Job Applicant Privacy Notice

Company: FindPlay, Inc.
EIN: 36-5170181
Effective Date: 27 March 2026
Governing Law: Delaware, United States (primary); Australian Privacy Act 1988 (Cth); EU/UK GDPR; and applicable laws in all jurisdictions in which FindPlay operates, including the United States, Australia, the European Union, the United Kingdom, and Asia-Pacific markets.

Version: v1.0

This notice describes how FindPlay, Inc. collects, uses, stores, and manages personal data provided by job applicants during the recruitment process. It applies to all applicants for employment, contract, or internship positions with FindPlay globally, regardless of the jurisdiction in which the role is located.

1. Who This Notice Applies To

This notice applies to:

Applicants for full-time, part-time, or casual employment with FindPlay, Inc.
Applicants for contractor or freelance engagements with FindPlay.
Interns and work experience applicants.
Candidates referred by recruitment agencies acting on FindPlay's behalf.
Speculative applicants who submit an expression of interest.

2. What Personal Data We Collect

FindPlay may collect the following categories of personal data from job applicants:

Identification data: Name, address, date of birth, nationality, and government-issued ID (where required for employment eligibility verification).
Contact data: Email address, telephone number, and postal address.
Professional data: CV/résumé, work history, qualifications, certifications, professional memberships, portfolio, and references.
Application data: Cover letter, responses to application questions, interview notes, and assessment results.
Right to work data: Visa status, work authorisation documentation, and citizenship information (where required by law in the relevant jurisdiction).
Background check data: Criminal record checks, professional licence verifications, and working with children checks (where the role requires these, and subject to applicable law).
Diversity and inclusion data: Where voluntarily provided and permitted by applicable law, demographic information for the purposes of equal opportunity monitoring. This data is anonymised before use in reporting.

FindPlay does not collect sensitive personal data (including health information, religious beliefs, or political opinions) in the recruitment process unless it is directly relevant to the role and permitted by applicable law.

3. How We Use Applicant Data

FindPlay uses job applicant data for the following purposes:

Assessing the applicant's suitability for the role.
Communicating with the applicant during the recruitment process.
Conducting background and reference checks where required for the role.
Complying with applicable employment law, immigration law, and right-to-work verification requirements.
Improving FindPlay's recruitment processes (using anonymised or aggregated data only).
Maintaining records required by applicable law.

FindPlay does not use applicant data for marketing, profiling, or any purpose unrelated to recruitment.

4. Legal Basis for Processing

The legal basis for processing job applicant data varies by jurisdiction:

Jurisdiction	Legal Basis
EU / UK	Processing is necessary for the performance of steps prior to entering into a contract (GDPR Article 6(1)(b)); compliance with legal obligations (Article 6(1)(c)); and FindPlay's legitimate interest in assessing candidates (Article 6(1)(f)).
Australia	Collection and use is authorised under the Privacy Act 1988 (Cth), APP 3 (collection for a purpose directly related to FindPlay's functions and activities) and APP 6 (use for the primary purpose of collection).
United States	Processing is governed by applicable federal and state employment law, including the FCRA (for background checks), the ADA (for disability-related information), and applicable state privacy law.
Singapore	Processing is in accordance with the PDPA, subject to the employment-related exception under the Second Schedule of the PDPA.
Japan	Processing is in accordance with the APPI, with collection limited to the purpose of assessing candidacy.

FindPlay may share applicant data with:

FindPlay's internal hiring team and relevant managers involved in the recruitment process.
Third-party recruitment agencies acting on FindPlay's behalf, subject to confidentiality obligations.
Background screening providers (where a background check is required for the role), subject to applicable consent and legal requirements.
Reference providers nominated by the applicant.
Professional licence verification bodies as required.
Government authorities where required by applicable immigration or employment law.

FindPlay does not sell or share applicant data with third parties for marketing purposes.

6. Retention

FindPlay retains job applicant data for the following periods:

Outcome	Retention Period
Unsuccessful applicant	12 months from the date the application is closed, unless a longer period is required by applicable law or unless the applicant consents to being retained in a talent pool.
Successful applicant	Data is transferred to the employee record and retained in accordance with applicable employment law in the relevant jurisdiction (typically 7 years post-employment).
Speculative applicant (no open role)	6 months from receipt, after which the applicant will be contacted to confirm whether they wish to remain in the talent pool.

Regional Retention Requirements

Australia: Records must be retained in accordance with the Privacy Act 1988 (Cth) and Fair Work Act 2009 (Cth). Employee records are exempt from the APPs during employment but privacy obligations resume post-employment.
EU/UK: Retention must comply with GDPR storage limitation principle (Article 5(1)(e)). Applicants have the right to erasure under Article 17 following the retention period.
USA: Background check records must be retained for a minimum of 5 years under FCRA. EEO-1 records must be retained for 1 year. State-specific requirements vary.
Singapore: Retention governed by PDPA; personal data should not be retained longer than necessary for the purpose of collection.
Japan: Retention governed by APPI; data should be deleted when the purpose of collection is achieved.

7. Applicant Rights

Applicants have the following rights in relation to their personal data, subject to applicable law in their jurisdiction:

Right	Jurisdictions
Right of access	All jurisdictions
Right to correction / rectification	All jurisdictions
Right to erasure / deletion	EU/UK (GDPR Article 17); Australia (APP 13); USA (CCPA); Singapore (PDPA); Japan (APPI)
Right to data portability	EU/UK (GDPR Article 20)
Right to restriction of processing	EU/UK (GDPR Article 18)
Right to object	EU/UK (GDPR Article 21)
Right to opt-out of sale of personal information	USA (CCPA/CPRA)

To exercise any of these rights, contact privacy@findplay.com. FindPlay will respond within the timeframe required by applicable law (typically 30 days, or 45 days with extension under CCPA).

8. Automated Decision-Making

FindPlay does not use automated decision-making or profiling to make final recruitment decisions. Technology tools may be used to assist with initial screening (e.g., applicant tracking systems), but all final hiring decisions involve human review.

EU/UK applicants have the right under GDPR Article 22 not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects. FindPlay does not make such decisions in its recruitment process.

9. Contact

For questions about this notice or to exercise your rights, contact:

Privacy team: privacy@findplay.com
Legal team: legal@findplay.com