This privacy notice describes how Electronic Arts Inc. with address at 209 Redwood Shores Parkway, Redwood City, CA 94065 (including our subsidiaries and affiliates, collectively, "EA" or “we”) processes personal information relating to athletes, which includes but is not limited to professional, amateur and collegiate athletes, managers, coaches, referees, umpires and other similar personnel or participants (“you”, “your”, “Athletes”) whose likeness or image is depicted in EA’s games, services, marketing and live events hosted by or in connection with EA (collectively, “Services” or “EA Services”). This privacy notice does not cover other talent who may contribute to EA’s Services. If you are a consumer of EA Services, please see EA’s Privacy & Cookie Policy for details about how EA processes your personal information in that context: http://privacy.ea.com/.

EA is the data controller responsible for processing your personal information.

1. INFORMATION WE PROCESS

We may process the following categories of personal information relating to you:

• Name and identifying information, such as date of birth, gender, age, and nationality;
• Voice, image and photographs (including facial scans that we have worked directly with you to obtain);
• Various technical, performance and physical attributes (e.g., points, statistics, scores, fouls, runs, races, splits, speeds, motion captured data, positioning and movements, distances, match fitness);
• Creative/artistic representations of you, including subjective attribute scores related to certain skills, behaviours, qualities and other characteristics; and
• Information related to the maintenance, review and updating of the data referred to above.

The above personal information is referred to as “Athletes’ Information”.

2. HOW WE USE YOUR INFORMATION

We may process Athletes’ Information to:

• develop, produce, maintain, promote, sell and distribute the EA Services;
  
• protect our rights and the rights of others, including to enforce our agreements and policies; and
• comply with the law.

3. LEGAL BASIS FOR PROCESSING

We will only process your personal information where we have a legal basis to do so, such as under a contract, when required to comply with law or to pursue our legitimate business interests. The legal basis will depend on the purposes for which we collect and use Athletes’ Information including:

• where you have entered into a contract with us and we need to use Athletes’ Information to carry out that contract; and
• our legitimate interest to use a licence (such as an image and likeness licence) obtained through your employer, team, league, federation, or authorised representative in connection with EA Services as described in Section 2 (“How we use your information”).

4. HOW WE COLLECT YOUR INFORMATION

We may obtain and collect Athletes’ Information:

• directly from you (e.g., in facial scan or motion capture sessions);
• from publicly available sources such as the news, media and/or where it has been manifestly made public by you;
• contractually through your participation in the underlying activity or organisations (e.g., a league match). You should refer to these organisations’ respective privacy notices to understand how each of these organisations processes your personal information;
• from sports analytics providers; and
• using other methods such as motion capture during public events.

We may also create and/or infer certain Athletes’ Information by observing your performance in/at events and by creating certain attributes as described in this notice (See Section 1 “Information we process”).

5. WHO MAY RECEIVE YOUR INFORMATION

We may share Athletes’ Information:

• within EA, as well as with our affiliates and subsidiaries, suppliers, service providers, advisors, licensors and licensees, and business partners, such as the companies that provide the platform on which consumers use EA Services, including Sony (PlayStation®), Microsoft (Xbox), and others;
• with the consumers who purchase and/or play EA Services (to the extent such data is discernible within EA Services and/or on our websites and other digital properties);
• in the event of reorganisation, divestiture, merger, sale, or bankruptcy, we may transfer Athletes’ Information to the relevant third party;
• if we are under a duty to disclose or share Athletes’ Information in order to comply with any legal or regulatory obligation or request; and
• with your express consent to persons or entities identified by you.

6. WHERE WE HOLD YOUR INFORMATION

We may transfer Athletes’ Information to countries outside of the countries in which it was collected, including outside the UK, and/or the European Economic Area (EEA). Athletes’ Information may be stored and processed for the purposes set out in this Privacy Notice in the United States or any other country in which EA, its subsidiaries, or third-party agents operate that may not offer the same level of privacy protections as the laws in the Athlete’s country of residence or citizenship.

EA's privacy practices comply with the Asia-Pacific Economic Cooperation Cross-Border Privacy Rules System (APEC CBPR). The APEC CBPR System provides a framework for organisations to ensure protection of personal information transferred among participating APEC economies. More information about the APEC framework is available here: https://www.apec.org/about-us/about-apec/fact-sheets/what-is-the-cross-border-privacy-rules-system.

EA complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. EA has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. EA has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Notice and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

EA is responsible for the processing of personal data it receives, under the EU-U.S. DPF and Swiss-U.S. DPF, and subsequently transfers to a third party acting as an agent on its behalf. EA complies with the EU-U.S. DPF and Swiss-U.S. DPF Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

The Federal Trade Commission has jurisdiction over EA’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, EA may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, EA commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit U.S.-based third-party dispute resolution provider for more information or to file a complaint. The services of TrustArc are provided at no cost to you.

Under certain conditions, more fully described on the Data Privacy Framework website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

7. RETENTION OF YOUR INFORMATION

We store Athletes’ Information for the duration of the commercial lifetime of our Services. We may retain Athletes’ Information beyond that period if necessary for legal, operational or other legitimate reasons, such as ensuring the consistency of information across our Services. We determine this period in accordance with our requirements under data protection law. Once Athletes’ Information is no longer needed we will either permanently delete or de-identify it according to legal requirements.

8. YOUR RIGHTS

You have certain rights in relation to your Athletes’ Information. These include: the right to object to the processing of Athletes’ Information for certain purposes, the right to access Athletes’ Information, and the ability to erase, correct, restrict or receive a machine-readable copy of Athletes’ Information. We will handle any request to exercise such rights in accordance with applicable law and any relevant legal exemptions. If Athletes wish to exercise any of these rights they should contact us using the contact details in this Privacy Notice below.

You can use an authorised agent to make a request to exercise your data privacy rights. Please use our My Privacy Rights portal to contact our Data Protection Officer. If you use an authorised agent to exercise your right to deletion, access, or correction, we will require that you verify your identity directly with us, unless you have provided your agent with a valid power of attorney consistent with applicable law, including California law (if applicable), that includes a comparable proof of identity.

We generally do not process Athletes’ Information on the basis of consent because, as described in Section 4 (“How we collect your information”), the majority of processing of Athletes’ Information is necessary for the purposes of the performance of a contract with the Athletes or the legitimate interests pursued by EA. However, whenever consent is obtained from an Athlete, such consent can be withdrawn at any time.

Athletes also have the right to lodge a complaint with the applicable supervisory authority.

9. INFORMATION FOR CALIFORNIA RESIDENTS

A. Notice at Collection

Depending on the context and nature of how we receive Athletes’ Information, the following categories of personal information may have been collected and disclosed in the preceding 12 months, as these categories are defined under the California Consumer Privacy Act (“CCPA”):

• Identifiers; such as a real name, email, online identifiers, and other identifiers, including those from government documents;
• Characteristics of Protected Classifications under state or federal law; such as age, or gender;
• Audio, visual, or electronic information; such as your voice, photographs, facial scans and images of you;
• Biometric information; such as what may be collected during qualifying motion capture sessions;
• Professional or employment-related information; such as team or club associations, as well as professional statistics; and
• Inferences drawn from the personal information collected to create a profile.

Collection, use, and disclosure of this information is made for one or more of the business or commercial purposes listed in Section 2 (“How we use your Information”).

Athletes’ Information is not “sold” or “shared,” as those terms are defined under the CCPA for purposes of targeted advertising.

We retain Athletes’ Information for the length of time specified in Section 7 (“Retention of your Information”).

For additional details, please review this overall privacy notice.

B. Supplemental California Privacy Notice

Please see below for more details about how we process your personal information, incorporating the notice immediately above.

For each of the categories of personal information referenced above:

• The categories of sources from which the personal information may have been collected are listed in Section 4 (“How we collect your Information”).
• The categories of third-party recipients to which the personal information may be disclosed are listed in Section 5 (“Who may receive your Information”).

C. Your Rights

Please see Section 8 (“Your Rights”) for a summary of your California privacy rights and how to exercise them.

10. CONTACTS

If you have questions about this Privacy Notice, please use our My Privacy Rights portal to contact our Data Protection Officer.

EU Representative:
Electronic Arts Inc.'s representative in the European Union is:
Electronic Arts Ireland Limited, Parkmore West Business Park, 1, Ballybrit, Galway, H91 Y2R5, Ireland.

UK Representative:
Electronic Arts Inc.'s representative in the UK is:
Electronic Arts Limited, Onslow House, Onslow Street, Guildford, GU1 4TN, United Kingdom.

11. CHANGES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time. The date this Privacy Notice was last updated appears below.

Last Updated: October 10, 2023.

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