Privacy Policy

PRIVACY POLICY FOR JOB APPLICANTS

Last modified: 14th December 2022

OVERVIEW

This privacy policy (“the Policy”) is for job applicants or contractors (“Applicants”) who apply for a job at Miniclip or create an account on our Portal. If you would like to know more about how we use your personal information, please read this Policy.

About us and how to contact us

Miniclip, a provider of online games, manages the job application process and will need to process your personal information. If you have any questions about our data practices, your rights or have any concerns or complaints, you can contact us at talentacquisition@miniclip.com, or send a letter to the address provided in this Policy.

Personal information we collect

We collect personal information from you directly (e.g. when you register on our Portal for Applicants), from third parties (e.g. if you apply via an employment agency or if a former employer provides a reference) and also generate information about your interactions with us. More information.

How we use your personal information

We use your information to assess your experience, eligibility and suitability for the roles you apply or other roles that may be relevant to you. We will also use your information to respond to your questions , provide reasonable adjustments, prevent fraud, defend Miniclip against legal claims or disputes, enforce our terms and to comply with our legal obligations. More information.

We rely on third parties for the purposes set out in this Policy, including service providers. Additionally, we share your information within our group and as required by law. More information.

Where we process your personal information

We will process your Information in the EEA or the UK if possible. If not possible we will use appropriate safeguards to protect your personal information. More information.

Your rights

You may have rights to access, receive a copy of, or delete, your information or restrict processing of your data, and you also have the right to object to our use of your information for certain purposes, including tailored marketing and advertising. More information.

Changes to the Privacy Policy

Any updates or changes to this Policy will be published here.

INTRODUCTION

This privacy policy informs you of your choices and our practices in relation to your Information (as defined below). In this Policy, “Miniclip”, “we” or “us” refers to the Miniclip company recruiting for a particular position, which could be any of the following:

a. Miniclip SA, a company registered in Switzerland with its office located at Rue des Beaux-Arts 8, 2000 Neuchatel, Switzerland. b. Miniclip Portugal, Unipessoal LDA a company registered in Portugal with its office located at Taguspark, Edificio Ciencia II, Av. Prof. Dr. Aníbal Cavaco Silva, Nº 11 - 1C, 2740-120, Oeiras, Portugal. c. Miniclip (UK) Limited, a company registered in England with its office located at 2nd Floor, Bureau, 90 Fetter Lane, London, England, EC4A 1EN. d. Gamebasics B.V., a company registered in The Netherlands with its office located at Buitenom 263, 2711 KB, Zoetermeer, The Netherlands. e. Yakuto Limited, a company registered in England with its office located at 2nd Floor, Bureau, 90 Fetter Lane, London, England, EC4A 1EN. f. AppyNation Limited, a company registered in England with its office located at River Studio, Old Milverton Lane, Blackdown, Lemington Spa, England CV32 6RW. g. Playsports Games Ltd, a company registered in England with its office located at Floor 2 Tempus Court, Onslow Street, Guildford, Surrey, England, GU1 4SS. h. Testaluna s.r.l., a company registered in Italy with registered address at Via Melchiorre Gioia, 8, 20124, Milano (MI), Italy.

The company recruiting for a particular position is considered a data controller in certain countries. If you have any questions about this, please ask us.

For the purpose of this Policy, “Information” means any information relating to an identified or identifiable individual. This includes Information relating to your use of our portal for job applicants (the “Portal ”). When you apply for a job, you acknowledge we collect, process, use and store your Information as described in this Policy. If you do not agree with this Policy, please do not share Information with us. If you apply for a job but then change your mind, you must stop using the Portal and you may exercise your rights in relation to your Information as set out in this Policy.

Please bear in mind that this Policy applies only to your personal Information as a job applicant. If you want to know more about how we handle your personal data in relation to our games, please visit our players’ privacy policy

1. PERSONAL INFORMATION WE COLLECT

We will collect and use the following Information about you:

Information you provide to us
- Information you provide while creating an account on the Portal: name, surname, contact details (i.e. address, email address), how you heard about the position, position of interest, immigration status.
- Information you provide in your CV/resume, cover letter or during interviews: education history, current and previous employment details, hobbies, languages, nationality, picture, being part of a protected category (in certain countries), immigration status (e.g. nationality, right to work or visa requirements), current and desired compensation.
- Information we automatically collect or is generated about you
  - Identifiers: Candidate ID.
  - Test results: we will obtain results from different tests or challenges that we may create during the hiring process.
  - Cookies: we use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience when using the Portal. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality. You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies or instruct the device or web browser to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Portal may be unable to operate as designed.
- Information received from third parties
  - Employment Agencies: information contained in CVs, email address, name, surname, salary expectations, current compensation package.
  - Reference providers: confirmation on name, surname, employer, location of employment, job title, length of service.

2. HOW WE USE YOUR PERSONAL INFORMATION

We use your Information to:

Assess your suitability for roles that you have applied for
Recommend new roles based on the profile that you have created on our Portal.
Provide reasonable adjustment if you need them.
Provide you with support and respond to your requests or complaints.
Pay you: we will use your billing Information to pay you any sum that we owe you.
Prevent fraud, defend Miniclip against legal claims or disputes, enforce our terms and to comply with our legal obligations: it is in our legitimate interests to protect Portal users against online abuse and other anti-social or illegal activity. We will also be (1) monitoring Portal use to detect fraud or any other user behaviour which prejudices the integrity of our Portal, (2) taking steps to remedy fraud and behaviour, (3) defending ourselves against legal claims or disputes, and (4) enforcing our terms, agreements and policies. When doing so, we will process the Information relevant in such a case, including information you provide us, information we automatically collect about you, and information which is provided to us by third parties to ensure compliance with our contract and our legal obligations.

We share your Information with selected third parties, including:

Companies who belong to the same group as Miniclip if there is a need for them receive your Information.
Employment Agencies.
Service providers (e.g. the company that we use to create the Portal or other companies that help us assess your suitability to a role).
Law enforcement agencies, public authorities or other judicial bodies and organisations. We disclose Information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection).
Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganisation, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.

Security

Although we have in place security measures to maintain the privacy and integrity of your Information, unfortunately, the transmission of Information via the internet is not completely secure. We may also take extra steps to protect your Information and minimise the Information we process.

4. WHERE WE PROCESS YOUR PERSONAL INFORMATION

Your Information will be processed by our employees and service providers in the European Economic Area (“EEA”), the United Kingdom (“UK”) and in Switzerland. If we need to transfer your Information outside these territories we will make sure we do so legally and including additional safeguards, like Standard Contractual Clauses or similar.

5. HOW LONG WE STORE YOUR INFORMATION

We will retain your Information for a maximum of five (5) years from the last date you accessed the Portal. While deleting Information, we will take measures to make the Information irrecoverable or irreproducible, and electronic files which contain Information will be deleted permanently.

6. YOUR RIGHTS

If you are based in the EEA, Switzerland or are a legal resident of California in the U.S., you have certain rights in relation to your Information. For Californian residents, please refer to Addendum 1 – California Privacy Rights. For EEA and Switzerland based, you will find more information below on when which rights can apply.

To exercise your rights, please email us at talentacquisition@miniclip.com.

Access. You have the right to access Information, and to receive an explanation of how we use it and who we share it with. This right is not absolute. For example, we cannot reveal trade secrets , or give you Information about other individuals.
Erasure. You have the right to request deletion of your Information. We may need to retain some of your Information where there are valid grounds for us to do so under data protection laws. For example, for the defence of legal claims, respect freedom of expression, or where we have an overriding legitimate interest to do so, but we will let you know when this is the case. Note that where the Information is held by a third party data controller we will use reasonable steps to inform them of your request, but we recommend you contact them directly in accordance with their own privacy policies to ensure your personal data is erased.
Objection and withdrawal of consent. You have the right to (i) withdraw your consent where you previously provided such consent; or (ii) object to our processing of your Information where we process such Information on the basis of our legitimate interests (see above under How we use your personal information).
Portability. You have the right to receive a copy of Information we process on the basis of consent or contract in a structured, commonly used and machine-readable format, or to request that such Information is transferred to a third party.
Correction. You have the right to correct any Information held about you that is inaccurate. You can access your account on the Portal to amend Information if you wish to.
Restriction. You have a right in certain circumstances to stop us processing Information other than for storage purposes.

7. CONTACT & COMPLAINTS

We welcome questions, comments and requests regarding this Policy. These should be addressed to talentacquisition@miniclip.com. You can also send a letter to Data Protection at Miniclip SA, Rue des Beaux-Arts 8, 2000 Neuchatel, Switzerland. Alternatively, if you are based in the UK, you can send a letter to Miniclip (UK) Limited at Legal Department at Miniclip, 2nd Floor, Bureau, 90 Fetter Ln, London EC4A 1EN, United Kingdom.

If you wish to make a complaint about how we process your Information, please contact us at talentacquisition@miniclip.com and we will endeavour to deal with your complaint as soon as possible. This is without prejudice to your right to launch a claim with a data protection authority.

CHANGES

Any updates or changes to this Policy will be published here.

ADDENDUM 1 – CALIFORNIA PRIVACY RIGHTS
The terms of this Addendum apply to residents of California under the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”). For the purposes of this addendum, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the CCPA. Personal Information does not include information that is: lawfully made available from government records, deidentified or aggregated, or otherwise excluded from the scope of the CCPA.

We collect personal Information for the purposes set out in this Privacy Policy and may also disclose this personal Information with third parties in accordance with section 3 - “Who we share your personal Information with” of this Privacy Policy.

SALES OF PERSONAL INFORMATION / NOTICE OF RIGHT TO OPT-OUT

Rights under the CCPA

The CCPA provides California residents with certain legal rights; these rights are not absolute and are subject to certain exemptions. If you are a California resident, and the CCPA does not recognize an exemption that applies to you or your personal information, you have the right to:

• submit a verifiable request for the following information covering the 12 months preceding your request: o the categories of Personal Information about you that we collected, sold, or disclosed; o the categories of sources from which the Personal Information was collected; o the purpose for collecting or selling Personal Information about you; o the categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that was disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and o the specific pieces of Personal Information we collected about you; • Submit a verifiable request that we delete Personal Information we collected from you; and • Be free from unlawful discrimination for exercising your rights, including providing a different level or quality of services or deny goods or services to you when you exercise your rights under the CCPA, subject to certain limitations. We aim to fulfill all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

How to Exercise Your Rights You can exercise your rights by using our web form (and choosing: Type of issue ‘Related to my account’ > I have data related question) or by emailing us at talentacquisition@miniclip.com.

Verification

Requests for access to or deletion of Personal Information, whether submitted by you directly or via an authorized agent, are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, please be prepared to provide us with identifying information (such as your User ID, Game name etc.) that and we can match against our records in order to confirm you are the rightful account holder.

Authorizing an Agent

To authorize an agent to make a request to know or delete or opt out on your behalf, please email us at talentacquisition@miniclip.com.

Shine the Light

We do not rent, sell, or share Personal Information with non-affiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code § 1798.83), unless we have your permission.

Do Not Track

There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.