PURPOSE OF THIS NOTICE: This ZeniMax Media Canadian Applicant Privacy Notice (the “Notice”) describes our collection and use of personal information about Canadian residents who apply for employment (“Applicants”) at ZeniMax Media Inc. or its subsidiaries (together, “ZeniMax,” “we,” “our” or “us”). This Notice supplements but does not supersede nor replace any other consent ‎you may ‎have previously provided to us regarding your personal information‎. This Notice does not apply to employees who are covered by a separate privacy notice once an employment relationship has been established. This Notice has been developed in compliance with applicable privacy ‎legislation. If this Notice conflicts with any applicable legislation, the legislation will govern. ‎

SCOPE OF THIS NOTICE: This Notice applies to the personal information that we collect, use, and disclose in order to review your application and assess your eligibility for employment.

For the purposes of this Notice, “personal information” refers to any information that relates to an individual and allows that individual to ‎be identified directly or indirectly. ‎

This Notice does not address or apply to our collection, use, or disclosure of personal information that is not subject to applicable privacy laws, such as business ‎contact information, or to collection, ‎use or disclosure that is otherwise permitted by law.

Are our practices the same for all Applicants? The categories of personal information we collect, and our use of personal information, may vary depending upon the position(s) or location, as well as the associated qualifications and responsibilities. The information in this Notice is intended to provide an overall description of our collection and use of personal information about Applicants.

CATEGORIES OF PERSONAL INFORMATION COLLECTED: Generally, we may collect the following categories of personal information about Applicants, where consistent with applicable law:

• Identifiers: such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.
• Paper and Electronic Records: such as records that may contain name, signature, address, telephone number, education, employment, employment history, driver’s license or provincial identification card number, or evidence of authorization to work in Canada (if applicable).
• Personal Characteristics: such as race/ethnicity, gender, sex, age, date of birth, veteran status, disability, citizenship status, and other characteristics of protected classifications under applicable law. (Note: generally, this information is collected on a voluntary or de-identified basis, and is used in support of our equal opportunity and diversity and inclusion efforts or where otherwise permitted or required by law.)
• Audio, Video and Other Electronic Data: such as audio, electronic, visual, or similar information, including CCTV footage, photographs, call recordings, and other audio recording (e.g., recorded meetings).
• Location Data: location information about a particular individual or device.
• Employment Information and History: professional or employment-related information, resume, reference letters, interview notes, reference checks, background checks, salary, pay level, positions held, training and courses completed or attended, evaluations, performance reviews, discipline, promotions, demotions, awards, or commendations‎.

• Education Information: such as information about education history or background.

• Sensitive Personal Information. Social insurance number, driver’s license number, passport number, evidence of valid authority to work in Canada, race/ethnicity, religion, sexual orientation, gender identity, and precise geolocation information.
  
  

DISCLOSURE AND TRANSFER OF PERSONAL INFORMATION: We may transfer and disclose the categories of personal information described above to the following categories of third parties for the purposes described in this Notice:

• Affiliates and subsidiaries (including Microsoft Corporation and the Activision Blizzard group companies)
• Service providers and suppliers (for example, benefits providers, payroll providers, information technology and hosting providers)
  
  

These third parties may be located outside of your province of employment, including outside of Canada.  Applicable ‎‎laws in those ‎‎foreign jurisdictions might permit foreign governments, courts, law enforcement or ‎‎regulatory agencies to ‎‎access the information in those jurisdictions.‎ In these cases, we will comply with local law ‎requirements relating to the conditions for disclosure of personal information. ‎

To the extent that we need to transfer personal information of Québec residents ‎outside of the province of Québec (including to other Canadian provinces), we shall ‎only do so in full compliance with applicable law. Where necessary, we will conduct ‎all necessary data privacy impact assessments and take all necessary measures (including, ‎without limitation, contractual measures) to ensure that the personal information that we transfer will receive ‎an adequate level of protection in the jurisdiction to which it is transferred.‎

We may also disclose personal information where required or permitted by law, including to taxing authorities, workers compensation authorities, provincial medical service plans, law ‎enforcement agencies, industry associations or regulatory bodies.‎

PURPOSES FOR COLLECTING AND USING PERSONAL INFORMATION: We collect, use, and disclose Applicant personal information reasonably required to assess eligibility and suitability for employment in accordance with applicable law. ‎Generally, we may collect, use, and disclose the above categories of personal information for the following purposes:

Management of the Application Process. To manage our relationship with Applicants, including:

• Assessing eligibility and suitability for employment
• Administering or performing employment contracts where applicable
• Conducting pre-employment and employment screening (where relevant and pursuant to applicable laws)
• Professional development and training purposes
• Verification and management of applicable Applicant credentials, licensing, and other qualifications
• Facilitating Applicant communication and collaboration
• Supporting our equal opportunity employment policy and diversity and inclusion programs
  
  

Business Operations and Client Services. Relating to the organization and operation of our business and our performance of services to clients, including related to:

• Operating our business by developing, producing, marketing, selling, and providing goods and services
• Providing after-sales services to clients
• Providing and maintaining a healthy and safe work environment for all personnel
• Auditing and assessing performance of business operations, including client services and associated activities
• Training and quality control
• Satisfying client reporting and auditing obligations
• Facilitating business development opportunities, as relevant
• Facilitating communications in furtherance of the foregoing
  
  

Security and Monitoring. To monitor and secure our resources, network, premises, and assets, including:

• Monitoring for, preventing, and investigating suspected or alleged misconduct or violations of work rules
• Monitoring for, preventing, investigating, and responding to security and privacy incidents
• Providing and managing access to physical and technical access controls
• Monitoring activities, access, and use to ensure the security and functioning of our systems and assets
• Securing our offices, premises, and physical assets, including through the use of electronic access systems and video monitoring
• Preventing theft, fraud, and ‎similar ‎risks‎
  
  

Auditing, Accounting and Corporate Governance. Relating to financial, tax audits, accounting audits, audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations, and for other internal business purposes such as administration of our records retention program.

M&A and Other Business Transactions. For purposes of planning, due diligence, and implementation of commercial transactions, such as mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization, or other similar business transactions.

Defending and Protecting Rights. To protect and defend our rights and interests and those of third parties, including to manage and respond to Applicant, employee, and other legal disputes, to investigate, manage, and address legal matters such as harassment complaints, unlawful ‎behaviour, criminal behaviour, fraud, civil claims, ‎and insurance matters‎, to respond to legal claims or disputes, and to otherwise establish, defend, or protect our rights or interests, or the rights, interests, health, or safety of others, including in the context of anticipated or actual litigation with third parties.

Compliance with Applicable Legal Obligations. Relating to compliance with applicable legal obligations (such as hiring eligibility, responding to subpoenas and court orders) as well as assessments, reviews, and reporting relating to such legal obligations, including under employment and labour laws and regulations, social security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions, and guidance.

Other Business and Commercial Purposes. In addition, we may use certain personal information we collect about Applicants for other purposes including analytics and insights.

We do not sell Applicants’ personal information to third parties, and we do not share Applicants’ personal information for cross-context behavioural advertising purposes.

As the employer, in general, we have the right to collect, use, and disclose Applicant personal ‎information without consent (but with notice) where reasonably required to establish, manage, and ‎terminate the employment relationship. If and where required by applicable law, we will obtain ‎consent to collect personal information. ‎

RETENTION OF PERSONAL INFORMATION

We will retain your personal information, including sensitive personal information, as long as necessary for purposes for which the personal information was collected and is used by us, as stated in this Notice. To the extent permitted by applicable law, we will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements. We will keep personal information used to make a decision affecting you for at least one year after using ‎it to make the decision.‎

We will destroy, erase, or make anonymous (to the extent permitted by applicable laws) documents or ‎other records containing Applicant personal information as soon as it is reasonable to assume that the ‎original purpose is no longer being served by retaining the information and retention is no longer ‎necessary for a legal or business purpose.‎

PROTECTING INFORMATION

We protect the personal information in our custody or control by making reasonable security ‎arrangements designed to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal, ‎or similar risks. Any Applicant who is aware of, or who suspects, that there has been an unauthorized ‎collection, use, or disclosure of personal information should immediately contact us as set out below. Any Employee or Applicant who accesses, collects, uses, or discloses personal information ‎without authorization will be subject to discipline, up to and including termination of employment. ‎

ACCURACY

We will make reasonable efforts to ensure that Applicant personal information is accurate, complete ‎and ‎‎up-to-date for the purposes for which it is to be used, including information disclosed to third ‎parties or ‎‎used to make a decision about you. In most cases, we will rely on you to ensure that ‎information is ‎‎correct, accurate, and complete.‎ You have access and correction rights as described below.

APPLICANT RIGHTS

Applicants have the following rights with respect to their personal information:

• Right to access:  You may have a right to access your personal information held by ZeniMax, subject to your jurisdiction of residence. Where an access request is refused, we will notify you in writing, document the reasons for refusal, and outline further steps which are available to you.
• Right to correct inaccurate information: You may have a right to request correction of your inaccurate personal information that we have collected about you and to have such personal information corrected. If a challenge regarding the accuracy of your personal information is not resolved to your satisfaction, we ‎‎will annotate the personal information under our control with a note that the correction was requested but ‎‎not made.‎
  
  

Applicants who are residents of the province of Québec have the following rights with respect to their personal information, in addition to the ‎rights identified above:‎

• Applicants have the right to withdraw their consent to our use or disclosure of ‎personal information, without affecting the lawfulness of any uses or disclosures made up until withdrawal. Withdrawal of ‎consent does not create an ‎obligation for us to delete personal information ‎which we are otherwise allowed or required to ‎retain under applicable law. If you withdraw your consent we may not be able to continue to employ you.
• Applicants may have the right to obtain a machine-readable copy of their personal information or ‎to have us transfer it to another third party of their choice (data portability).‎
• Applicants may, in certain circumstances, have the right to request that we cease disseminating their ‎personal information or to ‎de-‎‎index any hyperlink that allows access to that personal information by ‎‎technological means, if ‎‎such dissemination contravenes applicable law or a ‎court (right to de-indexation).‎
  
  

Submitting Requests. You may submit requests to us at applicantprivacy@zenimax.com.

Please note that we may require additional information from you in order to verify your identity and request.

Authorized agents or mandataries may submit requests to us at applicantprivacy@zenimax.com. If you are submitting a request through an authorized agent or mandatary, the authorized agent or mandatary must confirm their relationship with you. We may also request that any authorized agents or mandataries verify their identity, including by providing information about themselves, such as their name, email, phone number, and address. We may reach out to you directly to confirm that you have provided the agent or mandatary with your permission to submit the request on your behalf.

There may be circumstances where we will not be able to honour your request. Where an access request is refused, we will notify you in writing, document the reasons for refusal, and ‎outline further steps that are available to you.

CHANGES: This Notice is subject to change from time to time.‎ We will provide notice of such changes. If the scope of our collection, use, or ‎disclosure of your personal information is modified ‎as a result of such changes, Applicants ‎may, if required by applicable law, be asked to confirm ‎their continued consent to such practices.

CONTACTING US ABOUT THIS NOTICE: If you have any questions or concerns regarding our use of personal information as described in this Notice, please contact applicantprivacy@zenimax.com