UAE Exchange Group Job Applicant Privacy Statement

1. Introduction

UAE Exchange Centre LLC, its subsidiaries and affiliated companies including, among others: (Xpress Money Services Limited (UK), XM Services (Australia) Pty Ltd, UAE Exchange Hong Kong Limited & UAE Exchange Centre Co. - Bahrain WLL).

Those entities together referred to as "UAE Exchange Group" or “we” throughout this document) collect and process personal data relating to job applicants as part of its recruitment process. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.

This statement sets out the basis on which we collect, use and disclose the personal data of our job applicants, as well as your rights in respect of such personal data.

2. Personal Data processed by UAE Exchange Group

2.1 What does Personal Data mean?

Personal data means any information relating to an identified or identifiable individual directly or indirectly, such as name, address, telephone number and e-mail address.

2.2 Personal data collected by UAE Exchange Group

UAE Exchange Group collects a range of information about you. This includes:

  • Your name, address, email address, telephone number and other contact information;
  • Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process;
  • Information about your entitlement to work in the country where the job position is open; and
  • Information from interviews and phone-screenings you may have, if any;
  • Details of the type of employment you are or may be looking for, current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences;
  • Your personal image independently or as a part of your resume;
  • Details of how you heard about the position you are applying for;
  • Any sensitive and/or demographic information obtained during the application or recruitment process such as gender, information about your citizenship and/or nationality, medical or health information and/or your racial or ethnic origin;
  • Reference information and/or information received from background checks (where applicable), including information provided by third parties; Information relating to any previous applications you may have made to UAE Exchange Group and/or any previous employment history with UAE Exchange Group.
  • Information about your educational and professional background from publicly available sources, including online, that we believe is relevant to your application or a potential future application (e.g. your LinkedIn profile); and/or
  • Information related to any assessment you may take as part of the interview screening process.

We may collect this information in a variety of ways. For example, data might be contained in application forms or CVs (including when these are sent to us as part of speculative applications or queries), obtained from your passport or other identity documents, or collected through interviews or other methods of assessment.

Data will be stored in a range of different places, including on your application record, in our HR management systems and our email system.

2.3 Personal Data collected by UAE Exchange Group websites

At its websites, UAE Exchange Group collects aggregated user data (i.e. information that cannot be used to identify you), personal data that Data Subjects voluntarily provide, and personal data collected by the use of cookies (as explained in the next section).

2.3.1 Definition and Usage of Cookies

A "cookie" is a small piece of information that is stored on your device (such as your computer) and which records the way that you use a website so that, when you revisit that website, UAE Exchange Group can provide tailored options based on the information that has been collected from your last visit. Cookies can also be used to analyse traffic and, in some cases, to provide you with tailored advertising and marketing.

With the exception of essential cookies (described below), users of UAE Exchange Group websites are asked to accept cookies when visiting UAE Exchange Group websites for the first time. Alternatively, where a user has set his/her browser to warn him/her with a message for each cookie, only those cookies that have been accepted will process personal data. Whilst essential cookies are necessary to run UAE Exchange Group Websites, the rest are not compulsory and require your consent.

Following are the broad categories of cookies used on UAE Exchange Group websites:

  • Essential cookies: These cookies make UAE Exchange Group website operation work and therefore they cannot be turned off or rejected. These cookies do not gather any information about you and do not have the ability to remember how you have used our website;
  • Performance cookies: UAE Exchange Group use these cookies to help analyse how its website is used and to improve its performance. For example, UAE Exchange Group use them to understand where visitors to the UAE Exchange Group site are based, how many people visit the website and which sections of the website are the most used;
  • Functionality Cookies: These cookies allow UAE Exchange Group UP website to remember if you have previously visited the UAE Exchange Group site or the choices you made (e.g. language preferences) to provide a more personalised online experience.
  • Third-Party cookies: These cookies collect information from your device and perform tasks that analyse behaviour and collect other information, such as demographics. These cookies may be used to provide you with personalised advertising.

2.3.2 How to Manage Cookies

Our Performance, Functionality and Third-Party cookies are not strictly necessary for our website to work but will provide you with a better browsing experience. You can delete or block these cookies, but if you do this, you may have to manually adjust some preferences every time you visit our website and some features of the site may not work as intended. Most internet browsers are initially set up to automatically accept cookies, however you can decide at any time what type of cookies you want to accept. You can change the settings on your browser to block cookies or to alert you when cookies are being sent to your device.

3. Purpose of Data Processing

Your personal data will be used by UAE Exchange Group for the purposes of carrying out its application and recruitment process which includes:

  • Assessing your skills, qualifications, experience and interests against our career opportunities;
  • Verifying your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job;
  • Communications with you about the recruitment process and/or your application(s), including, in appropriate cases, informing you of other potential career opportunities at UAE Exchange Group;
  • Creating and/or submitting reports as required under any local laws and/or regulations, where applicable;
  • Where requested by you, assisting you with obtaining an employment visa or work permit where required;
  • Making improvements to UAE Exchange Group’s application and/or recruitment process including improving diversity in recruitment practices; and/or
  • Complying with applicable laws, regulations, legal processes or enforceable governmental requests; and/or
  • Proactively conducting research about your educational and professional background and skills and contacting you if we think you would be suitable for a role with us.

We will also use your information to protect the rights and property of UAE Exchange Group, our clients, applicants, candidates, employees or the public as required or permitted by law.

If you are offered and accept employment with UAE Exchange Group, the information collected during the application and recruitment process will become part of your employment record.

4. Legal basis for processing Personal Data

If European Union data protection laws applies to the processing of your personal data, UAE Exchange Group will collect it and process it for a number of purposes and where we have a legal basis to do so, as follows.

UAE Exchange Group has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.

In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant's eligibility to work in the country where the job position is open, before employment starts.

UAE Exchange Group may process information about whether or not applicants are disabled so we can make reasonable adjustments for candidates who have a disability. Where we process other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes. Our processing of these types of data will be carried out to ensure you or us can meet our obligations or exercise our rights under law related to employment or (only where applicable) to enable us to establish, exercise or defend legal claims.

We will not use your data for any purpose other than the recruitment process of which you are a part.

5. Who may have access to your information

Your information may be shared within our affiliates and subsidiaries in the UAE, Qatar, Bahrain, Oman, Kuwait, India, Hong Kong, USA, Canada, Australia, UK, and in other jurisdictions, in relation to the purposes described above. If you have been referred for a job at UAE Exchange Group by a current UAE Exchange Group employee, with your consent, we may inform that employee about the progress of your application and let the UAE Exchange Group employee know the outcome of the process. In some cases, if it is identified that you have attended the same university/school or shared the same previous employer during the same period as a current UAE Exchange Group employee we may consult with that employee for feedback on you.

UAE Exchange Group may also use service providers acting on UAE Exchange Group’s behalf to perform some of the services described above including for the purposes of the verification / background checks. These service providers may be located outside the country in which you live or the country where the position you have applied for is located.

UAE Exchange Group may sometimes be required to disclose your personal data to external third parties such as to local labour authorities, courts and tribunals, regulatory bodies and/or law enforcement agencies for the purpose of complying with applicable laws and regulations, or in response to legal process.

We will also share your personal data with other third parties if we have your consent (for example if you have given us permission to contact your referees), or to detect, prevent or otherwise address fraud, security or technical issues, or to protect against harm to the rights, property or safety of UAE Exchange Group, our users, applicants, candidates, employees or the public or as otherwise required by law.

It is your responsibility to obtain consent from referees before providing their personal information to UAE Exchange Group.

UAE Exchange Group operates globally, which means your information may be stored and processed outside of the country or region where it was originally collected.

UAE Exchange Group takes appropriate steps to protect information about you that is collected, processed, and stored as part of the application and recruitment process.

6. Cross Border Personal Data Transfers

If European Union data protection laws applies to the processing of your personal data, please consider the following:

UAE Exchange Group may transfer personal data to destinations outside of the European Economic Area (“EEA”). When transferring personal data outside the EEA, UAE Exchange Group ensures that security measures and appropriate safeguards are put in place to protect the personal data and to ensure that all transfers comply with applicable data protection law. For example, UAE Exchange Group relies on the Standard Contractual Clauses provided by the EU Commission (Article 46.2 General Data Protection Regulation (“GDPR”) and the EU Commission’s ‘adequacy decisions’ in respect of certain territories (Article 45 GDPR) to transfer personal data outside the EEA lawfully. For transfers of personal data between UAE Exchange Group companies, UAE Exchange Group has in place intra-group data transfer agreements incorporating the Standard Contractual Clauses. More information about these transfer mechanisms is available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en

7. Data Subject’s Rights

In certain countries, you may have certain rights under applicable data protection laws. In summary, these are:

  • To be informed: You have the right to receive certain information about how your personal data is processed. This is why we are providing you with this Privacy Statement.
  • Access: You have the right to access and receive a copy of your personal data.
  • Rectify: You have the right to correct your personal data when inaccurate.
  • Erasure: You have the right to request deletion of your Personal Data in certain circumstances.
  • Restriction of processing. You can restrict or limit the way that UAE Exchange Group processes your personal data in certain circumstances.
  • Right to object: In some circumstances, you have the right to object to UAE Exchange Group’s data processing activities, for example, if you do not want to be contacted by UAE Exchange Group to continue with the recruitment process.
  • Consent: if UAE Exchange Group relies on consent to process personal data, you have the right to withdraw their consent at any time by contacting us using the details below.
  • Data portability: In certain scenarios you may request UAE Exchange Group to provide a copy of your personal data in a digital format or send it to a third party appointed by you.

In certain scenarios, depending on the applicable regulation, you may be entitled to lodge a complaint with a regulatory authority, in particular in the jurisdiction where you live, where the application was submitted, or where you consider UAE Exchange Group is processing your personal data unlawfully. We would, however, appreciate the chance to deal with your concerns before you approach the regulator, so please contact us in the first instance.

For more information on your rights, please contact us using the details below.

8. UAE Exchange Group Contact

If you wish to exercise any of your rights, or if you have any queries or suggestions about this Privacy Statement, you can contact UAE Exchange Group and our Data Protection Officer, at: data.privacy@uaeexchange.com.   

9. Third Party Websites

UAE Exchange Group websites and emails may contain links to various other websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy statement of every website you visit.

10. Security Measures to protect Personal Data

UAE Exchange Group takes all reasonable steps to ensure that personal data collected is treated securely and in accordance with this privacy statement and strict data protection standards.

11. Retention of Personal Data

If you apply for a job at UAE Exchange Group and your application is unsuccessful (or you withdraw from the process or decline our offer), UAE Exchange Group will retain your information for a period after your application. We retain this information for various reasons, including in case we face a legal challenge in respect of a recruitment decision, to consider you for other current or future jobs at UAE Exchange Group and to help us better understand, analyse and improve our recruitment processes.

If you do not want us to retain your information for consideration for other roles, or want us to update it, please contact careers@uaeexchange.com or careers.recruitment@xpressmoney.com, based on to the targeted employer.

Please note, however, that we may retain some information if required by law or as necessary to protect ourselves from legal claims.

12. Changes to this Privacy Statement

We may change this Privacy Statement from time to time. We will post any changes to this Privacy Statement on this page. Each version of this statement is identified at the top of the page by its effective date.

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