Bungie Candidate Privacy Notice

Bungie, Inc. takes privacy seriously. Seriously. This Candidate Privacy Notice ("Notice") has been written to explain what info we collect during our application and recruitment process, as well as to explain and offer examples of the different ways we may use or share it. To learn more about Bungie's privacy practices for its products and services such as our websites and games, visit the Bungie Privacy Policy.

Bungie is proud to operate and support our services from around the globe. In this Notice, "Bungie" or "we", refers to the relevant hiring entity within Bungie that you are being considered for a role with. That entity is a "controller" of your personal data for purposes of data protection laws and is primarily responsible for how your personal data is held, used and disclosed. When we say "personal data'' (or "personal info"), we mean information that can be used to identify you. We also collect, use, and share non-personal data that does not directly identify you.

Note that we don't collect every piece of info detailed here from every candidate. The specific info we collect about you typically depends on the nature of our relationship, including where you are in the recruitment process, the role for which you are being considered, and the applicable laws in your region.

This Notice does not replace any national or local data protection laws. Any such applicable laws will be followed and take precedence over this Notice where they provide for stricter standards on privacy and data protection. Similarly, if this Notice conflicts with local law in your jurisdiction, local law applies.

1. Information Bungie Collects & How We Collect It

During the application process, we collect info on every applicant. This info can be collected from the job application, or in conversation with the recruiter or job interviewers. This Notice applies to this info you share with us directly. It also applies to info we may obtain or produce through our own recruitment efforts (such as from third parties, including recruitment agencies, background check providers, your references, networking websites like LinkedIn, and info collected from publicly available sources--including social media platforms you use or other info available online).

The exact info we gather usually depends on how you interact with us, how far along you are in the recruitment process, and the role you are being considered for. Some common examples include:

Contact info: We collect your name, email addresses, residential addresses, phone numbers, and similar business or personal contact information to help us communicate with you.
Personal details: This info includes your name and pronunciation recording, pronouns, date of birth, and government identifier (for example, your Social Security number). In addition, we may collect info about your social media, websites, and professional memberships (where permitted by law) to support our recruitment efforts.
Experience info: To understand your past experiences we collect info regarding your current employer, current title, employment history, education, language abilities, qualifications, references, and other info included in a CV/résumé or cover letter or as part of the application process to learn more about you and your qualifications.
Reference, Referral, and Background information: We collect info from any references you provide. Remember, it is your responsibility to gain any necessary consent from your references before sharing their info with us. We collect info from your referrals about how they know you. We may also collect info from background checks subject to relevant legal requirements.
Previous Applications and Roles: We collect info about any previous applications submitted to Bungie and/or any prior employment history with Bungie.
Immigration and Visa Status: We collect immigration and/or right to work information.
Demographic and Sensitive information: Bungie seeks to be a leader in diversity, inclusion, and equity in gaming. In accordance with this, Bungie does not require sensitive personal info regarding racial or ethnic origin, religious, political, or philosophical beliefs, genetic data, biometric data, trade union membership, or info about your health, sex life, sexual orientation during recruiting or on your application. Where collection of such data is permitted under applicable law and to the extent you choose to provide us with that kind of info, you expressly authorize Bungie to handle such info in accordance with this Notice. However, sometimes, and where local laws allow, we may collect or request such information for legitimate employment-related purposes. This can include details about your:
- Info about your racial/ethnic origin, gender, date of birth, and disabilities that can help aid Bungie's pursuit of an equitable workplace through equal opportunity diversity and inclusion efforts; or
- Info about your physical or mental health condition can help Bungie provide work and interview related adjustments, or to manage absences from work.
What You Choose to Provide: We collect any info you provide us during an interview and/or from tests undertaken during the interview process.
On Campus Footage: Bungie facilities are outfitted with video recording equipment to help ensure the security of its employees and visitors. We collect security video images or other info included in facilities access records. If you interview in one of our offices with security cameras, you may appear in video footage.
Criminal Convictions: We collect info about criminal convictions and offenses when relevant to the role for which you have applied. Such information is not registered or stored by us, except to the extent required or permitted by applicable law.

Under the California Consumer Privacy Act of 2018 ("CCPA"), the categories of info we hold about you are described as:

Identifiers (such as your name and email address).
Demographic info (like age, race, and gender identity).
Audio, electronic, visual, or similar info (like photographs or voice messages).
Geolocation info (such as your physical address).
Employment-related info (such as job history and performance evaluations).
Education info (such as information within your résumé or background search).
Other "personal info" as defined under California law (like your Social Security number or financial account information).
Inferences drawn from any of these categories. Some of these categories are also described as 'sensitive personal information' under California Law, and Bungie's use of that sensitive personal information is included below under 'How We Use Sensitive Personal Data'.

2. How Bungie Uses Your Information

When you applied for the role, you provided consent to Bungie processing your info for the purposes of recruitment. We use that information to:

Process your application (put your info in our system so the right people see it).
Communicate with you (schedule interview times and dates and keep you updated on the status of your application).
Assess your skills, qualifications, and suitability for the role (and for potential future openings at Bungie you may have not considered).
Measure and improve our recruiting process (including analyzing hiring trends and enhancing diversity efforts).
Potentially enter and perform a contract with you.
Verify the info you give us (including background and reference checks).
In some cases, help you coordinate immigration, work permit, relocation, travel, or other similar arrangements.

In some cases, we may need to process info from candidates to defend against legal claims and/or to comply with legal obligations. Security video footage is used for our legitimate interest in security at Bungie headquarters. We will also use info as we believe necessary or appropriate under applicable law to protect the rights and property of Bungie, players, other candidates, our employees, and the general public.

If you are accepted for a role, the info collected during the recruitment process will form part of your personnel record and will be processed in accordance with our employee privacy policies.

If you aren't hired for a particular role, we may keep your application to allow us to consider you for other suitable openings within Bungie in the future. We will always delete your CV, résumé, and cover letter in line with local retention requirements.

Unless otherwise specified under this Notice or during the application process, personal data that we request from you is necessary for the purposes of processing your application. If you don't provide certain info when requested, we may not be able to review your application and/or offer you a position.

How We Use Sensitive Personal Data

We will use your sensitive personal data in the following ways:

We'll use information about your disability status to consider whether we need to provide appropriate accommodations during the recruitment process, for example whether accommodations need to be made during a test or interview.
We'll use information about your race or national or ethnic origin, or your sexual life or sexual orientation (should you provide those details to us), to ensure meaningful equal opportunity monitoring and reporting as part of our commitment to equality of opportunity and treatment within the workplace.
When considering a candidate for specific roles that involve access to confidential or other sensitive info, where there are specific professional obligations and/or where a candidate will have contact with children or vulnerable adults, where permitted by law or with your consent, we'll use info about criminal convictions and offenses to carry out our obligations and exercise specific rights in relation to employment. In addition, where we process other sensitive info concerning criminal convictions, it is where it is necessary to carry out obligations and rights in relation to employment or for the establishment, exercise, or defense of legal claims.

3. How Bungie Keeps Information

To the extent required or permitted by applicable law, we generally retain candidate info for as long as is necessary for our standard recruiting efforts and operations. These practices can include resolving disputes, conducting audits, establishing legal defenses, pursuing our legitimate business purposes, and complying with applicable law. After this period your info will be securely destroyed. If your application is successful, info collected as part of the recruitment process will be transferred to your personnel file.

In some circumstances we may anonymize or de-identify your info so that it no longer directly identifies you individually, in which case we may use such info without further notice to you. Bungie will retain and securely destroy your personal info in accordance with this Notice, and applicable laws and regulations.

4. How Bungie Shares Information

If we permit a third party to access personal info, we will use appropriate measures to make sure the info is used in compliance with this Notice. We will also make sure the security and confidentiality of the info is maintained.

Bungie is a global company. For the purposes of recruitment, your info may be shared within the Bungie family of companies. This means your info could be sent to or stored in the US or other locations outside of the European Economic Area (the "EEA"), UK, and/or your country of residence. Specifically, your info is likely to be shared with Bungie entities in the US. Your info will only be disclosed to necessary members of Bungie's People team, relevant team managers, and people involved in the recruitment process to make recruiting decisions.

We use service providers to support Bungie's recruitment efforts. Such service providers might be outside your country of residence or the country where the position is located. These providers provide some of the services discussed in this Candidate Privacy Notice on Bungie's behalf, including:

Recruitment or executive search agencies involved in your recruitment.
Background checking or other screening providers and relevant local criminal records-checking agencies.
Data storage, shared services and recruitment platform providers, IT developers and support providers and providers of hosting services in relation to our careers website. and
Third parties who provide support and advice including in relation to legal, financial/audit, management consultancy, insurance, health and safety, security and intel and whistleblowing/reporting issues.
Application processing, such as in connection with a relocation, to coordinate travel, or to help you with immigration or other matters related to your application.

Additionally, we use and share info to comply with our legal obligations and as we believe is necessary or appropriate under applicable law to protect the rights and property of Bungie, players, other candidates, our employees, or the public, or in connection with the sale, assignment or other transfer of all or part of our business. This means we may share info (i) to comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) to protect your, our or others' rights, property, or safety; (iii) to enforce our policies and contracts; (iv) to collect amounts owed to us; or (v) when disclosure is necessary or appropriate to prevent financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity. As permitted by law and/or contract, we may also share info in the event of a possible merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale or restructuring of our business, or transition of service to another entity.

Sometimes, the sharing outlined above may mean your personal info must be transferred internationally, including from the European Economic Area ("EEA") to a country outside the EEA. When your personal data is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of that foreign jurisdiction, including any law permitting or requiring disclosure of the info to the government, government agencies, courts, and law enforcement in that jurisdiction. However, we have taken appropriate safeguards to require that your personal info will remain protected in accordance with this Notice. These include implementing the European Commission's Standard Contractual Clauses approved by the EU Commission or Information Commissioner's Office ("ICO") for that purpose. If you are in the EEA or UK and would like to know more about the safeguards we put in place when transferring your personal data outside the EEA or the UK, please contact us at privacyrequests@bungie.com.

5. Data Security

We use appropriate security measures to help protect your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. For example, we use computer systems with limited access in controlled facilities to store information. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need-to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have procedures in place to deal with any suspected security breach and will notify you and any applicable regulator of a suspected security breach where we are legally required to do so. However, please note that no server, communications network, or data transmission over the Internet is 100% secure. Our services are no exception, and we cannot fully guarantee the security of any info transmitted to us.

6. Cookies and Tracking Technologies

Bungie's recruiting site uses cookies and similar technologies that are required to enable the core features of the site to function. These cookies help you navigate between pages, route you to the correct site, and remember the information you've provided as you progress through your application. Bungie's recruiting application software tracks events from logged in users, even if the user has a Do Not Track signal present: this is required for the recruiting software to work correctly. We do not track logged out users. We collect and use your info in accordance with your legal rights, such as described in this Notice or otherwise requested or approved by you.

7. Your Rights

We will typically only retain your info as long as is necessary or appropriate for our recruiting efforts and operating our business (including for purposes like complying with our legal obligations, managing internal books and records, preventing fraud, resolving disputes, and enforcing our contracts and terms), unless a longer retention period is permitted or required by law.

You may exercise the rights available to you under applicable data protection laws including if you wish to access, correct, update or request deletion of your personal info by contacting us using the contact details provided below. Depending on where you reside, you may have the right to:

Request access to your personal data (commonly known as a "data subject access request"), or to know more about the categories and specific pieces of info we collect, use, and disclose.
Request correction of the personal data that we hold about you. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your application process.
Request the erasure/deletion of your personal data, where there is no good reason for us continuing to process it.
Request us to stop processing personal data where we are relying on a legitimate interest and there is something about your situation which makes you want to object to processing on this ground. Alternatively, in the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
Request the restriction of processing of your personal data. This may include restricting the processing of certain info, or restricting processing for certain purposes (for example, the right to opt out of sale of personal data, if any).
Request to transfer your personal data to another party.

You also have the right to not be discriminated against for exercising any of these rights. If, for some reason, we cannot accommodate your request, we will let you know why.

You may request further information or make these requests by contacting us as described in "Who to Contact" below. We may ask you for additional information to help us verify who you are before completing your request. We will not discriminate against you for exercising any of your rights.

8. Automated Decision Making

You will not be subject to decisions that will have a legal or similarly significant impact upon you based solely on automated decision making. Bungie does not auto-reject any candidates unless the position has already been filled.

9. Legal Basis

Under European data protection law, our legal basis for processing your personal info as part of the recruitment process is:

Our legitimate interests (as outlined in How We Use Information).
To comply with applicable immigration and/or employment laws and regulations.
To take steps prior to entering an employment contract with you, if you are considered for employment.
In circumstances where you have made the data public.
Where we have your consent to do so. Where we have requested your consent to process your personal data, you have the right to withdraw your consent at any time and
To protect the rights and interests of Bungie, our employees, applicants, and others, as required and permitted by applicable law.

10. Updates to this Notice

We may update this Notice from time to time as necessary. Updates may reflect changes in technology, law, our business operations, or any other reason we determine necessary or appropriate. When we do make changes, we will change the "last modified" date above. We encourage you to check back every so often for the most recent version of the Notice. If there are any material changes to this Notice, we will notify you as required by applicable law.

11. Who to Contact

If you have any questions about this Notice, you (or your authorized agent) may email us at privacyrequests@bungie.com. If you are in the EEA or UK, you can also contact our Data Protection Officer at dpo@bungie.com.

You may also raise complaints with a supervisory authority in your jurisdiction. The name and contact details of the Data Protection Authorities in the European Union can be found at: https://edpb.europa.eu/about-edpb/about-edpb/members_en. In the UK, the ICO is the relevant supervisory authority, and their contact details can be found at https://ico.org.uk.

Last Modified: October 17, 2022