DATA PRIVACY NOTICE FOR EA’S REPORTING LINE

Last updated 09/05/2018

This notice describes how Electronic Arts Inc. and its subsidiaries (for a list of our subsidiaries click https://www.sec.gov/Archives/edgar/data/712515/000071251516000111/ex-211subsidiariesofthere.htm) (“EA”) use the personal data of those submitting a report using the Reporting Line, a confidential online reporting system operated by NAVEX, Inc. on behalf of Electronic Arts Inc.

1. What Data Do We Collect And How Is It Used?

The use of the Reporting Line is entirely optional and is complementary to other means of reporting. It is recommended you consider first contacting HR, Legal, a member of your management team, or for non-employees, your local EA office.

Depending on the location you selected, the use of the Reporting Line may be limited to certain matters, in accordance with local laws. All other issues can be reported to HR, Legal, or management.

After a report is made, it is automatically forwarded to limited EA personnel for initial review. The information you submit in a report (for example, your name, contact information, details of your report, etc.) will be used by EA to investigate your report and to take appropriate corrective action. We may need to contact you with follow up questions.

We strongly encourage you to identify yourself when making a report as that will facilitate the investigation and make your report more effective. If you choose to submit your report anonymously, please provide as much information as possible to help us properly investigate the concern.

Any individuals named in your report will be informed a report has been made but your name or identity (if provided) will not be revealed to them. All such individuals will have the right to respond to or correct information contained in your report.

Please be aware that your report may result in actions or decisions that affect others. Only submit information that, to the best of your knowledge, is correct. Provided you genuinely believe the information to be true, submitting information that later turns out to be inaccurate or that is deemed to not warrant follow-up will not expose you to sanctions. Knowingly providing false or misleading information will not be tolerated and could expose you to disciplinary or legal action. Do not use the Reporting Line to air grievances or address issues that are better handled by management, HR or Legal.

2. Legal Basis For Processing

If you are a resident of the European Union, then we rely on a number of legal grounds to process your personal data. For example, we will process your personal data where we have a legitimate interest to do so, where the processing is necessary for the performance of a contract with you, or where we have a legal obligation to process your personal data. If you wish to learn more about the specific legal ground(s) we rely on to process your data for any particular purpose (including any legitimate interests we have to process information), then please contact us using the details provided below.

3. Where We Hold Your Data

EA is a global company headquartered in the United States (Electronic Arts Inc., 209 Redwood Shores Parkway, Redwood City, CA 94065). As such, your personal data is stored and processed for the purposes set out in this notice by EA in the United States and, also in other countries in which EA, its subsidiaries, or third-party agents operate. Some of these countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship, but EA has taken appropriate measures to protect your personal data in accordance with this notice wherever your personal data is stored and used.

In respect of personal data from the European Economic Area (EEA), Electronic Arts Inc. holds certifications under the EU-US and Swiss-US Privacy Shield. Details of our Privacy Shield certifications are available here. When Electronic Arts Inc. transfers personal data from the EEA to other affiliates, agents or service providers who are outside the EEA, it will do so in compliance with the 'Accountability for Onward Transfer' principle of the Privacy Shield.

4. Does EA Share Your Data?

We will maintain the confidentiality of your report and, unless we are required to share your data for the purposes outlined below, it will only be reviewed and used by those individuals necessary to manage the Reporting Line, conduct an adequate investigation, and take any follow up action. Depending on the facts, this may include HR, Internal Audit, Legal, Security and management personnel at EA. Those at NAVEX, Inc. responsible for managing the Reporting Line will also have access to reports.

We will not share data that directly identifies you with independent third parties without your consent, unless such disclosure is:

(a) in response to lawful requests by public bodies, including to meet national security or law enforcement requirements;

(b) otherwise required by law;

(c) reasonably necessary to enforce our policies, procedures, rights, property or operations or to protect our employees, non-employee workers, players or third parties; or

(d) reasonably necessary in the event of a reorganization, divestiture, merger, sale or bankruptcy.

We use third party agents and service providers to process your information on our behalf. It is our responsibility to ensure that our agents and service providers protect your data in accordance with the commitments given in this notice.

Where personal data is transferred to third party agents in accordance with this notice, EA remains liable for treatment of your personal data (including for any onward transfers made according to the Privacy Shield Principles).

5. How Does EA Protect Data?

EA takes a range of technical, organizational and legal steps to protect personal data. Even so, please be aware that no security measure is 100% perfect.

6. For How Long Does EA Retain Data?

We will only retain personal data for as long as reasonably necessary to comply with the law and/or where there is a legitimate purpose to retain it. Generally, this means your personal data will be retained as necessary to respond to your report and/or take any corrective action, to comply with archiving requirements or statutory limitations, or as otherwise required to operate the Reporting Line.

7. Your Rights

Electronic Arts Inc., located at 209 Redwood Shores Parkway, Redwood City, California, USA is data controller of your personal data processed by EA in respect of the Reporting Line. Electronic Arts Inc.’s representative in the European Union is Electronic Arts Limited, Onslow House, Onslow Street, Guildford, GU1 4TN, United Kingdom.

To request access to any personal data that we hold about you, send us an email at DPO@ea.com headed “Subject Access Request”. Before we process any request, we may ask you for certain personal information in order to verify your identity.

Depending on where you are resident, you may have other rights available to you under your local data protection laws, beyond those described above. These may include rights to request erasure or portability of personal information, to object to processing of information, or to request that we restrict processing of information. Where applicable, you can exercise these rights by e-mailing DPO@ea.com.

8. Contact Us

For any questions or complaints regarding this notice please contact our Data Protection Officer at DPO@ea.com.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

You also have the right to contact your local Data Protection Authority if you prefer. Contact details for Data Protection Authorities in the EU are available at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

9. Changes To This Notice

We may update this notice from time to time, so please review it frequently. We’ll notify you of material changes via email thirty days before they go into effect. We will seek your consent to any material changes if and where required by applicable laws to do so.