GLOBAL JOB APPLICANT PRIVACY NOTICE

Privileged & Confidential

Attorney-Client Communication

ZYNGA JOB APPLICANT PRIVACY NOTICE

Last Revised: January 2021

This Privacy Notice explains how Zynga Inc. and its affiliated companies (collectively, “ Zynga, ” “ we ,” “ our ,” or “ us ”) collects, uses, stores, discloses, and erases (“ Processes ”) personal data about our recruits and job applicants (“ Applicants ”),   why we Process it and how that Processing may affect you.  

This Privacy Notice is not a contract and does not create any legal rights or obligations.

The Zynga entity to which you submit your application will be the data controller of your personal data, which means they determine and are responsible to you for how your personal data is used.  For a list of our global affiliated entities, please see the Annex 2  to this Privacy Notice.

What is Personal Data?

When we use the term “ Personal Data ” we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you within the context of you acting as a job applicant. It does not include aggregated, anonymized or deidentified information that is maintained in a form that is not capable of being associated with or reasonably linked to you.

Our Collection of Personal Data

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

  • Contact Information:  such as your full name, email address, home address and telephone number.

  • Professional History & Qualifications: such as your previous employers, positions and work experience, professional licenses, certificates or other qualifications, and employment references or referrals.  

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

  • Financial Information:  such as your desired salary, bonus, benefits, expenses, and stock or equity grants. You may volunteer your previous salary and/or financial and benefit package as part of the recruitment process but we will not ask for this information.

  • Background Check Information: when permitted by applicable law, we may choose to conduct a background check in connection with your application such as to verify professional and educational history and qualifications or identify criminal history that may be relevant for a position with us. The results of the background check may include Personal Data we do not already have about you.

  • Equal Opportunity Information: as part of our diversity and inclusion strategy depending on jurisdiction we will monitor and report on gender/gender identity, race, ethnicity and veteran status when you choose to provide it and where this is applicable. As part of the standard recruitment process outside of the equal opportunity monitoring we may also collection information related to age, national origin, citizenship, sex, gender identity, gender expression, sexual orientation, religion, disability or accommodation request, or marital status. When you choose to provide any such information it will not be used in the hiring decision, unless specifically permitted by law.
  • Other Application and Interview Information:  any Personal Data you choose to share with us in your interview or application, CV, resume, transcripts or other supporting documentation or to help us coordinate travel for an interview.

Although we often collect the Personal Data described above directly from you, we may also collect certain information from references, recruiters, job-related social media sites (such as LinkedIn), and publicly available sources. In addition, we may also collect this information through service providers and other third parties that collect it on our behalf, such as communications providers, scheduling providers and application providers.

Our Use of Personal Data

We use the Personal Data we collect during the recruiting process to:

  • Identify you as a potential candidate and review your application for a position with us;

  • 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;

  • Facilitate the recruiting and interview process;

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

  • Where you provide consent to do so if required, conduct diversity monitoring as part of any Diversity and Inclusion initiative;

  • Assess and improve the performance and success of our recruiting and hiring process;

  • Fulfill contractual obligations to you in the event you become an employee, and other third parties (such as third-party recruiters);

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

  • Comply with applicable law, rule, regulation, legal proceeding and government investigations, including relating to tax reporting and immigration.

Legal Grounds for the Processing of Your Personal Data

We will process your Personal Data in accordance with any legal grounds set out by local law.  

The table in the Annex 1  sets out the categories of Personal Data we collect about you and how we use that information. The table also lists the legal basis which we rely on to Process the Personal Data.

We are not required to obtain your consent for most of the Processing activities that we undertake in respect of your Personal Data.

In certain circumstances, we may need your consent to use certain "sensitive" information, such as information about your health or ethnicity, in particular ways. You will never be obliged to give us this consent. Where you have given us consent to collect, use or disclose your Personal Data in a certain way you may withdraw your consent at any time by contacting us using the details below.  

For Applicants Located in India :

You expressly consent to the collection, storing, processing, dealing in, handling of, disclosure and transfer of the Personal Data collected from you per this Privacy Notice. Under the Information Technology Act (2000), with respect to your sensitive personal data or information, you may decline to provide us with such information and you may request to withdraw such information from our Processing.

For Applicants Located in Israel:

Please note that you are not legally obliged to provide us with your Personal Data, and if you provide us with your Personal Data, you are doing so of your own free will and consent. Should you choose to refrain from providing us with your Personal Data, we may not be able to consider your job application and/or employ you.

Retention

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

If your application is successful and you become an employee, where permitted by local law the Personal Data we collect during the application Process may be transferred to your personnel file and stored in accordance with our Employee Privacy Policy, a copy of which you will receive  at the start of your employment with Zynga.

If your application is not successful, to the extent that you give us consent to do so, we may also keep your Personal Data for the purpose of considering your application for employment with other Zynga companies or for other positions with Zynga.

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.

Recipients of Personal Data

Zynga entities : We are headquartered in the United States and have offices in the UK, Ireland and Finland and outside the EEA in Turkey, Canada and India.  Therefore, we may transfer your Personal Data to members of our group (or to acquiring or acquired entities) to pursue legitimate interests in connection with the following purposes: to facilitate internal communication and task management within Zynga; to facilitate group-wide HR planning and administration (including staffing, succession planning, forecasting and budgeting, investment decisions, and training and performance management); and to fulfill the employment relationship within our global structure (i.e., to facilitate global cooperation and employee transfers within Zynga).

Certain Zynga entities may act as a data controller for some of these purposes (typically this would include any Zynga entity that makes its own decisions concerning some of the purposes described above (e.g., employee transfers)).

Service providers : we may share your Personal Data with third party vendors and other service providers that perform services for us or on our behalf. Such data may be disclosed in connection with:

(i)        the provision of centralized human resources management;

(ii)        the provision of centralized IT infrastructure;

(iii)        centralized Processing of salary and benefits payments;

(iv)        obtaining professional services such as legal and accountancy services on behalf of the entire group;

(v)        coordinating travel accommodations for our Applicants;

(vi)        conducting background check; and

(vii)        the provision of professional recruitment and talent management services.

Other third parties : Zynga may transfer your Personal Data to government agencies, regulators, or authorities (e.g., tax authorities or law enforcement), social insurance carriers, 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).

Cross-Border Data Transfers

We transfer your Personal Data outside of the country where you are located. If we transfer your personal information internationally we will take the steps required to ensure that your personal information is treated securely, lawfully, and in the manner we describe in this Privacy Notice.  Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the place(s) where your information is transferred to or stored, used, or processed in, may be different from the privacy laws applicable to the place where you are a resident.

For Applicants Located in the European Economic Area :

Some recipients located outside of the EEA are certified under the EU-U.S. Privacy Shield. Others are located in countries for which the European Commission has issued adequacy decisions, including Canada (non-public organizations). In each case, the transfer is thereby recognized as providing an adequate level of data protection from a European data protection law perspective (GDPR Art. 45).

Some recipients are located in countries for which the European Commission has not issued an adequacy decision in respect of the level of data protection there, including: The U.S. (where the recipient is not Privacy Shield certified), India, and Turkey. By entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EU and/or 2004/915/EC) as referred to in GDPR Art. 46 (5) or other adequate means, we have established that all such recipients will provide an adequate level of data protection, and that reasonable and appropriate technical and organizational security measures are in place to protect Personal Data. Any onward transfer (including to our affiliates outside the EEA) is subject to appropriate onward transfer requirements as required by applicable law. The mechanisms and safeguards (except commercial information) we rely on in relation to international transfers of Personal Data can be provided to you upon request.

Your Rights

Depending on where you are located, you may have certain statutory rights in relation to your Personal Data.  For example:

  For Staff Members Located in the European Economic Area :

Under the GDPR and corresponding local data protection law, you have the following rights:

  • Right to Access: You have the right to know if we are Processing your Personal Data and to a copy of your Personal Data upon request. Subject to applicable law, we may charge a reasonable fee for copies, based on administrative costs.
  • Right to Rectification:  You have the right to correct or update your Personal Data (depending on the purposes of the Processing).
  • Right to Erasure:  You have the right to ask us to delete your Personal Data.
  • Rights to Object, to Restrict, and to Portability:  You have the right to object to Processing of your Personal Data, to ask us to restrict Processing of your Personal Data, or to request portability of your Personal Data (if technically feasible).
  • Right to Complain : You have the right to lodge a complaint with the competent data protection authority.

For Staff Members Located in Turkey :

Under the Law on the Protection of Personal Data (no.6698), you have the following rights:

  • Right to Know : You have the right to know whether or not your personal data is processed, how your data is processed, the purpose of the processing, and whether or not the data is being processed in accordance with these purposes and to know of any third parties located inside or outside Turkey to whom their personal data is transferred.
  • Right to Correction :   You have the right to request the correction of incomplete or inaccurate information. You also have the right to request that the correction of your personal data is notified to the third parties to whom your personal data has been transferred
  • Right to Erasure :   You have the right to request erasure of your Personal Data in case the legal ground for processing the relevant Personal Data does not exist anymore. You also have the right to request that the erasure of your Personal Data is notified to the third parties to whom your Personal Data has been transferred.
  • Right to Object :   You have the right to object to any negative results produced through a fully automated processing of your Personal Data.
  • Right to Compensation : You have the right to request compensation if you suffer damage due to processing of their Personal Data that is contrary to the law.

For Staff Members Located in Canada :

Under PIPEDA, independent contractors and other non-employee Staff Members have the following rights:

  • Right to Access: You have the right to know if we are Processing your Personal Data and to a copy of your Personal Data upon request. Subject to applicable law, we may charge a reasonable fee for copies, based on administrative costs.
  • Right to Rectification:  You have the right to correct or update your Personal Data (depending on the purposes of the Processing).

For Staff Members in Israel:

Under the Protection of Privacy Law, 1981 (the " Law "), you have the following rights, subject to the conditions set forth in the Law:

  • Right to Inspect : you have the right to inspect, either by yourself or through a representative authorized by you in writing, any Personal Data, as defined under the Law, about you which is maintained by us in a computerized database.
  • Right to Amend or Delete : You have the right to request us to amend or delete your Personal Data, as defined under the Law, if upon inspecting such Personal Data, you find that it is incorrect, incomplete, not clear or outdated.
  • Right to Object to Using your Personal Data for Direct Mailing Purposes : You have the right to object to our use of your Personal Data for direct mailing purposes (this is applicable when and if we engage and advertise to you with content based on your belonging to a group of the population that is determined by one or more characteristics), or to restrict the use of your Personal Data for direct mailing services.  

If you wish to exercise one of these rights, please email privacy@zynga.com .

We will not charge you a fee for complying with your request to exercise one of these rights, other than where the request is manifestly unfounded or excessive (such as if you submit a number of 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.

You also have the right to lodge a complaint to your national data protection authority. For further information about how to contact your local data protection authority, please contact us at privacy@zynga.com .

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please email privacy@zynga.com .

ANNEX 1 – PERSONAL DATA WE COLLECT

Category of Personal Data

How we use it

Legal basis for the Processing

Contact Information  such as your title, name, phone number, date of birth, home address and personal e-mail address.

We use this information to open and maintain applicant records.

The Processing is necessary for our legitimate interests, namely managing job applications for positions with Zynga.

We use this information to communicate with you as part of the recruitment process.

The Processing is necessary for our legitimate interests, namely communicating with applicants and managing job applications for positions with Zynga.

We use this information to conduct identity and background checks.

We will use your Personal Data in this way to the extent you have given us consent to do so.

Job Application Information , Professional History, Educational History and Qualifications  such as position applied for, previous roles, job description, responsibilities and assignments, years of service, qualifications and experience, compensation and salary data, eligibility for and participation in benefit schemes and other information contained in your CV.

We use this information to Process and assess your application, including assessing your suitability for a role.

The Processing is necessary in order to take steps prior to entering into a contract with you.

We use this information to calculate proposed salary and assessing eligibility for certain benefits.

The Processing is necessary in order to take steps prior to entering into a contract with you.

We use this information to monitor and improve our application process.

The Processing is necessary for our legitimate interests, namely reviewing and updating our applications process.

Results of Reference Checks and Screening , such as verification of education and employment history.

We use this information to Process and assess your application, including assessing your suitability for a role.

The Processing is necessary in order to take steps prior to entering into a contract with you.

We use this information to fulfil our obligations under applicable law, regulations, legal processes or enforceable government requests.

The Processing is necessary for compliance with a legal obligation to which we are subject.

Background Check Information , such as criminal records checks, disbarment checks and other searches relevant to the role for which you are applying.

We use this information to verify your suitability for a role, where the nature of the role requires additional background checks (e.g. disbarment or criminal record searches).

We will only Process this Personal Data to the extent that you have given us your explicit consent to do so.

Nationality, Citizenship and Right to Work Information , such as country of birth, government identification documents (including passports and residency permits) and, where relevant, visa information.

We use this information to determine your eligibility to work.

The Processing is necessary for compliance with a legal obligation to which we are subject.

We use this information to fulfil our obligations to relevant government authorities.

The Processing is necessary for compliance with a legal obligation to which we are subject.

Interview Information, such as comments and notes made by interviewers or other Zynga employees in connection with your application.

We use this information to Process and assess your application, including assessing your suitability for a role.

The Processing is necessary in order to take steps prior to entering into a contract with you.

We use this information to calculate proposed salary and assessing eligibility for certain benefits.

The Processing is necessary in order to take steps prior to entering into a contract with you.

We use this information to monitor and improve our application process.

The Processing is necessary for our legitimate interests, namely assessing and managing applications for positions with Zynga.

Any other data provided by you in the course of the application process , including electronic communications with you in relation to the application process.

We use this information to Process and assess your application, including assessing your suitability for a role.

The Processing is necessary in order to take steps prior to entering into a contract with you.

We use this information to respond to your enquiries and to monitor and improve our application process.

The Processing is necessary for our legitimate interests, namely managing applications and improving the application process.

Equal Opportunity Information , such as information relating to your gender, race, ethnicity, and veteran status.

We will anonymize this information where possible. We will aggregate this information to understand, monitor and improve our application process in line with our diversity and inclusion strategy.

We will only Process this Personal Data to the extent that you have given us your explicit consent to do so.

ANNEX 2 – ZYNGA ENTITIES

Entity

Country

Address

Gram Games Teknoloji A.S.

(Company ID: 839736)

Turkey

Küçükyalı, Turgut Özal Blv. No: 35, 34840 Maltepe/İstanbul, Turkey

Gram Games Limited

(Company Number 10276324)

United Kingdom

The Aircraft Factory, 100 Cambridge Grove, London, W6 0LE

NaturalMotion Games Limited

(Company Number 05973612)

United Kingdom

6 Agar Street, London WC2N 4HN

Peak Oyun Yazılım ve Pazarlama Anonim Şirketi

(Company Number 750337)

Turkey

Ömer Avni Mahallesi İnebolu Beytulmalci Sokak No.39 Haktan İş Merkezi Kat:3, Kabataş, Beyoğlu, İstanbul

Rollic Games Oyun Yazılım ve Pazarlama Anonim Şirketi

(Company Number 169468-5)

Turkey

Hacımimi Mahallesi Hocaali Sokak No.14/2 Beyoğlu, İstanbul/Turkey

Small Giant Games Oy

(Business ID: 2534733-4)

Finland

Kasarmikatu 42, FI-00130 Helsinki

Zynga Finland Oy

(Business ID 2788675-3)

Finland

Aleksanterinkatu 9 A 
00100 Helsinki

Zynga Game Canada Ltd.

(Company ID: BC0914129)

Canada

110 Spadina Ave, Suite 900, Toronto ON M5V 2K4, Canada

Zynga Game Ireland Limited

(Company Number 481954)

Ireland

25-28, North Wall Quay, Dublin 1

Zynga Game Network India Pvt Ltd.

(Company ID:   U72200KA2009FTC051639)

India

4th   & 5th   Floor, Prestige Falcon Towers,
No. 19 Brunton Road, Richmond Town,
Bangalore 560025

Zynga Israel Ltd

(Company Number: 51-628549-1)

Israel

7 rival st., Tel Aviv, Israel

Zynga Turkey Oyun Anonim Sikrti

(Company ID: 108219-5)

Turkey

Acibadem Mahallesi Cecen Sokak Akasya Evleri A (Kule) Blok No:25/A K:5 Uskudar, Istanbul