Take-Two Job Applicant Privacy Notice

Last updated: June 26, 2023

1. Introduction

This Privacy Notice explains how Take-Two Interactive Software, Inc. and its subsidiaries (collectively, “Company”, “Take-Two”, “we”, “our”, “us”) process the personal information of job applicants. It is not a contract and does not create any legal rights or obligations. The Take-Two entity to which you submit your application will be the data controller of your personal information.

Notice at Collection of Personal Information: Please see the Categories of Information Collected and Our Use of Personal Information sections for an overview of what information we collect, and why, and the Your Rights section for information about how to exercise your privacy rights.

2. What is Personal Information?

The term “personal information” in this Privacy Notice, means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or anonymized information that is maintained in a form that is not capable of being associated with you.

3. Categories of Personal Information We Collect

We collect personal information about you when you apply for a job with us and during the recruitment process which, depending on the location, may include information such as:

• Identifiers: name, contact details (email address, home address and telephone number), IP address, and other similar identifiers.

• Professional & Employment-Related Information: your previous employers, positions and work experience; professional licenses, certificates or other qualifications; employment references or referrals; any test results, evaluations, or assessments required to ascertain suitability for specific roles; and any personal information you choose to share with us in your interview or application, such as: CV, resume, social accounts (e.g., LinkedIn profile), work location preferences, code samples, immigration and work authorization requirements, or other supporting documentation.

• Educational History & Qualifications: your highest level of education, the educational institution you attended and when, degrees, certificates or other educational qualifications, your transcripts, and educational references.

• Financial Information:  salary, bonus, benefits, expenses, and stock or equity grants.

• Web-Related Information: such as technical details about your visit to our online services, or analytics data relating to your usage and activity on our online services.

• Audio / Visual Information: such as portfolios, reels, and other videos and images you choose to share with us in your interview or application.

We may also collect and process sensitive personal information if necessary for limited purposes, and subject to local law:

• Background Check Information: when permitted by applicable law, we may choose to conduct a background check in connection with your application, which may include a credit check, verification of professional and educational history, or identification of criminal history.

• Equal Employment Opportunity Information: when you choose to provide it, this includes age, race, ethnicity, nationality, citizenship, sex, gender identity, preferred pronouns, sexual orientation, religion, marital status, veteran status, disability, or accommodation request. This personal information will not be used in the hiring decision, unless specifically permitted by law.

• Health-Related Information: such as health check indicators of possible infection, vaccination status and records, clearance or registration to enter an office or location and any other information necessary to manage health risks or make reasonable adjustments.

4. Our Use of Personal Information

We use the personal information we collect during the recruiting process and when you apply for a job with us to:

• identify you as a potential candidate and review your application;

• verify the information provided to us in connection with your application or received from other sources;

• determine your eligibility and suitability for the potential position or other opportunities with us (such as conducting assessments);

• review immigration status including supporting visa applications;

• facilitate the recruiting and interview process, including pre-hire actions (such as coordinating travel accommodations and expenses, providing physical and/or network access, and IT support and services);

• communicate with you about the status of your application or other opportunities with us that may be of interest to you;

• assess and improve the performance and success of our recruiting and hiring process, resource and financial planning, and administration;

• support a diverse workplace and promote diversity, inclusion, and equal employment opportunities;

• conduct internal investigations, audits, compliance, risk management, problem resolution and security operations; and

• comply with applicable laws, rules, regulations, legal proceedings, enforcement actions, and government investigations, including relating to tax reporting and immigration.

5. Sources of Personal Information We Collect

Although we often collect the personal information described above directly from you, we may collect certain information from references, recruiters, job-related social media sites, publicly available sources, and background screening providers.

6. The Legal Reasons We Rely on to Process Your Personal Information

Take-Two processes your personal information based on several legal grounds depending on the jurisdiction you are in, the nature of the information and the processing involved. For example, our processing is necessary to:

• Pursue our legitimate interests – such as to review your application, communicate with you, protect physical and network security and prevent fraud, and manage your job application for positions with us, including extending any job offer to you and completing the steps necessary to further the employment relationship.

• Comply with a legal obligation – such as establishing or obtaining the right to work in certain jurisdictions and retaining information for fixed periods of time to comply with local legal requirements on recordkeeping.

• Take steps prior to entering a contract with you or, where applicable, necessary for conducting human resource management – such as to assess your application, and your suitability for a role, to assess any entitlement to benefits, to set up any resources or assistance required for any potential role.

Another legal ground we rely on is:

• Consent - In certain countries and in some limited situations, Take-Two relies on your voluntary consent to process your personal information. Without such consent, we are not able to process your application. Where you have provided consent, you can withdraw this at any time by contacting us at the email below.

7. Your Rights

Depending on where you are located, you may have certain rights regarding your personal information including rights to:

• Information: to know what personal information we are processing and why.

• Access: to request a copy of your personal information.

• Correction: to request correction of your personal information where it is inaccurate.

• Deletion:  in certain circumstances, to request deletion of your personal information where the continued processing is no longer necessary.

• Object:  to request that we stop processing your personal information particularly where there are no longer sufficient legitimate grounds to continue such processing.

• Restrict: to request that we limit the processing of your personal information.

• Portability: in certain circumstances, you may request that your personal information is transferred to a third-party.

If you wish to exercise one of these rights, please contact the local Human Resources/Recruiting department or email [email protected]. We will not charge you a fee for dealing with your request, other than where the request is manifestly unfounded or excessive (such as if you submit several repeated requests), in which case we may charge you a reasonable fee to cover our administrative costs. We may also ask you to provide certain information to help us confirm your identity.

Depending on applicable law, you may also have the right to lodge a complaint with your national data protection authority.

8. Recipients of Personal Information

• Take-Two Entities: Your personal information will be provided to the Take-Two entity that has posted the position for which you are applying and may also be shared with Take-Two Interactive Software, Inc. and its subsidiaries and affiliates in the United States, United Kingdom, Europe, and other entities outside of your region, where necessary for legitimate business purposes.

• Service Providers: We may share your personal information with third parties that perform services for us on our behalf in connection with human resources-related tasks and data hosting services, such as IT service providers, background screening providers, or HR database services. We will (i) exercise appropriate due diligence in the selection of such third party service providers, and (ii) require via appropriate contractual measures that such third party service providers maintain adequate technical and organizational security measures to safeguard personal information, and process personal information only as instructed by Take-Two and for no other purposes.

• Government or Public Authorities: Take-Two may transfer your personal information to government agencies, regulators, or authorities (such as tax authorities or law enforcement), or courts, or where otherwise required or permitted by applicable law (which may include lawful access by foreign courts, law enforcement or other government authorities).

• Sale or Merger: Where we consider a business transition, like a merger, acquisition by another company, or sale of all or part of our assets, we may disclose or transfer your personal information to the purchaser.

Except as described above, we do not sell or share for cross-context behavioral advertising applicants’ Personal Data or Sensitive Personal Data.

9. Cross-border transfers of personal information

As necessary in connection with the purposes described in this Privacy Notice, limited members of the human resources, finance, legal, and the IT departments and Take-Two or affiliated company points of contact (i.e., persons with assigned responsibility for the services performed by an applicant) may access and otherwise process personal information in the United States, United Kingdom, Europe, and other locations in connection with their job responsibilities. Personal information may also be shared with service providers, affiliates, other members of the Take-Two company group, and other third parties located in countries that may not provide an equivalent level of data protection. Where we transfer your personal information internationally, we will take appropriate steps to ensure that your personal information is subject to appropriate safeguards, including through the use of approved standard contractual clauses or other legally authorized methods to legitimize such transfer. For more information about international data transfers, please contact [email protected].

10. Security Safeguards in Place

We have implemented reasonable and appropriate technical, administrative, organizational, and physical security measures that are designed to protect your information from unauthorized access, disclosure, use, and modification.

11. Retention

We will store the personal information we collect about you for no longer than necessary and in accordance with our legal obligations and our legitimate interests.

• If your application is successful and you become an employee, where permitted by local law, the personal information we collect during the application process may be transferred to your personnel file and stored in accordance with Take-Two’s data retention practices and local law.

• If your application is not successful, we will hold your personal information to contact you (unless you have asked us not to) about any other relevant employment opportunities that may arise with Take-Two (and its subsidiaries), and to protect Take-Two’s legal rights, including in connection with legal claims, compliance, regulatory, and auditing purposes. We will retain your personal information for a period after you have been informed your application is not successful. If you do not wish to be notified of future employment opportunities, please email [email protected], confirming this preference.

• Where you have given us your consent to process certain Equal Opportunities Information, we may anonymize and aggregate this information and store it in such form that does not personally identify you, for the purpose of monitoring and improving the application and recruitment process.

12. Updates to this Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will provide appropriate notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

13. Contact Us

If you have any questions or requests in connection with this Privacy Notice, please contact [email protected] or Data Protection Officer.