Employee Privacy Policy

CCPA Employee Privacy Policy

CCPA Employee Privacy Policy

(505 Games (U.S.), Inc. / 505 Games Interactive, Inc. / 505 Mobile (U.S.), Inc.)

Effective Date:  January 1, 2022

505 Games (U.S.), Inc., 505 Mobile (U.S.), Inc. and 505 Games Interactive, Inc. (collectively “505,” “we,” “us,” or “our”) provide this CCPA Employee Privacy Notice which applies to California resident employees, employee applicants, owners, directors, officers, or contractors of 505, including as applicable, those individuals’ emergency contacts and beneficiaries.  This Privacy Notice sets forth our privacy practices as required by the CCPA.  Please note, there may be additional or different privacy notices or disclosures that govern our use of your personal information beyond the CCPA.  Where collection, use and disclosure of personal information is subject to the CCPA, this Privacy Notice shall prevail.  For collection, use and disclosure of personal information beyond the CCPA, those separate and relevant privacy notices and disclosures shall prevail.  Any terms defined in the CCPA have the same meaning when used in this notice.

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we provide the following details regarding the categories of Personal Information we have collected or disclosed within the preceding twelve (12) months:

For Applicants: We only ask and collect personal information that we require to enable us to make a decision about whether or not to offer you employment. If you do not provide particular information to us, then we will have to make a decision on whether or not to offer you a role without that information, which in some cases could result in us deciding not to pursue your recruitment. In addition, some of the personal information you provide to us is required by law, such as documentation we need to check your right to work. If you choose not to provide us with such required personal information, we will be unable to proceed with considering you for employment, and we will inform you of this decision accordingly.

INFORMATION WE COLLECT:

Within the last twelve (12) months, 505 has collected the following categories of personal information about its job applicants, employees, and contractors (some example elements overlap with multiple categories):

505 obtains the categories of personal information listed above from the following sources:

• Directly from you, such as forms you complete as an applicant or employee, or services we provide you.
• Indirectly from you, such as monitoring information that your work computer or mobile device transmits when interacting with our applications.
• Third parties, including recruiters who submit your information to us for an employment position that may interest you and consumer reporting agencies for employment background checks.

Please note that “personal information” as defined in the CCPA does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.

HOW WE USE YOUR PERSONAL INFORMATION:

505 may use or disclose personal information that we collect about you for one or more of the following business purposes:

• To recruit new employees, and prior to employment, to conduct employment related background screening and checks.
• To administer benefits, such as medical, dental, optical, commuter, and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, and insurance.
• To pay or reimburse for expenses, including salary administration, payroll management, payment of expenses, to administer other compensation related payments, including assigning amounts of bonus payments to individuals, administration of departmental bonus pools and administration of stock option plans.
• To conduct performance-related reviews, including performance appraisals, career planning, skills monitoring, job moves, promotions and staff re-structuring.
• To monitor work-related licenses and credentials, including provisioning software licenses for use in the course of an employee’s work related responsibilities, ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies.
• To provide human resources management services, including providing employee data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of employee claims, and travel administration.
• To maintain your contact information.
• To assist you in the case of an emergency, including maintenance of contact details for you, and your dependents or emergency contacts in the case of a personal or business emergency.
• To monitor eligibility to work in the United States.
• To foster and improve our culture and working environment, including conducting staff surveys, providing senior management information about other employees, and conducting training.
• To ensure a safe working environment, which includes information collected relating to disciplinary actions, and code of ethics conduct processes and investigations.
• To protect health and safety in the workplace, including conducting surveys and health screenings involving collection of personal health and biometric information about you and your household, to permit contact tracing and reduce the risk of spreading viruses or other diseases during a pandemic or public health emergency.
• To maintain security on 505 systems and infrastructure, which includes hosting; management of our software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; and monitoring email and internet access.
• To comply with applicable law or regulatory requirements, such as legal (state and federal) and internal company reporting obligations, including headcount, management information, demographic and other required reporting.

HOW WE SHARE YOUR PERSONAL INFORMATION:

When disclosing your personal information to a third party for a business purpose, 505 enters into a contract with the third party describing the purpose of such disclosure and requiring that such personal information be kept confidential and not used for any purpose except to perform the services under the contract or respond to regulatory or law enforcement requests.

In the preceding twelve (12) months, 505 has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers

Category B: California Customer Records personal information categories

Category C: Protected classification characteristics under California or federal law

Category E: Biometric Information

Category F: Internet or other similar network activity

Category I: Professional or employment-related information

We disclose your personal information to the following categories of third parties:

• Our affiliates, including, for purposes of this section, other companies with the 505 name.
• Our vendors and service providers (e.g., website hosting, information technology and security, cloud storage, etc.).
• Third parties who provide professional services such as attorneys, auditors, etc.
• Third parties to whom you or your representatives authorize us to disclose personal information in connection with products or services we or they provide to you.
• Government agencies as required by laws and regulations or otherwise to comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal information necessary for the specific purpose and circumstances.

WE HAVE NOT SOLD, AND WILL NOT SELL, YOUR PERSONAL INFORMATION:

In the preceding twelve (12) months, 505 has not sold any personal information, and we have no future intention of selling such information.

For purposes of this CCPA Notice, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

CHANGES TO THIS CCPA EMPLOYEE PRIVACY POLICY:

505 reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the notice’s Effective Date above.

OUR RETENTION POLICY:

In general, Personal information will not be kept for longer than is necessary for the business purpose for which it is collected and processed and will be retained in accordance with our internal document retention policies. In certain cases, laws or regulations require us to keep records for specific periods of time, including following termination of the employment relationship. In other cases, records are retained in order to administer the employment relationship or to resolve queries or disputes which arise from time to time.

As such, we retain Personal Information (1) for as long as necessary to provide you with our services, comply with our legal obligations, preserve and protect our rights as allowed by law, resolve disputes, maintain security, prevent fraud and abuse, and enforce our agreements (including our Terms of Service), (2) with your consent, or (3) as required by law.

Other California privacy rights:

California”s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. We do not disclose your Personal Information to third parties for their direct marketing purposes.

CONTACT US:

If you have questions regarding this CCPA Employee Privacy Policy or our data privacy practices, please write us at:

Attn: Human Resources

505 Games

5145 Douglas Fir Road

Calabasas, CA 91302

Or email us at: info@505games.com

Privacy Notice for Job Applicants (UK)

In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, as prospective employees of our Company, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data

A) DATA PROTECTION PRINCIPLES

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

1. processing is fair, lawful and transparent
2. data is collected for specific, explicit, and legitimate purposes
3. data collected is adequate, relevant and limited to what is necessary for the purposes of processing
4. data is kept accurate and up to Data which is found to be inaccurate will be rectified or erased without delay
5. data is not kept for longer than is necessary for its given purpose
6. data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
7. we comply with the relevant GDPR procedures for international transferring of personal data

B) TYPES OF DATA HELD

We keep several categories of personal data on our prospective employees in order to carry out effective and efficient processes. We keep this data in recruitment files relating to each vacancy and we also hold the data within our computer systems, for example, recruitment logs.

Specifically, we hold the following types of data:

1. personal details such as name, address, phone numbers;
2. name and contact details of your next of kin;
3. your photograph;
4. your gender, marital status, information of any disability you have or other medical information;
5. right to work documentation;
6. information on your race and religion for equality monitoring purposes;
7. information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter;
8. references from former employers;
9. details on your education and employment history etc;
10. driving licence;
11. criminal

C) COLLECTING YOUR DATA

You provide several pieces of data to us directly during the recruitment exercise.

In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.

Should you be successful in your job application, we will gather further information from you, for example, your bank details and next of kin details, once your employment begins.

D) LAWFUL BASIS FOR PROCESSING

The law on data protection allows us to process your data for certain reasons only.

The information below categorises the types of data processing we undertake and the lawful basis we rely on.

E) SPECIAL CATEGORIES OF DATA

Special categories of data are data relating to your:

1. health
2. sex life
3. sexual orientation
4. race
5. ethnic origin
6. political opinion
7. religion
8. trade union membership
9. genetic and biometric

We carry out processing activities using special category data:

1. for the purposes of equal opportunities monitoring
2. to determine reasonable adjustments

Most commonly, we will process special categories of data when the following applies:

1. you have given explicit consent to the processing
2. we must process the data in order to carry out our legal obligations
3. we must process data for reasons of substantial public interest
4. you have already made the data

F) FAILURE TO PROVIDE DATA

Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract of employment with you. This could include being unable to offer you employment, or administer contractual benefits.

G) CRIMINAL CONVICTION DATA

We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment. We use criminal conviction data to determine your suitability, or your continued suitability for the role. We rely on the lawful basis of legitimate interests to process this data.

H) WHO WE SHARE YOUR DATA WITH

Employees within our company who have responsibility for recruitment will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR.

Data is shared with third parties for the following reasons: the administration of payroll, HR compliance and absence/leave records.

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

We do not share your data with bodies outside of the European Economic Area.

I) PROTECTING YOUR DATA

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.

J) RETENTION PERIODS

We only keep your data for as long as we need it for, which, in relation to unsuccessful candidates, is six months to a year.

If your application is not successful and we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable job vacancies, we will keep your data for six months once the recruitment exercise ends.

If we have sought your consent to keep your data on file for future job vacancies, and you have provided consent, we will keep your data for nine months once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data and there will be no consequences of withdrawing consent.

If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.

K) AUTOMATED DECISION MAKING

Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.

L) YOUR RIGHTS

You have the following rights in relation to the personal data we hold on you:

1. the right to be informed about the data we hold on you and what we do with it;
2. the right of access to the data we hold on We operate a separate Subject Access Request policy and all such requests will be dealt with accordingly;
3. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
4. the right to have data deleted in certain This is also known as ‘erasure’;
5. the right to restrict the processing of the data;
6. the right to transfer the data we hold on you to another This is also known as ‘portability’;
7. the right to object to the inclusion of any information;
8. the right to regulate any automated decision-making and profiling of personal

In addition to the above rights, you also have the unrestricted right to withdraw consent, that you have previously provided, to our processing of your data at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

If you wish to exercise any of the rights explained above, please contact the 505 Games Directors.

M) MAKING A COMPLAINT

If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.

N) DATA PROTECTION COMPLIANCE

Our Data Protection Officers are the 505 Games Directors.