Candidate Privacy Notice

Your privacy is important to EA and we take our responsibility of caring for it seriously. This Candidate Privacy Notice describes how Electronic Arts Inc. (“EA Inc.”), and/or its local subsidiaries as better described in Section 11 below (“EA”, “we”, “us”, “our”), uses personal information from candidates we consider and/or recruit for a position at EA, including when candidates create an EA Job Board Account on ea.gr8people.com (“Account”), otherwise engage with global and/or local EA recruitment services, or when EA proactively sources potential candidates (collectively, “EA Recruitment Services”). This notice also describes how we use personal information from individuals who provide references for candidates (“referees”). In some cases, our subsidiaries may be considered data controllers, either together with EA or by themselves.

1.      Personal Information We Collect 

We may collect personal information as follows:

A.    Information You Give Us Directly

• Name, e-mail address, resume including education and professional qualifications, and any other information candidates submit when registering for an Account or when engaging with other EA Recruitment Services.
• Visa/immigration information, when applicable and as governed by local law.
• Demographic information - such as race, ethnicity, gender, age, sex, disability, and/or veteran status, when applicable and as governed by local law.
• From referees, we may collect name, email address, contact number and the details about their relationship with the candidate, as well as the opinions expressed in the references provided.

B.     Information Provided to Us by Third Parties

We receive information from third parties, such as the following:

• Facebook and LinkedIn, if a candidate chooses to log into their Account using their credentials for these services;
• Google, if they choose to upload their resume and/or any other materials demonstrating their skills and abilities for review by EA (“Material(s)”) directly from their personal Google Drive to their Account;
• Background check services providers, these providers may grant EA access to criminal history when applicable. The collection and use of this data is subject to local laws;
• Contact details, resume, job and education history, endorsements and interests from third party publicly available sources, such as LinkedIn, and third-party recruitment platforms that collate this information from publicly available sources.

Please also see Section 10(A): “Notice at Collection” for a list of the types of information we collect, as described by categories specified in California law, which is incorporated into this section by reference.

C.     Information Automatically Collected

We and third parties may collect additional personal information like IP address, mobile and hardware or device identifiers, browser information, platform type, and similar information when you are using your Account or interacting on ea.gr8people.com.

Cookies are small text files stored on an Internet browser. We may use cookies and similar technologies to help enable functionality on our site, assist with third-party log-ins (e.g. LinkedIn), or assist in managing user sessions (such as whether you have created a profile or to navigate back and forth within the same session), and to understand how you use EA Recruitment Services. We use other technologies for similar purposes as cookies.

We may use tracking pixels or clear GIFs to collect information about your use of EA Recruitment Services, including for analytics. We use Internet log files (which contain technical data such as your IP address, and device) to monitor web traffic, and troubleshoot technical problems.

We will display a way for you to manage your preferences about the loading of cookies and similar technologies when required by applicable law. We will similarly respond to Do Not Track signals, specifically the Global Privacy Control or "GPC,” when required by applicable law.

In the absence of being provided a way to manage your preferences on our website, or as a complement to this functionality, please manage your browser's preferences. You can disable cookies, limit the types of cookies allowed, or set your browser to alert you when cookies are being sent. Please refer to guidance provided by your individual web browser if you'd like help in managing your cookie preferences. Please note that disabling certain cookies may impact the functionality of some features within our websites.

2.      How We Use Personal Information

EA uses the information described above to:

• Manage a candidate’s relationship with us, including Account management.
  
• Contact candidates (including by email) about suitable job opportunities as they arise.
• Assess candidates’ eligibility for available positions at EA.
• Process job application(s).
• Send invitations to EA recruitment events (including by email).
• Send EA recruitment newsletters by email.*
• Assist in EA’s business planning, including analysis of hire trends and internal data reporting purposes.

*You can opt-out of receiving email newsletters from EA at any time by clicking the unsubscribe link in each email newsletter you may receive.

Demographic information will be used for statistical purposes, but it is not taken into consideration by EA in its employment decisions. Candidates will not be subject to any adverse treatment as a result of the answers provided or any decision not to answer. Collection and use of this data is subject to local laws.

EA uses internal tools to analyze your hiring information (which includes start date of hiring, offer details and background checks among others). To do so, EA processes your hiring information mostly in aggregate. This enables us to gain a better understanding of hiring trends and our workforce needs.

3.     Who May Receive Your Personal Information

Service providers. Vendors and other service providers that help us operate our business and provide you with EA Recruitment Services may receive your personal information. We require that any service provider processing your personal information only do so on our behalf and for purposes consistent with this Notice, such as the purposes described in Section 2: How We Use Personal Information.

Disclosures to protect us or others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the event of merger, sale, or other asset transfer. In the event of a reorganization, divestiture, merger, sale, or bankruptcy, we may transfer all information we collect to the relevant third party and will obtain your consent to do so if required by law or contract.

Third-party plugins. When third-party technologies or social tools are integrated into our EA Recruitment Services, those third parties may collect information about your use of our EA Recruitment Services. For example, when you apply to an EA job using LinkedIn.

Candidates. Referees’ opinions may be shared with the relevant candidate in limited circumstances.

With your consent. We may disclose your information to other recipients with your express consent, unless otherwise described above.

4.      Legal Basis for Processing

We rely on a number of legal grounds to process your personal information. For example, we will process your personal information where we have your consent, where we have a legitimate interest to do so (and that legitimate interest is not overridden by your data protection interests or fundamental rights and freedoms), where the processing is necessary for the performance of a contract with you, or where we have a legal obligation to process your personal information. For EA candidates residing in regions where legitimate interest is not recognized as a lawful basis under applicable law, such as Mainland China, EA will identify and use other appropriate lawful bases to process your personal information such as those listed above.

If you wish to learn more about the specific legal ground(s) we rely on to process your personal information for any particular purpose (including any legitimate interests we have to process personal information), then please contact us using the details provided below.

5.      Where We Hold Your Personal Information

When accessing EA Recruitment Services, including those available on third-party platforms, your personal information is typically collected by EA directly and processed in the United States. Personal information we collect may be subsequently stored and processed for the purposes set out in this notice in the United States or any other country in which EA, its subsidiaries, or third-party agents operate. By consenting to the transfer of your personal information outside of your country of residence, you acknowledge that your personal information may be transferred to recipients in the United States and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship.

EA complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. EA has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. EA has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this notice and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

EA is responsible for the processing of personal data it receives, under the Data Privacy Framework, and subsequently transfers to a third party acting as an agent on its behalf. EA complies with the Data Privacy Framework Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

 The Federal Trade Commission has jurisdiction over EA compliance with the EU-U.S. DPF and Swiss-U.S. DPF. In certain situations, Electronic Arts Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, EA commits to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF in the context of the employment relationship.

For complaints regarding DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website: https://www.dataprivacyframework.gov/.

EA's privacy practices comply with the Asia-Pacific Economic Cooperation Cross-Border Privacy Rules System (APEC CBPR). The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies. More information about the APEC framework is available here: https://www.apec.org/about-us/about-apec/fact-sheets/what-is-the-cross-border-privacy-rules-system.

For EA candidates residing in Mainland China, EA will rely on a cross-border data transfer agreement (including the terms in the standard contract released by the Cyberspace Administration of China, where applicable) between Electronic Arts Computer Software (Shanghai) Co., Ltd. and EA Inc. to transfer personal information for the purposes described above. EA is contractually obligated to ensure there are necessary and appropriate safeguards to maintain the security of your personal information during and after the transfer.

6.      How We Protect Your Personal Information

Security of your information is a priority at EA and we take a range of technical and organizational measures to help protect it, including encryption of sensitive information. Even so, please be aware that no security measure is perfect. Thus we cannot guarantee the security of your information at all times. You should always be diligent when it comes to the protection of your personal information. Learn more about EA Security.

7.      Retention of Your Personal Information

We retain the information we collect for as long as necessary to process your personal information as it relates to your candidacy for a position at EA, and we may retain that information beyond that period if necessary for legal, operational, or other legitimate reasons. Generally, this means EA retains your personal information for as long as your Account(s) remain active and as needed to provide EA Recruitment Services.

Your Account may be deactivated and some personal information may be automatically deleted from the Account database after a period of inactivity. We may retain other information for a reasonable period of time after account deactivation or after providing any other EA Recruitment Service for purposes such as responding to recruitment inquiries, addressing legal matters, or to comply with archiving or other legal requirements.

Where possible, we may also de-identify, anonymize, or aggregate the information we collect, or collect it in a way that does not directly identify you. We may use and share such information as necessary for our business purposes and as permitted by applicable law.

8.      Your Privacy Rights

You may be entitled to exercise several privacy rights, such as:

Right to access (or “know”). You may have the right to access the personal Information we hold about you, including the categories of personal information collected, where we collect it from, why and how we use it, and who may receive this information.

Right to correction and deletion. You can request correction of your personal information where it is inaccurate. You can also correct, update or delete your personal information by accessing your user profile online.

If your Account is deleted, you will not be considered for an available position at EA unless you submit your information through another means. Should you wish to delete your personal information, EA may still be required to retain certain personal information for legal or administrative reasons. For example, EA may require some personal information to resolve disputes, protect our legal rights, and comply with technical and legal requirements and constraints related to the security, integrity and operation of our business. We will however only retain personal information for as long as reasonably necessary to comply with the law and run our business.

Where we rely on consent to collect and use information about you, you can withdraw your consent at any time. This does not however affect the processing of that personal information data prior to your request to withdraw your consent.

Other rights

 You may have the right to object to the processing of your personal information for certain purposes, and the right not to receive discriminatory treatment for the exercise of these privacy rights.

How to exercise your rights. To request access to any other personal information we hold about you, to request deletion, or to submit any other request in relation to your privacy rights, please submit the request via our My Privacy Rights portal and click on “EA candidates’ privacy enquiries”. Before we process any request, we may ask you for certain personal information to verify your identity.

You may appeal our decision regarding your privacy rights. To do so, please visit our My Privacy Rights portal and click on “EA candidates’ privacy enquiries”.

Verification of account ownership. If you are contacting us through your authenticated EA communication tool (such as email), we will generally consider that as sufficient verification of your identity to process your request. Depending on the kind of right being exercised and the mode of the request to exercise the right(s), we may require additional verification of your identity.

Authorized agents. You can utilize an authorized agent to make a request to exercise your privacy rights. If you use an authorized agent to exercise your right to deletion, access, or correction, we will require that you verify your identity directly with us, unless you have provided your agent with a valid power of attorney consistent with relevant local law, such as California law that includes a comparable proof of identity.

9.      Third-Party Services

EA Recruitment Services websites may contain links to third-party services (e.g., if you share one of our open jobs on social media). By clicking on those links, you will be visiting a third-party service or site that is not controlled by EA. Please consult that service's or site's privacy policy as your use of third-party sites or services is governed by their privacy policies.

10.      Information for California Residents

A.     “Notice at Collection”

The following categories of personal information may have been collected and disclosed in the preceding 12 months, as these categories are defined under the California Consumer Privacy Act (“CCPA”):

• Identifiers; such as a real name, alias, postal address, IP address, email address, social security number or other government document such as passport other government-issued documents; document numbers, signature, or other information that relates to, describes, or is capable of being associated with, a particular individual;
• Account login data; for example, the credentials necessary for you to access your Account;
• Characteristics of persons that entitle them to specific protections under California or federal law; such as age, sex, racial or ethnic origin;
• Internet or Electronic Network Activity information; such as job browsing history;
• Approximate (coarse) geolocation data; such as location data derived from IP address or device settings;
• Audio, visual or Electronic information; such as when you participate in job interview or while on site at EA premises;
• Professional or employment-related information; such as professional qualifications;
• Health information to provide reasonable accommodations;
• Education information; to the extent qualifying as nonpublic personally identifiable information protected by US federal law.

Collection, use, and disclosure of this information is made for one or more of the business or commercial purposes listed in Section 2: How We Use Personal Information.

We may collect and disclose other categories of personal information to the extent that you provide them through company systems.

We do not Sell or Share personal information (as these categories are defined under the CCPA).

We retain the information we collect for as long as necessary, and we may retain that information beyond that period if necessary for legal, operational, or other legitimate reasons. See Section 7: Retention of Your Personal Information for more detail.

B.     Supplemental California Privacy Notice

Please see below for additional details regarding how we process your personal information, incorporating the notice immediately above.

For each of the categories of personal information referenced above:

• The categories of sources from which the personal information may have been collected are listed in Section 1: Personal Information We Collect.
• The categories of third-party recipients to which the personal information may be disclosed are listed in Section 3: Who May Receive Your Personal Information.

C.    Your Rights

Please see Section 8: Your Privacy Rights for a summary of your California privacy rights and how to exercise them.

11.   EA entities potentially acting as data controller for EEA, United Kingdom and Switzerland Candidate/Referee Personal Information

12.   Changes to This Notice

This notice may be amended consistent with the requirements of applicable laws, regulations, and certifications. When EA updates the notice, we will revise the “Last Updated” date at the end of this document. We will notify candidates of any material changes to this notice thirty (30) days prior to such changes taking effect.

13.   Contact Us

If you have questions about this notice, please use our My Privacy Rights portal to contact our Data Protection Officer.

To contact EA, including our Data Protection Officer, you can also use the following address: Electronic Arts Inc., 209 Redwood Shores Parkway, Redwood City, CA 94065. Electronic Arts Inc.'s representative in the European Union is Electronic Arts Ireland Limited, Parkmore West Business Park, 1, Ballybrit, Galway, H91 Y2R5, Ireland. Electronic Arts Inc.'s representative in the United Kingdom is Electronic Arts Limited, Onslow House, Onslow Street, Guildford, GU1 4TN, United Kingdom.

14.   Right to Contact a Data Protection Authority

If you have a concern about how we collect and use information, please contact us. You also have the right to contact your local Data Protection Authority if you prefer, such as:

• Data Protection Authorities in the EEA;
• Swiss authorities;
• UK authority;
•  China authority

Where appropriate, your local data protection authority may also forward the matter to the U.S. Department of Commerce or FTC for consideration.

If you have an unresolved concern over our data practices that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge).

15.   Additional Disclosures

Material Submissions

Materials are not generally required. If a candidate chooses to submit Materials, whether from their Google Drive or otherwise, we will use those Materials only for evaluation purposes. Copies of the materials may remain attached to the candidate's profile and will be purged in accordance with the data retention rules in place.

EA engages in a continuous program to develop new products and ideas internally, and we also regularly receive other submissions for consideration. The products, ideas or concepts that EA develops internally or that others submit may be similar to a candidate’s Material. As a result, we cannot agree to treat as confidential any Material submitted, even if it is marked as confidential or proprietary. Our acceptance or review of a candidate’s Material does not imply that we will use, develop or market it. Nor does our review of candidate’s Material prevent us from using, developing, or marketing technologies, ideas or products that may be similar in concept or idea to such Material.

Last Updated: October 10, 2023

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