Open Payment Technologies Ltd, (“The Company”), with registered office at Second Floor, The Old Court House, Athol Street, Douglas, Isle of Man, IM1 1LD is responsible for the processing and protection of your personal data, and in accordance herewith the Isle of Man Data Protection Act 2002 and the implementing regulations relating to the introduction of the GDPR 2018 (“The Data Protection Rules”), informs you that it will process the personal data and sensitive personal data, listed below, for the purposes indicated in this Privacy Policy.

Consent.

By accepting this Privacy Policy, you expressly consent to the use and processing of your personal data by the Company, for the exclusive purposes defined in this Privacy Policy.

The use of your personal data provided includes storage, either in a register or in a database, by your own means or provided by third parties; and processing, can be both automated or non-automated in nature that allows the collection, storage, recording, organization, elaboration, selection, extraction, comparison, interconnection, dissociation, communication, assignment, transfer, transmission, or cancellation of personal data.

Declaration

It is stated that, to comply with this privacy statement, you must be of legal age and certify that the information you provide is accurate and truthful at the time of accepting this Privacy Policy. If you require a modification, we ask that you notify us as soon as possible in accordance with the procedure established in the section on the exercise of privacy rights.

Please note that to comply with this privacy statement you must be of legal age, nowhere on our website, platform or job boards will we knowingly collect personal data or information from minors.

What personal data will we use and how do we obtain it?

The Company may collect your data directly, through the internal job board, for any job application that you send us, or we collect by physical and/or electronic means through the use of technologies, such as mail, cookies, website and mobile applications. We may also collect your personal data indirectly through publicly accessible sources, external job boards, even social networks.

All personal and sensitive data that, as part of the personnel registration process and the selection and recruitment of candidates, will be safeguarded with the technical, administrative and physical security measures necessary to guarantee the protection of your information, will only be used for the purposes described herein.

If You are an employee:

Personal Data: 1) Identification Data, 2) Contact Data, 3) Financial, Tax and National Insurance Data, 4) Employment Data, 5) Professional and Academic Data, 6) In the case of non-local individuals: Details and documentation required within the framework of immigration laws, such as citizenship, passport data, residence or work permit details, country of origin and domicile of country of origin, 7) Data on administrative procedures followed in the form of a trial and/or jurisdictional, 8) Access photograph, images captured by video surveillance cameras, if you attend or are in our offices, if applicable, 9) Photographs, videos or personal image, image and/or voice records and authorizations, 10) Personal references and family data.
Sensitive Personal Data: 1) Health Data, 2) Physical Characteristics, 3) Life and Personal Habits, 4) Psychometric Data, 5) Only in cases where the position is of a high level or if required by the relevant Regulator(s), may you request a criminal record.

If you are a candidate or applicant:

Personal Data: Identification data, employment data, academic data, personal data contained in your CV, data contained in immigration documents (if applicable), reason for departure, positions held, seniority, social security number, economic or financial data (related information, gross and/or net income), as well as socio-economic studies and data of third parties such as professional and/or personal references (Name, telephone, address).
Sensitive Personal Data: Depending on the position for which you are applying, the following may be collected: Psychometric data, technical tests, intelligence, reasoning, behavior, personal data related to the execution of tests as part of the documentation process for the identification of the candidate. Only in cases where the position is of a high level or if required by the relevant Regulator(s), may you request a criminal record.

Personal data of third parties.

In order to comply with the legal obligations acquired with you, the Company may process personal identification and contact data of third parties, whether family and/or work references that will be provided to us by you, solely for the purpose of verifying your references and information given by you, for which you are obliged to inform such third parties about the processing of your personal data and the purpose.

What are the purposes of the processing?

Employees: We will use the personal data we collect from you for the following primary purposes, which are necessary to formalize the employment relationship: 1) Training and measurement of development skills, 2) For everything related to the fulfillment of payments, provision of employment benefits and other additional benefits that the Company may provide, 3) To comply with fiscal, employment and judicial obligations, as well as to identify and keep a record of the employees who work in any of the Company’s offices to which it provides services, 4) To carry out operational and/or administrative activities, which include internal or external campaigns, 5) Monitoring of the activities carried out in the computer equipment assigned for analysis and performance evaluation, 6) Data update for emergencies, as well as for the generation of employee numbers and institutional email.

The databases that are generated for the fulfillment of our obligations will be in accordance with the applicable legislation, they will only be managed by passwords and by internal personnel of the Company (or if applicable with a Data Processor, with which the Company has entered in to an Agreement with. The Company will at all times ensure that any outsourcing arrangement has the same or comparable Data Protection rules). with the sole purpose of complying with what is described in this notice, likewise, said information will always be safeguarded and handled only for the purposes described herein.

Candidate or applicant: 1) For all purposes related to selection and recruitment, 2) verify references of previous jobs, educational level, validation of information related to the curriculum vitae, socioeconomic studies, internal and external job bank with authorized third parties, talent attraction programs, timely information on job offers or vacancies that arise in the Company, 3) evaluation, training and measurement of development skills, make recruitment and selection decisions, conduct interviews, whether in person or remotely, 4) make evaluations and exams for hiring, evaluate the candidate’s skills and knowledge in relation to those required for the execution of the vacancy offered, 5) In case the candidate is not a local Isle of Man resident, validate their legal stay on the Island and if they have authorizations to perform a job in the Isle of Man, 6) carry out employee investigations, as well as request personal and work references to know the candidate’s background, and evaluate their suitability, 7) maintain communication with the candidate during the recruitment and selection process by the means established by the Company, 8) Make a comparison between the compensation and current salary of the candidate in order to prepare an offer.

In addition to the aforementioned purposes, all personal data may be used for the purpose of complying with the legal obligations of the Company.

Legal basis for processing

For the processing of personal data, the Company starts from the following legal bases:

a. Consent. Based on the consent you provide us for the processing of your personal data during your application and the selection and recruitment process.
b. Contractual and pre-contractual relationships. We process personal data to formalise the employment relationship and to comply with the respective legal obligations we have with the different authorities.

How long do we store your personal data?

We will keep your data only for the period strictly necessary for the respective purposes of the processing or for the legal period, if applicable.

Who do we share your data to?

The Company shares your data with other entities of the business group that operate under the same standards, processes and/or internal policies under which the group businesses operate and may also share the data with companies that provide us with recruitment services, to fully comply with the services, we offer.

The Company also shares data with sub-processors, such as service providers or business partners with whom the Company has a legal relationship. Such service providers or business partners comply with the same data protection standards as the Company.

The Company confirms that it does not transfer data to third parties, except in exceptional cases and that the Company does not require your consent, as provided for in the applicable legislation, such as those necessary or legally required to safeguard a public interest, or for the prosecution or administration of justice.

How can you exercise your privacy rights?

You have the right to request, in accordance with The Data Protection Rules, confirmation of the existence of the processing of personal data (information); to have access to your data, to request the availability of a copy of the personal data you have provided to us (access); the rectification of incomplete, inaccurate or outdated data (rectification); the revocation, at any time, of your previously given consent to data processing, as well as information on the possibility that you do not consent to certain data processing and the consequences of not consenting (revocation); anonymization, blocking or deletion of data that is unnecessary, excessive or processed in violation of applicable legislation on personal data, (deletion); object to the use of your personal data for specific purposes (objection); limit the processing of your data (limitation), the portability of your personal data to another service or product provider (portability), as well as information about the public and private entities with which we share data.

To exercise any of the rights mentioned above, you will need to send a request to the email address dataprotection@kuady.com which you will need to comply with the following requirements and documents:

1. Full name of the interested party.
2. Copy of the document proving your identity on both sides.
3. If the holder appears through a legal representative, he or she must also show, by the same means, the documents that prove the legal representation (simple power of attorney signed by the holder, the attorney and two witnesses, accompanied by a copy of the identifications of the attorney and the two witnesses);
4. Clear and precise description of the personal data with respect to which you seek to exercise any of the rights.

Requests will be dealt with under the terms provided for by the Data Protection Rules through our data protection officer, who can be contacted for questions or clarifications through the email address dataprotection@kuady.com

Security of personal data

The Company maintains technical and organizational security measures to prevent the loss, theft, modification and/or unauthorized access to your personal data, such as access controls, minimization of the number of people accessing data, implementation of cybersecurity tools such as firewalls, antivirus, as well as monitoring of our recruitment system based on the Data Protection Rules.

You are also informed that in case you do not want your application to be kept in our system, the information will be deleted from our database.

How can you find out about changes to this Privacy Policy?

This Privacy Policy may be modified, changed, or updated as a result of new legal requirements, our own needs for the products or services we offer, our privacy practices or changes in our business model or other causes. The responsibility for this Privacy Policy lies with the Board of Directors of the Company.

The procedure through which notifications about changes or updates will be carried out will be through an informative notice on our website, by email or any other technological means available at the time.

Last updated: July 2024