Taptap Send Global Privacy Policy for Candidates

Effective Date: 22 January 2024
Version number: 1.2

  1. Introduction

This Policy explains what you can expect from us and what we need from you in relation to your personal data. Personal data means any information about an identified or identifiable individual. It does not include anonymous data, which cannot be linked back to an individual.

The Taptap Send Group (“Taptap Send” or “we” “our” “us”) offers a software platform and services to help individuals send money to emerging markets. As we are based globally, our office locations which hire for positions are considered at all times as separate data controllers (see below for the contact information for each entity). None of our office locations are considered as joint data controllers for recruitment at any time. Depending on your country / region, the relevant data controller is:

● EU: Taptap Send Belgium S.A. Address and company information here. Phone +32 460 20 73 09.
● UK: Data controller: Taptap Send UK Limited. Address and company information here. Phone: +44 808 168 7707.
● US: TapTap Send Payments Co. Address and company information here. Phone: +1 833 916 0670.
● Canada: Taptap Send Payments Canada Inc. Address and company information here. Phone: +1 833 916 0670.
● UAE: Taptap Send (DIFC) Limited. Address and company information here. Phone: +971 800 03 212 18.
● Morocco: Taptap Send Morocco. Taptap Send Morocco is incorporated in Casablanca, Morocco, with company number 521757, registered address Rue Soumaya, Residence Schehrazade 3, 5th floor, N° 22, 20340, Casablanca, Morocco.

In this Policy, we sometimes refer to “You”. “You” are a potential employee or contractor of Taptap Send.

You can contact us about your privacy, to exercise your data rights and for information about how we use, process, store and protect your personal data by emailing us at privacy@taptapsend.com. We have appointed data protection officers. If you have any questions or concerns about data protection, you can contact them using the details below:

Your location Data Protection Officer (“DPO”)
UK, US, Canada or Europe Our DPO is Evalian Limited, you can contact them at:
Website: www.evalian.co.uk
Address: West Lodge, Leylands Business Park
Colden Common, Hampshire
SO21 1TH, United Kingdom
UAE We have appointed a DPO to oversee compliance with this Policy. If you have any questions over how we protect or use your personal data, please email our DPO at privacy@taptapsend.com

  1.   Lawful basis

The lawful basis for our recruitment process is contractual obligation, to help us enter into or take the necessary steps required to enter into employment contracts.

We do not rely on consent for our recruitment activities at any time.

  1.   Collecting personal data

We receive personal data during the application and recruitment process through various means, which includes (but is not limited to):

● Directly from you
● Recruiters
● Former employers
● DBS / background check providers
● Credit reference agencies
● Specified referees
● Recommendations from staff/officers

In connection with your application for the role, you may have have to provide us personal data :

● Name
● Address
● Email
● Phone number
● Current job details
● Past and present work experience
● Work / academic qualifications
● Other information provided to us in your CV or cover letter
● Social network (such as your LinkedIn profile)
● Salary expectations
● Language proficiency
● Information provided to us during your interview
● Information about your demographic, race and/or ethnicity
● Any additional information you provide to us

We may need to process special category personal data (e.g. disability information) as part of the recruitment process which we have detailed below. If a candidate informs us that any adjustments are needed (e.g. wheelchair user or visually impaired) we will be sure to document this and keep it safe and secure, and make it available to those who need access to this personal data. This personal data will also be held for as long as necessary under our Personal Data Classification, Retention and Destruction Policy.

  1.   Data Use

We are required to process your personal data in order to further our legitimate interests in determining whether to hire you for the role. We may use your personal data in the following ways:

● Assessing your skills, qualifications and suitability for the role
● Carrying out reference checks, where applicable
● Communicating with you about the recruitment process
● Keeping records related to our hiring process
● Complying with our legal and regulatory requirements
● Offering contracts of employment

If you do not provide certain information to us when requested, which is necessary for us to consider your application (e.g., evidence of your qualifications or work history), we may not be able to process your application successfully.

  1.   Criminal conviction and offences data

As a regulated financial institution, we carry out basic criminal background checks as part of our onboarding process for successful applicants. We will only request checks when a job offer has been made and we use a third party to help carry out these checks. Where we do process any criminal conviction and offence data we will ensure the safety and security of this personal data so it is not compromised in any way.

  1.   Data sharing

We may share personal data where required by law, where it is necessary to administer the relationship with you or where we have another legitimate interest in doing so. As mentioned above personal data of job applicants can be shared amongst staff who may be in different countries across the globe, and this may be due to various factors such as a hiring manager being based in a different country to where a hiring position may be based or to encourage any recommendations for any suitable vacancies.

Our global HR team is based in our offices in the UK, so they may receive personal data of any new employees from any territory. When an applicant has successfully become one of our employees, that hiring manager and/or local Taptap Send recruitment representative may then share and transfer any personal data that is relevant for employee onboarding with our UK HR team. Our HR team will be the ones leading the employee onboarding process and will be in touch with the successful person joining us.

We may share personal data with third party companies assisting us in the recruitment process. Personal data sharing for recruitment purposes also helps us to ensure the recruitment process has been carried out in accordance with our recruitment policies and the appropriate files can be created and maintained. We ensure the appropriate safeguards are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.

  1.   Automated Decision-Making and Profiling

We do not conduct any automated decision making and profiling as part of our recruitment process.

  1.   How we protect your personal data

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. If we become aware of any loss, misuse, alteration of personal data we will work closely with our IT team, DPO and other parties as necessary to investigate the incident at hand. We have put into place the relevant procedure and policies in place to investigate, mitigate and report (when needed to relevant parties) such instances. If you feel your personal data has been compromised in any way, please contact us immediately.

  1.   Data retention

We retain personal data for as long as needed as part of our recruitment process. If you have not been successful we will typically retain this data in accordance with our Personal Data Classification, Retention and Destruction Policy so we can show and evidence a fair recruitment process and there is no discrimination on any protected characteristics/grounds. After this period has ended all relevant personal data will be securely destroyed.

Successful candidates will have their recruitment data added to their HR file which is maintained and held by our head office.

  1.   Your Rights

Please see Section 16 of our Global Privacy Policy for information on your data protection rights.

If you would like to exercise any of your rights you can do so by sending us a written request to privacy@taptapsend.com.

  1.   How to complain

If you’re unhappy with how we’ve handled your personal data or any request you have made to exercise your rights, you can complain using the details set out below.

Where you are based How to make a complaint
EU Our lead EU supervisory authority is the Belgium Authority, and you can submit a complaint via this link.
If you are based elsewhere within the European Economic Area a list of supervisory authorities can be found here.
UK You can submit a complaint directly to the UK ICO via this link.
US If you have any concerns about our use of your personal data, you can make a complaint to the Attorney General of your State or Territory of residence, or to our regulator in your State or Territory of residence.
Canada If you are based in Canada, you can contact the Office of the Privacy Commissioner via this link. You can also find a list of supervisory authorities in different provinces here.
UAE For Dubai DIFC privacy complaints, you can contact the Commissioner whose contact details are available using this link.
Morocco For Morocco privacy complaints, you can contact the National Commission for the Control and the Protection of Personal Data.

  1.   Changes to this Policy
    We will review this Policy and make changes to it from time to time. We recommend that you check this Policy to see where changes have been made and to ensure you are able to review updated information at all times.
  2.   What happens if our business changes hands?
    We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will be permitted to use that personal data only for the purposes for which it was originally collected by us.