Last Updated: 3-16-2022
(c) Gray provides construction, engineering, and architecture services. The Site provides information about Gray’s services, opportunities to contact Gray, and materials, tools, and other resources related to Gray’s services, including job opportunities and vendor tools. The Site also permits you to
register for webinars, conferences, and other events hosted by Gray.
2. Information We Collect.
As explained in more detail below, Gray collects various types of information that identifies you or may identify you as an individual, as well as information that does not.
(a) “Non-personal Information” is any information that does not identify you individually or does not permit a direct association with an individual. Non-personal Information may include information derived from Personal Information that has been de-personalized by removing unique identifiers and/or combining it with information about other users to form aggregated data.
(b) “Personal Information” is information that is reasonably capable of being associated or could be linked, directly or indirectly, with a particular consumer or household. Gray collects some information that is about you individually, but does not identify you, and collects information about your internet connection, your device used to access the Site, and your use of the Site. If Gray combines that information with information that identifies you, Gray will treat it as personal information.
(c) Examples of information Gray collects include:
(i) Registration information you provide when you register for a Gray webinar or other event, including your name, date of birth, postal address, phone number, email address, username, and password;
(ii) Information you provide when you contact us, apply for a position, or make an query through the Site, including your name, phone number, email address, postal address, and job title;
(iii) Information you provide when you subscribe to the Site, including your email address;
(iv) Information we obtain from a third party, such as a third party site, vendor, service provider, analytics partner, marketing or remarketing partner, or other platform provider;
(v) Location information, including location information provided by a mobile device or other device as you navigate our Site;
(vi) Activity information about your use of the Site;
(vii) Information you provide at a trade show, such as a name, company, title, email address, address, and phone number;
(viii) Information you provide at a career fair or through a job board, such as name, email address, phone number, professional background, educational institution, and job interest.
(ix) Information team members provide for payroll and benefits administration, including information about dependents when you select coverage for them.
(x) Usage, viewing, technical, and device data when you visit the Site or interact with communications from our Site.
3. How We Collect Information.
Gray collects information from and about you directly when you provide such information to Gray and automatically when you use the Site.
(a) Information You Provide. Gray collects information you provide when you make inquiries using the “contact us” form, register for an event, register with the site, sign up to receive communications, provide your information at a trade show, join the partner database, provide your information at a career fair or through a job board, apply for a position, contact the ethics hotline, and during team member onboarding and benefits enrollment. The information collected may include anything submitted by you to the Site or to Gray through other means. Gray may retain copies of the correspondence submitted by you. If you voluntarily provide your Personal Information to us, we collect it. You choose whether to disclose Personal Information, but you may not be able to use the Site, use certain features of the site, or conduct certain tasks without doing so.
(b) Information Collected Automatically. When you visit or otherwise use the Site, Gray collects details about your access and use of the Site automatically through cookies, pixels, web beacons, and other similar technology, including details about your device, internet connection, operating system, browser type, browsing actions, and the resources that you access and use on the Site, other traffic data, and, location data. The information Gray collects automatically may include personal information or Gray may associate it with personal information it collects in other ways or receives from third parties. If Gray associates such data with personal information, Gray will treat it as personal information, but if such data is not associated with other personal information, Gray will treat it as non-personal information.
4. Cookies and Related Technology.
(a) “Cookies” are small pieces of data that a website, when visited by a user, asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Cookies set by Gray are called first party cookies. Third party cookies are cookies from a domain different than the domain of the website you are visiting. Cookies can be either persistent or temporary. A persistent cookie retains user preferences for a particular website,
allowing those preferences to be used in future sessions and remains valid until its set expiry date (unless deleted by the user before the expiry date). Temporary cookies expire at the end of a user session when the browser is closed.
(b) “Web beacons” and “pixels” are small bits of code embedded in web pages or emails that assist in delivering cookies and measuring statistics. Web beacons and pixels help Gray determine whether a page on this Site has been viewed and, if so, how many times. Gray may also use web beacons and pixels in email messages to determine what the recipient has done with the message. Although you cannot decline to receive web beacons and pixels when visiting a web page, you can choose not to receive them by email if you disable HTML images or refuse HTML email messages.
5. How We Use Your Information.
Gray uses information that you provide and/or that Gray collects to present the Site to you, improve the Site, deliver more personalized services to you, to provide you with information or services that you request from Gray, to market Gray’s services to you, to consider you for employment with Gray, to fulfill any other purpose for which you provide such information, to provide you with other information you requested, in any other way Gray may describe when you provide the information, and for any other purpose with your consent. The way Gray uses such information is described in more detail in the chart below. Gray may aggregate the information you provide or that Gray collects from you with information collected from other users to allow Gray to evaluate its services. Gray may use the information it collects to contact you about Gray’s services or employment opportunities that may interest you; and, if required by law, we will obtain your approval to do so. If you do not want Gray to use your information this way, please see Section 7 below.
Why GRAY processes your information
Legal basis for the processing purpose
|To respond to your request, to complete your registration,
to fulfill the purpose for which you provide the
|o Performance of a contract
|To personalize and improve your experience with the Site||o Legitimate interest|
|To ensure technical functionality and proper operation of
|o Legitimate interest|
|To improve our services and develop new services||o Legitimate interest|
|To communicate with you for services-related purposes, such
as regarding support issues and customer service inquiries
|o Performance of a contract
o Legitimate interest
|To communicate with you, for the following purposes: to
respond to a request, marketing, remarketing, research, or
other promotional purposes, via email, notifications or
other messages, consistent with any permissions you may
have communicated to us
o Legitimate Interest
|To communicate with you regarding employment opportunities,
confirm your qualifications for employment, or for other
purposes related to human resources or benefits
o Legitimate Interest
|To administer payroll and benefits for team members and
o Legitimate Interest
|To comply with our legal obligations||o Legitimate Interest|
|To carry out our obligations and enforce our rights||o Legitimate Interest
o Performance of a contract
|In any other way described when the information is
|o Legitimate interest
6. To Whom We Disclose.
(b) Google Analytics and Google Advertising Analytics. The Site uses Google Analytics. Google Analytics assists Gray with collecting and monitoring data about Site traffic and usage. Google Analytics collects visitation information and identifiers via browser cookies. You can learn how Google collects and processes data by visiting the following website:
If you would like to opt-out of the collection of data by Google Analytics, visit
For more information about targeting and advertising cookies and how to opt out of those, visit optout.aboutads.info. For more information about Google Analytics’ currently available opt-outs, visit the following website:
7. Your Choices. You have some choices about how personal information you provide to us or that we collect is used.
(b) Updating Information. To request access to, correct, or delete certain personal information that you have provided to Gray, you may contact Gray at the contact information included below or click here. Gray will process requests to the extent required by applicable law. Gray may not accommodate a request to change information if Gray believes the change would violate any law or legal requirement or cause the information to be incorrect.
(c) Do Not Track. The Site does not respond to web browser Do Not Track (DNT) signals.
(d) Email Marketing. You may opt out of receiving electronic marketing communications by using the unsubscribe link in our email communications. Please allow a reasonable time to process your request. Please note that even if you opt out of receiving electronic marketing communications from us we may still contact you for non-marketing purposes such as customer service, notices, or to fulfill legal obligations.
(e) California Residents. You may see the Supplemental Notice applicable to California residents here.
8. For Residents of EEA.
(a) If you reside in the European Economic Area (the “EEA”), the following provisions apply to you:
(i) Access. You may request access to your personal information and the following information regarding our use of it: (i) purpose of the use, (ii) categories of personal information used, and (iii) to whom we have disclosed your personal information.
(ii) Correction. You may request that Gray correct any inaccurate personal information we have.
(iii) Right to Be Forgotten. You may request that Gray erase your personal information when Gray no longer needs such data.
(iv) Withdraw Consent. If Gray’s ability to use your personal information depends on consent you have given, you may withdraw such consent.
(v) Restriction. You may request that Gray restrict (or suspend) use of your personal information.
(vi) Object. You may object to Gray’s use of your personal information to perform services you have not requested.
(vii) Copies and Portability. You may request copies of your personal information that Gray possesses in a structured, commonly used, and machine readable format (for example, .CSV format) and you may request that this be transmitted to another controller.
(viii) Complaint. You may lodge a complaint with the supervising authority of your country.
(b) Exercise of Rights. If you reside in the EEA and would like to exercise any of the rights described in Section 8(a) above or exercise any other data subject right available to you under the EU General Data Protection Regulation (GDPR), you can click here. Gray’s privacy team will examine your request and respond to you as promptly, as required by applicable law.
9. Data Transfer.
10. Data Retention and Security.
(a) Data Retention. Gray may store your personal information as long as you use Gray’s services in order to provide you with such services and for its legitimate business purposes. Gray may store your personal information to the extent required to comply with Gray’s legal, accounting, and/or reporting requirements and to provide information about Gray’ products or services that you may request. Upon your request, Gray will delete or de-identify your personal information unless Gray is legally required or permitted to maintain such personal information. Additionally, Gray may continue to store your personal information contained in standard backups.
(b) Data Security. Gray has implemented technical, organization, and administrative security measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Gray cannot guarantee the security of your personal information transmitted to or through the Site. Any transmission of personal information is at your own risk. Gray is not responsible for circumvention of any privacy settings or security measures contained in the Site.
The Site is not for children. Gray does not knowingly collect personal information from children under the age of 13 through the Site. If Gray learns that it has collected or received such information, it will delete that information. If you believe we might have information from or about a child under the age of 13, please let us know by contacting us using the information set forth in Section 15.
13. Nevada Residents.
Under Nevada law, Nevada residents may submit a request directing Gray not to make certain disclosures of personal information we maintain about them. If you are a Nevada resident and wish to exercise this right, you may contact us by email at email@example.com or by phone at 888-338-6432.
15. Contact Information.
Or these alternative means:
10 Quality Street
attn: Data Subject Requests – CCPA
Lexington, KY 40507