Last updated: April 22, 2024

This Candidate Privacy Notice (“Notice”) describes how Nium Pte. Ltd. and its subsidiaries and affiliates (collectively, “Nium”, “we”, “us” and “our”) collects, uses, and discloses information about individuals who apply for positions at Nium (“you”, “your”, “yours”).

1. Types of Personal Information We Handle

We collect, use, and store various types of information that identifies, relates to, or could reasonably be linked to you (“personal information”) in connection with your application for employment with us. We collect such information either directly from you or (where applicable) from another person or entity, such as professional networking websites, job posting websites, employment agencies, recruitment companies, academic institutions, background check providers, or your professional references. We may collect additional personal information throughout the course of your application process.

The information we collect from and about you includes, where applicable:

• Identifiers, such as first and last name, postal address, telephone number, and email address, and, if provided an offer, identifiers related to your citizenship documents, such as Social Security Number, national ID card, passport, and copies of work permits and birth certificates (which include date and place of birth).
• Professional or employment-related information, including:

• • • Recruitment, employment, or engagement information, such as application forms and information included in a resume, cover letter, or otherwise provided through the application and recruitment process; information about your eligibility to work in the country where you are applying for a job, such as information related to citizenship and/or immigration status; references; our evaluations of your performance during the interview process; and if provided an offer, background screening results (including any criminal convictions).
    • Career information, such as past employers, titles, job history, work dates and work locations, salary expectations, notice period, and information about skills, qualifications, and experience.

• Education information, such as institutions attended, degrees, academic record, certifications, licenses, transcript information, and professional memberships.
• Business travel and expense information, such as travel itinerary information and expenses incurred for travel during the interview process.
• Audio or visual information, such as CCTV footage, as well as other information relating to the security of our premises collected during in-person interviews or other parts of the recruitment process, and video or audio recordings of events and recruitment activities.
• Internet and electronic network, and device activity and device information and related identifiers, such as information about your use of our network while you are on our premises, including IP address and device identifiers and attributes.
• Potentially protected classification information to the extent required or as permitted by law and voluntarily provided such as race/ethnicity, nationality, sex/gender, gender identity, citizenship, religion, marital status, military service, disability, race, accommodation information, and other information to help us monitor compliance with equal opportunity legislation.
• Other information that you may voluntarily choose to include on your resume, in connection with your application, or otherwise.

2. How We Use Personal Information

We may collect, use, disclose, and store personal information for our business purposes, which include, where applicable:

• Engaging in the recruitment process, including communicating with you, interviewing, and selecting and hiring new personnel.
• HR management and administration, including determining compensation, scheduling, IT and informational security purposes, fraud prevention, and conducting internal analyses and audits.
• Security operations, including detecting security incidents, debugging and repairing errors, and preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution; monitoring and controlling access to our premises and locations (including through use of CCTV); and safeguarding Nium and its locations, services, and employees.
• Safeguarding Nium and our services, including the protection of Nium, our workforce, users, partners, and others.
• Legal compliance, such as complying with applicable laws, and responding to and cooperating with legal or regulatory requests and investigations.
• At your request, to fulfil your instructions.
• Exercising our legal rights, including seeking legal advice from our external lawyers or in connection with litigation with a third party.

We may also use personal information for any other legally permitted purpose (subject to your consent, where legally required).

Some personal information we collect in the recruitment process, such as ethnicity and veteran status, may be considered “sensitive” under applicable law. We use such information only for equal employment opportunity purposes. Some “sensitive” information may be required for certain job applications.

Some jurisdictions require us to state our “legal bases” for processing your personal information as described in this Notice. These legal bases are:

• Contract: We may process your personal information as necessary to perform a contract with you, such as to administer payroll and provide benefits.
• Legal obligation: We may process your personal information to comply with a legal obligation or request, such as to comply with employment and tax regulations.
• Legitimate interest: We may process your personal information for purposes of our or another party’s legitimate interests, such as to maintain the security of our premises, personnel, and property.
• Consent: We may process your personal information consistent with your consent to the extent permitted by applicable law.

3. How We Disclose Personal Information

We may disclose certain personal information to the following types of entities or in the following circumstances, where applicable:

• Internally: To employees within Nium who participate in the recruitment process, such as HR managers and employee interviewers, and among our corporate affiliates.
• Vendors: Such as background check companies, security providers, information technology providers, travel management companies, and employment businesses (e.g., recruiting contractors or agency workers) that provide us with services relevant to recruiting and hiring.
• Recruiters: To the extent you are working with a recruiter in connection with your application for employment and your recruiter is authorized by you to obtain feedback from us regarding your application and interview process.
• Legal compliance and exercising legal rights: (i) When required to do so by law, regulation, or court order, (ii) in response to a request for assistance by the police or other law enforcement agency; (iii) to seek legal advice from our external lawyers or in connection with litigation with you or a third party or (iv) as otherwise necessary to exercising our legal rights or to protect Nium or its employees.
• Business transaction purposes: In connection with the sale, purchase, or merger of all or a portion of our company.
• Consent: With your consent and as permitted by law, we may disclose personal information to any other parties in any other circumstances.

4. Data Retention

The personal information we collect from you will be retained until we determine it is no longer necessary to satisfy the purposes for which it was collected and our legal obligations. As described above, these purposes include our business operations and complying with reporting, legal and accounting obligations. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of the personal information, the purposes for which we process the personal information and whether we can achieve those purposes in other ways, the applicable legal requirements, and our legitimate interests.

5. Personal Information Rights

Depending on your jurisdiction of residence, you may have certain rights regarding your personal information, subject to certain exceptions and limitations as provided by applicable law:

• Right to Know and Access: You may request to know and receive a copy of the personal information we hold about you. You can also request to port your information to another entity, where technically feasible.
• Right to Delete: You may request deletion of certain information we have about you.
• Right to Correct: You may request to correct or update personal information held by us that is incomplete or inaccurate.
• Right to Object or Restrict Processing: You may have the right to restrict or object to your personal information being processed for certain purposes.
• Right to Withdraw your Consent: To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. However, please note that we may not be able to continue providing the Services to you as a result.
• Right to Opt-Out: You have the right to opt out from the sale and sharing of your personal information, including the processing of your personal information for purposes of targeted advertising.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your rights provided under the law.
• Right to Lodge a Complaint: You may lodge a complaint about our practices with respect to your personal information with the supervisory authority of your country or state.
• Right to Appeal: As provided by applicable law, you may have the right to appeal our decision to deny your request. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you.

Where we process your personal information based on your consent and not another legal basis, you may withdraw consent to further processing. However, withdrawing your consent only affects our processing after the withdrawal.

Exceptions: There are certain exceptions to the above rights. For instance, we may retain your personal information if it is reasonably necessary for us or our service providers to provide a service that you have requested, to comply with law, or to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for that activity. In addition, we reserve the right not to process requests that are manifestly unfounded or excessive, as provided in applicable law, or that we are not legally obligated to process.

Exercising your rights: To exercise your rights, please contact us and specify the right(s) you want to exercise and the personal information which you want to exercise such right(s). You can submit your request by emailing us at [email protected]. We may take reasonable steps to verify your identity before responding to a request, and to do so, we may ask you for additional information to verify your identity.

California disclosure: California law places certain obligations on businesses that “sell” personal information to third parties or “share” personal information with third parties for “cross-context behavioral advertising” as those terms are defined under the California Consumer Privacy Act. We do not “sell” or “share” the personal information covered by this Notice and have not done so in the twelve months prior to the effective date of this Notice.

6. International Transfers

We operate globally and in accordance with applicable law, may transfer, store, and/or process your personal information to or with other entities within the Nium or other third parties such as trusted service providers and partners in locations around the world. The data protection laws of these locations may not provide the same protections as the data protection laws in the jurisdiction where you reside. Wherever your information is transferred, stored or processed by us, we take reasonable steps to protect your information in accordance with this Notice and applicable laws. These measures may include implementing standard contractual clauses and/or international data transfer agreements to govern the transfer of your information, or other means recognized by applicable laws. By providing us with your information, you acknowledge and agree to any such transfer, storage, or processing.

7. Contact Us

If you have questions about our handling of personal information under this Notice, please contact us at [email protected].