CloudPixel Games Limited - Applicant Privacy Notice

Effective Date: June 25, 2024

Last Updated: June 25, 2025

CloudPixel Games Limited ("CloudPixel Games," "CloudPixel," "we," "us," or "our") respects the privacy of people who apply for employment, internships, contractor roles, freelance assignments, or other work opportunities with us (collectively, "Applicants" or "you"). This Applicant Privacy Notice ("Notice") explains how and why we collect, use, disclose, retain, transfer, and protect personal data in connection with recruitment and hiring.

This Notice applies when you apply directly to CloudPixel Games, submit information through a recruitment platform or agency, are referred to us, participate in an interview or assessment, communicate with our recruiting team, or are considered for a role. It applies before an employment or service relationship begins. If you join CloudPixel Games, we will provide or make available any additional workforce privacy information that applies to personnel.

Personal data means information that identifies, relates to, describes, or could reasonably be linked with you. It does not include information that has been aggregated or de-identified so that it can no longer reasonably identify you.

This Notice supplements our general Privacy Policy. The general Privacy Policy applies to technical information collected when you browse our website, while this Notice applies to information processed for recruitment.

1. Data Controller and Scope

CloudPixel Games Limited is a company based in Hong Kong and is the controller of the personal data covered by this Notice, unless a particular job posting or recruitment communication identifies another controller. Our contact details appear in Section 13.

This Notice does not create an employment contract, promise of employment, or obligation to proceed with an application. Recruitment decisions remain subject to business needs, qualifications, lawful eligibility requirements, and any terms communicated for the relevant role.

2. Personal Data We Process

The personal data we process depends on the position, application stage, location, and information you choose to provide. Please do not submit information that is not reasonably relevant to your application.

Data Category	Examples	Typical Purposes	Typical Legal Bases
Identity and contact data	Name, preferred name, title, date of birth where lawfully required, photograph, home or mailing address, country or region, email address, telephone number, and online professional profile.	Identify and communicate with you, manage your application, schedule interviews, and maintain recruitment records.	Pre-contract steps: evaluating your application and taking steps at your request before entering into an employment or service contract. Legitimate interests: recruiting qualified personnel, managing workforce planning, securing our systems, improving recruitment, and protecting legal rights. Legal obligations: complying with employment, immigration, tax, equality, recordkeeping, sanctions, and other applicable laws. Consent: where required for optional talent-pool retention, certain background checks, recordings, or sensitive data. Legal claims and vital interests: establishing, exercising, or defending claims and protecting health or safety where necessary.
Application materials	Resume or curriculum vitae, cover letter, portfolio, demo reel, artwork, writing samples, code samples, certificates, licenses, transcripts, and other documents you submit.	Assess qualifications, experience, creativity, technical ability, communication, and suitability for the role.
Education and professional history	Schools, degrees, training, qualifications, employment history, job titles, responsibilities, projects, professional memberships, awards, skills, languages, and compensation expectations.	Verify relevant background, compare qualifications with role requirements, and plan potential employment terms.
Interview and assessment data	Interview notes, recruiter and interviewer feedback, test or exercise results, case studies, technical assessments, work samples, availability, role preferences, and hiring recommendations.	Conduct interviews and assessments, compare candidates, document decisions, and improve the recruitment process.
Eligibility and compliance data	Work authorization, visa or immigration status, location, notice period, willingness to relocate, conflicts of interest, non-compete restrictions, and information needed for legally required sanctions or eligibility checks.	Confirm ability to perform the role lawfully, arrange immigration support, identify conflicts, and comply with legal obligations.
References and verification data	Referee names and contact details, reference responses, confirmation of employment or education, and—where lawful and appropriate—background-screening results.	Verify information, evaluate trust and suitability, protect our people and business, and make an informed hiring decision.
Communications and recruitment records	Emails, messages, interview scheduling, call notes, offer discussions, accommodation requests, complaints, and other correspondence.	Communicate with you, administer the recruitment process, respond to questions, resolve issues, and maintain an accurate record.
Technical and usage data	IP address, browser and device type, operating system, referral page, timestamps, activity logs, and security information generated when you use a careers page or recruitment platform.	Operate and secure recruitment systems, prevent fraud, troubleshoot, analyze usage, and improve accessibility and performance.

2.1 Sensitive Personal Data

Depending on the role and applicable law, we may process limited sensitive personal data, such as disability or health information needed to provide an interview accommodation; demographic or equal-opportunity information collected voluntarily or as required by law; government identification, immigration documents, or financial details needed after a conditional offer; or criminal-history information where a lawful and role-appropriate background check is permitted.

We process sensitive personal data only when necessary and lawful, such as to meet employment-law duties, exercise rights in the employment context, assess working capacity, provide accommodations, protect vital interests, establish or defend legal claims, or with explicit consent where required. We do not use voluntary equal-opportunity information to make discriminatory hiring decisions.

Unless specifically requested through a secure process, please do not include government identification numbers, bank details, medical records, detailed criminal-history information, or other sensitive data in your resume or initial application.

2.2 Whether You Must Provide Personal Data

Providing personal data during recruitment is generally voluntary. However, information identified as required is necessary for us to evaluate your application, communicate with you, verify eligibility, comply with law, or take steps toward an employment or service contract. If you do not provide required information, we may be unable to consider or progress your application. Please do not provide information that we have not requested and that is not reasonably relevant to the role.

3. How We Collect Personal Data

We may collect Applicant personal data from the following sources:

Directly from you. Through applications, resumes, portfolios, forms, interviews, assessments, emails, calls, events, and other communications.

Recruitment platforms and service providers. Through job boards, applicant-tracking systems, assessment providers, recruitment agencies, staffing firms, background-screening providers, and professional networking services when you apply or authorize information to be shared.

Referees and other people. From references, former employers or educational institutions where lawful, CloudPixel personnel who refer you, or other people involved in the recruitment process.

Publicly available and professional sources. From professional profiles, portfolios, publications, conference materials, company websites, and other sources that you have made public for professional purposes.

Automatically. Through cookies, logs, and similar technologies when you visit a careers page or interact with a recruitment system, as described in our general Privacy Policy and any platform-specific notice.

If you provide personal data about another person, such as a referee, you should inform that person that you are providing their information to CloudPixel Games and direct them to this Notice where appropriate.

4. How We Use Applicant Personal Data

We may use Applicant personal data to:

receive, review, organize, and manage applications; communicate with Applicants; schedule and conduct interviews, tests, and assessments; evaluate qualifications, experience, interests, and suitability; compare candidates and document hiring decisions; verify information and references; make and manage offers; and conduct lawful pre-employment checks.

We may also use the data to provide accessibility or disability accommodations; plan workforce and compensation; improve recruiting operations; analyze recruitment outcomes; maintain the security and integrity of our systems; prevent fraud or misconduct; respond to complaints; comply with legal and regulatory obligations; and establish, exercise, or defend legal claims.

With your consent where required, we may retain your details in a talent pool and contact you about future opportunities that may be suitable. You may ask us to stop future recruitment communications at any time.

5. Legal Bases for Processing

Where applicable law requires a legal basis, we rely on one or more of the following:

Steps before a contract. Processing necessary to evaluate your application and take steps at your request before entering into an employment, contractor, or service agreement.

Legitimate interests. Recruiting and selecting qualified people, managing workforce needs, operating and improving recruitment, securing our systems, preventing fraud, and protecting legal rights, where those interests are not overridden by your rights and interests.

Legal obligations. Processing needed to comply with employment, immigration, equality, health and safety, tax, recordkeeping, sanctions, and other applicable laws.

Consent. Processing based on your permission where required, such as optional talent-pool retention, certain checks, recordings, or sensitive data. You may withdraw consent at any time without affecting processing carried out before withdrawal.

Legal claims and vital interests. Processing needed to establish, exercise, or defend legal claims or protect someone's life, health, or safety.

6. How We Disclose Personal Data

We do not sell Applicant personal data. We may disclose it only as reasonably necessary to the following recipients:

CloudPixel personnel and related entities. Recruiters, interviewers, hiring managers, human-resources personnel, finance, legal, security, information technology, senior management, and affiliated entities involved in the relevant recruitment decision or business operation.

Service providers. Recruitment platforms, applicant-tracking systems, hosting and cloud providers, communications tools, assessment and interview providers, recruitment agencies, professional advisers, background-screening providers, relocation or immigration advisers, and other vendors supporting recruitment. We require providers that process data for us to protect it and use it only as authorized by contract and law.

Referees and verification sources. Former employers, educational institutions, professional bodies, and referees, when checking information with your authorization or as otherwise permitted by law.

Authorities and legal recipients. Courts, regulators, law-enforcement agencies, government bodies, professional advisers, and other parties where disclosure is required by law or reasonably necessary to protect rights, safety, systems, or the integrity of the recruitment process.

Corporate transaction recipients. Actual or prospective purchasers, investors, lenders, advisers, and successors in connection with a merger, financing, acquisition, reorganization, or sale or transfer of some or all of our business or assets, subject to appropriate confidentiality protections.

7. International Transfers

CloudPixel Games is based in Hong Kong. We and our service providers may process Applicant personal data in Hong Kong and other countries where we or they operate. Those countries may have data-protection laws that differ from the laws where you live.

Where required, we use recognized safeguards for international transfers, such as adequacy decisions, standard contractual clauses, data-transfer agreements, access controls, encryption, or other lawful mechanisms. You may contact us for more information about safeguards relevant to your data.

8. Automated Decision-Making

We do not currently make final hiring decisions based solely on automated processing that produces legal or similarly significant effects. We may use tools to organize applications, identify job-related qualifications, administer assessments, or support human reviewers, but authorized personnel make or meaningfully review recruitment decisions.

If we introduce solely automated decision-making that is regulated by applicable law, we will provide any required notice, explanation, safeguards, and right to request human review.

9. Data Retention

We retain Applicant personal data only for as long as reasonably necessary for recruitment and the other purposes described in this Notice. If your application is unsuccessful, we normally retain the application record for up to 24 months after the recruitment process ends so that we can consider you for future roles where appropriate, answer questions, demonstrate fair hiring practices, and establish or defend legal claims. A shorter or longer period may apply where required by local law, a dispute, a legal hold, or your consent.

If you join CloudPixel Games, relevant recruitment information may become part of your workforce record and be retained under the retention rules that apply to personnel. If you ask us not to retain your information for future opportunities, we will honor the request subject to any information we must keep for legal, security, or recordkeeping purposes.

At the end of the applicable period, we delete, anonymize, or securely isolate the data. Residual copies may remain for a limited time in protected backups.

10. Data Security

We use reasonable administrative, technical, organizational, and physical safeguards designed to protect Applicant personal data against unauthorized access, loss, misuse, alteration, or disclosure. Measures may include role-based access, authentication, encryption, secure transfer methods, logging, staff confidentiality obligations, vendor controls, and incident-response procedures.

No transmission or storage system is completely secure. Please use an authorized application channel and do not send sensitive documents unless requested. If you believe recruitment correspondence is fraudulent or your data may have been compromised, contact us promptly.

11. Your Privacy Rights

Depending on where you live, you may have the right to request access to or a copy of your personal data; correct inaccurate or incomplete data; delete data; restrict or object to processing; receive portable data; withdraw consent; obtain information about international transfers; and lodge a complaint with a privacy or data-protection authority.

To exercise an applicable right, email cloudpixelgame@outlook.com with the subject line "Applicant Privacy Request." Please describe your request and identify the role and approximate application date. We may request information to verify your identity and locate the relevant application. We will respond within the period required by applicable law.

Privacy rights are subject to legal exceptions. For example, we may need to retain certain records to comply with law or defend legal claims, and we may withhold information that would adversely affect another person's rights, reveal confidential references where protected by law, compromise security, or disclose legally privileged material.

If you are in the European Economic Area, United Kingdom, or Switzerland, you may complain to the data-protection authority where you live or work or where you believe a violation occurred. If you are in Hong Kong, you may contact the Office of the Privacy Commissioner for Personal Data. Other Applicants may contact the privacy regulator in their jurisdiction. We encourage you to contact us first so we can try to resolve the issue.

12. Recruitment Platforms and Third-Party Sites

A job board, recruitment agency, professional network, assessment service, or other platform may independently collect and use personal data under its own privacy policy. This Notice does not govern a third party's independent processing. Review the third party's privacy information before submitting an application through its service.

13. Contact Us

For questions, concerns, complaints, or requests concerning this Notice or our processing of Applicant personal data, contact:

CloudPixel Games Limited
Attn: Applicant Privacy
FLAT/RM A, 12/F, ZJ 300
300 LOCKHART ROAD, WAN CHAI
Hong Kong
Email: cloudpixelgame@outlook.com

14. Changes to This Notice

We may update this Notice to reflect changes to recruitment practices, technology, or law. We will post the revised Notice and update the "Last Updated" date. If a change materially affects an active application, we will provide additional notice where required.