Applicant and Candidate Privacy Notice

Applicant and Candidate Privacy Notice

1. Scope and Application of Notice

1.1. Coda Payments Pte. Ltd. and/or its affiliates or subsidiaries (collectively referred to as “Coda”, “we”, “us”, or “our”) only collect and process personal data from you where it is necessary for us to do so or where it is relevant to our application and recruitment process. This privacy notice (the “Candidate Privacy Notice”) sets out our privacy practices in respect of the collection, processing, use, disclosure, transfer, retention, storage, and disposal of your Personal Data when you apply for roles at Coda.

1.2. When you check the consent box involving this Candidate Privacy Notice, you agree to and acknowledge the collection, processing, use, disclosure, transfer, retention or storage, and disposal of your Personal Data in the manner described in thisCandidate Privacy Notice. 

1.3  “Personal Data” shall refer to your personal information as an individual, whether true or not, from which you can be identified either by itself, or together with other information to which we have or are likely to have access. The Personal Data that we collect and process during the application or recruitment process may include:

(a)    Your name, home address, email address, telephone number and other contact information;

(b)    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;

(c)    Information from interviews and phone-screenings you may have, if any;

(d)    Details of the type of employment you are or may be looking for,  desired salary and other terms relating to compensation and benefits packages, willingness to relocate, visa requirements or other job preferences;

(e)    Details of how you heard about the position you are applying for;

(f)      Any sensitive and/or demographic information processed 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;

(g)    Reference information and/or information received from background checks (where applicable), including information provided by third parties;

(h)    Information relating to any previous applications you may have made to Coda and/or any previous employment history with Coda;

(i)      Your information 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

(j)      Information related to any assessment you may take as part of the interview screening process.

1.4 Your use of Coda services is governed by any applicable terms and conditions and our general Privacy Notice.

1.5. We may collect your Personal Data directly from you when you apply through our careers website or indirectly through our recruiting partners.

1.6 We reserve the right to amend this Candidate Privacy Notice from time to time. Any amendments will be made available and published on this page and will take effect on the effective date stipulated herein above. You may determine if any such revision has taken place by referring to the date on which this Candidate Privacy Notice was last updated set out herein above.

2. Use of your Personal Data

2.1 Your Personal Data will be used by Coda for the purposes of carrying out its application and recruitment process which includes:

(a)    Assessing your skills, qualifications and interests against our career opportunities;

(b)    Verifying your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job;

(c)    Communications with you about the recruitment process and/or your application(s), including, in appropriate cases, informing you of other potential career opportunities at Coda;

(d)    Creating and/or submitting reports as required under any local laws and/or regulations, where applicable;

(e)    Where requested by you, assisting you with obtaining an immigration visa or work permit where required;

(f)      Making improvements to Coda’s application and/or recruitment process including improving diversity in recruitment practices;

(g)    Complying with applicable laws, regulations, legal processes or enforceable governmental requests; and/or

(h)    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.

2.2 We will also use your Personal Data to protect the rights and property of Coda, our users, applicants, candidates, employees or the public as required or permitted by law.

3. Disclosure of your Personal Data  

3.1 Your Personal Data may be shared with our affiliates, subsidiaries in Singapore and in other jurisdictions, in relation to the purposes described above. If you have been referred for a job at Coda by a current Coda employee, with your consent, we may inform that employee about the progress of your application and let the Coda employee know the outcome of the process. In some cases, if it is identified that you shared the same previous employer during the same period as a current Coda employee we may consult with that employee for feedback on you.

3.2 Coda may also use service providers acting on Coda’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. In some cases, Coda may also share your Personal Data with hiring managers who’ve accepted Coda’s offer but have not yet joined Coda, for the purposes of conducting interviews and assessing your skills.

3.3 Coda 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.

 3.4 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 Coda, 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 Coda.

4. Storage of your Personal Data

4.1 Coda operates globally, which means your Personal Data may be stored and processed outside of the country or region where it was originally collected including in Singapore and the United States. In some of these countries, you may have fewer rights in respect of your information than you do in your country of residence. Regardless of where your Personal Data is processed, we apply the same protections described in this Candidate Privacy Notice. We utilize standard contractual clauses approved by the European Commission, and rely on the European Commission’s adequacy decisions about certain countries, as applicable, for data transfers from the EEA to the United States, Singapore and other countries.

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

5. Legal Basis for our Processing

We process Personal Data only if at least one of the following applies:

(a)  You have given consent to the processing of your Personal Data, which you may revoke at any time;

(b)  The existence of our legitimate interest, including our interests in considering candidates for current and future employment opportunities, and in managing and improving our recruitment and hiring processes, unless those interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data;

(c)  To protect your vital interests, or those of others;

(d)  As necessary to prepare and enter into an employment contract with you; and/or

(e)  We are required to comply with legal and regulatory obligations, which require the processing of the Personal Data concerned.

6. Retention and Disposal of your Personal Data

6.1 If you apply for a job at Coda and your application is unsuccessful (or you withdraw from the process or decline our offer), Coda will retain your information for as long as is necessary to fulfill or complete the purpose for which it was collected or permitted by applicable law and until it is no longer necessary for any other legal or business purposes. 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 Coda and to help us better understand, analyze and improve our recruitment processes. Thereafter, we dispose of your Personal Data in a manner that prevents further access or processing, including but not limited to deletion or irreversible anonymization.

6.2 If you do not want us to retain your information for consideration for other roles, or want us to update it, please contact dpo@codapayments.com. Please note, however, that we may retain some information if required by law or as necessary to protect ourselves from legal claims.

6.3 If you are offered and accept employment with Coda, the Personal Data collected during the application and recruitment process will become part of your employment record. In such cases we may share your Personal Data with our service providers such as insurance companies, payroll agencies etc., to fulfill our legal and/or contractual obligation.

7. Your Rights in Respect of your Personal Data

7.1 In certain countries, you may have certain rights under data protection law. This may include the right to request access or to update or review your information, request that it be deleted or anonymized, or object to or restrict Coda using it for certain purposes.

7.2 If you wish to exercise any of the rights available to you then please contact dpo@codapayments.com. We will respond to any requests in accordance with applicable law, and so there may be circumstances where we are not able to comply with your request.

7.3 If you can’t find the answer to your question in this notice, you can contact Coda’s Data Protection Officer at: dpo@codapayments.com. Depending on your country of residence, you may also raise any questions or concerns you have regarding your personal information with your local data protection authority.

8. Security of your Personal Data

Coda makes reasonable efforts to safeguard Personal Data in our possession or under our control, in order to protect against loss, misuse, modification, unauthorised or accidental access or disclosure, alteration, or destruction. Unfortunately, no data transmission or storage over the internet can be guaranteed as totally secure. Nonetheless, we have adopted and currently practice administrative, organizational, technical, and physical security measures to protect your Personal Data to the best of our reasonable capacity, including but not limited to the following:

(a)  Limiting Personal Data access to authorized and/or necessary personnel;

(b)  Implementing technical solutions to ensure information security;

(c)  Continuous monitoring and review of Personal Data protection measures; and

(d)  Other security measures as may be required by the laws and regulations applicable in the country where you are located.

9. Contact Us 

To contact us on any aspect of this Candidate Privacy Notice or your Personal Data, including but not limited to withdrawing consent, requesting access to your Personal Data, requesting an update or correction to your Personal Data, or exercising any of your rights under this Candidate Privacy Notice or applicable data protection laws, you may contact our Data Protection Officer at dpo@codapayments.com.

This Addendum is made for compliance with the Personal Information Protection Law (“PIPL”) of the People’s Republic ofChina (“PRC”), and shall apply only to the applicants and candidates who reside within the PRC. This Addendum is an integral part of Candidate Privacy Notice, and shall prevail in case of any discrepancy.

1. Personal Information Handler

Name: Coda Information Technology (Shanghai) Co., Ltd.(“Coda SH”)

Mailing Address: 10, No. 2447, Jiaotong Road, Putuo District, Shanghai, China

Coda SH will handle your Personal Information falling in the categories set out in section 1.3 of Candidate Privacy Notice during the application or recruitment process.

Personal Information refers to all kinds of information related to identified or identifiable natural persons recorded by electronic or other means, excluding the information processed anonymously. The handling of Personal Information includes the collection, storage, use, processing, transmission, provision, disclosure and deletion etc. of Personal Information. In case of any conflict between this definition and the definition in section 1.3 of Candidate Privacy Notice, this definition shall apply and prevail.

2. Handling your Sensitive Personal Information

Sensitive Personal Information refers to the Personal Information that is likely to result in damage to your personal dignity or damage to your personal safety or property security once divulged or illegally used, including information such as biometric identification, religious belief, specific identity, medical health, financial account and whereabouts and tracks. 

For the purposes stated in section 2 of Candidate Privacy Notice, we need to handle your Sensitive Personal Information such as the PRC ID or passport information, and medical or health information. When processing your Sensitive Personal Information, we will ensure to not affect your rights and interests (e.g. we will only grant access to your Sensitive Personal Information to necessary persons, use encryption for necessary transmission and storage of your Sensitive Personal Information).

3. Sharing your Personal Information

We will seek your consent in accordance with the PIPL when it is necessary to share your Personal Information with third parties for the purposes stated in section 3 of Candidate Privacy Notice.

Such third parties will use your Personal Information in accordance with its data protection policies. You may contact our Data Protection Officer at dpo@codapayments.com, with “Third Party Information Request” in the subject line if you wish to know about the third parties involved in the sharing of your Personal Information, and we will respond within a reasonable time after receiving the email.

4. Providing your Personal Information overseas

Coda, of which Coda SH is a member, is a multinational company and operates globally including the PRC. For integrated management and optimization of human resources effectiveness within the organisation across all markets, your Personal Information may be transmitted to and stored in other countries/regions or may be accessed from overseas.  

The laws on the protection of Personal Information in the country/region where the overseas recipients are located may differ from the laws in the PRC. We will use lawful cross-border transmission mechanisms to transmit your Personal Information overseas and take appropriate measures to protect your personal information.

You may contact our Data Protection Officer at dpo@codapayments.com, with “Overseas Recipient Information Request” in the subject line, if you wish to know about the overseas recipients involved in the outbound transfer of your Personal Information or to exercise your legal rights in the PIPL, and we will respond within a reasonable time after receiving the email.