Applicant Privacy Notice

Effective Date: December 14, 2020

 

This Applicant Privacy Notice (“Notice”) applies to The Pokémon Company International, Inc., 10400 NE 4th Street, Suite 2800, Bellevue, WA 98004, USA (“TPCi”), and our subsidiaries and affiliated companies acting on our behalf (collectively “Pokémon” or “we,” “us,” or “our”), and describes how Pokémon collects, processes, and discloses personal data from you through the Pokémon Careers website (“Site”) and/or through other means during your application process or while attending one of our recruiting events.

This Notice does not cover use of personal data collected about you as a consumer through the Pokémon network of websites (for example, Pokemon.com and PokemonCenter.com), as well as apps, features, services, events, and communications provided by Pokémon (“Services”). To learn more about Pokémon’s data collection practic​es that cover your use of Pokémon Services as a consumer, please read our Privacy Notice.

This Notice does not form part of any offer of employment or any contract of employment, and does not provide any contractual right on you or place a contractual obligation on Pokémon.

 

Collection of Personal Data

For purposes of this Notice, personal data means any information about an identifiable individual collected in connection with the recruitment process and the Site. Pokémon may collect personal data directly from you, as you apply for a job opening, or may receive personal data from third parties—for example, in connection with a background, employment, or reference check—subject to your consent where required by law. Personal data excludes anonymous or de-identified data that is not associated with a particular individual. We may collect, store, and process the following categories of personal data, some of which we require in connection with our recruiting activities:

  • Contact Details and Identifiers: such as name, title, addresses, telephone numbers, and personal email addresses.
  • Facial Images and Video Recordings: such as photos, security video recordings
  • Demographic Data: may include date of birth, gender, marital status, spouse and dependents, and certain sensitive data categories as described in the “Collection and Use of Special Categories of Personal Data” section below.
  • Professional and Background: such as your work history, certifications, language capabilities, credit and criminal history background checks, and other relevant experience, qualifications, and recommendations, including information contained in a resume, CV, cover letter, or job application.
  • Work Eligibility Status: such as immigration, residency, official government documents, and related information.
  • Benefits Information: such as information for determining benefits and cost estimation (which may require personal data similar to that in “Demographic Data” above).
  • Social Media: such as public profiles, posts, likes, and replies.
  • Information related to previous applications to Pokémon or previous employment history with us.
  • Other Information: such information as is necessary for a legitimate human resources, business, security, or safety-related purpose.
  • Inferences: Inferences drawn from information in other categories

Failure to provide or allow us to process some of the personal data may affect our ability to accomplish the purposes stated in this Notice.

We utilize a third-party applicant tracking system that collects your information when you visit their site to submit your application to us, using web beacons, cookies, system logs, and other technologies on their sites and related services. For more information, please see their privacy policy ().

Sources of Personal Data

Pokémon may collect personal data from a variety of third-party sources, including as follows:

  • Service providers (e.g., hiring, recruiting service providers, aptitude testing, and applicant tracking systems)
  • Insurance and benefits providers
  • Background check services
  • Online sources including social networks (e.g., LinkedIn, Facebook, twitter, etc.)
  • Open government databases and other public sources

 

Use of Personal Data and the Legal Bases

We process your personal data only where applicable law permits or requires it in connection with carrying out our application, recruitment, and hiring process, including for human resource purposes; and for purposes related to operations and business, security, and safety; and to take steps necessary to enter into an employment contract with you. We may process your personal data for the following legitimate business purposes under the legal basis to do so.

Entering Into a Contract with You:

  • Contact Details and Identifiers; Professional and Background; Benefits Information; Previous Applications; Demographic Data Categories; Inferences used for identifying and evaluating job applicants, including assessing skills, qualifications, and interests for the purposes of determining suitability for the job position you have applied for or other job positions you may be considered for.
  • Contact Details and Identifiers; Professional and Background; Benefits Information; Previous Applications Categories; Inferences used for verifying your information and carrying out employment, background, and reference checks, where applicable, subject to your consent where required by applicable law.
  • Contact Details and Identifiers Categories used for communicating with you about the recruitment process and your application.
  • Contact Details and Identifiers; Other Information Categories use for reimbursement of costs made by you for which you are eligible to receive reimbursement.
  • Contact Details and Identifiers; Demographic Data; Work Eligibility Status Categories used for assisting you with obtaining an immigration visa or work permit where required.

Legitimate Interests:

  • Contact Details and Identifiers; Professional and Background; Benefits Information; Previous Applications; Demographic Data Categories; Inferences used for as permitted by applicable law, verifying your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job position.
  • Contact Details and Identifiers Categories used for to send you job opening alerts informing you of other potential career opportunities at Pokémon, newsletters, and information regarding upcoming events that we believe will be of interest to you. As part of these communications, we will include an unsubscribe link that you can use if you don’t want us to send messages in the future.
  • Contact Details and Identifiers; Social Media Categories used for to register you for Pokémon recruitment events (if applicable).
  • Professional and Background; Benefits Information; Previous Applications Categories; Inferences used for keeping records related to our hiring processes, for only as long as appropriate under the circumstances.
  • Other Information Categories used for creating and submitting reports as required by applicable laws or regulations.
  • Demographic Data Categories; Other Information Categories; Inferences used for analyzing and improving our application and recruitment process.
  • Contact Details and Identifiers Categories; Professional Background; Facial Images and Video Recordings; Other Information Categories; Inferences used for to prevent fraud.
  • Other Information Categories; Inferences used for to ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.
  • Contact Details and Identifiers; Facial Images and Video Recordings Categories; Inferences to manage monitor, protect and improve office space, facilities, catering, including monitoring and administering building occupancy, physical security systems such as CCTV, guest logs; exit and entry times and emergency services notification.

Compliance with Legal Obligations:

  • Professional and Background; Demographic Data; Facial Images and Video Recordings; Benefits Information Categories; Inferences used to comply with our legal, regulatory, or other corporate governance requirements.

We will process your personal data only for the purposes we collected it for, or for compatible purposes. If we need to process your personal data for an incompatible purpose, we will provide notice to you and, if required by law, seek your consent. We may process your personal data without your knowledge or consent only where required by applicable law or regulation.

You will not be subject to hiring decisions based solely on automated data processing without your prior consent.

 

Collection and Use of Special Categories of Personal Data

The following special categories of personal data may be considered sensitive under the laws of your jurisdiction and may receive special protection: racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data; data concerning health; data concerning sex life or sexual orientation; and data relating to criminal convictions or offenses.

We may collect and process the following special categories of personal data when you voluntarily provide them, or when we receive them from a third party with your consent, when relevant for a particular job position to carry out our obligations under employment law, or as applicable law otherwise permits:

  • Physical or mental health condition or disability status to determine appropriate accommodations and evaluate fitness for a particular job position.
  • Race or ethnic origin to comply with statutory obligations.
  • Previous criminal charges or convictions where relevant for the job position.

Where we have a legitimate need to process special categories of personal data about you for purposes not identified above, we will do so only after providing you with notice and, if required by law, obtaining your prior, express consent.

 

Sharing of Personal Data

We will disclose your personal data to third parties only as described in this Notice or where required by law, or to our employees, subsidiaries, affiliated companies, contractors, designated agents, or third-party service providers who require such information to assist us with administering our application, recruitment, and hiring process, including third-party service providers who provide services to us or on our behalf. We may use third-party service providers for various purposes, including but not limited to: obtaining employment verification and background checks, assisting with travel arrangements, reimbursement of interview expenses, and data storage or hosting. These third-party service providers may be located outside of the country in which you live or the country where the job position you have applied for is located.

We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal data, consistent with our policies and any data security obligations applicable to us. We do not sell your personal data. We do not permit our third-party service providers to process your personal data for their own purposes. We permit them to process your personal data only for specified purposes in accordance with our instructions.

We may also disclose your personal data for the following additional purposes where permitted or required by applicable law:

  • Compelled Disclosures: TPCi may be required to release personal information in response to a legal obligation or legal process. Such obligations may include lawful requests by public authorities, including to meet national security and law enforcement requirements. When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we disclose only the minimum personal data necessary for the specific purpose and circumstances to comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders.
  • We will also access, transfer, disclose, and preserve personal data when we believe that doing so is necessary to:
  • operate and maintain the security of our computer systems and networks, including to prevent or stop an attack on our computer systems or networks;
  • protect the rights and property of Pokémon; and
  • act in urgent or emergency circumstances such as protecting the health or safety of a candidate, employee, agent, customer, or member of the public.
  • Where the personal data is publicly available.
  • Analytical Purposes: in aggregate form and/or a form that does not identify an individual; for example, demographic profiling or industry analysis.
  • If a business transfer, corporate transaction, change in ownership, or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or transfer, divestiture, or sale of business or assets occurs and the disclosure is a part of the transaction.
  • For additional purposes with your consent, where such consent is required by law.

 

Cross-Border Data Transfers

Personal data as described in this Notice may include overseas transfers of personal data to countries whose data protection laws are not as comprehensive as those of the countries that are part of the European Economic Area (EEA) or the United Kingdom (UK).

TPCi will only transfer your personal information outside of the EEA, UK, and Switzerland by using a variety of legal mechanisms, including contracts and standard contractual clauses / model clauses, so that your rights and protections travel with your data. The standard contractual clauses approved by the EU Commission are available at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.

We also participate in the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework. Although the EU-U.S. Privacy Shield has been ruled invalid as a legal basis for data transfers to the U.S., we continue to comply with the Privacy Shield Principles with respect to all HR related personal information transferred from the EEA, UK, and/or Switzerland to the United States in reliance on the Privacy Shield. If there is any conflict between the terms in this Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. If third-party agents process personal data on our behalf in a manner inconsistent with the Privacy Shield Principles, we remain liable unless we prove we are not responsible for the event giving rise to any damages.

EEA, UK, or Swiss individuals with inquiries or complaints regarding our adherence to Privacy Shield Principles should first contact TPCi using the contact details at the end of this Notice. For any complaints that cannot be resolved with us directly, you may refer the matter to the EU Data Protection Authorities (DPAs), and the Swiss Federal Data Protection and Information Commissioner (FDPIC). If your complaint under the Privacy Shield Principles is still not resolved, in limited situations, a binding arbitration option may be available.

 

Data Security

We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal data to those employees, agents, contractors, and other third parties who have a legitimate business need for such access.

 

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will retain your personal data only as long as necessary to fulfill the purposes we collected it for (between 1 and 3 years depending on jurisdiction), as required to satisfy any legal, accounting, or reporting requirements, or as necessary to resolve disputes. Please contact us using the details below if you require further information.   

We have the right to delete application information at any time, and you may want to retain copies of any information, including resumes/CVs that you provide to us during the application process.

Under some circumstances, we may anonymize your personal data so it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

If you are offered and accept employment: The personal data we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our employee personal data policies.

If you are not offered employment and do not become an employee: The personal data collected during the application and/or recruitment process will be retained in order to consider you for other jobs. Additionally, Pokémon may refer back to personal data collected earlier in the event you submit a new application in the future. Pokémon will retain your personal data as documented in our corporate data retention schedule unless otherwise required by law.

 

For United Kingdom (UK), European Economic Area (EEA), or Switzerland Applicants - Your Choices and Rights

If you are a UK, EEA or Swiss data subject, you have the following rights:

  • A right to be informed of the ways in which we use your information.
  • A right to request from Pokémon access to personal data, including (i) the categories and specific pieces of information we have collected about you, (ii) the categories of sources collected, (iii) the purpose for collecting or using the information, and (iv) the third parties with whom we share your personal information; and rectification or deletion/erasure of personal information under certain circumstances and subject to a number of exceptions; and certain rights to data portability.
  • A right to object to the processing of your personal data or to obtain a restriction of such processing under certain circumstances.
  • A right to have your personal data transferred to another organization should it be technically feasible for Pokémon to do so.
  • If the processing of personal data is based on your consent, a right to withdraw consent at any time (without affecting the lawfulness of processing before its withdrawal).
  • A right to bring your complaint to a regulator. If you are based in the EEA and believe that we have not complied with data protection laws, you can complain to our regulator, the UK Information Commissioner’s Office, or your local supervisory authority; however, regardless of where you are based, we would appreciate it if you would give Pokémon the chance to deal with your concerns directly by contacting us.

There may be exceptions to these rights in certain circumstances, and where you cannot exercise a right due to an exception, we will provide that explanation. To make any of the requests in this section, please contact Pokémon using the information in the “Contact Us” section below.

If you submit a request, we will require you to verify your identity either by making the request through an existing account and/or by providing a form of governmental identification, where, if feasible, we may match your identification information with personal data we have about you, depending on the type of request made and verification measures proportional to the risk of the personal data involved with the request(s). There is no reasonable method by which we can verify your identity to the degree of certainty required by law for certain pieces of personal data, for example: unique identifiers such as cookie IDs, device ID, and IP address (where that information is not held by us in connection with directly identifiable information). Pokémon will use reasonable efforts to fulfill your request within the response times of the applicable laws.

Additional Disclosures for California Applicants

These disclosures describe the categories of personal data that Pokémon collects about you, and the purposes for collecting that data.

Pokémon collects the following categories of personal data in relation to your consideration for employment with Pokémon:

  • Identifiers
  • Financial, medical, or health insurance information
  • Demographics
  • Commercial information
  • Professional or employment-related information
  • Internet or other electronic network activity information
  • Geolocation information
  • Audio, visual, or other similar information
  • Inferences drawn from information in other categories

For more detail about the types of personal data we collect and the purposes for which we use your data, please refer to the “Collection of Personal Data,” “Use of Personal Data and the Legal Bases,” and “Collection and Use of Special Categories of Personal Data” sections of this Notice.

Pokémon does not sell your personal information as defined by the California Consumer Privacy Act and has not done so in the past 12 months.

 

Changes to This Notice

We reserve the right to update this Notice at any time. If you want to see changes made to this Notice from time to time, we invite you to access this Notice to see the changes. If we make material changes or changes that will have an impact on you (e.g., when we start processing your personal data for purposes other than set out above), we will contact you prior to commencing that processing.

 

Contact Us

‌If you have questions or comments about our data practices or this Notice, you can contact us or our data protection officer at:

The Pokémon Company International, Inc.
Attn.: Data Protection Officer—Job Applicant Privacy Notice

10400 NE 4th Street
Suite 2800 
Bellevue, WA 98004
USA

3rd Floor Building 10, Chiswick Park 
566 Chiswick High Road
London, W4 5XS
United Kingdom

HRPrivacyPolicy@pokemon.com, with “Job Applicant Privacy Notice in the subject line


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