California Employee Privacy Notice

Last Updated: October 15, 2024

DeNA Corp. (“we”, the “Company”) provides this California Employee Privacy Notice (“Notice”) to notify you of our privacy practices as required by the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time ("CCPA").

This Notice applies only to individuals residing in the State of California who are considered “Consumers” (as defined in the CCPA) – namely, job applicants and candidates of employment (“Candidates”), and employees (“Employees”, collectively with Candidates, “you”)– from whom we collect Personal Information defined in the CCPA. When we refer to Consumers, we mean you to the extent you are a California Candidates, and Employees.

Categories of Information We Collect

For the purposes of this Notice, 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 .

We may collect and use the following categories of your Personal Information in the preceding twelve months since this Notice was last updated.

Personal Information does not include information that is:

• Publicly available, as defined by the CCPA.
• Deidentified or aggregated.
• Otherwise excluded from the scope of the CCPA.

We do not use or disclose sensitive personal information defined in the CCPA (“Sensitive Personal Information”) for purposes which would require us to offer consumers the right to limit under the CCPA.

Use of Personal Information

We collect your Personal Information for the purposes, including the business and commercial purposes, below:

• Comply with all applicable laws and regulations.
• Recruit and evaluate Candidates based on skills and experience.
• Conduct background checks.
• Manage your employment relationship with us, including for:
  • onboarding processes;
  • timekeeping, payroll, and expense report administration;
  • employee benefits administration;
  • employee training and development requirements;
  • the creation, maintenance, and security of your online employee accounts;
  • reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill;
  • workers' compensation claims management;
  • employee job performance, including goals and performance reviews, promotions, discipline, and termination; and
  • other human resources purposes
• Manage and monitor employee access to the Company facilities, equipment, and systems
• Conduct internal audits and workplace investigations
• Investigate and enforce compliance with and potential breaches of the Company policies, rules, and procedures
• Engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers and acquisitions of the Company
• Maintain commercial insurance policies and coverages, including for employees’ compensation and other liability insurance
• Perform workforce analytics, data analytics, and benchmarking.
• Administer and maintain the Company's operations, including for safety purposes.
• Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents.
• We use and process Sensitive Personal Information to comply with laws and regulations including anti-discrimination laws and regulations and disability accommodation laws and regulations.

Source of Personal Information

In the preceding twelve months since this Notice was last updated, we have collected Personal Information from the following categories of sources:

• Directly from you. For example, employment agreement, meeting with CEO and E-mail .
• Indirectly from you. For example, from observing your actions on our website or from information your computer or mobile device transmits when interacting with our website or mobile applications.
• Third parties. For example, from recruiters who submit your information to us for an employment position that may interest you and consumer reporting agencies for employment background checks.

Disclosure of Personal Information

We may disclose your Personal Information for a business purpose to our affiliates, service providers or contractors who assist us in administering our workforce including benefits providers, payroll and expense administrators, worker’s compensation vendors and government agencies, professional advisors such as attorneys, auditors and accountants, and, where appropriate, law enforcement or government regulators. We may also disclose your personal information to our affiliated companies for the purpose of business communication, personnel management and recruitment support across the entire group of companies.

We do NOT sell your Personal Information.

We do NOT share your Personal Information with third parties for behavioral or cross-context marketing purposes.

Your California Privacy Rights

If you are a California resident, you may exercise the following rights.

Right to Know and Access.
You may submit a verifiable request for information regarding the (1) categories of sources from which we collect Personal Information; (2) categories of third parties with whom we disclosed Personal Information; and (3) specific pieces of Personal Information we have collected about you.

Right to Delete.
Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you. We are not permitted to delete information that we need in order to operate our business, administer our employees, protect our legal obligations and rights, or to provide security for our employees, our systems and the Company.

Right to Correct.
Subject to certain exceptions, you may submit a verifiable request that we correct inaccurate Personal Information that we maintain about you.

Verification.
We may need you to provide additional information to verify your request, such as providing certain data elements so that we can confirm they match the Personal Information already maintained by us. We will not use this additional information for anything other than handling your request.

Right to Opt Out.
You have the right to opt-out of the sale of your Personal Information to third parties, however, we do not “sell” Personal Information, as that term is defined in the CCPA. You also have the right to opt-out of “sharing” your information for advertising purposes, however, we do not share your information for advertising purposes as it is defined in the law.

Non-Discrimination.
You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

Shine the Light.
We do not rent, sell, or disclose Personal Information to nonaffiliated companies for their direct marketing uses as contemplated by California’s "Shine the Light" law (Civil Code § 1798.83), unless we have your permission.

Submit Requests.
To exercise your rights under the CCPA, please follow the instructions described in the "Your California Privacy Rights" above and send an email via our Contact Information section.

Authorizing an Agent.
If you are acting as an authorized agent to make a request to know, delete, correct, or opt out on behalf of a California resident, please contact us via the Contact Information section and attach a written authorization signed by the resident.

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.

Contact Information

If you have any questions, comments, or concerns about this notice or our processing activities, or you would like to exercise your privacy rights, please email us at hr.denacorp_my@dena.jp.