic files, messages, and emails sent or stored on its information technology systems and hardware. To the maximum extent permitted by law, Team Members have no expectation of privacy while at Graphite Growth premises or while using Graphite Growth information technology systems, networks, and electronic communication tools. However, this should not be construed to mean that all Team members will not have access to every file, network, and programs used by other Team members.

We may also collect or receive information about Applicants and Team members from other sources, including through third-party services and organizations to supplement information provided by you, including:

  • Audiovisual Information. We may collect audio and visual information such as through photographs used for identification purposes, and we might also use photos of Team members to promote Graphite Growth, such as in our website or in marketing materials. We may also collect audio and video recordings of training sessions or other Graphite Growth meetings.
  • Inferences Drawn from Other Personal Information. We may collect inferences drawn from other personal information such as your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • Information from Other Sources. We may collect or receive information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, where permitted by law, we may conduct background and credit checks on you prior to your employment with Graphite Growth.



We collect your personal data for a variety purposes for the operation of our business, including:

  • To determine if you are a good fit for our team, to communicate with you about your application, and to help you get on board if we make you an offer;
  • To assist you with obtaining an immigration visa or work permit (where required and requested by you);
  • For Payroll and the provision of benefits;
  • For compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
  • For performance evaluation;
  • To contact your emergency contacts in the event of an emergency;
  • For human resources operations administration and communication;
  • For workflow management, including assigning, managing and administering projects;
  • To pursue our legitimate interests (for example, for fraud prevention, network, and information security, to disclose to affiliated organizations for administrative tasks, Team monitoring for safety or management, whistleblowing schemes, for the establishment, exercise, or defense of legal claims, to perform internal and/or external or governmental compliance investigations or audits, and for research purposes).

Retention and International Transfer. Regardless of what’s obtained, we only retain your data as long as we need to. After we complete any necessary work, like conducting audits, ensuring we comply with laws, carrying out HR operations, resolving disputes, etc., we endeavor to safely and securely destroy and delete the data we’ve collected about you. Note that it’s possible that your information will be shared, processed, and kept in a country different from where you live. To help keep your personal data safe, we keep informed of local laws and take best efforts to follow those.



To run our business, we may share your information with the following categories of parties: (i) vendors and other service providers, such as those we use for HR and it needs; (ii) our corporate affiliates, parents, and subsidiaries to optimize our operations; (iii) to law enforcement if we’re served with a court order, a subpoena, receive a proper request from law enforcement, or if we reasonably believe it is necessary to protect the rights or safety of you or the team; and (iv) to other individuals (including other team) if you post content to the intra-company or our public-facing sites. While we expect all team to use professional judgment and treat other team fairly, we are not responsible for practices of the individuals who view and use your information.

Additionally, if we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another entity, that might entail your personal information being seen by or transferred as part of such a transaction as permitted by law and/or contract.



In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to or restrict our uses of your personal information; (v) seek correction of inaccurate, untrue or incomplete personal information; (vi) withdraw your consent; and (vii) request erasure of personal information held about you by Graphite Growth, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

We will process such requests in accordance with applicable laws. To protect your privacy, Graphite Growth will take steps to verify your identity before fulfilling your request.

Note: If you are a Graphite Growth Team member or Applicant who lives in the European Economic Area, Switzerland, the United Kingdom, or Brazil, you may have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.



We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue your employment with or services to Graphite Growth after the new Privacy Notice takes effect. If at any point you do not agree to any portion of the Privacy Notice in effect, you must immediately contact Human Resources.



If you have any questions about our practices or this Privacy Notice, please feel free to reach out to us by emailing or by contacting our Human Resources Department.