TAKE-TWO INTERACTIVE SOFTWARE, INC.
SAFE HARBOR PRIVACY POLICY FOR
JOB APPLICANT DATA

Take-Two Interactive Software, Inc. (“Take-Two”) and its affiliated companies (collectively, or as the case may be individually, the “Company”) strive to properly address applicable data protection and privacy legal requirements. The Company recognizes that the European Union (“EU”) and Switzerland have implemented “omnibus” data protection regimes established pursuant to the European Data Protection Directive (95/46/EC) (the “Directive”) and the Swiss Federal Act on Data Protection (together, the “Data Protection Laws”). Among other things, these laws generally require “adequate protection” for the transfer of personally identifiable information about Company job applicants in the EU and Switzerland (“European Job Applicant Data”) to Company operations in the United States (“US”). To address this requirement, the Company adheres to the US/EU and US/Swiss Safe Harbor Privacy Principles as set forth by the US Department of Commerce (“Safe Harbor”) regarding the collection, use, and retention of European Job Applicant Data from the EU and Switzerland. The Company has certified that it adheres to the Safe Harbor privacy principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. For more information about the Safe Harbor, please refer to the US Department of Commerce website at http://www.export.gov/safeharbor/.  

SCOPE.
This Safe Harbor Privacy Policy for Job Applicant Data (“Safe Harbor Privacy Policy”) provides the job applicants of the Company and its subsidiaries and affiliates in the EU and Switzerland with certain important information about how the Company handles their European Job Applicant Data in the United States in accordance with the Safe Harbor. This Safe Harbor Privacy Policy does not apply to data about job applicants located outside of the EU and/or Switzerland or otherwise outside the scope of the Directive, such as job applicants in the US and other non-European jurisdictions.

DATA CONTROLLER.
The data controller in respect of the receipt of European Job Applicant Data will be the potential employer of the job applicant.  A list of potential employers is provided below. Please review the description for each position to determine the employer for the position.

Take-Two Interactive Software, Inc., 622 Broadway, New York, New York 10012
Rockstar Games, Inc., 622 Broadway, New York, New York 10012  
Rockstar San Diego, Inc. 2000 Faraday Avenue, Carlsbad, California 92008
Rockstar New England, Inc. 100 Burtt Road, Suite 200, Andover, Massachusetts 01810
2K Games, Inc. 10 Hamilton Landing, Novato, California 94949
Visual Concepts Entertainment, 10 Hamilton Landing, Novato, California 94949
Firaxis Games, Inc. 10 Loveton Circle, Sparks, Maryland 21152
Cat Daddy Games, LLC 720 4th Avenue, Suite 200, Kirkland, Washington 98033
2K Vegas, Inc. 302 East Carson Avenue, Las Vegas, Nevada 89101

European Job Applicant Data will also be processed during the recruitment process by the Take-Two local affiliate to which the Job Applicant applies for a job position, and its contracted parties for job recruiting and placement purposes, human resources analysis and (for successful candidates), employment purposes. The Take-Two local affiliate will also be a data controller for these purposes.

USES OF EUROPEAN JOB APPLICANT DATA.
The Company will use and otherwise process European Job Applicant Data in the United States for job recruiting and placement purposes.

As necessary in connection with these purposes, limited members of the Human Resources department, the Finance department, the IT department, the Legal department and senior executive company managers in the United States may access and otherwise process European Job Applicant Data in connection with their job responsibilities. The Company takes appropriate steps to ensure that such personnel are bound to duties of confidentiality with respect to European Job Applicant Data.

SENSITIVE PERSONAL DATA.
By submitting an application, the job applicant agrees that he/she will not supply sensitive personal data to support that application or as part of his/her personal profile unless the job applicant is expressly requested to do so (such requests will only be made if they are not prohibited under local law). Sensitive personal data could include: racial or ethnic origin, political opinions, religious or philosophical beliefs, religious, party or trade-union membership, as well as data concerning health, genetic code, addictions or sex life and data relating to convictions, decisions on penalty, fines and other decisions issued in court or administrative proceedings.

RETENTION.
If an application for employment is successful and a job applicant commences employment with the Company, the European Job Applicant Data will be transferred to the individual’s employment/personnel file and will be processed for employment purposes in accordance with the Company's Employee Privacy Notice.

European Job Applicant Data in respect of unsuccessful applications will be retained only for so long as reasonably necessary for the purposes set out above, and will be deleted in accordance with the time periods established in applicable laws. For details of the applicable time periods in your jurisdiction, please contact the Safe Harbor Privacy Contact at the email address below.

If a job applicant does not wish to be notified of future job opportunities, and only wants the Company to use his/her European Job Applicant Data for the purpose of considering the job applicant’s suitability for the specific position for which he/she applied, the job applicant should send an email to the Safe Harbor Privacy Contact specified below, confirming this preference - in which case the job applicant’s data will be deleted promptly, in accordance with local law, in the event that the application is unsuccessful.

DATA SECURITY AND DATA INTEGRITY.
The Company maintains reasonable security measures to safeguard European Job Applicant Data from loss, misuse, unauthorized access, disclosure, alteration or destruction. The Company also maintains reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete and current.

TRANSFER TO THIRD PARTIES.
Job applicants submit their applications to the Company via a website operated by third party vendors: Jobvite, Inc. for applications to any Rockstar entities, and Taleo for applications to Take-Two and any 2K entities (collectively, the “Vendors”). Both Vendors are located in the US and are covered by the Safe Harbor status. Their certifications may be viewed on the US Department of Commerce’s web site at http://safeharbor.export.gov/list.aspx.

European Job Applicant Data may be transferred to select recruitment consultants who help the Company to identify suitable candidates and assist in the management of its recruitment operations and processes.

The recipients of European Job Applicant Data identified in this Safe Harbor Privacy Policy may be located in the US and other jurisdictions that may not provide the same level of data protection as the job applicant’s home country. To the extent required by applicable law, the Company will (i) address any applicable requirement to assure an adequate level of data protection before transferring European Job Applicant Data by assuring the execution of appropriate data transfer agreements or confirming other controls, and (ii) establish that European Job Applicant Data will be made available to individuals within the recipient entities on a need-to-know basis only for the relevant purposes described above.

If at any time a job applicant wishes to view the list of Take-Two affiliates and contracted parties who have access to his/her data and their location, the job applicant may request a list by sending an e-mail to the Safe Harbor Privacy Contact at the address below.

ACCESS
Job applicants are entitled to request access, review and update of their own European Job Applicant Data in accordance with applicable law. Job applicants should transmit requests for access and/or change to their own European Job Applicant Data, in writing (an email message is acceptable), to the Human Resources department and/or to the Safe Harbor Privacy Contact identified below. If a European job applicant is aware of changes or inaccuracies in his or her European Job Applicant Data of which Company is not aware, the job applicant is responsible for informing the local Human Resources department and/or the Safe Harbor Contact of such changes so that the European Job Applicant Data may be updated or corrected.   

DISCLOSURES REQUIRED OR PERMITTED BY LAW.
Regardless of any other provisions in this Safe Harbor Privacy Policy, the Company may disclose or otherwise process European Job Applicant Data in the context of any sale or transaction involving all or a portion of the business, or as may be required or permitted by law or the Safe Harbor.

CONTACT INFORMATION.
Company job applicants located in Europe can raise any questions, comments, or access requests regarding the Safe Harbor with the Company Safe Harbor Privacy Contact shown below. If job applicants cannot resolve their issues directly with the Company, they are permitted to contact the local data protection authority in their home country for further information.

Safe Harbor Privacy Contact:

dataprotection@take2games.com




2K GAMES, INC. SAFE HARBOR PRIVACY POLICY FOR JOB APPLICANT DATA (AUSTRALIA)

2K Games, Inc., a wholly owned subsidiary of Take-Two Interactive Software, Inc., and its affiliated companies (collectively, the “Company”, "we", or "us") strives to properly address applicable data protection and privacy legal requirements. The Company recognizes that the European Union (“EU”) has an “omnibus” data protection regime established pursuant to the European Data Protection Directive (95/46/EC) (the “Directive”), and that many non-EU countries have similar data protection laws. Among other things, the Directive generally requires “adequate protection” for the transfer of personally identifiable information about the Company’s job applicants in the EU (“EU Job Applicant Data”) to the Company’s operations in the United States. To address this requirement, the Company adheres to the US/EU Safe Harbor Privacy Principles published by the US Department of Commerce (“Safe Harbor”) with respect to Job Applicant Data that it receives in the United States from the EU and non-EU countries where similar data protection laws apply, including Australia. For more information about the Safe Harbor, please refer to the US Department of Commerce website at http://www.export.gov/safeharbor/.

SCOPE.
This Safe Harbor Privacy Policy for Job Applicant Data (“Safe Harbor Privacy Policy”) provides the job applicants of the Company’s subsidiaries and affiliates with certain important information about how the Company handles their Job Applicant Data in the United States in accordance with the Safe Harbor. This Safe Harbor Privacy Policy does not apply to data about job applicants located in the United States.

COLLECTION OF PERSONAL INFORMATION
We collect personal information relevant to your job application including information about your identity, education, work experience, referees and anything else in your resume ("Job Applicant Data").

PURPOSE AND USE OF JOB APPLICANT DATA.
The Company will collect, hold, use, disclose and otherwise process Job Applicant Data in the United States for job recruiting and placement purposes, including notification of future job opportunities.

As necessary in connection with these purposes, limited members of the Human Resources department, the Finance department, the IT department, and senior executive company managers in the United States may access and otherwise process Job Applicant Data in connection with their job responsibilities. The Company takes appropriate steps to ensure that such personnel are bound to duties of confidentiality with respect to Job Applicant Data.

RETENTION
Job Applicant data will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws.

Job Applicant Data will ordinarily will be retained for a period of up to three years unless:

    a) the applicant requests deletion of the information prior to the end of such period (see "Access" section below); or
    b) the applicant is hired and the data is incorporated into the employment file. Such data will not be deleted, but will be retained for employment purposes and treated in accordance with the Company's employment policies.

DATA SECURITY AND DATA INTEGRITY.
The Company maintains reasonable security measures to safeguard Job Applicant Data from loss, misuse, unauthorized access, disclosure, alteration or destruction. The Company also maintains reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete and current.

TRANSFER TO THIRD PARTIES
Job Applicants submit their applications to the Company via a website operated by a third party vendor, Taleo ("the Vendor"), located in the USA. The Vendor has maintained Safe Harbor status since April 18, 2002 and its certification can be viewed on the US Department of Commerce's web site at http://safeharbor.export.gov/list.aspx.

EU Job Applicant Data may be transferred to select recruitment consultants who help the Company to identify suitable candidates and assist in the management of its recruitment operations and processes.

ACCESS.
Job Applicants are entitled to request access, review, update and deletion of their own Job Applicant Data in accordance with applicable law unless there is a lawful reason to refuse access or the correction. Job Applicants should transmit requests for access and/or change or deletion to their own Job Applicant Data, in writing (an email message is acceptable), to the Human Resources department and/or to the Safe Harbor Privacy Contact identified below. If a job applicant is aware of changes or inaccuracies in his or her Job Applicant Data of which the Company is not aware, the job applicant should inform the local Human Resources department and/or the Safe Harbor Contact of such changes so that the Job Applicant Data may be updated or corrected.

DISCLOSURES REQUIRED OR PERMITTED BY LAW.
Regardless of any other provisions in this Safe Harbor Privacy Policy, the Company may disclose or otherwise process Job Applicant Data in the context of any sale or transaction involving all or a portion of the business, in a permitted general situation or as may be required or permitted by law or the Safe Harbor.

CONTACT AND COMPLAINT INFORMATION.
Job applicants can raise any issues or complaints regarding our privacy practices with their local Human Resources department. Questions, comments, complaints or access requests can also be directed to the Take-Two Safe Harbor Privacy Contact shown below. If job applicants cannot resolve their issues directly with Take-Two within 30 days of providing a written complaint or are dissatisfied with their response, they are permitted to contact the local data protection authority in their home country for further information.

Take-Two Safe Harbor Privacy Contact:

safeharbor@take2games.com