Applicant Privacy Notice – European Applicants

Effective: 25 May 2018

What is an Applicant Privacy Notice?

AFEX is committed to maintaining the accuracy, confidentiality, and security of certain information provided by candidates in the application or recruitment process. The use of “AFEX,” “we,” or “us” in this Applicant Privacy Notice refers to Associated Foreign Exchange Limited, Associated Foreign Exchange Ireland Limited, AFEX Markets Plc., AFEX Offshore Limited, and all affiliate entities and branches.

AFEX is a data controller. This means that AFEX is responsible to decide how to use your information. This Applicant Privacy Notice refers to identifying information relating to you as “Personal Data.” The collection, use, and disclosure of your Personal Data is governed by this Applicant Privacy Notice. Specifically, this Applicant Privacy Notice will address:

  • The types of Personal Data we collect about you
  • How we use your Personal Data
  • How we store and protect your Personal Data
  • Who we share your Personal Data with
  • Your rights in relation to Personal Data


This Applicant Privacy Notice applies only to candidates residing within the European Union. If you reside outside the European Union or are unsure if or how this Applicant Privacy Notice applies to you, please AFEX’s Data Protection Officer at DPO@afex.com.

What Personal Data do we collect?

AFEX collects the following Personal Data from candidates in the application or recruitment process:

  • Contact Data. This includes your name, address, email address, telephone number, and any other information necessary to contact you in the application or recruitment process.
  • Professional Data. This includes information on your resume, Curriculum Vitae, or cover letter. Additionally, this includes previous work or volunteer experience, education, transcripts, information from professional references, details of the type of employment you are or may be looking for, current or desired salary, willingness to relocate, and any other information you provide us in the application or recruitment process.
  • Communication Data. This includes information from any interviews, phone-screenings, and written or electronic correspondence between you and AFEX.


AFEX requires certain Personal Data in order for you to commence the application or recruitment process. Failure to provide such Personal Data may impact AFEX’s ability to adequately assess your skills, qualifications and interests against our career opportunities and ultimately hinder your candidacy.

How do we collect Personal Data?

AFEX collects your Personal Data from different sources, including from:

  • You directly. This is the primary source of Personal Data during the recruitment process and includes Personal Data you provide directly to AFEX through the application, including all attachments and supplemental information you provide to support your application.
  • Other natural persons or legal entities. This includes Personal Data, such as resumes, Curriculum Vitae, and cover letters, which a third party may provide to AFEX on your behalf in the application or recruitment process.


Why do we collect Personal Data?

AFEX collects, processes, and uses Personal Data for the legitimate interest of carrying out its application or recruitment process. Such uses of Personal Data include:

  • Evaluating your professional and educational qualifications, skills, and interests
  • Conducting job interviews or phone-screenings
  • Communicating with you about the recruitment process and your application
  • Verifying your information and conducting reference checks
  • Complying with applicable laws, regulations, legal processes, or enforceable governmental requests
  • Any other purpose reasonably required by AFEX in connection with the application or recruitment process


Who do we share your Personal Data with?

AFEX may share Personal Data, to the extent necessary, with the following parties:

  • Affiliated Entities and Branches. This includes, but is not limited to, Associated Foreign Exchange Holdings, Inc.; Associated Foreign Exchange, Inc.; PT AFEX Indonesia; AFEX Global Holdings Ltd.; Associated Foreign Exchange, ULC; Associated Foreign Exchange Australia Pty. Ltd.; Associated Foreign Exchange (Schweiz) AG; AFEX Hong Kong Ltd.; and Associated Foreign Exchange (Singapore) Pte. Ltd.
  • Service Providers. This includes recruitment service providers or other human resources service providers that act under AFEX’s instruction to process your Personal Data in the application or recruitment process. Service providers are subject to contractual obligations that require the implementation of appropriate technical and organizational security measures to safeguard Personal Data. Further, service providers are bound by contract to only process Personal Data as instructed by AFEX.
  • Government and Judicial Authorities. This includes all regulatory bodies, law enforcement bodies, courts, and government agencies that may either permit or require the disclosure of Personal Data by law or regulation.
  • Business Transfers and Combinations. AFEX may sell, buy, restructure or reorganize its businesses or assets. In the event of any actual or proposed sale, merger, reorganization, restructuring, dissolution or any similar event involving our business or assets, AFEX may share Personal Data with the relevant entity.
  • Other Persons. This includes persons and tribunals used by AFEX to assert or defend its rights or interests.

 

The recipients of Personal Data identified above may be located in jurisdictions outside the European Union that may not provide the same level of data protection as your home nation. If necessary, AFEX will establish appropriate data transfer agreements with these recipients. These data transfer agreements may include terms based on European Union Model Contractual Clauses with respect to Personal Data transferred outside the European Union, or otherwise provide appropriate safeguards regarding transfers of Personal Data to other countries. Additionally, AFEX may rely on the European Commission’s adequacy decisions about certain jurisdictions.

How long do we keep your Personal Data?

We will keep Personal Data until the role you applied for is accepted by another candidate or otherwise closed. Occasionally, AFEX may maintain Personal Data beyond this timeframe in response to a regulatory audit, investigation, or other legal matter.

How do we keep your Personal Data safe?

AFEX will safely store Personal Data in its information technology systems. All Personal Data is held and maintained by AFEX or on behalf of AFEX by its service providers. AFEX takes appropriate measures to promote the accuracy of Personal Data. All Personal Data is maintained in accordance with applicable security requirements. In an effort to prevent the loss, misuse, unauthorized access, disclosure, alteration, or destruction of Personal Data, AFEX takes appropriate legal, organizational, and technical measures. AFEX takes appropriate organizational and technical measures to ensure that Personal Data is only accessed by employees that use such data to carry out their dedicated tasks.

What are your Personal Data rights?

You are entitled to appropriate control and oversight over what your Personal Data. This Applicant Privacy Notice provides an overview of your Personal Data rights.

  • Right of Access. You can ask AFEX for a description of the Personal Data we hold about you and our purposes for holding it.
  • Right to Rectification. You can ask AFEX to amend, revise, or otherwise correct your Personal Data if you determine that the Personal Data is inaccurate or incomplete.
  • Right to Erasure. You can ask AFEX to permanently erase or destroy your Personal Data if you determine that its use is no longer necessary, if you believe we are using your Personal Data in an inappropriate manner, or if you withdraw your consent. You can also exercise the Right to Erasure after you object to AFEX’s use of your Personal Data.
  • Right to Restriction of Processing. You can request that AFEX temporarily cease use of your Personal Data when you exercise your Right to Rectification, immediately after you exercise your Right to Object, when you believe use is unlawful, or when you wish for AFEX to maintain, but not use, your Personal Data beyond certain period of time.
  • Right to Data Portability. You have the right to receive all your Personal Data maintained by AFEX. AFEX must provide your Personal Data in a structured, commonly used, and machine-readable format. You also have the right to request that AFEX, where technologically feasible, securely transmit your Personal Data to a third party. The Right to Data Portability only relates to Personal Data AFEX processes based on your consent or by contract.
  • Right to Object. You have the right to object to AFEX’s processing of your Personal Data where such processing is based on our legitimate interests, on public interests, or where AFEX acts under an official authority. You may also object if we use your Personal Data for direct marketing.


In certain circumstances, AFEX may be required by law or regulation to use your Personal Data even after your request to delete or restrict our use of it. In these events, AFEX takes reasonable measures to use your Personal Data in a lawful, fair, and transparent manner. At any time, you have the right to initiate a complaint with a data protection supervisory authority within the European Union.

How can you revoke consent for AFEX to use your Personal Data?

To the extent that consent is required by applicable law and our collection, use, disclosure or other processing of Personal Data is not otherwise permitted by applicable law, by providing Personal Data to AFEX you consent to the collection, use, disclosure, cross-border transfers to countries outside the European Union, and other processing of Personal Data as detailed in this Applicant Privacy Notice.

You may revoke consent at any time by providing notice to AFEX’s Data Protection Officer. The Data Protection Officer’s contact information is listed below.

How do you exercise your Personal Data rights?

AFEX has a dedicated Data Protection Officer to respond to requests, questions, or concerns about your Personal Data rights. You may contact our Data Protection Officer at:

Attn: AFEX Data Protection Officer
4th Floor
40 Strand
London
WC2N 5RW

Telephone: +44 (0)207 004 3939
Email: DPO@afex.com

Can AFEX amend this Applicant Privacy Notice?

We will modify this Applicant Privacy Notice as a result of amendments to laws or regulations, or due to other reasons involving changes in our operations. Any amended Applicant Privacy Notice will be posted on AFEX’s website or distributed directly to you by email. The Applicant Privacy Notice will indicate the date when it was last updated.