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Rovio Entertainment Corporation

Recruitment Privacy Notice

What is the purpose of this document

This privacy notice describes how we collect and use personal data about you for recruiting related purposes, in accordance with the General Data Protection Regulation (GDPR) and in accordance with local privacy laws.

In this notice “Rovio” means the specific Rovio company, its affiliates, and contracted service providers who will collect, use, and maintain your personal data in connection with your application for recruiting process.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information.

Data Controller

Data controller is responsible for deciding how we hold and use personal data about you. This means that we are required under data protection legislation to notify you of the information contained in this privacy notice.

Rovio acts as data controller of the personal data you submit via the on-line recruitment system or otherwise for recruitment purposes.

Depending on the recruiting Rovio company the Data Controller is:
  • Rovio Entertainment Corporation, Keilaranta 7, 02150 Espoo, Finland;
  • Rovio Sweden AB, Rosenlundsgatan 29 D, 118 63 Stockholm, Sweden; or
  • Rovio UK Ltd, 10 John Street, London WC1N 2EB, UK.
  • Blue Bird Distribution, Inc.14724 Ventura Boulevard Suite 350, Sherman Oaks, California 91403, USA.
  • Rovio (Shanghai) Commerce and Trading Co., Ltd, Room 3108 Lippo Plaza, No. 222 Middle Huaihai Road, Shanghai 2000021, People’s Republic of China.
Data Processor

Rovio has engaged Jobylon AB, a Swedish company, to act as Rovio’s data processor for purposes of operating on-line application system for recruitment purposes.

Jobylon AB, c/o The Park, Hälsingegatan 49, Stockholm, Sweden, email [email protected]

Rovio Entertainment Corporation acts as data processor for its affiliates when these companies are the recruiting entities.

Data protection principles

We will comply with data protection law. This says that the personal data we hold about you must be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.
How data is collected for recruitment purposes

Generally open positions are made available and may be applied via Applicant Tracking System (referred below also as on-line recruitment system) that Rovio uses.

As discussed above we collect applications and personal data through our on-line recruitment system. We envisage that in certain limited key roles we may engage third party recruitment agencies to seek for candidates or seek for candidates by ourselves. In case we get a referral this policy will apply.

This policy will apply in such circumstances, but on-line recruitment system may not be applied by us.

In case we receive applications through other means we may ask to submit the information to the said system and will delete the applications submitted by other means.

What data is collected for recruitment purposes

We collect personal data that you submit to us, via online application system or otherwise, and we use it for recruiting-related purposes. We may collect data for recruitment purposes via LinkedIn or other such services where you have posted your public professional profile.

Personal data we collect is discussed below in section “What personal data will Rovio collect”.

Who is collecting your personal data?

Rovio as potential employer will collect and use personal data. Potential employer may be Rovio Entertainment Corporation and other Rovio companies, such Rovio Sweden AB, Rovio UK Ltd., Blue Bird Distribution, Inc, and/or Rovio (Shanghai) Commerce and Trading Co.

Personal data is collected, used and retained during the recruitment process and for the purpose of considering your qualifications for employment, as required by law and/or as otherwise described below.

What personal data will Rovio collect?

Rovio will collect the following information for the purposes set out in this notice:

  • Personal data you submit via the online application system i.e.
  • First name, last name, email address
  • You may, but have no obligation, submit to us
  • Your phone number
  • LinkedIn profile link.
  • Data you submit via the online application system, or otherwise to Rovio, in your CV, cover letter and other documents you submit to us at your own discretion;
  • Such data may be combined, as applicable, with:
  • Data generated by interviewers and recruiters, based on their interactions with you;
  • Data provided by third-party placement firms, recruiters, or job-search websites, where applicable, in case you have given permission to share data with us;
  • Recommendations provided on your behalf by others, in case you have given permission to ask for recommendations;
  • personal data necessary to make an employment offer to you, which may include also relocation services:
  • For these purposes we may need to request your nationality, passport number, information of your family status and the same information of your dependants.
The data we collect and ask you to submit are needed to evaluate your eligibility to a position in Rovio.

Where required, your submission of personal data constitutes your consent to our use of your data and your verification that it is accurate.

You are not required to provide any requested information to Rovio, but failing to do so may result in not being able to continue your candidacy for the job for which you have applied.

How we use particularly sensitive personal data "Special categories" of particularly sensitive personal data require higher levels of protection.

We foresee that we do not collect any sensitive information.

We may also collect, store and use the following "special categories" of more sensitive personal data i.e.:

  • Information about your health, including any medical condition, health and sickness records.
  • Information about criminal convictions and offences.
  • Information about your race or ethnicity or religious beliefs.
  • Trade union membership.
We need to have further justification for collecting, storing and using this type of personal data. We foresee that we do not collect any of the above mentioned special categories of data, unless you provide such information to us.

However, we may process special categories of personal data in the following circumstances:

  • In limited circumstances, with your explicit written consent.
  • Where we need to carry out our legal obligations and in line with our privacy policy.
  • Where it is needed in the public interest, such as for equal opportunities monitoring.
  • Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

We may only use information relating to criminal convictions where the law allows us to do so. In case we would need information about your criminal records for your employment or service with us we will ask you to provide us with your criminal record.

Correctness of information you have submitted

You acknowledge that all representations made by you are true and correct to the best of your knowledge and belief, and you have not knowingly omitted any related information of an adverse nature. Falsifying or withholding relevant information may make you ineligible for employment.

What will Rovio do with your personal data?

Rovio will use your personal data to:

● Assess your suitability for employment for the role for which you are applying;

● Perform administrative functions (e.g. reimburse you for interview-related expenses);

● In some cases, record your online interview for review by additional recruiters and hiring managers. In such cases, we will seek your express consent to be recorded;

● notify you about new positions that may be of interest to you, in case you are willing to be notified of positions with Rovio.

From what other sources may Rovio obtain personal data?

We obtain the data about candidates from the following sources:

● From you, when you submit resumes or other information via the online application tool or through other venues;

● From conversations with recruiters and interviews with Rovio’s hiring managers and other Rovio personnel or representatives. Some of the conversations may be recorded with your express knowledge and consent.

● From job search or professional networking websites (e.g. LinkedIn) where you may have incorporated such data to your application by yourself. You may decide if you wish to incorporate any profile information from job search or professional networking websites.

● Through our own referral program where Rovio employees may introduce potential candidate’s information to us.

● From third-party recruiters, staffing companies, or websites when you are introduced to Rovio through one.

● With your prior consent to do the following for recruitment purposes:

o We may conduct background checks, as applicable. Rovio may contract with a third party to perform a pre-employment background screening when allowed by applicable law.

o The content of background check information varies by country to comply with local requirements. These types of information will only be collected with your prior consent, and you will receive more information about the nature of such a background if such is considered necessary and always before it begins.

Who will have access to your personal data?

Access to your personal data will be restricted to minimize the number of people in Rovio

● Who need it in order evaluate your application for employment;

● Human Resources organization supporting recruiting; or

● to whom we are compelled to provide it by applicable law.

Subject to the above restrictions, the following categories of individuals may have access to your personal data:

● Rovio’s Human Resources professionals and / or recruiters engaged by Rovio, working with the country where the position you are applying for is based. Such individuals may be based in a different country;

● Hiring managers;

● Other interviewers relevant to assess your suitability to the position – such as people with whom the role in question is expected to work with.

o Hiring managers and other interviewers will be based in the country where the position is based, but in some cases they may be located in other countries;

● Individuals performing administrative support functions;

● Authorized personnel at our service providers, including:

o Data Processor Jobylon, which hosts and supports the on-line recruitment system;

o Companies contracted by Rovio to perform background screenings and recruitment services, such as Scede.io in UK. These companies may be based in another country, and may obtain data from other countries where you have lived, worked or studied, as may be relevant as part of a background check. You will receive more information about any such check before it begins, and will take place subject to your consent.

o Companies contracted by Rovio to perform relocation and moving services to you, such as Alfa Quality Moving Oy.

Where are your personal data located?

Your data is located at data processor’s systems and it’s service providers’ systems that reside in European Union. Data Processor utilizes Amazon Web Services Inc. and Heroku Inc., whose systems are located in Ireland.

Rovio may utilize third party service providers such as Google Inc, subject to Google Inc.’s data processing policies and security mechanism. Data with Google is located in Google’s data centers and we seek to keep data in European data centers.

Rovio will, however, follow its internal global privacy policy in such cases and secure data accordingly.

There are circumstances not covered by this privacy notice where the use or disclosure of personal data may be justified or permitted, or where we may be obligated by applicable laws to disclose information without acquiring your consent.

How long will Rovio retain my personal data?

If we choose to employ you your personal data will be processed in accordance with our employee privacy notice.

If Rovio does not employ you, we retain the application for a period 12 months from the date your application is filed to our on-line system whereafter your application is automatically deleted from the system.

We may also perform research and analysis on type of people applying to Rovio. In these situations we see to anonymization of data. If you do not wish us to retain your data (i.e. you wish to erase your data), please mention about it explicitly by contacting [email protected] Do we need your consent?

We do not need your consent if we use special categories of your personal data in accordance with our written notice to carry out our legal obligations or exercise specific rights in the field of employment law i.e. we need your consent on limited occasions when we do not have legitimate interest or use of data is not based on your application for open positions with you as above discussed.

In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us. With your consent we retain the data collected during the recruitment process in order to consider you for new positions.

How Rovio protects your personal data?

Rovio employs organizational, technical, and physical security measures in order to protect your data from loss or misuse. Where we contract with third-party suppliers to provide services that may enable them to access your personal data we require them by contract to have similar security controls in place.

Which third-party service providers process my personal data?

"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. The third-party service providers listed in Annex A process personal data about you for the following purposes set out therein. How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

However certain third-party services, such as health care provider and insurance companies may act also as data controllers on their own legal basis for processing personal data.

When might you share my personal data with other entities in the group?

We will share your personal data with other entities in our group for purposes of your potential recruitment as discussed in this notice.

What about other third parties?

We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.

We will share your data with the data processors discussed above.

Transferring information outside the EU

We may transfer the personal data we collect about you to the following countries outside the EU i.e. USA and People’s Republic of China in order to process the recruitment activities with you and our companies in these countries.

Kindly note that transfer of data to USA is relevant only for candidates for roles with Blue Bird Distribution, Inc. and in case Rovio’s data processors are located in USA.

Kindly note that transfer of data to People’s Republic of China is relevant only for candidates for roles with Rovio (Shanghai) Commerce and Trading Co., Ltd.

There is not an adequacy decision by the European Commission in respect of those countries. This means that the countries to which we transfer your data are not deemed to provide an adequate level of protection for your personal data.

However, to ensure that your personal data does receive an adequate level of protection we have put in place the following appropriate measure[s] to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the national laws on data protection: EU Standard Contractual Clauses or acting under EU-U.S. Privacy Shield. If you require further information about these protective measures, you can request it from [email protected] Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal data on our instructions and where they have agreed to treat the information confidentially and to keep it secure. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 as above explained. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Your rights in connection with personal data Under certain circumstances, by law you have the right to:

● Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

● Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected

● Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).

● Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.

● Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

● Request the transfer of your personal data to another party.

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact [email protected]

You may also request us to cease our processing and have the right to lodge a complaint with a supervisory authority as where such rights are provided to you by applicable laws. Note that we may be limited by our mandatory legal obligations and the purposes of processing from fully accommodating with such requests.

No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Automated decision making Your personal data and application is not subject to automated decision making.

Data protection manager We have not appointed Data Protection Officer to oversee compliance with this privacy notice. However, we oversee compliance with data protection requirements by a team consisting of HR professionals, legal counsel and IT manager. In case you have any questions you can contact [email protected] You have always the right to lodge your complaint with local national supervisory authority.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.

If you have any questions about this privacy notice, please contact [email protected]