Privacy Policy for Recruitment Activities

The Rakuten Group company for whose open position you apply or from which you sign up to receive information on prospective job postings will be the controller of your Personal Information for processing. Rakuten jointly shares its recruitment platforms among the participating Rakuten Group companies for the purpose of Candidate pooling. This means you may apply to any advertised position to any of the above-mentioned companies using the same profile in our recruitment platforms. At the same time, we may contact you with an offer or prospective job opportunity from another Rakuten Group company in the event that your application for the original position is rejected, but we consider you to be potentially suitable for another open position. In such case, authorized individuals within the Rakuten Group companies may access and use the Personal Information submitted by Candidates applying for positions within other individual Rakuten Group companies for the purposes described in this Policy and such companies will also be data controllers of your Personal Information.

During the course of the recruitment process, we may collect different kinds of Personal Information about you. We may receive Personal Information either directly from you via your submission or from someone acting on your behalf, such as a recruitment agency, or by collecting it from publicly available sources that are job-related, such as business networking websites or job boards, where permitted by applicable laws. Furthermore, where permitted by applicable laws, we may collect information from additional sources, such as our service providers, for example during background checks.

Unless not permitted by local laws, the Personal Information we collect relates to the following categories:

• Information to create a 'Candidate Profile' in our recruitment platforms, such as username, password and e-mail address
• Basic profile information, such as name, age, gender, date of birth, telephone number, address, or other contact information
• Information necessary to evaluate your suitability for a position, such as educational records, work history, relevant skills, qualifications, or certifications, and, for any skills evaluation or screening test, the responses you provide and the results
• Information relevant to the position for which you apply or are considered, such as current annual salary, desired annual salary, employment interest area, type and level of position or job in which you are interested
• Information contained in any CV, resume, application, entry sheet, and any other documents you submit to us in order to support your candidacy, including any information you volunteer regarding your non-employment-related interests or activities
• Information relevant to the screening process that we may collect through background checks, reference checks, drug screening, and/or other confirmation procedures
• Contents of any form of communication conducted between us and you as the Candidate, including face-to-face conversations, telecommunications, emails, letters, phone inquiries and other forms of interviews
• Information about the Candidate's usage of the recruiting platforms, such as login information, login date and time, pages navigated, browsing history
• Past records and results of any prior application, interviews, and screening processes for a Candidate

Where permitted by applicable law and/or where you have provided any consent required by applicable law, the Personal Information we collect may include information that falls into one or more of the following categories (referred to herein as **'Sensitive Personal Information'**)

• Race or ethnic origin
• Political opinion or membership in a political association
• Religious beliefs, affiliations, or philosophical beliefs
• Membership in a professional or trade association or membership in a trade union
• Genetic or biometric data
• Sexual preferences or practices
• Criminal records
• Health, age and disability

Where we are permitted to collect Sensitive Personal Information under local law or to the extent that a Candidate voluntarily provides information that includes Sensitive Personal Information, we will only use that information in accordance with applicable law and in line with this Policy. For example, in some countries we may be permitted or even required to conduct equal opportunities monitoring and request information from candidates regarding gender and ethnicity. As another example, if a Candidate requests accommodation related to any special needs or health conditions, we may be permitted or even required to collect and use such information to respond to such requests. In such cases the provision of the information will be optional, and we will only use the information for the specified purposes.

We do not knowingly collect information from minors under 16 years of age.

We will use the Personal Information for the following purposes, where such uses are permitted under applicable laws

• To assess Candidates' qualifications with regard to available positions
• To provide Candidates with information about employment opportunities
• To contact and correspond with Candidates regarding job applications or employment opportunities
• To check information held in relation to Candidates who have made previous applications
• To improve or simplify your experience in using our recruiting platforms
• If you were referred, to inform the referrer of the status and outcome of your application
• To contact you about a similar position in the future, in the event your initial application is rejected, according to local law or depending on your settings
• To conduct background checks on suitable Candidates
• In order to diagnose or remedy technical or operational problems with our recruiting platforms, websites, portals, or other recruiting activities
• To maintain and improve our recruiting processes and for internal planning and reporting purposes
• To comply with applicable laws and regulations or exercise or defend our legal rights
• For security and fraud prevention purposes

Candidates offered employment will be provided with a separate privacy policy addressing the way in which their Personal Information will be processed by Rakuten during the term of their employment.

Where we collect, handle or process your Personal Information as part of our recruiting process, we may rely on certain legal bases to do so, depending on the region of the Candidate, the position you apply for, and the respective applicable law. These legal bases for processing your Personal Information may include, without limitation:

• A Candidate's consent
• As necessary to perform or fulfill a contractual obligation with a Candidate
• To comply with our legal or regulatory obligations
• As necessary for our legitimate interests, including our interest in considering a broad array of Candidates for current and future employment opportunities within the Rakuten Group and our interest in maintaining or improving our recruiting processes, provided that the interests or fundamental rights and freedoms of the Candidate, under applicable law, are not overridden

We acknowledge that special attention needs to be paid to the handling of Personal Information. In compliance with applicable law, the Rakuten Group Companies have implemented appropriate technical and organizational measures in order to prevent the unauthorized, accidental, or unlawful access, loss, alteration and leakage of Personal Information, to maintain the accuracy of such information and, when necessary, to ensure its proper deletion. When collecting or transferring your personal information, we employ data encryption technology, and restrict access only to those persons who require it to fulfil their job responsibilities. For more information, please refer to the website below.

Information Security at Rakuten

We will retain your Personal Information for as long as your application process is ongoing and/or for as long as you consent to remain part of the Candidate pool or Talent Community, in order to contact you about relevant job opportunities. We also retain your Personal Information as required for our legal or regulatory obligations and where necessary to protect or assert our legal rights, in accordance with applicable law. You can ask us to delete your Personal Information at any time by contacting us using the form in Section 11. "Inquiries About the Companies in Scope and Career Activities in Rakuten". The Rakuten Group Companies retain de-identified statistical and anonymous information about Candidates to help improve recruitment activities and processes.

Within the Rakuten Group

• The Rakuten Group relies on the Rakuten Group Binding Corporate Rules to safeguard international data transfers within the Group.
• The Rakuten Group Binding Corporate Rules can be found at https://corp.rakuten.co.jp/privacy/en/bcr.html. In addition, for more information about the countries outside of Japan that we may disclose your personal information and the data protection legal systems in such countries, please refer to this page.

To Third Parties

Personal Information collected by us in the recruiting process may be disclosed to:

• Third-party Service Providers that we engage to process Candidates' Personal Information on our behalf or for our sole benefit, such as for the purpose of:
  • Facilitating interview-related travel booking and expenses
  • Hosting the recruitment platforms
  • Sending communications to Candidates
  • Facilitating relocation
• Third parties that we have hired in order to perform pre-employment checks (in accordance with applicable law)
• Recruitment agencies selected by us to handle the recruitment process
• Immigration advisors, including lawyers and consultants
• Where permitted by applicable law, in connection with a transaction for the purposes of corporate restructuring, sale, or assignment of assets, merger, divestiture, or other changes of the financial status of the Rakuten Group Companies, to a party or prospective party of such transaction
• Any third party as necessary to comply with applicable law, legal or regulatory obligations or regulatory inquiries or requests

The recipients of these disclosures may be located in countries where data protection laws may not provide an adequate level of protection in comparison to applicable data protection laws in your region. In such cases, we will implement appropriate safeguards (such as Standard Contractual Clauses) for any transfers in compliance with applicable data protection laws.

a. Privacy Rights

You have certain rights regarding your personal information, subject to local law. These include the following rights to:

• Access your personal information
• Rectify the information we hold about you
• Erase your personal information
• Restrict our use of your personal information
• Object to our use of your personal information
• Receive your personal information in a usable electronic format and transmit it to an external party (right to data portability)
• Learn more about the sources from which we collect information, the purposes for which we collect and share information, the information we hold, and the categories of parties with whom we share your information
• For California residents, opt out of certain disclosures of personal information that California law defines as "sales" even if no money is exchanged (for the avoidance of doubt, we will only use the Candidate's personal information for the purposes described herein, so we do not sell your Personal Information per the California Consumer Privacy Act ("CCPA"))
• For California residents, request information annually about any disclosure of your Personal Information to third parties for the third parties' direct marketing purposes (for clarity, our practice is not to disclose your Personal Information for the purposes of third-party direct marketing unless you explicitly consent)
• Exercise privacy rights without fear of being denied goods or services in a discriminatory fashion as a result
• Lodge a complaint with your local data protection authority

b. Exercising Your Privacy Rights

In order to exercise your Privacy Rights, depending on the applicable law in your location or jurisdiction, please contact us using the contact form at the bottom of this page.

In addition, job applicants may check, change, and update the Personal Information they have provided to create their profile and submit their application at any time by logging into the recruitment platform for job applicants. For any specific application, the documents provided during the application process cannot be changed once they have been submitted. However, a Candidate may at any time take back the application and request deletion of their information.

For those who join or consent to remain in our Talent Community separate from an application for a particular position, please contact us at the above address to exercise your privacy rights, including to correct any information in your profile or to withdraw your consent to our continued processing of your Personal Information.

If you signed up to receive communications from us by email about potential future job opportunities, you can contact us at the above address in order to stop receiving these communications, or you can also opt-out or withdraw your consent to receive these communications by following the instructions in any such email communication from us. We will contact you if we need additional information from you in order to honor your privacy rights requests.

Information about cookies is available in our cookie policy.

Currently using this recruitment platform are the following Rakuten Group companies. For any inquiries, please refer to Section 11. "Inquiries About the Companies in Scope and Career Activities in Rakuten".

Please fill in the form linked below for any question about this Policy.

Click here for the Inquiry Form

Privacy Policy Addendum for Recruitment Activities in the Rakuten International Region
Effective Date: September 15, 2025

This Privacy Policy Addendum for Recruitment Activities in the Rakuten International Region (the "Addendum") supplements the Privacy Policy for Recruitment Activities (the "Global Policy"). It applies specifically to candidates who participate in recruitment activities with Rakuten Group Companies headquartered in the "Rakuten International" business region, which generally includes the Americas (U.S., Canada, Brazil) and the EU/UK, although the included business locations may be global. As of the date of this Addendum, it governs recruiting for Rakuten USA, Inc., and the brands represented at the Rakuten International website https://rakuteninternational.com. This Addendum does not replace the Global Policy but rather provides additional details regarding recruitment tools or systems and practices that are unique to the Rakuten International region.

For the purposes of this Addendum, the terms "Rakuten," "we," "us," and "our" refer to the applicable Rakuten Group Company conducting recruitment activities in the Rakuten International region via this site or the Rakuten International regional services teams who provide shared support functions to the group companies, who act as the controller of your information processed hereunder. Capitalized terms not defined in this Addendum have the meanings set forth in the Global Policy.

1. Scope & Relationship to the Global Policy

Rakuten Group Companies conducting recruitment activities in the Rakuten International region primarily use the recruitment and applicant management platform shared among the Rakuten Group Companies for the purposes of managing job applications and the Talent Community, as described in the Global Policy. However, in addition to that platform, other recruitment tools, sites and systems may be used in this region. The categories of additional tools and their purposes of use may include, but are not limited to:

• Talent sourcing and pipeline management tools used to publicize jobs and engage and manage prospective candidates for open positions or forthcoming job opportunities
• Campus recruiting platforms for engaging with student and university talent
• Communication tools for managing candidate communications
• Interview scheduling tools for coordinating and scheduling interviews with candidates
• Video conferencing platforms for conducting remote interviews
• Technical assessment platforms for evaluating candidates' coding and technical skills (where applicable)
• Non-technical skills assessment tools for evaluating other relevant job skills (where applicable)
• Document storage platforms for storing candidate screening feedback and evaluations
• Background check service providers for conducting pre-employment screenings
• Survey tools for soliciting feedback on candidates' recruiting experiences
• Analytics tools for internal analysis and improvement of hiring processes and tools

This Addendum describes how Personal Information is collected, used, shared, and protected when sourcing and evaluating candidates for open positions or prospective positions in the Rakuten International region using these additional tools and systems.

2. Additional Data Collection and Processing and Purpose of Use

In addition to the categories of Personal Information listed in the Global Policy, the recruitment tools and systems used in the Rakuten International region may collect the following types of data:

• Job history and skills information (resume data) collected through applicant tracking systems (ATS), including uploaded documents and manually entered information
  ‍
• Interview scheduling and communication data, including:
  • Calendar invites and scheduling details stored in ATS and communication tools
  • Emails, phone calls, and messages exchanged through internal and external communication platforms
    
• Candidate assessment data, including:
  • Interview feedback and evaluations stored in recruitment platforms and document storage systems
  • Reference, education, and credential check feedback or responses
  • Technical assessment results from coding and skills testing platforms
  • Skills and cultural fit assessments gathered and created during screening interviews
• Offer and onboarding data, including:
  • Offer letter and employment agreement details processed through offer management systems
  • Onboarding documentation, such as tax forms, background checks, and contracts
• Talent pipeline and engagement data, including:
  • Interaction records with potential candidates through talent sourcing and engagement platforms
  • Campus recruitment data collected through platforms used for university outreach and student engagement

3. Legal Basis

Where we collect, handle or process your Personal Information as part of our recruiting process, we may rely on certain legal bases to do so, depending on the region of the Candidate, the position you apply for, and the respective applicable law. These legal bases for processing your Personal Information may include, without limitation

1. Consent

In certain jurisdictions, or for specific activities, we may rely on your consent to process your Personal Information. You may withdraw your consent at any time without affecting the lawfulness of prior processing.

We rely on consent for:

• Campus recruitment and engagement where consent is required to collect and retain your information for future opportunities
• Talent pipeline retention and future contact with potential candidates, where required
• In Certain Jurisdictions where applicable privacy laws require consent

2. Performance of a Contract

We process Personal Information necessary to evaluate your application and, if successful, to prepare an offer of employment or execute pre-contractual steps.

This includes:

• Application and resume data** collected through our applicant tracking system (ATS), including uploaded CVs and manually entered information
• Reference, education, credential check data**, such as feedback received from verifying application and resume data and checking references
• Interview scheduling and communication data**, such as calendar invites, scheduling details, and messages coordinated through internal and external tools
• Offer and onboarding documentation**, including offer letters, employment agreements, and required pre-employment forms (e.g., tax and immigration documents, background checks)

3. Legal Obligations

We process or disclose, where legally required, certain Personal Information to comply with our legal or regulatory obligations, including employment, labor, and data protection laws.

This includes:

• Onboarding documents, such as tax forms, compliance certifications, eligibility-to-work verification, where required by law, or acknowledgement of certain policies to demonstrate compliance with anti-discrimination laws
• Applicant demographic data to demonstrate compliance with anti-discrimination and equal opportunity hiring laws

4. Legitimate Interests

We also process your Personal Information where it is necessary for our legitimate interests in the conduct of our business, and where such interests are not overridden by your rights and freedoms.

Our legitimate interests include:

• Evaluating candidate qualifications and suitability for roles at Rakuten International
• Assessing and improving our recruitment processes, including reviewing interview feedback and assessment results
• Reviewing records of candidate communications, interview outcomes, and hiring metrics for business planning and quality control
• Managing a talent pipeline for potential future recruitment, where permitted without consent
• Ensuring secure and efficient operation of our recruitment platforms and tools

When relying on legitimate interests, we conduct balancing tests to ensure your privacy rights are respected. Where applicable, when our need for the processing is not compelling, you have the right to object.

4. Retention Periods

Personal Information collected through additional recruitment tools will be retained for the for as long as necessary to fulfill the purposes for which it was collected, including to comply with legal, regulatory, or reporting obligations, or to establish, exercise, or defend legal claims. If applicable laws in the Rakuten International region mandate shorter or longer retention periods, we will adhere to those legal requirements.

5. Data Sharing & Transfers

In addition to the disclosures set forth in the Global Policy, we may share Personal Information collected through Rakuten International-specific recruitment tools, as necessary, with:

• External recruitment vendors and service providers for interview scheduling, background screening, or pre-employment assessments
• Third-party technology providers hosting virtual interviews or assessment platforms
• Rakuten Group entities outside of the Rakuten International region, where cross-border collaboration is necessary for hiring decisions

Within Rakuten Group, we rely on our Binding Corporate Rules (BCRs) for the transfer of EU data to other jurisdictions. Where transfers of Personal Information occur outside of the Rakuten International region, we ensure appropriate safeguards (such as Standard Contractual Clauses (SCCs) or other measures) are in place, in compliance with applicable data protection laws.

6. Your Privacy Rights in the Rakuten International region

Candidates in the Rakuten International region may have additional privacy rights under laws such as:

• California Consumer Privacy Act (CCPA) (for candidates located in California, U.S.)
• General Data Protection Regulation (GDPR) (for candidates located in the EEA and UK)
• Personal Information Protection and Electronic Documents Act (PIPEDA) or Quebec Law 25 (for candidates located in Canada)
• General Data Protection Law (LGPD) (for candidates located in Brazil)
• Privacy Act 1988 (for candidates located in Australia)

These rights may include the ability to:

• Request access to your Personal Information
• Request correction or deletion of your Personal Information
• Opt-out of or object to certain data processing activities
• Withdraw consent for processing where applicable

To exercise your rights, you may submit a request to the email:
RI-RS_privacy@rakuten.com

7. Contact Information

For inquiries regarding this Addendum and recruitment activities in the Rakuten International region, please contact our Americas DPO or EU DPO at: RI-RS_privacy@rakuten.com or +18885512118

For general privacy inquiries related to recruitment, please refer to Section 11 of the Global Policy.

Updates to this Addendum

We may update this Addendum from time to time to reflect changes in recruitment practices or legal requirements. Any updates will be communicated through the appropriate channels.

This Addendum is effective as of October 2, 2025 and should be read in conjunction with the Global Policy for Recruitment Activities.