This privacy notice applies to the processing of personal data, which means information about an identifiable individual (“you“), that Quadrature Capital Limited (“Quadrature“, “we“, “us” or “our“) collects about candidates for employment with Quadrature or its affiliates (“<Affiliates”), including candidates for internships and prospective contractors. It also describes your data protection rights.

More information about your rights, and how to exercise them, is set out in the Your Choices and Rights section.

WHAT PERSONAL DATA WE COLLECT

  • Personal identification and communication information: your name (including any alias or preferred name), gender, home address, phone number, email address, your nationality, passport number and immigration status (including documents proving your right to work, such as visa documents);
  • Application-related information: your curriculum vitae (CV), cover letter and LinkedIn or other social media usernames and profiles (if relevant), information on how you were introduced or referred to us, your employment history, education history, qualifications and skills, reference contact information, position preferences, willingness to relocate, desired salary, interests and aspirations, our interview notes and background screening information if relevant;
  • Health information: information about your health and disabilities, to the extent you disclosed the information to us and we need that information to make any reasonable adjustments; and
  • Any other personal data provided to us by yourself, your referees or interviewees.

WE COLLECT, USE AND STORE YOUR PERSONAL DATA FOR THE REASONS SET OUT BELOW.

  • Where this is necessary for Quadrature or its Affiliates to enter into an employment or consultancy contract with you:
    • to make informed decisions on recruitment and assess your suitability for the role;
    • to communicate with you about our hiring process; and
    • to reimburse you for any agreed expenses incurred in the application process.
  • Where necessary for Quadrature or its Affiliates to comply with a legal obligation, e.g.:

    • to assess your fitness and propriety in connection with your engagement in a regulated function, where applicable.
    • to confirm that you have the right to work in the country in which your role is located.
    • to the extent required by the applicable law, to run the necessary background checks on you in relation to your potential role with us or our Affiliates (however, we will also obtain your consent to the extent such consent is required under the applicable laws.
  • Where necessary for Quadrature’s or its Affiliates’ legitimate interests, as listed below, but only where our or our Affiliates’ interests are not overridden by your data protection rights:
    • to improve our recruitment process and activities;
    • to verify the details you have supplied and conduct pre-employment background checks (however, we will obtain your consent to the extent such consent is required under the applicable laws);
    • to contact you about future career opportunities at Quadrature or its Affiliates;
    • to protect our and our Affiliates’ legitimate business interests and legal rights, including, for use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements; and
    • to analyse and monitor the diversity of our and our Affiliates’ workforce in accordance with applicable laws. This includes, for example, compliance with equal opportunity employment laws.

Where you do not provide your personal data to us, this may result in adverse outcomes for you. For example, if you do not make the relevant personal data available, then we or our Affiliates (i) may be unable to proceed with the recruitment process with you, (ii) would be unable to enter into a contract with you and/or may need to withdraw our offer of employment or a contractor role, and/or (iii) may be unable to provide certain benefits to you or make relevant adjustments in the course of your interview process Where you do not provide the relevant data in these circumstances, the consequences may be further explained to you at the time.

VERIFICATION AND BACKGROUND CHECKS

For certain positions, it will be necessary for us to verify the details you have supplied (for example, in relation to your identity, employment history, academic qualification and professional credentials) and to conduct pre-employment background checks (for example, in relation to previous criminal convictions or financial standing). The level of checks will depend on your role, in particular whether you will occupy a regulated role, and will be conducted at as late a stage as is practicable in the recruitment process and often only after you have been selected for the position. Before we proceed to pre-employment background checks, we will provide further information about the checks involved and will obtain any necessary consent required under the applicable law prior to performing such checks.

HOW WE SHARE YOUR PERSONAL DATA

Your personal data will be shared with companies providing services under contract to us or our Affiliates as part of the recruitment process, such as background checks or assessment tests. Your personal data also will be shared with government authorities and/or law enforcement officials if mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws. In the event that our, or our Affiliates’, business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business in accordance with applicable laws.

YOUR CHOICES AND RIGHTS

You may have the following rights with respect to our processing of your personal data, namely the right to:

  • request that we provide you with a copy of your personal data (you will receive your data in a structured, machine readable format);
  • request that we correct the personal data we hold about you (if the data is inaccurate, incomplete or otherwise incorrect);
  • request that we delete the personal data we hold about you (where we have no legitimate reason to keep the data or you’ve exercised your legal right to object to processing);
  • object to processing in some circumstances where we are relying on legitimate interests as the basis for processing;
  • request the restriction of processing of your personal data, which enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it; and
  • request the transfer of your personal data to another person.

Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to us or our Affiliates processing your data, this will not affect any processing which has already taken place at that time.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.

If you wish to exercise any of your rights under this section, you may submit your request through any of these methods: (i) contact us at +44-20-3743-0400; (ii) submit a webform request here; or (iii) send an email to privacy@quadrature.ai .

We will confirm receipt of your request within 5 (five) days, and we will respond within 30 days (or, if your request is complex or we receive numerous requests within a short period of time, within 90 days). Any information will be provided to you free of charge.

If you have unresolved concerns, you have the right to complain to your local data protection authority. The UK’s data protection authority is the ICO and you can make complaints at https://ico.org.uk/make-a-complaint/ .

HOW LONG WE RETAIN YOUR PERSONAL DATA

If you are successful: we will retain your personal data only for as long as we need it for our or our Affiliates’ legitimate interests or to comply with any with applicable law, for the purposes of the recruitment process. If you’re a contractor/consultant, once this process is finished, we will retain your personal data for an appropriate period so as to be able to manage the relationship between you and us or our Affiliates and once that relationship ends to deal with any legal claims linked to the application process or the relationship. After this period, we will take steps to delete your personal data or hold it in a form that no longer identifies you. If you become our or our Affiliate’s employee, personal data you provide will become a part of your employee file and may be used later for (i) the management of the employment relationship in accordance with our group-wide employment privacy policies, which will be made available to you upon joining and/or to protect our interests with respect to any legal claims that may be made in connection with the recruitment process.

If you are not successful: we will retain your personal data to review our recruitment decision (six months), as well as to keep you in mind for future recruitment processes. If you would prefer that we did not keep your details on file, please let us know.

INTERNATIONAL TRANSFERS

Your personal data may be processed in or accessed from jurisdictions outside the UK by us (or our Affiliates) or certain service providers (who provide services to us or our Affiliates in relation to our recruitment processes) for the purposes outlined above, and such jurisdictions may not have equivalent data protection laws to those in the UK for the purposes outlined above.

When we transfer your data to jurisdictions other than the UK and such jurisdictions do not offer a level of protection equivalent to that in the UK, we make use of standard contractual data protection clauses or other appropriate measures to safeguard the transfer and your rights as required under the UK GDPR and Data Protection Act 2018 (or any other data protection law applicable to our processing of your personal data). For further information, including how to obtain a copy of the documents used to protect your information, please contact us as described in the Contact Us section below.

UPDATES TO THIS PRIVACY NOTICE

This privacy notice will be updated from time to time. We will update the date at the bottom of this privacy notice accordingly and encourage you to check for changes to this privacy notice. On some occasions, we may also actively advise you of specific data handling activities or significant changes to this privacy notice, as required by applicable law.

CONTACT US

The data controller for your personal data will be Quadrature Capital Limited. If you have questions about this privacy notice or wish to contact us for any reason in relation to our personal data processing, please contact us at privacy@quadrature.ai.

Effective from 5 August 2020