Data Privacy Notice (Candidates)

(Last updated 1 September 2021)

This notice describes how Electronic Arts Inc. (“EA Inc.”), and/or its local subsidiaries as better described in Section XII below (“EA”, “we”, “us”, “our”), uses data from candidates we consider and/or recruit for a position at EA and/or on behalf of our trusted partners (“Partners”), including when candidates create an EA Job Board Account on careers.ea.com (“Account”), otherwise engage with global and/or local EA recruitment services (“EA Recruitment Services”), or when EA proactively sources potential candidates. This notice also describes how we use data from individuals who provide references for candidates (“referees”).

I.          Data We Collect (General)

We may collect personal data as follows:

-     Name, e-mail address, resume and any other information candidates’ submit when registering for an Account or when engaging with EA Recruitment Services.

-     Information provided to us by third parties, for example (1) Facebook and LinkedIn if a candidate chooses to log into their Account using their credentials for these services; and (2) Google if they choose to upload their resume and/or any other materials demonstrating their skills and abilities for review by EA (“Material(s)”) direct from their personal Google Drive to their Account.

-                    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.

-     Information about gender, gender identity or gender expression for statistical purposes, although that 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.

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 and will not make any copies without the candidate’s permission, nor will we distribute any copies of the Materials to any third parties. We will return or destroy all copies of Materials upon completion of our review or upon the candidate’s earlier request. 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.

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.

II.        Additional Data We Automatically Collect in careers.ea.com

We and third parties may collect additional data like IP address, mobile and hardware or device identifiers, browser information, platform type, etc., when EA Recruitment Services are used via the technologies described below in order to deliver better experiences.

A.      Cookies and Similar Technologies

Cookies are small text files stored on a person’s Internet browser. We use cookies and similar technologies to help us understand things like what web pages a user has visited.

Users can disable cookies, limit the types of cookies allowed, or set their browser to alert them 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.

We use other technologies for similar purposes as a cookie. We may use tracking pixels or clear GIFs to collect information about your use of EA Recruitment Services. We use Internet log files (which contain technical data such as your IP address) to monitor traffic on ea.com/careers, and troubleshoot technical problems. Other examples include HTML 5 cookies and device fingerprints. We currently do not respond to Do Not Track (DNT) signals. You may opt out of certain types of tracking, including certain analytics by changing your cookie settings.

B.      Analytics Technologies

We use our internal and third-party analytic technologies to collect information about how you use EA Recruitment Services, your computer or device.

For instance, EA may collect and store data from your computer or device when you use EA Recruitment Services. This information includes technical and related information about your computer or device and operating system (such as IP Address and device ID), and is used to provide you with EA Recruitment Services.

Third-party analytics technologies integrated into EA Recruitment Services may combine the information they collect in connection with EA Recruitment Services with information they have independently collected over time and across different websites. Many of these companies collect and use information under their own privacy policies. A list of third party analytics companies that operate in EA Recruitment Services as well as how to opt out to the extent applicable can be found at privacyappendix.ea.com.

III.      How We Use Personal Data

EA uses the information described above to:

-     Provide EA Recruitment Services, including forwarding applications to our Partners when candidates apply to a role advertised by EA on the Partner(s) behalf.

-     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 or potentially with one of our Partners.

-     Process job application(s).

-     Send invitations to EA recruitment events (including by email).

-     Send EA recruitment newsletters by email.

-     In aggregate form only, for EA’s business planning, 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.

IV.      Legal Basis For Processing

We rely on a number of legal grounds to process your personal data. For example, we will process your data 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 data. If you wish to learn more about the specific legal ground(s) we rely on to process your data for any particular purpose (including any legitimate interests we have to process personal data), then please contact us using the details provided below.

V.        Where We Hold Your Data

EA Inc. is a global company headquartered in the United States, 209 Redwood Shores Parkway, Redwood City, CA 94065. As such, your data may be stored and processed for the purposes set out in this notice by EA Inc. and its subsidiaries in the United States, and also in other countries in which EA, its subsidiaries, or third-party agents operate. Some of these countries may not offer the same level of privacy protection as the laws in your country of residence or citizenship, but EA has taken appropriate measures to protect your personal data in accordance with this notice wherever your personal data is stored and used.

In particular, EA Inc. holds certifications under the (former) EU-US and the Swiss-US Privacy Shield which are available at www.privacyshield.gov. Where appropriate, EA will rely on EU Standard Contractual clauses and other safeguards to enable transfers outside of the EEA, United Kingdom or Switzerland. In line with the July 16, 2020 decision of the Court of Justice of the European Union in relation to the EU-US Privacy Shield and guidance from the European Data Protection Board, EA continues to assess the legal regime of the countries to which data is being transferred and, as necessary, updates measures to ensure that we provide adequate levels of protection.

In addition, to show our commitment to the safe transfer of EA Candidates’ personal information, EA complies with the E.U.-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, United Kingdom and Switzerland to the United States. EA has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Further, when EA transfers information from the EEA, United Kingdom, and Switzerland to other affiliates, agents, or service providers who are outside the EEA, United Kingdom, and Switzerland, it will do so in compliance with the ‘Accountability for Onward Transfer’ principle of the Privacy Shield.

VI.      APEC Participation

EA Inc.’s privacy practices, described in this Privacy Policy, comply with the APEC Cross Border Privacy Rules System. 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 can be found here.

VII.    Data We Share With Third Parties

We will not share data that directly identifies you with independent third parties without your consent, unless such disclosure is:

-     in response to lawful requests by public bodies, including to meet national security or law enforcement requirements;

-     otherwise required by law;

-     reasonably necessary to enforce our policies, procedures, rights, property or operations or to protect our employees, players or third parties;

-     reasonably necessary in the event of a reorganization, divestiture, merger, sale or bankruptcy.

We use third party agents to process your personal data on our behalf. It is our responsibility to ensure that our agents and service providers protect your data in accordance with the commitments given in this notice.

Where personal data is transferred to third party agents in accordance with this notice, EA remains liable for treatment of your personal data (including any onward transfers made according to the Privacy Shield Principles).

When you apply to a role advertised by EA on behalf of one of our Partners, we will share the information that you provide with the Partner identified in each relevant advert.

Referees’ opinions may only be shared with the relevant candidate in response to a subject access request. In those cases, we will endeavour to redact as much personal information from the opinion as possible.

VIII.  How We Protect Your Data

Security is a priority at EA, and we take a range of technical and organizational measures to help protect your personal data, such as encryption of data in transit (HTTPS) and at rest. Even so, please be aware that no security measure is 100% perfect.

IX.      How Long Does EA Retain Your Data?

We will only retain personal data for as long as reasonably necessary to comply with the law and/or where there is a legitimate business purpose to retain it. Generally this means EA retains your data for as long as your Account(s) remain active and as needed to provide EA Recruitment Services, plus a reasonable period of time thereafter to respond to recruitment inquiries, to deal with any legal matters (e.g. judicial or disciplinary actions), or to comply with archiving requirements or statutory limitations.

Any materials will be returned or destroyed upon completion of our review or upon your earlier request. See below for details of how to request deletion of your personal data.

Note: if you do not log into your Account for a specified period, your personal data will be automatically deleted from the Account database.

X.        Your Rights

Where you have registered for an Account, you can access, correct, update or delete your data by accessing your user profile online. 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 data prior to your request to withdraw your consent.

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 data, EA may still be required to retain certain data for legal or administrative reasons. For example, EA may require some personal data 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 data for as long as reasonably necessary to comply with the law and run our business.

To request access to any other personal data we hold about you, to request deletion or to submit any other request in relation to your privacy rights, please submit the form “EA candidates’ privacy enquiries” you can find in this page. Before we process any request, we may ask you for certain personal information to verify your identity.

Depending on where you are resident, you may have other rights available to you under your local data protection laws, beyond those described above. These may include rights to portability of personal information, to object to processing of personal information, or to request that we restrict processing of information. If available, you can request to exercise these rights through the form indicated above.

XI.      Privacy Related Queries

EA Inc. is the data controller of personal information processed by EA in respect of Accounts and global EA Recruitment Services. In respect of the local EA Recruitment Services, the data controller is the EA entity that you have applied for a position with. Where the EA data controller is located outside of the EEA, its representative in the European Union is Electronic Arts Ireland Limited, Parkmore West Business Park, 1, Ballybrit, Galway, H91 Y2R5, Ireland. When you apply to a role that EA advertises on behalf of one of our Partners, the data controller of the information that you upload to our platform is the entity identified in the relevant job advert.

Under Privacy Shield, EA Inc. is subject to investigation and enforcement by the FTC and commits to cooperate with EU data protection authorities and the Swiss Federal Data Protection and Information Commissioner and to comply with the advice given by such authorities with regard to human resources data transferred from the EU, United Kingdom and Switzerland in the context of the employment relationship.

For any concerns related to the handling of your personal data, you can:

-     contact EA’s DPO by submitting the form “EA candidates’ privacy enquiries” you can find in this page;

-     contact your local data protection authority (to contact EEA authorities please visit this website; to contact the Swiss authorities please visit this website; to contact the UK authority please visit this website) who will investigate your complaint free of charge; or

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

-     If you have an unresolved privacy or data use concern as it relates to our APEC Participation that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) here.

Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

EA Candidates located in a member country of the APEC framework with an unresolved privacy concern as it relates to our APEC Participation that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. EA headquarters are located in 209 Redwood Shores Parkway Redwood City, CA 94065 USA

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

XIII.  Changes To This Notice

We may update this notice from time to time, so please review it frequently. We’ll notify you of material changes via email thirty days before they go into effect. We will seek your consent to any material changes if and where required by applicable laws to do so.