I. INTRODUCTION
This T2 Boot Camp Friends & Family Data Protection Notice (“Notice”) describes how Take-Two Interactive Software, Inc. and Take Two Interactive Software Europe Limited (the “Company”) collects, uses, and otherwise processes certain personal data about T2 Boot Camp friends and family participants (“Participant Data”), as described in more detail below.
II. CATEGORIES OF PARTICIPANT DATA
The Company may collect and process all or some of the following categories of Participant Data:
Personal and contact information, including name, email address, video / image, screen name; and
Cookies and similar technology information, including cookies, web beacons, Internet log files, and similar tracking technologies.
III. PURPOSES OF PROCESSING OF PARTICIPANT DATA
The Company collects, uses, and otherwise processes Participant Data for the following purposes: conducting and recording T2 Boot Camp sessions (including for subsequent viewing and publication on Company and third party media available to the public); compliance with legal and regulatory requirements; monitoring and enforcing compliance with applicable policies and procedures; providing physical and/or network access and IT support and services; and protecting the security of Participant Data as well as Company systems and premises.
The Company will retain Participant Data no longer than is necessary to carry out the purposes listed in this Notice, to fulfill any reasonably anticipated future engagement and/or as required by applicable law.
The Company processes Participant Data with consent, as required by law, and where it is in the Company’s (or a third-party’s) legitimate interests and those interests are not overridden by privacy and data protection rights.
IV. DISCLOSURES OF PARTICIPANT DATA
As part of normal business operations, the Company may disclose Participant Data to third-party service providers in connection with the purposes described in Section III. The Company 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 the Participant Data, and process the Participant Data only as instructed by the Company. The Company may also disclose the T2 Boot Camp sessions publicly.
The Company may also disclose Participant Data to external advisors (e.g., lawyers, accountants, and auditors) and, to the extent required or permitted by applicable legal obligations, to governmental agencies and regulators, courts and other tribunals, and government authorities (including authorities located in the United States, such as the Securities and Exchange Commission or the Department of Justice). Participant Data may also be shared with Take-Two Interactive Software, Inc. and its subsidiaries and affiliates in the United States (collectively, “Take-Two US”) where necessary for legitimate business purposes.
V. INTERNATIONAL TRANSFERS OF PARTICIPANT DATA
As necessary in connection with the purposes described in this Notice, limited members of the human resources, finance, legal, and the IT departments and Take-Two US or affiliated company points of contact may access and otherwise process Participant Data in the United States in connection with their job responsibilities. Participant Data may also be shared with service providers, affiliates, other members of the Take-Two US company group, and other third-parties located countries that do not have equivalent data protection legislation to the EU. The Company takes appropriate steps to ensure that any transfers to such countries are subject to appropriate safeguards, including through the use of European Commission-approved Standard Contractual Clauses. For more information on how the Company transfers Participant Data, please contact [email protected].
VI. DATA SECURITY AND DATA INTEGRITY
The Company and Take-Two US maintain all reasonable physical, technical, and organizational security measures to safeguard Participant Data from loss, misuse, or unauthorized access, disclosure, alteration or destruction. The Company and Take-Two US also maintain reasonable procedures to help ensure that such data is reliable for its intended use, accurate, complete and current.
VII. DATA PROTECTION RIGHTS
Depending on location, participants have the right to access, review, correct, or request the deletion or portability of their Participant Data in accordance with applicable law. Participants may also object to the processing of Participant Data in some circumstances, and where processing relies on consent, the participant may withdraw it at any time. These rights may be limited in some circumstances, for example if a participant requests the deletion of Participant Data that the Company is required by law to keep. Participants also have the right to complain to the relevant data protection authority. Also, participants are responsible for informing the Company if there are any changes or inaccuracies to their Participant Data. Participants should transmit any requests for access or updates to, or corrections or deletions of their own Participant Data to the Company as specified below in Section VIII.
VIII. QUESTIONS ABOUT PROCESSING OF PARTICIPANT DATA
Participants who have any questions about this Notice or wish to exercise any of the rights here described, should contact the T2 data protection contact at [email protected].
NOTICE OF RISKS
This Notice is to inform you of certain risks regarding your participation in off-duty social, recreational, and/or athletic activities facilitated by or associated with Take-Two Interactive Software, Inc. (the “Company”), whether during normal working hours or otherwise, including the T2 Boot Camp (collectively, the “Recreational Activities”).
Recreational Activities may involve certain elements of risk, including, but not limited to, the potential for personal injury, including serious disability, as well as damage to or loss of property. The Company will not be liable for the payment for any injury or loss that arises out of your voluntary participation in activities that are not part of your work-related duties, including Recreational Activities. If you participate in Recreational Activities, you knowingly assume the risk of injury or loss resulting from your own acts and/or the acts of third persons including Company employees participating in such Recreational Activities. The Company makes no representations, endorsements, or warranties of any kind regarding the ability, competency, or expertise of any such third parties or Company employees who lead, instruct, participate, or otherwise become involved in Recreational Activities, nor does it make any warranties regarding the suitability of facilities and equipment used for Recreational Activities.
By participating in Recreational Activities, you agree to accept and assume any and all risks related with those activities and agree that you will not hold the Company or any of its respective affiliates, directors, employees, equity holders, partners or representatives liable for any resulting illness or injury or for any damages or losses in connection therewith.
In addition, you should not participate in Recreational Activities if you are not in good physical condition and, if necessary, you should consult a physician regarding participation in such activities.
RELEASE
You understand that you shall not be entitled to payment of any kind or nature in connection with the use of your appearance, likeness, name or other personal data (“Likeness”), or the exploitation thereof, in connection with the T2 Boot Camp sessions. You hereby irrevocably and unconditionally: (a) waive any right of inspection or approval of my Likeness in the T2 Boot Camp sessions or the uses to which such Likeness may be put; and (b) release the Company from any and all claims or demands of any kind that you may now or hereafter have in connection with your participation in the T2 Boot Camp sessions or the exploitation thereof, or in respect of any exercise by any of the Company of any of the rights you are granting hereunder, including but not limited to any claims for defamation, violation of rights or privacy and/or publicity, negligence, and intentional infliction of emotional distress.