Candidate Privacy Notice

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 Quadrature Climate Foundation (“QCF”), 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. We also may provide you with additional information when we collect personal data, where we feel it would be helpful to provide relevant and timely information.

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 QCF ¹ to enter into an employment 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 QCF 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.
Where necessary for Quadrature or QCF’s legitimate interests, as listed below, but only where our or QCF’s 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;
- to contact you about future career opportunities at Quadrature or QCF;
- to protect our and QCF’s 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 QCF’s workforce in accordance with applicable laws. This includes, for example, compliance with equal opportunity employment laws.

Where we or QCF require the information to enter into an employment contract with you, or where we or QCF are required under applicable employment, social security, social protection or other laws, the provision of information is mandatory. Where you do not provide your personal data to us, then we or QCF would be unable to enter into a contract with you or we or QCF may need to withdraw our offer of employment for certain roles, such as regulated roles. All other provision of your information is optional. Where you do not provide the relevant data for in these circumstances, the consequences will be explained to you at the time. However, these can include Quadrature or QCF being unable to provide certain benefits to you or make relevant adjustments in the course of your interview process.

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 prior to performing such checks.

HOW WE SHARE YOUR PERSONAL DATA

Your personal data will be shared with companies providing services under contract to Quadrature or QCF 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 a Quadrature business or QCF 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

IF YOU ARE IN THE UK OR THE EU:

If you are a resident of the UK or the EU, you have the following rights, including 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 (in particular, where we don’t have to process the data to meet a contractual or other legal requirement)
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 Quadrature 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/.

IF YOU ARE A RESIDENT OF BRAZIL:

If you are a resident of Brazil, you have the following rights, including the right to:

request confirmation of whether we process your personal data;
request that we provide you with access to a copy of your personal data;
request that we correct the personal data we hold about you (if the data is inaccurate, incomplete or outdated);
request that we anonymise, block or delete unnecessary or excessive data or data that is not being processed in compliance with applicable law;
request that we port your personal data to another service or product provider, by means of an express request and subject to limitations under applicable law;
request that we delete the personal data we hold about you, except where we are permitted to retain such data under applicable law;
request information about the public and private entities with which we have shared your personal data; and
request information about the possibility of denying consent and the consequences of such denial.

Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Quadrature 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.

We will confirm receipt of your request within five days, and we will respond within 15 days if the data requested is not in simplified format. Any information will be provided to you free of charge.

IF YOU ARE A RESIDENT OF CALIFORNIA:

If you are a resident of California, you have certain consumer rights under the California Civil Code and applicable California privacy laws, which may be subject to certain limitations and/or restrictions. Specifically, under California law you have the right to:

request that we disclose information about (i) the categories of personal data collected; (ii) the sources from which the personal data was collected; (iii) the business or commercial purpose for collecting the information; (iv) the categories of third parties with whom we share the information; and (v) the specific pieces of personal data we collect about you;
request that we delete your personal data; and
opt out of the sale of your personal data.

We do not, and will not, sell your personal data and you will never receive discriminatory treatment for exercising your privacy rights.

You may use an authorised agent to submit a request on your behalf in relation to the rights listed above. When using an authorised agent, we will require that you provide your agent with written permission to do so, and verify their own identity and agent status with us. If you would like to designate an authorised agent to make a request on your behalf, please email us at privacy@quadrature.ai

We may need to verify the identity of a person making a request under this section and this may require that we request further information on the person making a request. If we cannot verify your identity in accordance with California law, we may deny your request in whole or in part.

For requests to know and requests to delete, we will confirm receipt of the request within ten days and provide information about how the business will process the request, and we will respond within 45 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.

Please note that we cannot provide you with information on your data more than twice in a 12-month period.

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 the toll-free telephone number +1 833 7474784; (ii) submit a webform request here or (iii) send an email to privacy@quadrature.ai.

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 Quadrature’s or QCF’s legitimate interest in accordance with applicable law, for the purposes of the recruitment process and, once this process is finished, for an appropriate period so as to be able to deal with any legal claims linked to the application process. 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 a Quadrature employee, personal data you provide will become a part of your employee file and may be used later for the management of the employment relationship in accordance with Quadrature’s privacy policies. If you become a QCF employee, personal data you provide will become a part of your QCF employee file and may be used later for the management of the employment relationship in accordance with QCF’s privacy policies.

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 European Economic Area (“EEA“) by certain service providers to be able to administer personnel records in jurisdictions that do not have equivalent data protection laws to those in the EEA, Brazil or California for the purposes outlined above.

When we transfer your data to organisations outside Quadrature, we make use of standard contractual data protection clauses, which have been approved by the European Commission or other relevant government bodies or authorities to safeguard the transfer, unless we transfer personal data to a third party that has implemented Binding Corporate Rules or which uses the EU-US Privacy Shield, in which case we may rely on one of those mechanisms to safeguard the transfer. 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 at least annually. 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

¹ Quadrature provides recruitment and HR management services to QCF. As such, personal data requested or provided in connection with an application for a QCF role will be processed by Quadrature. Quadrature and QCF have entered into appropriate agreements to ensure that the sharing of data is in accordance with legal and regulatory requirements.