CANDIDATE PRIVACY NOTICE

At Small World Financial Services Group Ltd (Small World) we are committed to protecting and respecting your privacy and therefore, all processing operations carried out upon personal data comply strictly with all the requirements established in the General Data Protection Regulation (GDPR) as well as any other applicable local data protection regulations.

1. SCOPE OF THIS PRIVACY NOTICE

This Privacy Notice applies when you interact with Small World anywhere in the world and when you apply for a job at a Small World, including if:

• You are job applicant;
• You are a potential candidate for employment; and
• You are applying for recruitment programs such as internships.

It describes how Small World and our providers collect, use, share, and keep your personal data and other information.

2. DATA CONTROLLER

Small World Financial Services Group Ltd (Small World) is the entity responsible for the management of the jointly-used personal data and other information. Small World incorporates, among others, the following European legal entities:

• LCC Trans-Sending Ltd
• LCC Trans-Envio SPRL
• Swiss Transfers GmBH
• Small World FS, Ireland Ltd
• Small World FS Norway AS
• Small World FS, Spain SAU
• Small World FS, Sweden AB
• Small World Financial Services Spain S.A. (including branches incorporated in Ireland, Germany, Netherlands & Italy)
• Small World Exchange Services, SLU
• Trans-Envio, Unipessoal LDA
• MoneyGlobe SAS

If you have any questions about the lawful bases upon which we collect and how we use your personal data, please contact:

SMALL WORLD FINANCIAL SERVICES GROUP

Group Data Protection Officer

[email protected]

Paseo del Club Deportivo 1, Edificio 13

Pozuelo de Alarcón, Madrid – Spain (28223)

 

3. HOW SMALL WORLD COLLECTS YOUR PERSONAL INFORMATION

We collect personal information in a variety of ways, including:

• Directly from you: when you apply for a position at Small World, including through LinkedIn (or other job application platform) or through our website.
• Indirectly from other third party sources: such as third party recruitment providers, government agencies, consumer and credit reporting agencies, background checking agencies and from other suppliers of information, in particular, for the prevention of financial crime.

When you apply through a third party recruitment provider, including third party websites, you should refer to their Privacy Notice to understand the personal data they collect and how they will use it.

4. WHAT INFORMATION DOES SMALL WORLD PROCESS AND FOR WHAT PURPOSES

In order to comply with the duty of information contained in the GDPR, we want to provide you with as much information as possible regarding the personal data processing operations Small World carry out, which categories of data are used and for what specific purpose and what the legitimate purpose is for each of the personal data processing operations.

The categories of personal data we collect may include:

• First name, middle name and last name;
• Address;
• Phone number;
• Email;
• Documentation to confirm your identity and your right to employment;
• Career history; and
• Other categories of personal data that enable us to prevent any kind of misconduct, in particular, money laundering, financing terrorism and other fraud or criminal activities, according to our compliance program or when required or permitted by law.

When you submit your application for employment through our website, we may collect:

• Browser and device information; and
• Information collected through cookies and similar technologies.

Unless specifically requested, please do not share with us other special categories of personal data (e.g. racial or ethnic origin, political opinion, religion or other beliefs, health, biometrics or genetic information or trade union membership).

We may use the information we collect about you, either on its own or combined with other information: (i) where it is necessary to perform and administer a potential employment contractual relationship with you; (ii) for our own legitimate interests to provide you with better services (such as to reduce fraud); (iii) where we have obtained your consent (such as for certain marketing purposes); or (iv) for compliance with applicable laws.

For clarity, the main personal data processing operations, their purpose & the legitimate reason for processing data related to Small World candidates are:

4.1. To perform and administer a potential employment contractual relationship with you, for our legitimate interests we may use your information to:

• Identify and evaluate you as a potential candidate for an open position at Small World, as well as for future roles or opportunities that may become available.
• To contact you in order to invite you to apply for open positions.

4.2. To comply with applicable laws and regulations and for our legitimate business interests, including to:

• Ensure compliance with legal requirements, including, but not limited to right to work checks and diversity & inclusion requirements and practices;
• Maintain records in relation to recruiting and hiring.
• Conduct pre-engagement background checks for anti-money laundering and counter financing terrorism, sanctions, credit and criminal record, where required or where permissible by law.

4.3. To improve our recruiting and hiring process and augment our ability to attract successful candidates for our legitimate interests.

We have in place different information security policies and procedures to manage the security of the information we hold and process. to ensure we protect your personal data and other information. All these policies & procedures are constantly reviewed to adapt to new technologies and applicable regulations.

Please know, however, that no data transmission, processing or storage system can be guaranteed to be 100% secure.

If you have reason to believe that your interaction with us is no longer secure, please contact us immediately at: [email protected]

 

5. HOW LONG WILL SMALL WORLD RETAIN YOUR DATA:

We keep your personal data and other information only as long as necessary for the purpose it was collected.

Once our relationship with you has come to an end, in particular, when your application for employment has been concluded and has not resulted in an accepted offer of employment, or following an accepted offer, your employment with Small World has been terminated for whatever reason, we will only retain personal data that enable us:

• Maintain business records for analysis and/or audit purposes;
• Defend or bring any existing or potential legal claims;
• Comply with record retention requirements under the law, in particular, as required under legislation concerning the prevention, detection and investigation of illegal work.

Once personal data and/or other information is no longer needed for its initial purpose it will be deleted in accordance with our policies and procedures related to data retention and data disposal.

The personal data retention period shall vary depending on the purpose for which it is retained, however data will only be held for the minimum period needed. Retained personal data and other information are also protected according to our Information Security policies and procedures.

 

6. HOW SMALL WORLD SHARE AND DISCLOSE YOUR INFORMATION:

We may share and disclose personal data and other information with:

• Small World Group companies such as:
• LCC Trans-Sending Ltd
• LCC Trans-Envio SPRL
• Choice Money Transfer Inc
• Small World Financial Services (Canada) Limited
• Swiss Transfers GmBH
• Small World Financial Services, Africa SA
• Small World Financial Services Ireland Ltd
• Small World Financial Services Norway AS
• Small World Financial Services Spain SAU (including branches incorporated in Ireland, Germany, Netherlands & Italy)
• Small World Financial Services Denmark ApS
• Small World Financial Services Sweden AB
• SW Brasil Services Financeiros e Turismo Ltda
• Small World Exchange Services Spain SLU
• Trans-Envio, Unipessoal LDA
• MoneyGlobe SAS

 

• Our vendors that provide us with services related to information technology and related infrastructure provision, such as website hosting, data centers and cloud computing;
• Our vendors that help us conduct recruitment campaigns and whom source candidates on our behalf;
• Our vendors that help us comply with background screenings where required or permitted by law, in particular, anti-money laundering and counter financing terrorism laws and regulations;
• Other third parties in the event of a reorganisation, merger, sale, joint venture, assignment, transfer to other disposition of our business, assets or stock, or in any bankruptcy or similar proceedings; and
• Law enforcement agencies, regulatory agencies, security authorities or other financial entities, when required or permitted by law, in particular, anti-money laundering and counter financing terrorism laws.

When you apply for an open position at Small World you understand that your personal data and other information may be transferred to a country other than your own for processing or storage. You also understand that data protection rules of other countries may be different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal data or other information.

To ensure an adequate level of data protection in the case of international data transfers, we rely on widely recognised data protection mechanisms, such as adequacy decisions or Standard Contractual Clauses approved by the European Commission or any other privacy or data protection authority in the world.

The mechanisms mentioned above are particularly in place for data transfers from inside the European Economic Area (EEA), Switzerland or from any other third country or jurisdiction in the world (like the US or UK) that requires the existence of adequacy decisions or appropriate safeguards for international data transfer. We may transfer your personal data and other information outside the European Economic Area and Switzerland, such as to the United States or UK (where our main operational data centres are located) for our legitimate interests or in case it is needed to fulfill the recruitment process.

 

7. WHAT ARE YOUR RIGHTS?

You can exercise (to the extent provided to you by applicable law) your rights to access; to rectification; to erasure; to restriction of processing; to data portability; to object and to not to be subject to automated individual decision-making; and/or to make a complaint about how Small World process your personal data, by contacting us at:

Group Data Protection Officer

[email protected]

Paseo del Club Deportivo 1, Edificio 13 - Pozuelo de Alarcón, Madrid – Spain (28223)

In order to process your data protection right requests, Small World may need to verify your identity for your security and protection of your personal data and other information. We will respond to your request without undue delay and within the applicable time period.

If you consider that we have not given you a satisfactory response to your request to exercise a right or complaint, you can file a complaint with the competent Data Protection Supervisory Authority.

For your information, our Lead Supervisory Authority within the European Union (EU) is the Spanish Data Protection Agency (Agencia Española de Protección de Datos - AEPD). Please visit www.aepd.es for further details.

For complaints related to UK operations or processing, the competent data protection supervisory authority is the Information Commissioner's Office (ICO). Please visit https://ico.org.uk/ for more information.