Issued on [Month] [Day], 2025
SNK Corporation (Head Office: 4-5-41 Miyahara, Yodogawa-ku, Osaka City; hereinafter referred to as "the Company") handles personal information concerning job applicants as a personal information handler as defined by the Act on the Protection of Personal Information (hereinafter referred to as the "Personal Information Protection Act"). The Company shall comply with the Personal Information Protection Act, other relevant laws and regulations, and the matters stipulated in this "Handling of Personal Information Concerning Job Applicants" (hereinafter referred to as "this Policy"), and shall endeavor to ensure the appropriate protection and use of job applicants' personal information.
The Company shall acquire personal information concerning job applicants by proper and lawful means within the scope necessary for its business operations. The acquired personal information shall be used only to the extent necessary to achieve the purposes of use described below in "Purposes of Use of Personal Information Concerning Job Applicants" and shall not be used for any other purposes.
During the recruitment process, the Company acquires information necessary for recruitment activities directly from job applicants themselves or indirectly through recruitment agencies and background screening companies. The personal information about job applicants acquired by the Company includes the following.
Photograph, name, date of birth, address, telephone number, email address, nationality, gender, educational background, work history, qualifications held, presence of awards/disciplinary actions, dependents (including relationship), desired annual income, and evaluations obtained from interviews, etc.
In addition to the items listed in the above <General Job Applicants>, we also collect: Possession of a Residence Card, Residence Status, Period of Stay
In addition to the items listed in the above <General Job Applicants>, current annual income
In addition to the items listed above under <General Job Applicants>, type and grade of disability, and disability certificate number
We use personal information concerning job applicants for the following purposes:
Our company may provide personal information regarding job applicants to Electronic Gaming Development Company and MiSK Foundation (collectively referred to as "our parent companies") located in Saudi Arabia in order to make optimal personnel placement and hiring decisions across the entire group. The overview of Saudi Arabia's personal information protection system is as follows, and our parent companies have implemented all measures corresponding to the OECD Privacy Guidelines' 8 Principles.
・Existence of a Personal Information Protection System
The following laws exist as comprehensive legislation:
◼ Personal Data Protection Law ("PDPL")
- URL:https://sdaia.gov.sa/en/SDAIA/about/Documents/Personal%20Data%20English%20V2-23April2023-%20Reviewed-.pdf
- Effective September 23, 2024.
- Applicable Entities: Public and private sectors (does not apply to processing of personal data for personal or family use)
- Covered Information: All information relating to a data subject (individual). This includes data relating to deceased persons if it leads to the identification of the deceased or their family.
◼ The Implementing Regulation of the Personal Data Protection Law.
(Protection Law)
- URL:
https://sdaia.gov.sa/en/SDAIA/about/Documents/ImplementingRegulation.pdf
- Effective Date: Effective September 4, 2024.
◼ Implementing Regulation for Personal Data Transfer Outside the Kingdom.
(Personal Data Transfer Outside the Kingdom.)
- URL:
https://sdaia.gov.sa/Documents/RegulationonPersonalDataEN.pdf
- Effective Date: Effective September 4, 2024.
・Information that may serve as an indicator regarding the personal information protection system
There is no information regarding the EU adequacy decision or the APEC CBPR system.
・The obligations of businesses and other entities, or the rights of individuals, corresponding to the following OECD Privacy Guidelines 8 Principles are stipulated in the above laws and regulations.
Principle of Collection Limitation, Principle of Data Content, Principle of Purpose Specification, Principle of Use Limitation, Principle of Security Safeguards, Principle of Disclosure, Principle of Individual Participation, and Principle of Accountability
・Other systems that may significantly impact the rights and interests of individuals
None under applicable laws and regulations.
Furthermore, the Company may provide personal information concerning job applicants to third parties without obtaining the consent of the job applicant ( ) or the applicant ( ) in the following cases:
When acquiring sensitive personal information (including but not limited to race, creed, social status, etc.) as defined in Article 2, Paragraph 3 of the Personal Information Protection Act ( ) from job applicants, the Company will obtain such information only after obtaining the applicant's consent (including when provided directly by the applicant) in accordance with laws and regulations. Furthermore, the Company will collect information regarding race, ethnicity, social status, family background, domicile of origin, place of birth, and other matters that may cause social discrimination, as well as information regarding ideology, beliefs, and labor union membership status, only when there is a special occupational necessity or it is otherwise indispensable for achieving the purpose of the business, and only when collecting such information from the job applicant themselves after disclosing the purpose of collection.
Our company implements the following security management measures to prevent the leakage, loss, or damage of personal information.
(1) Formulation of Basic Policy
To ensure the proper handling of personal information, we comply with relevant laws and regulations and have established a basic policy regarding our inquiry contact point.
(2) Organizational Security Measures
We have established internal regulations concerning the secure handling of personal information and have built a reporting and communication system and framework for cases where facts or signs of violations of laws or internal regulations are identified.
(3) Personnel Security Measures
We conduct regular training for employees on points to note regarding the handling of personal information.
(4) Physical Security Measures
We manage employee access to areas where personal information is handled and implement measures to prevent unauthorized individuals from viewing personal information.
(5) Technical Security Measures
We implement access controls to limit the scope of personnel and personal information databases handled. We also introduce mechanisms to protect information systems handling personal information from unauthorized external access or malicious software.
(6) Understanding the External Environment
We implement security measures after understanding the personal information protection systems in each country where personal information is stored.
To ensure the smooth and efficient operation of our business, we may entrust the handling of personal information concerning job applicants to contractors with whom we have concluded business outsourcing agreements. The scope of work entrusted to such contractors is limited to the purposes specified in the "Purpose of Use of Personal Information Concerning Job Applicants" section above. Furthermore, we will exercise necessary and appropriate supervision over such contractors.
Job applicants may request notification of the purpose of use, disclosure, correction/addition/deletion, suspension of use/erasure, cessation of provision to third parties, or disclosure of records of provision to third parties regarding their retained personal data by sending an email from the applicant themselves to the contact point below. Upon confirming the applicant's identity, we will respond appropriately and promptly in accordance with the Personal Information Protection Act and other applicable laws and regulations.
Please note that we cannot return submitted application documents or disclose information regarding evaluation results during the recruitment process. Personal information of unsuccessful applicants will be deleted (including erasure of the information and rendering it incapable of identifying specific individuals) by appropriate means after the completion of the relevant recruitment process.
We may revise this policy from time to time. The revised policy will be posted on our website.
Inquiries regarding personal information of job applicants should be directed to:
SNK Corporation, Human Resources Department, Recruitment Team
Email Address: recruit@snk-corp.cp.jp
*Please note that we cannot accept requests made by visiting our office in person.
We process the personal information of job applicants located within the EEA in accordance with the EU General Data Protection Regulation (hereinafter referred to as "GDPR"). This policy may be amended due to changes in legal regulations or internal processes. We use this data for specific purposes in accordance with the principles outlined below.
We process personal information in accordance with the GDPR as follows.
The legal basis for processing acquired personal information is as follows for each purpose of use.
We do not make decisions based solely on automated data processing that produce legal effects or similarly significant effects on job applicants.
Where the provision of personal data is required by law or contract, or is necessary for the conclusion of a contract, we will separately notify applicants whether they are obligated to provide such data and the consequences of not providing it.
We retain job applicants' personal information only for as long as necessary to achieve the purposes of use described above. The specific retention period is determined based on the purpose of use of the personal information, the nature of the personal information, and the legal or operational necessity for retaining the personal information.
Job applicants located within the EEA have the following rights:
You have the right to confirm whether we are using your personal information and, if so, to access that personal information. You may request a copy of your personal information and inquire with us whether we are using it, how and for what purposes we are using it, and whether we are transferring it outside the region.
You have the right to request that we change or correct any personal information we have collected and are using if it is inaccurate. However, this does not apply if it is impossible or would involve disproportionate effort.
You have the right to request the erasure of personal information held by us under certain conditions. Job applicants may inquire with us regarding these specific conditions. However, this may not apply if another legal basis for processing exists.
We will also communicate deletion requests to third parties with whom we share job applicant personal information. However, this does not apply if it is impossible or would require disproportionate effort.
You have the right to restrict our processing of your personal information under certain conditions. Applicants may inquire with us about these details. We will also communicate the applicant's request to third parties with whom we share the applicant's personal information. However, this does not apply if it is impossible or involves disproportionate effort. Applicants may inquire with us about such third parties.
You have the right to receive the personal information we hold about you and to have it transferred to another party (including the right to request that we provide the information directly to another party).
To exercise the above rights or for information on how to exercise them, please contact us at the "Contact Information" listed above.
Job applicants have the right to object to the Company's handling of their personal information based on the legitimate interests of the Company or others, and to request the cessation of such handling.
Job applicants have the right to withdraw their consent. However, withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
To exercise any of the above rights or to learn how to exercise them, please contact the "Contact Information" listed above.
Job applicants have the right not to be subject to significant adverse effects based solely on profiling.
Job applicants may lodge a complaint with the data protection supervisory authority in their country of residence regarding our processing of personal data.
We strive to manage personal information safely and appropriately by appointing a person in charge of management and implementing appropriate security measures to prevent unauthorized access, loss, destruction, falsification, leakage, etc. of personal information.
When transferring your data to entities outside the EEA, the UK, or Japan, we protect your rights regarding your personal data through data transfer agreements with relevant recipients in accordance with the GDPR/UK GDPR.
We have appointed a Data Protection Officer (DPO) whom you may contact if you have any questions or concerns regarding your personal information. The contact details for our DPO and our representatives within the EEA and UK are as follows:
Controller
4-5-41 Miyahara, Yodogawa-ku, Osaka-shi, Osaka
SNK Corporation
TEL: 06-6734-5100
DPO
Email: snk-dpo-office@iij.ad.jp
Local Representative
Data Protection Representative Limited
Email: datarequest@datarep.com
DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany
DataRep, BPM 335368, 372 Old Street, EC1V 9AU, London, United Kingdom
Pursuant to the California Privacy Rights Act (hereinafter referred to as "CPRA"), we provide the following details regarding the categories of personal information we collect, use, and disclose about California residents.
We collect personal information from job applicants.
We may transfer personal information we collect to our parent company and other entities located overseas in accordance with applicable laws and regulations.
The types of personal information we collect from California residents, the types of personal information we "sell" or "share" for cross-context behavioral advertising purposes, and the types of personal information we collected and disclosed for our business purposes in the past 12 months are as follows.
| Types of Personal Information Collected | Recipients of Personal Information | Types of Personal Information Sold |
|---|---|---|
|
Personal Identifiers Name, date of birth, address, phone number, email address, and facial photographs, etc. |
Our Parent Company, etc. | Not sold |
|
Employment Information Current or past employment history (including education, occupation, desired annual salary and awards/discipline), information regarding holdings, etc. |
Our parent company, etc. | Not sold |
|
Characteristics protected under California or federal law Gender, nationality, dependents (including relationship), age (40 or older), type and degree of physical or mental disability, disability certificate number, medical history, presence or absence of residence card and status of residence, period of stay, etc. |
Our parent company, etc. | Not sold |
The purposes for which we process the following personal information are as stated in the "Purpose of Use of Personal Information Regarding Job Applicants" above.
Job Applicants may request disclosure of the following information for the 12-month period preceding the request:
Job applicants may request deletion of personal information collected by us.
Job applicants may request that the Company correct their personal information if it is inaccurate.
To exercise your right to know, request correction, or request deletion, please contact us at the "Contact Information" above. We will review and respond to your request in accordance with applicable laws, taking into account the type and sensitivity of the personal information subject to the request.
In doing so, we may request additional information from the applicant, such as their name, email address, or address, to verify their identity.
Furthermore, job applicants have the right not to be discriminated against for exercising their rights under the CPRA.
Regarding the handling of personal information of job applicants located in the People's Republic of China (hereinafter referred to as "China"), we comply with the Personal Information Protection Law of the People's Republic of China and other relevant laws and regulations (hereinafter referred to as "PIPL, etc.").
As stated in the sections above titled "Acquisition of Personal Information Regarding Job Applicants" and "Purpose of Use of Personal Information Regarding Job Applicants."
Furthermore, sensitive information will be handled as described in the section "Regarding Personal Information Requiring Special Consideration."
Job applicants located in China have the following rights.
When exercising these rights, we will respond within a reasonable period and scope in accordance with the PIPL and other applicable laws. Please note that we may require prior identity verification when processing your request.
To exercise these rights, please contact us at the "Contact Information" listed above.
When providing your personal information to third parties (including provision through outsourcing involving joint use and transfer outside China), we will comply with the Personal Information Protection Law (PIPL) and other applicable laws.