Candidate & B2B Privacy Notice

Riot Games' candidate/B2B privacy notice got a notable update: it now says it collects a new category of 'internet activity' data (scheduling-portal and email-engagement tracking), it adds a full new section on AI tools used in hiring (including interview note-taking/transcription whose legal basis quietly shifted from 'consent' to 'legitimate interest'), and it extends international data transfers to cover Brazil. On the positive side, it adds a UK complaints procedure, clarifies the right to refuse consent, and broadens correction rights.

New tracking of your scheduling-portal and email activityRiot now collects data about how you use its interview-scheduling tool and how you…

Riot now collects data about how you use its interview-scheduling tool and how you interact with its emails (like whether you open or click them). This is a new form of behavioral tracking that wasn't disclosed before.

“Internet or other electronic network activity information. This information may include scheduling portal usage and email-engagement data.”

DATA COLLECTION

AI interview note-taking no longer legally based on your consentPreviously, Riot's AI transcription/note-taking tool was used only with your consent,…

Previously, Riot's AI transcription/note-taking tool was used only with your consent, which you could withdraw anytime going forward. Now Riot says it relies on 'legitimate interest' as the legal basis instead, even though it still frames it as opt-in. This matters because legitimate-interest processing is generally harder to stop than consent-based processing — you'd have to object rather than simply withdraw consent.

“We rely on our Legitimate Interest for this as it is optional for the candidate.”

What you can do — If asked to opt in to AI note-taking during an interview, you can decline; if you want to object after the fact, contact dpo@riotgames.com.

DATA COLLECTION

Deletion requests can now be satisfied with anonymization instead of actual deletionIf you ask Riot to delete your data, it can now choose to anonymize it instead of deleting…

If you ask Riot to delete your data, it can now choose to anonymize it instead of deleting it outright. Anonymized data may still exist in Riot's systems, just without info that directly identifies you.

“The right to delete or anonymize Personal Info that we have collected from you, subject to certain exceptions.”

DATA RETENTION

Brazil added to list of regions whose data may be sent abroadThe notice now says data from Brazil, not just the EEA, may be transferred to other…

The notice now says data from Brazil, not just the EEA, may be transferred to other countries with potentially weaker privacy protections, though Riot says it uses approved safeguard contracts for these transfers.

“including from the European Economic Area or Brazil to a country other countries”

JURISDICTION

20261023_rev01COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

ALSO IN THIS CHANGE, NOT TIED TO ONE LINE

+ ADDEDNew data category: internet/network activity tracking
Riot now explicitly says it collects data about your activity on its scheduling portal and how you engage with its emails (e.g. opens/clicks), and lists this as a category it discloses to others.
Internet or other electronic network activity information. This information may include scheduling portal usage and email-engagement data.

+## Riot Games Candidate & B2B Privacy Notice
+_Last Modified: October 21, 2026_
+_Last Modified: September 29, 2025_
 Riot Games, Inc. is a global gaming company headquartered in Los Angeles with offices and operations around the world. Riot Games, Inc. and its subsidiaries take privacy as seriously as we do play. This Candidate & B2B Privacy Notice ("Notice") explains what Personal Info we collect during our application and recruitment process, our business to business (B2B) relationships, info about your rights, as well as ways we may use or disclose Personal Info.
 By "Personal Info," we mean any information from or about an identified or identifiable person, including information that Riot Games can associate with an individual person. When we say "Riot Games" (or similar things like "we" or "us"), we're referring to the Riot Games entity or, where applicable, entities that control and are responsible for your Personal Info.
 We have developed this Notice to comply with applicable data protection laws globally. To the extent this Notice conflicts with local laws in your jurisdiction, local laws apply. To learn more about our privacy practices on other Riot Games services, like our games and the collection and disclosure of Personal Info on our websites, please be sure to check out the [Riot Games Privacy Notice](https://www.riotgames.com/en/privacy-notice).
 - _Previous applications/roles._ We ask you to provide and collect info relating to previous applications you have made to Riot Games and/or any previous employment history with Riot Games.
 - _Immigration/visa status._ We collect details of your immigration or visa status.
 - _B2B Info._ We collect tax ID numbers, Social Security numbers, and bank account info to provide payments. We use legal names to run risk assessments.
+- _Demographic & Sensitive Personal Info._We try to avoid collecting or processing info that reveals your racial or ethnic origin, religious, political or philosophical beliefs, genetic data, biometric data, trade union membership, or info about your health/sex life/sexual orientation ("Sensitive Personal Info"). However, in some circumstances, and where local laws allow, we may collect or request some Sensitive Personal Info for legitimate employment-related purposes where necessary. For example, Personal Info about your racial/ethnic origin, gender, date of birth, and disabilities, as well as photographs, for the purposes of equal opportunities monitoring and diversity and inclusion efforts.
+- _Demographic & Sensitive Personal Info._ We try to avoid collecting or processing info that reveals your racial or ethnic origin, religious, political or philosophical beliefs, genetic data, biometric data, trade union membership, or info about your health/sex life/sexual orientation ("Sensitive Personal Info"). However, in some circumstances, and where local laws allow, we may collect or request some Sensitive Personal Info for legitimate employment-related purposes where necessary. For example, Personal Info about your racial/ethnic origin, gender, date of birth, and disabilities, as well as photographs, for the purposes of equal opportunities monitoring and diversity and inclusion efforts.
+- _Internet or other electronic network activity information._ This information may include scheduling portal usage and email-engagement data.
 We collect Personal Info to support our application and recruitment process and our B2B relationships, including to:
 - Process your application (such as adding your Personal Info to our systems);
 - Communicate with you (like to schedule interview times and dates or in connection with services provided);
 If you are accepted for a role the Personal Info collected during the recruitment process will form part of your ongoing staff member record and will be processed in accordance with our GDPR Rioter and Contractor Privacy Notice or Privacy Notice for California Rioters and Contractors, as applicable.
 If you are not successful, we may still keep your application to allow us to consider you for other suitable openings within Riot Games in the future and will delete your CV, résumé, and cover letter in line with local retention requirements. Please inform us if you do not want us to do so.
 If you work for one of our suppliers, customers, partners, agents or investors, the processing is necessary for our legitimate interests, namely conducting and developing our business.
+### Usage of Artificial Intelligence tools
+We may use artificial intelligence tools when we identify potential candidates and during the interview process. They are not used for decision-making about your application and do not replace human judgement. Specifically:
+- We use artificial intelligence tools to help us find candidates whose skills and experience may be relevant to our open roles.
+- We use an artificial intelligence tool to schedule interviews and allow candidates to visualize their interview plans. The tool includes artificial intelligence assisted scheduling functionality which solely supports the coordination of interviews.
+- With your opt-in, we may also utilize real-time note-taking during interviews, so that our interviewers can give you their full attention. We rely on our Legitimate Interest for this as it is optional for the candidate. Only authorised members of our Talent Acquisition team and relevant hiring stakeholders may view the summaries. Metaview acts as our data processor under a contractual agreement that ensures your data is handled securely and in line with applicable laws and our Notice.
 ## 4\. How We Disclose Personal Info and International Transfers
 Whenever we permit a third party to access Personal Info, we will implement appropriate measures designed to ensure the Personal Info is used in a manner consistent with this Notice and that the security and confidentiality of the Personal Info is maintained.
 As part of the recruitment process, we disclose your Personal Info to hiring managers, interviewers and those directly involved in the recruitment process. As part of the B2B relationship, we disclose your Personal Info with security operations, the legal team, purchasing operations, finance, and those directly involved in the ongoing B2B services. In each case, these individuals may be spread across various offices and locations worldwide. We disclose the Personal Info we collect with our subsidiaries and affiliates, which means your Personal Info could be transferred to or stored in the US, UK, or other locations outside your country of residence.
 - recruitment or executive search agencies involved in your recruitment;
 - data storage, shared services and recruitment platform providers, IT developers and support providers, and providers of hosting services; and
 - third parties who provide support and advice including in relation to immigration, pre-engagement screening, legal, financial / audit, management consultancy, insurance, health and safety, security and intel, and whistleblowing / reporting issues.
+With your consent, we may also utilize an artificial intelligence tool service provider for real-time transcription and note-taking during interviews, so that our interviewers can give you their full attention. Any such tools would not be used for decision-making.
 We require these service providers to protect the Personal Info they receive with appropriate security measures and prohibit them from using the Personal Info for their own purposes or outside what is necessary to provide the service. These service providers may be located outside your country of residence or the country where the position for which you applied is located.
 We'll disclose Personal Info to third parties where we have a legitimate interest in doing so or where otherwise permitted by law. For example, we might disclose Personal Info to external parties if you ask us to do so in connection with a relocation, to coordinate travel, or to support you with immigration or similar issues related to your application. We don't sell or share your Personal Info for cross-context behavioral advertising.
 Additionally, we use and disclose Personal Info to comply with our legal obligations and as we believe is necessary or appropriate under applicable law to protect the rights and property of Riot Games, players, other candidates or B2B contacts, our employees, or the public, or in connection with the sale, assignment, or other transfer of all or part of our business.
+In some cases, the disclosure described above may result in your Personal Info being transferred internationally, including from the European Economic Area to a country outside it. These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective. However, we have taken appropriate safeguards to require that your Personal Info will remain protected in accordance with this Notice. These include implementing the European Commission's Standard Contractual Clauses for transfers to countries for which the European Commission has not issued an adequacy decision. The Standard Contractual Clauses can be provided to you upon request to [dpo@riotgames.com](mailto:dpo@riotgames.com).
+In some cases, the disclosure described above may result in your Personal Info being transferred internationally, including from the European Economic Area or Brazil to a country other countries. These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective. However, we have taken appropriate safeguards to require that your Personal Info will remain protected in accordance with this Notice. These include implementing the European Commission's Standard Contractual Clauses or, for transfers from Brazil, the standard contractual clauses approved by the Brazilian National Data Protection Authority (Autoridade Nacional de Proteção de Dados, or "ANPD"), for transfers to countries for which the European Commission or the ANPD, as applicable, has not issued an adequacy decision. The Standard Contractual Clauses can be provided to you upon request to [dpo@riotgames.com](mailto:dpo@riotgames.com).
 In summary, depending on how you interact with us and the role for which you are being considered, the following categories of Personal Info may have been collected and disclosed for a business purpose in the preceding 12 months:
 - Identifiers, including name, email address, and telephone number
 - Characteristics of protected classifications under state or federal law, including date of birth, age, gender, racial/ethnic origin, disabilities, and medical condition
+- Audio, electronic, visual, thermal, olfactory, or similar info, including photographs
+- Audio, electronic, visual, thermal, olfactory, or similar info, including photographs, and transcripts
 - Professional or employment-related info, including résumés, CVs, transcripts, cover letters, work samples, references, background checks, info from interviews and screeners, info relating to previous Riot Games applications, and immigration or visa status
+- Internet or other electronic network activity information, including scheduling portal usage and email-engagement data.
 We do not infer characteristics using Sensitive Personal Info, and do not use Sensitive Personal Info beyond the limited business purposes permitted by local laws, including the California Consumer Privacy Act.
 ## 6\. Security
 We use appropriate physical, technical, and organizational security safeguards to help protect your Personal Info from unauthorized access, destruction, use, modification, or disclosure both during transmission and in storage. For example, we use computer systems with limited access in controlled facilities to store Personal Info. We also use technologies like encryption and hashing to protect some of the Personal Info we collect.
 ## 8\. Your Rights, Choices & Controls
 We'll collect and use your Personal Info in accordance with your legal rights, such as described in this Notice. Based on your region, you have the rights listed below:
 - **Access:** The right to obtain confirmation as to whether your Personal Info is being processed, to know what Personal Info we have about you, including the categories of Personal Info, the categories of sources from which the Personal Info is collected, the business or commercial purpose for collecting the Personal Info, the categories of persons to whom we disclose the Personal Info, and the specific pieces of Personal Info we have collected about you.
+- **Correction:** The right to have rectified any inaccurate Personal Info concerning you.
+- **Deletion:** The right to delete Personal Info that we have collected from you, subject to certain exceptions.
+- **Correction:** The right to have rectified any incomplete, inaccurate, or out-of-date Personal Info concerning you.
+- **Deletion:** The right to delete or anonymize Personal Info that we have collected from you, subject to certain exceptions.
 - **Restriction:** The right to restrict the processing of your Personal Info in certain cases.
 - **Data portability:** The right, in certain cases, to receive the Personal Info concerning you in a structured, commonly used and machine-readable format and/or transmit that Personal Info to another data controller.
 - **Objection:** In some cases required by law, the right to ask us to stop processing your Personal Info.
+- **Right to withdraw consent:** Where your consent is required, you may at any time withdraw such consent by contacting us (though this will not affect the lawfulness of any processing of your Personal Info prior to that).
+- **Right to withdraw consent:** Where your consent is required, you may at any time withdraw such consent by contacting us (though this will not affect the lawfulness of any processing of your Personal Info prior to that). Where we ask for your consent, you may also refuse it, and we'll tell you the consequences of doing so.
 Website visitors who are using a browser that sends a Do Not Track signal or a browser that is Global Privacy Control compliant will have their signals automatically applied to their consent settings on Riot Games websites.
 We encourage you to always make sure that the Personal Info you disclose to us is kept up to date. You may exercise the rights available to you under applicable data protection laws by contacting us at [dpo@riotgames.com](mailto:dpo@riotgames.com) or using the contact details provided in Contact Us below. We may require specific Personal Info from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.
 You may also make a rights request using an authorized agent. If you submit a rights request from an authorized agent who does not provide a valid power of attorney, we may ask the authorized agent to provide proof that you gave the agent signed permission to submit the request to exercise rights on your behalf. In the absence of a valid power of attorney, we may require you to verify your own identity directly with us or confirm to us that you otherwise provided the authorized agent permission to submit the request.
 You have the right not to be discriminated or retaliated against for exercising any of these rights. We might not always be able to accommodate your requests in line with our legitimate interests, but if not, we'll let you know why. You can submit an unresolved complaint to a supervisory authority and we will work with them to address your concern. However, we strongly recommend that you engage with us first and we will endeavor to address any concerns.
+UK residents: If you consider that our processing of your personal info infringes data protection law, you have the right to complain to us. You can submit a complaint via [dpo@riotgames.com](mailto:dpo@riotgames.com) . We will acknowledge your complaint within 30 days of receiving it. We will take appropriate steps to investigate and respond without undue delay, keep you informed of progress, and tell you the outcome.
+Complaining to us does not affect your right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority \[ico.org.uk\], at any time.
 ## 9\. Legal Basis
+Under European data protection law, our legal basis for processing your Personal Info as part of the recruitment process is:
+Under European and Brazilian data protection law, our legal basis for processing your Personal Info as part of the recruitment process is:
 - Our legitimate interests (as summarized above in How We Use Personal Info);
 - To comply with applicable immigration and/or employment laws and regulations;
 - To take steps prior to entering into an employment or vendor contract with you, where you are considered for employment or a B2B relationship;
 - In circumstances where you have made the data public;
 - Where we have your consent to do so. Where we have requested your consent to process your personal data, you have the right to withdraw your consent at any time; and
+- To protect the rights and interests of Riot Games, our employees, applicants and others, as required and permitted by applicable law.
+- To protect the rights and interests of Riot Games, our employees, applicants and others, including in judicial, administrative or arbitral proceedings, as required and permitted by applicable law.
+In Brazil, we process Sensitive Personal Info only with your specific and prominent consent, for example for diversity monitoring, which is always voluntary and will not affect your application, or where the LGPD permits it without consent, such as to comply with a legal or regulatory obligation or to exercise our rights in contracts or legal proceedings.
+If you live in Latin America (excluding Brazil), we process your Personal Info on the basis of your consent and/or other legal basis as permitted under the data protection laws of your country. Where local law requires your consent, including for the processing of Sensitive Personal Info and for international transfers, we will obtain your prior and informed consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before such withdrawal.
 ## 10\. Policy Changes
 We'll update this Notice to reflect changes in technology, law, our business operations, or any other reason we determine is necessary or appropriate. When we make changes, we'll update the "Last Modified" date above and post it to our careers website. If we make material changes to the ways we process Personal Info, we'll provide you additional notice as well if we still retain your Personal Info.
 We encourage you to check back periodically to review this Notice for any changes since your last visit. This will help ensure you better understand your relationship with Riot Games, including the ways we process your Personal Info.
 Riot Games, Inc.
 Attn: Legal Department
 West Olympic Blvd.
 Los Angeles, CA 90064
 United States
+If you live in the EEA, UK or Switzerland:
+If you live in the EEA, UK, Switzerland, or Brazil:
 Riot Games Ltd.
 Attn: Legal Department
 PO Box 11989
 Dublin 2
 Ireland