Applying for a Role at Paddle: Candidate Privacy Notice

We take data privacy seriously and we ensure the highest level of protection and diligence when it comes to the collection, use and retention of the personal data of all candidates applying for a position at Paddle.

We care about your personal data and want you to be informed about how we use your personal data in the hiring process and the rights you have in relation to your personal data. Below you’ll find information about the personal data we collect, what we do with it, with whom we share it, how we secure it, how long we store it for and what rights you have as an applicant.

This information relates to anyone applying for a role at Paddle, so please read it through carefully.

Last updated 22 June 2022

What is the purpose of this document?

You are being provided with a copy of this privacy notice because you are applying to work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for.  It also provides you with certain information that must be provided under applicable privacy laws.

Your data controller

Paddle.com Market Ltd. ("we" or the "Company") and its group entities (together the "Group") are 'data controllers'.  This means that we are each responsible for deciding how we hold and use personal data.  The specific data controller for your personal data will depend on which recruiting Paddle entity that employs you (please see the details at Appendix 1 for details of the relevant Paddle group entity).

The kind of information we hold about you

In connection with your application for work with us, we will collect, store, and use the following categories of personal data about you:

• any information you have provided to us in your CV and covering letter;
• the information you have provided by way of an application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications; and
• any information you provide to us during an interview.

We may also collect, store and use the following "special categories" of more sensitive personal data, where you choose to share it with us:

• information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.

How is your personal data collected?

We collect personal data about candidates from the following sources:

• you, the candidate;
• third party recruitment agencies who may represent you;
• your named referees, from whom we obtain a standard reference; and
• data from third parties from a publicly accessible source e.g. results of social media searches such as LinkedIn. 

How we will use information about you and on what lawful basis

We will use the personal data we collect about you to:

• assess your skills, qualifications, and suitability for the role;
• carry out reference checks;
• communicate with you about the recruitment process;
• keep records related to our hiring processes; and
• comply with legal or regulatory requirements.

Having received your application, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role.  If you do, we will decide whether your application is strong enough to invite you for an interview.  If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role.  If we decide to offer you the role, we will then take up references and carry out any other relevant checks before confirming your appointment.

It is in our legitimate interests to decide whether to appoint you to the role since it would be beneficial to our business to appoint candidates to open roles.

We also need to process your personal data to decide whether to enter into a contract of employment or engagement with you and comply with legal obligations relevant to recruitment to which we are subject (such as establishing right to work status).

If you fail to provide personal data

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully.  

How we use particularly sensitive personal data

We will use your particularly sensitive personal data in the following ways:

• We will use information about your health and disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made.
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting. Data that the Company uses for these purposes will be collected on an anonymised basis.  Candidates are entirely free to decide whether or not to provide such information and your application will not be affected either way.

Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Recipients of your personal data

We may disclose your personal data to members of our HR team, the relevant team managers in respect of the role you are applying for in order to make hiring decisions.

It may be necessary from time to time for us to disclose your personal data to third parties or agents, including without limitation to the following:

• third parties or agents of clients to assist in the administration, processing and management of certain activities pertaining to prospective employees including travel and expense management service providers;
• other organisations within our Group;
• individuals or companies employed by the Company to carry out specific services, functions or consultancy work and other financial institutions;
• regulatory bodies to whom we are obliged or required to disclose information including Workplace Relations Commission, Courts and Court-appointed persons;
• relevant Government departments and agencies; and
• other support service providers necessary to support the organisation in the services listed.

Transfer of personal data outside the EEA

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"), for the purposes described above.  Due to the global nature of our business, your personal data may be disclosed to members of our group outside the EEA, including in particular in the USA.  It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers who act on our behalf. We will ensure appropriate safeguards, such as approved standard contractual clauses, are in place to protect the privacy and integrity of such personal data.  Please contact us using the relevant details in Appendix 1 if you would like more information concerning such safeguards.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need-to-know.  They will only process your personal data on our instructions and they are subject to a duty of confidentiality.  

How long will you use my information for?

Successful applicants

If your application for employment or engagement is successful, personal data gathered during the recruitment process will be transferred to our HR management system and retained during your employment in accordance with our staff privacy policy.

Unsuccessful applicants

If your application for employment or engagement is unsuccessful, we will hold your data on file for 12 months after the end of the relevant recruitment process to the extent necessary to enable the Company to comply with any legal obligations or for the exercise or defence of legal claims (subject to any applicable legal or regulatory obligations to retain such information for a longer period).

At the end of that period we will securely destroy your personal data in accordance with applicable laws and regulations.

In the event that any court actions or other legal proceedings are pending or impending, personal data will be deleted after termination of the court action or legal proceeding as appropriate.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.  You also have the right to object where we are processing your personal data for direct marketing purposes.
• Request the restriction of processing of your personal data.  This 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.
• Request the transfer of your personal data to another party.

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact the relevant data controller using the details in Appendix 1.

Complaints

You have the right to lodge a complaint with a supervisory authority if you are unhappy with how your personal data is being handled.

Further Information

If you require any further clarification regarding this privacy notice, please contact the Paddle Legal Department by email at privacy@paddle.com.

If you’ve been talking to a member of our Talent Acquisition team, they’ll also be happy to handle this request.

List of Paddle Group Data Controllers

The specific data controller for you will depend on the Paddle group entity you eventually employed by. These are as follows:

Paddle.com Market Ltd.

Judd House, 18-29 Mora Street, London, EC1V 8BT, UK

Paddle.com Inc.

54 W. 40th St. New York, NY, 10018, USA

Paddle Payment Ltd.

Limerick House, Limerick Lane, Newbridge, Kildare, Ireland

200OK LLC

129 Kingston Street 3rd Floor, Boston, Massachusetts, USA

All controllers can be reached at privacy@paddle.com.