Scopely

EEA and UK Job Applicant Privacy Notice

Last updated: 27 March 2025

This EEA and UK Job Applicant Privacy Notice (“Applicant Privacy Notice”) explains how Scopely, Inc. and our affiliates (collectively "Scopely", "we" or "us") process personal information regarding those in the European Economic Area (EEA) and United Kingdom (UK) who apply to work for us. This Applicant Privacy Notice applies to all job applicants, whether on a part-time, temporary or full-time basis, and including roles for a position as contractor or intern (“Applicants” or "you").

This Applicant Privacy Notice may be supplemented by additional statements to comply with local requirements in the country where you are located.

For the avoidance of doubt, nothing in this Applicant Privacy Notice shall be construed as forming part of a contractual relationship between us, whether or not your application is successful.

Contents

1. Introduction


2. Personal information we collect and process when you apply for a position with us


3. Legal grounds for processing personal information


4. How we use your personal information (our purposes) and our legal basis for processing it


5. Who we share your personal information with


6. How we keep your personal information secure


7. International data transfers


8. Data retention


9. Your data protection rights


10. Updates to this Applicant Privacy Notice


11. How to contact us

We recommend that you read this Applicant Privacy Notice in full to ensure you are completely informed about how we collect, process, share and protect your personal information. However, if you only want to access a particular section of this Applicant Privacy Notice, then you can click on the relevant link above to jump to that section.

Introduction

At Scopely, we respect the privacy rights of individuals and are committed to handling personal information responsibly and in accordance with applicable law. This Applicant Privacy Notice sets out the personal information that we collect and process about you, the purposes of the processing and the rights that you have in connection with it.
If you have any comments or questions about this Applicant Privacy Notice, then please contact us using the contact details under the “How to contact us” heading below.


Personal information we collect and process when you apply for a position with us

We collect personal information about you when you apply for a position with us and during the recruitment process.

Sources of personal information

We collect this personal information from the following different sources:

• Information that you provide directly
  
  We collect personal information directly from you when you submit your application via our recruitment portal on our website or when we receive your resume through other methods (e.g., email, LinkedIn, etc.). In connection with the recruitment process you may also choose to provide us with further personal information through any of these channels.


• Information from third parties
  
  Where a third party is representing you or has contacted you on our behalf, including recruitment agencies and third party recruitment platforms, such third parties may provide your personal information to us. Where necessary and to the extent permitted by applicable law, we use background checking agencies to confirm your employment history, whether you have any criminal convictions relevant to the position for which you are applying, and to confirm that you are legally entitled to work in the countries where we are recruiting.


• Information that we collect indirectly
  
  We collect your personal information indirectly, including through automated means, via our recruitment portal and website. Such information includes your IP address and information about the device used to complete and make your application. Some of the information we collect indirectly is captured using cookies and other tracking technologies. At any time, you can control the use of cookies by adjusting the settings on your browser. However, if you choose to disable some or all cookies, please note that by blocking any or all cookies, you may not have access to certain features, content, or personalization available through our recruitment portal and website.


• Information that we collect from publicly available sources
  
  We collect information about you from social media platforms aimed at making professional connections, such as LinkedIn, where you have made information available about yourself.


• Information that we create
  
  During the recruitment process we may create information pertaining to your application such as interview feedback and assessments, internal communications and communications with you directly.

Categories of personal information

We collect the following categories of personal information about you through our application process:

• Contact Data: Name or alias, title, honorific, home address, personal telephone number and personal email address.


• Application Information: Position applied for, age, date of birth, pronouns, salary expectations, CV/résumé information such as previous roles, job descriptions, responsibilities and assignments, years of service, education, academic/professional qualifications and experience.


• Interview Feedback and Assessments: Feedback and assessments made by interviewers or other staff in connection with your application.


• Sensitive Personal Information: If you include it as part of your application, information that reveals your racial or ethnic origin, religious, political or philosophical beliefs, information about your health and disability, sexual orientation.


• Background Checks: Criminal records and/or global sanctions checks, employment history, and other searches relevant to the role for which you are applying. This information will only be requested from you or obtained from third parties at the end of the recruitment process, once a conditional offer of employment has been made and you have accepted the position you applied for.


• Local Work Authorization Information: Information about where you are legally authorized to work, visa-related information (where relevant); government identification documents (including passports and residency permits) (this information will only be requested from you or obtained from third parties at the end of the recruitment process, once a conditional offer of employment has been made and you have accepted the position you applied for).


• Communications Data: Communications between us and you in relation to your application and the application process.


• IT Data: Information collected automatically through our recruitment portal (including by means of cookies and similar tracking technology, such as IP addresses, log files and login information). IT Data may also include inferred location based on your IP address or activities, device identifiers associated with your computer or device, and activity logs generated when you navigate our recruitment portal.


• Security and Access Data: If you are visiting a premises for an interview, closed-circuit television (CCTV) footage in public or common areas on or near our premises and other information obtained through electronic means such as security records (e.g., swipe card records, building entry / exit data to which Scopely may from time to time have access) and electronic guest book information.

Legal grounds for processing personal information

If you are based in the EEA or the UK, our legal basis for collecting and using your personal information will depend on the personal information concerned and the specific context in which we collect it. There are various legal bases on which we can rely when processing your personal information. In some contexts, more than one ground applies.

We have summarized the most relevant grounds below:

Term	Ground for processing	Explanation
Contractual necessity	Processing necessary for performance of a contract with you or to take steps at your request to enter a contract	This covers carrying out our contractual duties and exercising our contractual rights.
Legal obligation	Processing necessary to comply with our legal obligations	Ensuring we perform our legal and regulatory obligations.
Legitimate interests	Processing necessary for our or a third party’s legitimate interests	We or a third party have legitimate interests in carrying on, managing and administering our respective businesses effectively and properly and in connection with those interests processing your data. Your data will not be processed on this basis if our or a third party’s interests are overridden by your own interests, rights and freedoms.
Consent	You have given specific consent to processing your data	In general, processing of your data in connection with employment will not be conditional on your consent. But there may be occasions where we do specific things and rely on your consent to our doing so.

If we process sensitive personal information about you, as well as ensuring that one of the grounds for processing mentioned above applies, we will make sure that one or more of the grounds for processing sensitive personal information applies. In outline, these include:

• Where you have provided your explicit consent;


• Where the processing is necessary for the purposes of your or our obligations and rights in relation to employment in so far as it is authorized by law or collective agreement;


• Where the processing relates to data about you that you have made public;


• Where the processing is necessary for the purpose of establishing, making or defending legal claims.

How we use your personal information (our purposes) and our legal basis for processing it

We use the personal information that we collect from and about you only for the purposes described in this Applicant Privacy Notice. The following table provides more details on our purposes for processing your personal information and the related legal bases.

Purpose	Type of personal information	Legal basis
To communicate with Applicants during the course of the recruitment process	Contact Data Communications Data	Legitimate interests of managing applications for positions with us.
To assess suitability of applicants for the role they have applied for	Contact Data Application Information Interview Feedback and Assessments Communication Data Background Checks	Legitimate interests of managing applications for positions with us.
To maintain Applicant records	Contact Data Application Information Interview Feedback and Assessments Communications Data	Legitimate interests of managing applications for positions with us.
Determine your eligibility to work	Local Work Authorization Information	Legal obligation.
To conduct criminal record and background checks, which will differ depending on the position you’ve applied for (and where permitted by local law)	Background Checks	Legitimate interests of managing applications for positions with us or with consent (where required by applicable local law).
To calculate proposed salary and assess eligibility for certain benefits	Contact Data Application Information Interview Feedback and Assessments Communications Data	Legitimate interests of managing applications for positions with us.
To enter into an employment contract or other contractual engagements	Contact Data Communications Data	To take steps to enter into a contract with successful Applicants.
To monitor and improve our application process	Contact Data Application Information Interview Feedback and Assessments Communications Data IT Data	Legitimate interest of reviewing and updating our application process.
Physical and system security	Security and Access Data IT Data	Legitimate interest of ensuring the security of our systems and premises.
Address access needs and if an Applicant is successful to make workplace adjustments	Contact Data Sensitive Personal Information	Legal obligation In relation to Sensitive Personal Information: To comply with employment obligations (if required by applicable law), or otherwise with your explicit consent.
Disputes and legal proceedings	Any of the personal information described in section 2 above which is relevant or potentially relevant to a dispute or legal proceeding affecting us.	Legitimate interests Legal obligation

Who we share your personal information with

We take care to allow access to personal information only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it.

We share your personal information with the following categories of recipients:

• our group companies in order to manage the recruitment process and for related legitimate business purposes such as improving and monitoring our process and analysing recruitment and hiring trends;


• third party service providers and partners on a "need to know basis" and in accordance with applicable data privacy law. This may include third parties who provide services to us or otherwise support our relationship with you and advice, including our recruitment platform provider (Greenhouse) and recruitment agencies, candidate relationship management software provider (Gem), background check providers (HireRight, Lighthouse), professional advisors (such as our external legal counsel).


• any competent law enforcement body, regulatory, government agency, court or other third party (such as our professional advisers) where we believe disclosure is necessary (i) as a matter of applicable law or regulation (e.g., to provide certain salary information to tax authorities), (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;


• a buyer or prospective buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of the whole or any part of our business as permitted by law and/or contract;


• any other person with your consent to the disclosure (obtained separately from any contract between us).

How we keep your personal information secure

We follow generally accepted industry standards and maintain reasonable safeguards designed to secure the information in our possession and to provide a level of security appropriate to the risk of processing your personal information.

Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the information is used in a manner consistent with this Applicant Privacy Notice and that the security and confidentiality of the information is maintained.

International data transfers

Scopely is headquartered in the United States, with international offices including in the United Kingdom, Spain and Ireland. Our third party service providers and partners operate worldwide. This means that, in connection with our business and for employment, administrative, management and legal purposes, we may transfer your personal information outside of the country where you are located. As a result, your personal information may be transferred to a jurisdiction that may not provide the same level of data protection. If we transfer your personal information internationally, we will take the steps to ensure that your personal information is treated securely, lawfully, and in accordance with this Applicant Privacy Notice.

When we transfer your personal information internationally we treat your personal information securely, lawfully, and in accordance with applicable data protection laws. Where we transfer your personal information to countries and territories outside of the European Economic Area and the UK, for example, which have been formally recognised as providing an adequate level of protection for personal information, we rely on the relevant “adequacy decisions” from the European Commission and “adequacy regulations” (data bridges) from the Secretary of State in the UK.

Where the transfer is not subject to an adequacy decision or regulations, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Applicant Privacy Notice and applicable laws. Where applicable, we enter into the Standard Contractual Clauses approved by the European Commission (and equivalent clauses in the UK) for transfers to our group entities and to our third party service providers and partners.

Data retention

We will store the personal information 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 information we collect during the application process may be transferred to your personnel file and stored in accordance with our employee privacy notice and data retention policy.

If your application is not successful, we will hold your personal information and we may contact you about any other relevant employment opportunities that may arise (unless you have asked us not to). We will retain your personal information for this purpose for 6 months initially and we may then retain it for a further 6 months if we have your consent to do so.

Your data privacy rights

You may exercise the rights available to you under data protection laws as follows:

• If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided below.


• In certain circumstances, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided below.


• If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.


• You have the right to complain to a relevant data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. For contact details of the data protection authorities in the EEA, please see here. In the UK, the data protection authority is the Information Commissioner’s Office and the contact details are here.

You can make a request to exercise any of your privacy rights by contacting applicantprivacy@scopely.com. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Updates to this Applicant Privacy Notice

We may update this Applicant Privacy Notice from time to time in response to changing legal, regulatory, technical or business developments. When we update our Applicant Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

You can see when this Applicant Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Applicant Privacy Notice.

How to contact us

The entity with whom you are applying for a role will be the controller of your personal information. The relevant group entities are set out below.

We have appointed a Data Protection Officer (DPO) in the UK and Spain. Our DPO can be contacted at privacy@scopely.com or by mail using the details provided below.

If you have any questions, comments, or concerns regarding our Applicant Privacy Notice and/or privacy practices, please contact us by email at applicantprivacy@scopely.com or by mail as follows:

Scopely, Inc. Attn: Chief Legal Officer 3505 Hayden Avenue Culver City, CA USA 90232

Scopely Games Barcelona SL Attn: Legal Department C/Zamora 72 08018, Sant Martí, Barcelona, Spain