Privacy Notice for California Residents

Effective Date: 2021.07.30

This Privacy Notice (“Notice”) for California residents provided pursuant to the California Consumer Privacy Act (“CCPA”) supplements the Privacy Policy of KRAFTON, Inc. and its affiliates (“KRAFTON”, “we”, ‘our’, or “us”) and provides additional information on how your personal information is collected, used, disclosed and processed online or offline. Unless otherwise specified, all terms used within this Notice shall carry the same meaning as they are defined in our Privacy Policy. This Notice and the Privacy Policy together constitutes KRAFTON’s “California Privacy Policy”.

1. Information We Collect

We will collect the following categories of information that may directly or indirectly identify or describe you or your device, or information that may be reasonably capable of being associated with or reasonably linked to you or your device (“personal information”). We have collected these same categories of personal information from consumers over the past 12 months. Please refer to our Privacy Policy concerning the categories of sources from which this personal information is collected.

– Identifiers such as IP address, name, date of birth, contact information (such as email address, postal address, phone numbers), your employment and education history, referrals or references, and any other information you provide(such as information included in your resume or cover letter);
– Internet or other similar network activity information such as website, application or advertisement browsing history, device model, OS version, device and information about the device that you accessed;
– Geolocation data such as country of residence;
– Professional or employment-related information such as work experience, etc.;
– Education information such as education background collected during the application process.

2. Purposes of Collection

The above personal information was or will be used for the following purposes. We will also notify you and obtain your consent if and when previously collected personal information is used for any purpose other than those listed below.

– To manage our Sites, including inquiries and requests received from you through the Sites (e.g. through a Speak Up session, to respond to a partnership inquiry, etc.);
– To assess potential job applicants and progress through the recruitment process;
– Conduct analyses and develop reports of engagements and market trends;
– Prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behavior, and criminal activity;
– Comply with and enforce legal requirements, agreements, and policies; and
– Achieve purposes for which we provide specific notice at the time of collection.

3. Personal Information Disclosed to Third Parties

We may provide third parties with certain personal information to provide or improve our site or apply our company. We disclosed or shared each of the following categories of personal information over the past 12 months to the following categories of third parties. We do not sell personal information to third parties under the CCPA. Categories of Personal Information Categories of Third-Parties to whom Personal Information Was Disclosed

Categories of Personal Information	Categories of Third-Parties to whom Personal Information Was Disclosed
Identifiers	– our affiliates – job application system providers
Professional or employment-related information
Geolocation data
Education information

4. California Privacy Rights

You may exercise the following rights at any point in time in connection with your personal information. To exercise such rights, please email us at privacy@krafton.com.

Please note that at least your email address will be required to submit a request. If you exercise your rights via email, you must specify the right(s) you wish to exercise.

We will verify your identity and respond to your request within 45 calendar days. If necessary, we can take up to an additional 45 days to respond, for a maximum total of 90 days from the day the request is received, provided that we notifies you to explain the reason for the delay.

Your Rights	Description
Right to Access	You have the right to request the following information up to two times within a 12-month period. – The categories of personal information that we have collected from you over the past 12 months, and the specific pieces of personal information we have collected from you – Categories of the sources from which personal information was collected – Business or commercial purposes for which personal information is collected – Categories of the personal information that was disclosed for a business purpose or sold during the past 12 months, and categories of third parties to whom the information was disclosed or sold.
Right to Request Deletion	You have the right to request that the personal information collected from you be deleted.
Right to Opt-Out of Personal Information Sales	You have the right to “opt out” by requesting that your personal information not be sold in any form. However, we do not sell personal information.
Right to Non-Discrimination	You have the right to not be discriminated against for exercising your privacy rights under the CCPA.
Rights for California Minors	Minors under the age of 18 have the right to request the deletion of and/or obtain information posted on websites such as forums or bulletin boards.
Shine the Light	You have the right to request the categories of the personal information that we disclosed to third parties in the last year for direct marketing purposes and information on the relevant third parties. Furthermore, you may also request that your personal information not be disclosed to third parties for direct marketing purposes.

5. Authorized Agent

You may designate another person or entity (“authorized agent”) to act on your behalf in connection with your request for rights that are guaranteed by the CCPA. An authorized agent is a natural person or business entity registered with the Secretary of State to conduct business in California that you have authorized to act of your behalf to make a request to know or to delete.

In order to use an authorized agent for your request, we require that you provide signed permission to your agent, using the form available at [LINK]. Your authorized agent can submit a request to know or delete by sending an email to privacy@krafton.com attaching the signed permission.

The above requirement does not apply should your agent have power of attorney pursuant to Probate Code sections 4000 to 4465. Please note that we may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. Under the CCPA, your agent is responsible for implementing and maintaining reasonable security procedures and practices to protect your information and use your personal information only for the purpose of fulfilling your request.