Legal - Recruitment Privacy Policy

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1. Privacy Policy

Razer Inc. and its affiliates ("Razer”, "we," "us," or "our") are committed to safeguarding the privacy of prospective employees, job applicants and candidates ("you/your") and the Personal Information you have entrusted to us. It is important for you to understand what Personal Information we will collect, how we will use it, and who may access it.

“Personal Information” means information about an identifiable individual. It includes information that you have provided to us or was collected by us from other sources. It may include details such as your name and address, age and gender, personal financial records, identification numbers including your Social Insurance Number, Identity Card Number, Passport Number, employment and educational history, professional affiliations and personal references, to the extent permitted by local laws.

This Privacy Policy applies only to prospective employees, job applicants and candidates. It governs the collection, use, access and processing of Personal Information submitted by or about such persons through Razer’s online application platforms, recruitment drives, third party platforms, recruiters and other contacts, or directly communicated to Razer. It also applies to employees of a potential acquisition target whose Personal Information is collected by Razer in the course of due diligence. This Privacy Policy does not apply to our employees, customers, suppliers, contractors or to Personal Information that Razer collects for other purposes.

Further notices highlighting certain uses we wish to make of your Personal Information together with the ability to opt in or out of selected uses may also be provided when we collect Personal Information from you.

Our websites may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your Personal Information. Please check these policies before you submit any Personal Information to such third party websites.

This Privacy Policy is intended to explain our privacy practices in relation to recruitment and covers the following areas:
1. what Personal Information about you we may collect;
2. how we may use your Personal Information;
3. who we may share your Personal Information with;
4. how we protect your Personal Information;
5. how to contact us, your ability to prevent marketing communications and how to access and update your Personal Information;
6. our Cookies Policy; and
7. how changes to this Privacy Policy and the Cookies Policy will be made.
2. What Personal Information We May Collect

We will collect and process all or some of the following Personal Information about you, to the extent such collection and processing may be necessary in connection with the recruitment process relating to your candidacy:
1. Information you provide to us: Personal Information that you provide to us when you apply for a role with us, including your name, contact details, home address, email address, work and educational history, professional affiliations, photograph, identity documents, identification number, and other details. This may also include sensitive Personal Information consisting of racial or ethnic origin, trade union membership, or data concerning health;
2. Information about you provided to us by third parties or made publicly available: Personal Information about you provided by third parties such as recruitment agencies, prior employers, your references, (to the extent permitted by law) background check providers, as well as Personal Information which is publicly available;
3. Our correspondence: We will typically keep a record of any correspondence between us;
4. Device information: This will include information about your operating system, browser, software applications, IP address, geolocation, security status and other device information in order to improve your experience, to protect against fraud and manage risk; and
5. Website and communication usage details of your visits to the websites and information collected through cookies and other tracking technologies: This will include, but not be limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs, posts on the Razer Insider forum, other communication data, and the resources that you access.
3. How We May Use Your Personal Information

In this section, we set out the purposes for which we use your Personal Information and, in compliance with our obligations under applicable laws, identify the "legal grounds" on which we rely to process the information.

These "legal grounds" allow companies to process personal data only when the processing is permitted by the specific "legal grounds" set out in applicable laws. They are:
1. Consent: where you have consented to our use of your information;
2. Contract performance: where your information is necessary to enter into or perform our contract with you;
3. Legal obligation: where we need to use your information to comply with our legal obligations;
4. Legitimate interests: where we use your information to achieve a legitimate interest and the reasons for using it outweigh any prejudice to your data protection rights; and
5. Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.
Please note that in addition to the disclosures we have identified below, we may disclose Personal Information for the purposes we explain in this policy to service providers, contractors, agents, advisors (e.g. legal, financial, business or other advisors) and affiliates of Razer that perform activities on our behalf, as well as other members of the Razer group.

The purposes for which we use your Personal Information and the "legal grounds" on which we rely to process the information are:
1. To evaluate and communicate with prospective employees.
  Use justifications: consent, legitimate interests (to enable us to evaluate your candidacy and manage our relationship with you).
2. To conduct background checks and other due diligence procedures on prospective employees, where applicable.
  Use justifications: consent, legal obligation, legitimate interests (to enable us to evaluate your candidacy and ensure due diligence is performed on candidates).
3. To maintain recruitment records.
  Use justifications: consent, legal obligation.
4. To reorganize or make changes to our business in the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organization, we may need to transfer some or all of your Personal Information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analyzing any proposed sale or re-organization. We may also need to transfer your Personal Information to that re-organized entity or third party after the sale or reorganization for them to use for the same purposes as set out in this policy.
  Use justifications: legitimate interests (in order to allow us to change our business).
5. In connection with legal or regulatory obligations, or legal proceedings. We may process your Personal Information to comply with our regulatory requirements, dialogue with regulators, or in connection with legal proceedings, which may include disclosing your Personal Information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
  Use justifications: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities and to enforce our rights or defend ourselves).
6. Retention of Personal Information upon employment. If you are employed by us, any Personal Data provided to us during the recruitment process will form part of your personnel file and will be retained in accordance with our privacy policies applicable to Razer employees.
  Use justifications: consent, legitimate interests (to maintain personnel records).
7. Specifically in relation to sensitive Personal Information, we may process such Personal Information for any purposes to which your explicit consent has been obtained, for compliance with environmental, social and governance obligations imposed by applicable law and regulations (such tracking diversity in our workforce), or to the extent required by law or contractual obligations.
  
  Use justifications: explicit consent, necessary for the carrying out of obligations under employment law, social security or social protection law, or a collective agreement.

4. Sharing Your Personal Information (and Cross-Border Transfers)
1. Sharing outside the Razer group: Personal Information may be provided to third parties, including background check service providers, anti-fraud organisations, legal, regulatory or law enforcement authorities in cases of suspected criminal activity or contravention of law, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of governments, regulatory authorities or other self-regulatory organizations, or to comply with a court order or in connection with a legal or regulatory process.
2. Sharing within the Razer group: We may share your Personal Information within the Razer group, including locations outside of your country of residence or the European Economic Area (“EEA”), for recruitment and hiring purposes, for legal and regulatory purposes, to manage business risks, to perform analytics, to ensure we have correct or up to date information about you (such as your current address or date of birth) and for administrative and IT purposes.
3. Business sale or reorganization: Over time, we may buy new businesses or sell some of our businesses. Accordingly, Personal Information associated with the business being purchased or sold will be reviewed as part of the due diligence process and subsequently transferred as a business asset to the new business owner. We may also transfer Personal Information as part of a corporate reorganization or other change in corporate control.
4. Sub-contractors and agents: We may use affiliates or other companies to provide services on our behalf such as data processing, human resources management and fraud prevention and detection. Such companies will be given only the Personal Information needed to perform those services and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes. We have contracts in place holding these companies to the same standards of confidentiality by which we are governed.

5. EEA Rights to Personal Information / General Data Protection Regulation (“GDPR”)

EEA individuals have the right, under certain circumstances, to:
1. Access their personal information;
2. Correct inaccurate personal information;
3. Request erasure of their personal information without undue delay;
4. Request the restricted processing of their personal information;
5. Receive the personal information that they have provided us with, in a structured, commonly used and machine-readable format and you have the right to transmit that information to another controller without hindrance or ask us to do so; and
6. Object to the processing of their personal information.
Such individuals may request access to their personal information and modify or remove most information associated with their candidacy at any time by emailing us at [email protected].

EEA individuals also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of their habitual residence, place of work or place of the alleged infringement if they consider that our processing of their personal information infringes the applicable data protection laws. Please contact us at [email protected] and we will provide you with detailed information regarding the contact details of the respective competent supervisory authority.
6. Transfers Outside of the EEA

This section applies to EEA individuals.

Your Personal Information may be accessed by staff, suppliers or other persons in, transferred to, and/or stored at, a destination outside the EEA in which data protection laws may be of a lower standard than in the EEA. We will, in all circumstances, safeguard personal information as set out in this Privacy Policy.

Where we transfer Personal Information from inside the EEA to outside the EEA, we may be required to take specific additional measures to safeguard the relevant Personal Information. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export Personal Information to these jurisdictions. In countries which have not had these approvals (see the full list here http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm), we will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.

If you live outside the EEA, we will undertake best efforts to give you a similar degree of control over your privacy.
7. Security of Your Personal Information
1. We use physical, electronic and procedural safeguards to protect against unauthorized use, access, modification, destruction, disclosure, loss or theft of your Personal Information in our custody or control.
2. We have agreements and controls in place with third party service providers requiring that any information we provide to them must be safeguarded and used only for the purpose of providing the service we have requested the company to perform.
8. Security Over the Internet
1. No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Personal Information in accordance with data protection legislative requirements.
2. All information you provide to us is stored on our or our subcontractors' secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.
9. Retention of Your Personal Information

Our retention periods for personal data are based on business needs and legal requirements, which will differ depending on the jurisdiction or regulatory status of the Razer unit to which your candidacy relates. We retain your Personal Information for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. When Personal Information is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data.

If you have provided Personal Information to us via the Razer Careers website, you may also request for your Personal Information to be destroyed by clicking on the “Delete My Information” option under “Account Settings”.
10. Updating Information

We will use reasonable endeavours to ensure that your Personal Information is accurate. In order to assist us with this, you should notify us of any changes to the Personal Information that you have provided to us by contacting us as set out in the "Contacting Us" section below.
11. Your Rights

If you have any questions in relation to our use of your Personal Information, you should first contact us as per the "Contacting Us" section below. Under certain conditions, you may have the right to require us to:
1. provide you with further details on the use we make of your information;
2. provide you with a copy of information that you have provided to us;
3. update any inaccuracies in the Personal Information we hold;
4. delete any Personal Information the we no longer have a lawful ground to use;
5. where processing is based on consent, to withdraw your consent so that we stop that particular processing;
6. object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
7. restrict how we use your information whilst a complaint is being investigated.
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights, we will check your entitlement and respond in most cases within a month.
12. Contacting Us

If you have any questions or concerns about our privacy practices, the privacy of your Personal Information or you want to change your privacy preferences, please let us know.

To contact the Data Protection Officer, or get in touch with him/her at [email protected].
13. Cookies Policy

We use cookies on our websites. To find out more about how we use cookies, please see our Cookies Policy at http://www.razer.com/legal.
14. Changes to Our Privacy Policy and/or Cookies Policy

We may change the content of our websites and how we use cookies and consequently our Recruitment Privacy Policy and our Cookies Policy may change from time to time in the future. If we change this Recruitment Privacy Policy or our Cookies Policy, we will update the date it was last changed below. If these changes are material, we will indicate this clearly on our website.
15. General

The provisions of this Privacy Policy (including the Annex, where applicable) supersede all other policies, contracts, agreements or arrangements, whether oral or written, express or implied, between us and you in respect of the subject matter herein. This Privacy Policy prevails over any other terms contained in or referred to in any other applicable policy or implied by trade, custom or course of dealing.

This Privacy Notice for California Residents supplements the information contained in Razer’s Recruitment Privacy Policy and applies solely to visitors, users, and others who reside in the State of California ("consumers" or "you"). Razer and its subsidiaries (collectively, "we," "us," or "our") adopts this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

1. Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, we have collected the following categories of personal information from job applicants within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, online identifier, Internet Protocol address, email address or other similar identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Yes
D. Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric Information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	Yes
G. Geolocation data.	Physical location or movements.	Yes
H. Sensory Data	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or Employment-related information	Current or past job history	Yes
J. Education Information	Information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA).	Yes
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes

Personal information does not include:
1. Publicly available information from government records;
2. De-identified or aggregated consumer information; or
3. Information excluded from the CCPA's scope, like:
  1. health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
  2. personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
1. Directly from you. For example, from forms you complete on our website when completing job applications or which you provide to us via other forms of communication;
2. Indirectly from you. For example, from activity on our website or website usage details collected automatically; and
3. From third parties. For example, from reports generated by background check service providers.
2. Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:
1. To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in connection with a job application made via our website, we will use that information to process your application. We may also save your information to maintain recruitment records;
2. To evaluate your job application and communicate with you;
3. To conduct background checks and other due diligence procedures on prospective employees, where applicable;
4. To maintain recruitment records;
5. To reorganize or make changes to our business in the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organization, we may need to transfer some or all of your Personal Information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analyzing any proposed sale or re-organization. We may also need to transfer your personal information to that re-organized entity or third party after the sale or reorganization for them to use for the same purposes as set out in this policy;
6. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
7. To form part of your personnel file, if you are employed by us; and
8. As described to you when collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
3. Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
4. Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
- Category A: Identifiers
  We disclose your personal information for a business purpose to the following categories of third parties:
  1. Our Affiliates;
  2. Service providers; and
  3. Third parties to whom you or your agents authorize us to disclose your personal information in connection with the recruitment process.
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  We disclose your personal information for a business purpose to the following categories of third parties:
  1. Our Affiliates;
  2. Service providers; and
  3. Third parties to whom you or your agents authorize us to disclose your personal information in connection with the recruitment process.
- Category C: Protected classification characteristics under California or federal law.
  We disclose your personal information for a business purpose to our Affiliates in connection with the recruitment process, such as to back office shared service personnel.
- Category G: Geolocation Data
  There is some limited disclosure in our software processing of location information based on IP or zip code.
- Category I: Professional or Employment-related information
  We disclose your personal information for a business purpose to our Affiliates in connection with the recruitment process, such as to back office shared service personnel.
- Category J: Education Information
  We disclose your personal information for a business purpose to our Affiliates in connection with the recruitment process, such as to back office shared service personnel.
- Category K: Inferences drawn from other personal information.
  We disclose your personal information for a business purpose to our Affiliates in connection with the recruitment process, such as to back office shared service personnel.
5. Sales of Personal Information

In the preceding twelve (12) months, we have not sold any personal information.
6. Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
7. Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
1. The categories of personal information we collected about you;
2. The categories of sources for the personal information we collected about you;
3. Our business or commercial purpose for collecting or selling that personal information;
4. The categories of third parties with whom we share that personal information;
5. The specific pieces of personal information we collected about you (also called a data portability request); and
6. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  1. sales, identifying the personal information categories that each category of recipient purchased; and
  2. disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
8. Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
1. Complete the transaction for which we collected the personal information, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
3. Debug products to identify and repair errors that impair existing intended functionality;
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
8. Comply with a legal obligation; or
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
9. Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to: [email protected]. If you have provided personal information to us via the Razer Careers website, you may also request for your personal information to be destroyed by clicking on the “Delete My Information” option under “Account Settings”.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
10. Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
11. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
1. Deny you goods or services;
2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
3. Provide you a different level or quality of goods or services; or
4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

California’s "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message through our website or write us at our address listed on our webpage.
12. Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage and update the notice’s effective date.

RAZER RECRUITMENT PRIVACY POLICY

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PRIVACY STATEMENT - CALIFORNIA

RAZER RECRUITMENT PRIVACY POLICY

ANNEXPRIVACY STATEMENT - CALIFORNIA

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PRIVACY STATEMENT - CALIFORNIA