Scopely

Job Applicant Privacy Notice for California Residents

Last Updated: March 27, 2025

This Job Applicant Privacy Notice (“Applicant Privacy Notice”) applies to any job applicants who are California residents and about whom Scopely and/or its parents, subsidiaries, affiliates or related companies (“Scopely” or “we”, “our” or “us”) have collected personal information in the course of applying for employment with us (collectively, “you”). Scopely recognizes the confidential nature of the personal information in its care and is accountable for the compliance of itself and its directors, officers, management, employees, representatives, and agents in protecting this personal information. Any job applicants that Scopely chooses to employ will be subject to our employee privacy notice. Please note that this Applicant Privacy Notice does not apply to the personal information Scopely collects in connection with your visits or interactions with our games, mobile applications, websites, content, products, and any related services, but rather, our consumer Privacy Policy would apply, which is located at https://www.scopely.com/privacy.

Please read this Applicant Privacy Notice carefully. We may update it from time to time by posting a new version on our website. If we make any material changes, we will notify you through our website.

Contents

1. Personal Information Collected from Job Applicants


2. Categories of Personal Information Disclosed to Service Providers


3. Additional Personal Information Collected and Disclosed for Select Roles and Positions


4. Categories of Personal Information Sold or Shared to Third Parties


5. Enforcement


6. Personal Information Retention


7. Third-Party Products and Links


8. Security


9. Minors


10. California Data Privacy Rights


11. Contact Us

Personal Information Collected from Job Applicants

For the purposes of this Applicant Privacy Notice, “personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal information does not include publicly available information or information that has been de-identified, aggregated, or anonymized. We collect personal information directly from you in circumstances where you provide personal information (e.g., during the job application and hiring process). However, in some instances, the personal information we collect has been inferred about you based on other information you provide us, through your interactions with us, from third parties, or from service providers. When we collect your personal information from third parties, it is either because you have given us express permission to do so, your permission was implied by your actions, or because you provided explicit or implicit permission to the third party to provide the personal information to us.

If you are a job applicant, the categories of personal information listed below that we receive will be used to assess your suitability as a Scopely employee, to evaluate your qualifications for available or anticipated employment positions at Scopely, and for the purposes of complying with applicable laws. In some instances, the personal information you provide in connection with the application process may be collected and received directly by our vendors and service providers who assist us with the uses of personal information described in this Applicant Privacy Notice.

Unless you direct otherwise in writing, we are obligated to retain the personal information you provide as required by law for a minimum of four years from date of submission, and we may use that information to consider your eligibility for any available or anticipated employment positions at Scopely during that time. If you are hired and employed by Scopely, the personal information you provide during the application process will then be subject to and retained in accordance with our employee privacy notice.

Category of Personal Information	Source(s) of Personal Information	Purpose(s) of Collection	Retention Period
Identifiers: e.g., name, title/honorific, addresses, telephone numbers, and personal email addresses	Directly or indirectly (e.g. via recruiting companies or agencies) from you through your application for employment, resume and/or a publicly available LinkedIn profile	To determine suitability or qualifications for employment; To contact you and schedule interviews and other follow-up communications as needed during the application and interview process	Minimum four years, as required by law
Professional or employment-related information: e.g., previous positions of employment, work history, technical skills, referrals and references, job title and function, roles and responsibilities, language capabilities, resume or CV, cover letter, previous and/or relevant work experience or other experience, locations worked, salary expectations, letters of offer and acceptance of employment, interview feedback and assessments, information about where you are legally authorized to work, other information you provide to us in support of an application and/or the application and recruitment process	Directly or indirectly (e.g., via recruiting companies or agencies) from you through your application for employment, resume and/or a publicly available LinkedIn profile	To determine suitability or qualifications for employment	Minimum four years, as required by law
Education information: e.g., educational institutions attended or level of education, professional licenses held, certifications and registrations received, or any additional education or training relevant to application for employment	Directly or indirectly (e.g., via recruiting companies or agencies) from you through your application for employment, resume and/or a publicly available LinkedIn profile	To determine suitability or qualifications of employment	Minimum four years, as required by law
Information that reveals racial or ethnic origin, religious or philosophical beliefs, or union membership	Directly or indirectly (e.g., via recruiting companies or agencies) from you, only if voluntarily provided in a resume or other application materials submitted by you	This information is not requested or required by Scopely. If voluntarily provided by you, we may use this information to carry out other purposes as part of our business activities when reasonably required or permitted	Minimum four years, as required by law
Inferences drawn from any of the information identified above to create an applicant profile about you reflecting your behavior, attitudes, intelligence, abilities, and aptitudes to determine qualifications for employment	Directly or indirectly from you through your application for employment, resume and/or a publicly available LinkedIn profile, as well as interviews with Scopely	To determine suitability and qualifications for employment	Minimum four years, as required by law

Categories of Personal Information Disclosed to Service Providers

Personal information disclosed to our vendors and service providers is processed on behalf of Scopely pursuant to legal and other compliance obligations and may also be subject to their privacy policies, which may differ from this Applicant Privacy Notice. In the preceding 12 months, we have disclosed the following categories of personal information with the following categories of service providers and for the following business purposes:

Category of Personal Information	Purpose of Disclosure	Categories of Service Providers to Whom We Disclose Personal Information
Identifiers	To assist in the job application process (e.g., talent recruiting, scheduling interviews and follow-up communications, creating and managing letters of offer and acceptance of employment); To determine suitability or qualifications of employment	Applicant tracking system (ATS) provider; Candidate relationship management (CRM) software provider; Contract management software provider
Professional or employment-related information	To determine suitability or qualifications of employment; To assist in the job application process (e.g., talent recruiting, scheduling interviews and follow-up communications, creating and managing letters of offer and acceptance of employment)	Applicant tracking system (ATS) provider; Candidate relationship management (CRM) software provider; Contract management software provider
Education information	To determine suitability or qualifications of employment	Applicant tracking system (ATS) provider; Candidate relationship management (CRM) software provider
Information that reveals racial or ethnic origin, religious or philosophical beliefs, or union membership	If voluntarily provided by you, to assist in carrying out other purposes as part of our business activities when reasonably required or permitted	Applicant tracking system (ATS) provider; Candidate relationship management (CRM) software provider
Inferences drawn from other personal information	To determine suitability or qualifications of employment	Applicant tracking system (ATS) provider

Additional Personal Information Collected and Disclosed for Select Roles and Positions

For specific roles and positions at Scopely, the identifiers described above (e.g., name, title/honorific, addresses, telephone numbers, and personal email addresses) may also be collected and received directly by our vendors and service providers who assist us with the purposes of conducting credit checks, criminal background checks, employment history verification, and digital forensics. These categories of vendors and service providers include: background check providers and forensic service providers. Background check providers may also collect the following additional categories of personal information (on an as-needed basis to achieve the purpose): date of birth, the results of credit and criminal background checks, and information that reveals social security, driver’s license, and/or other government-issued identification number. Our vendors and service providers collect this personal information directly from you only after you receive a conditional offer of employment from Scopely and prior to starting employment.

Scopely uses the results provided by these background check providers and digital forensics providers for the following purposes: (i) to determine your suitability and qualification for certain roles and positions; (ii) to protect the safety and security of our workforce, property, and assets; and (iii) to comply with applicable laws and regulations. Unless you direct otherwise in writing by contacting us at applicantprivacy@scopely.com, we retain this personal information for a minimum of four years as required by law. If you are hired and employed by Scopely, the personal information you provide during this process will then be subject to and retained in accordance with our employee privacy notice.

Categories of Personal Information Sold or Shared to Third Parties

We have not sold or shared any personal information with any third parties in the preceding 12 months as those terms are defined under California law.

Enforcement

All Scopely employees having care over or access to personal information must comply with the policies, procedures and practices described in this Applicant Privacy Notice. Any Scopely employee who breaches any term or condition of this Applicant Privacy Notice, whether intentional or unintentional, will be subject to disciplinary action, up to and including termination.

Personal Information Retention

We generally retain personal information for as long as we reasonably need it for the purposes described in this Applicant Privacy Notice and for four (4) years after you submit your application (if not hired), unless a longer retention period is required or permitted by law.

The primary factors we consider in determining retention periods can include minimum requirements under applicable law, relevant industry standards, the types of data in question (such as its level of sensitivity), relevance to potential litigation or similar proceedings (such as defending ourselves against legal claims), and whether the personal information is required to prevent fraud or similar abuse of the job application process.

To learn more about how to request deletion of your personal information, please see the “California Data Privacy Rights” section below.

Third-Party Products and Links

In some cases, we may ask you or enable you to access or otherwise interact with third-party websites, products or services in connection with the job application process. Additionally, other websites may also reference, advertise, or link to Scopely’s job postings. Please note that those links and the content of such other websites, products or services are offered by third parties not controlled by us, and we are not responsible for their actions, their terms, their privacy practices and use of information, or their products or services. If you submit your information to a third party, that third party’s treatment of your information is governed by their privacy policy, which may differ from this Applicant Privacy Notice. We encourage you to review the applicable privacy policy of any third party you interact with in connection with the job application process.

Security

We follow generally accepted industry standards and maintain reasonable safeguards designed to secure the information in our possession, and take steps to ensure only those at Scopely with a legitimate business need to access your personal information are permitted to do so. We also take reasonable steps to assure that third parties to whom we transfer information will provide protections appropriate to that type of information. We also have in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so. If you have reason to believe that your personal information collected in accordance with this Applicant Privacy Notice is no longer secure, please immediately contact us at applicantprivacy@scopely.com.

Minors

We do not collect data about individuals that are under 18 years old as part of the job application and hiring process. We do not sell or share personal information with third parties, and thus, we do not sell or share the personal information of individuals under 16 years of age.

California Data Privacy Rights

California residents have the following data rights:

Right to Know and to Access

Subject to certain exceptions, and legal obligations, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months, including whether we sell or share such information. You also have the right to request access to personal information collected about you and information regarding the categories of personal information; the categories of sources of that information; the business or commercial purposes for which we collect, sell or share it; the third parties to whom we sell, share, or disclose it; and the specific pieces of personal information we collected about you.

This information is disclosed in the “Personal Information Collected from Job Applicants” and the “Additional Personal Information Collected and Disclosed for Select Roles and Positions” sections of this Applicant Privacy Notice. You may also submit a request for this information as described below. To protect your personal information, we are required to verify your identity before we can act on your request.

Right to Portability

You have the right to request that we provide a copy of the personal information we have collected about you, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. This right is subject to certain exceptions, and legal obligations imposed by state or federal privacy and employment laws. Once we receive your request and confirm your identity, we will provide to you a copy of your data as required under the applicable data protection laws. We may provide this data to you through your user account with us, or via email to the email address you have provided with your request.

Right to Delete

You have the right to request that we delete your personal information. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. This right is subject to certain exceptions, and legal obligations imposed by state or federal privacy and employment laws. We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Correct Inaccurate Information

Subject to certain exceptions, and legal obligations imposed by state or federal privacy and employment laws, you have the right to request that we correct inaccurate personal information that we have collected about you. Once we receive your request and confirm your identity, we will review your request, taking into account the nature of the personal information and the purposes of the processing of the personal information to see if we can correct the data. We may also request additional information showing that the information you want to correct is inaccurate.

Right to Opt Out of the Sale or Sharing of Personal Information to Third Parties

You have the right to opt out of the sale or sharing of your personal information by Scopely to third parties. We do not sell or share your personal information as those terms are defined under California law.

Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to direct us to limit our use of your Sensitive Personal Information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services. Our vendors and service providers who assist us with the uses of personal information described in this Applicant Privacy Notice may also collect the following pieces of personal information, which California law considers to be “sensitive,” when you provide it in connection with the application process: social security number, driver’s license number or other government-issued identification number. We use Sensitive Personal Information only as it is necessary to perform the services for which it was collected, as described above.

Non-Discrimination or Retaliation

We will not discriminate or retaliate against you for exercising any of your data privacy rights.

How to Submit a Request

You or an authorized agent may submit a request to exercise your rights by contacting us at applicantprivacy@scopely.com with California Data Privacy Rights in the subject line of your email and a description of the rights you wish to exercise in the body of the email.

Verification Procedures

We are required by law to take reasonable steps to verify your identity prior to responding to your request to exercise your rights (except for requests to opt out). Please note that your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). We verify your request by using information necessary to complete your request and by asking you to:

• Provide personal identifiers we can match against information we may have collected from you previously; and


• Confirm your request using the email provided in the request.

We will not collect additional personal information from you for the sole purpose of your exercising your rights under applicable data protection laws. Similarly, we will not require you to create an account with us, solely for the purpose of exercising your rights under the data protection laws.

Requests to exercise these rights may be granted in whole, in part, or not at all, depending on whether we are able to verify your identity and request or not, the scope and nature of the request, or as otherwise permitted by applicable law. Where required by applicable law, we will notify you if we reject your request, and notify you of the reasons we are unable to honor your request.

Authorized Agent

You may use an authorized agent, to make requests on your behalf. We may ask the individual to submit documentation or proof supporting their authority to represent you, and we may ask you to either verify your own identity or confirm that you provided the authorized individual to act on your behalf.

Contact Us

If you have any questions, comments, or concerns about this Applicant Privacy Notice, please contact us at applicantprivacy@scopely.com.