Version 1.0 effective 10 October 2018
Reference in this policy to “Luno”, “we”, “us”, “our” or any similar term is to Luno Pte. Ltd, who is the data controller.
Luno is committed to complying with data protection laws, including, where applicable, the General Data Protection Regulation. This privacy notice applies to you if you apply to work with us as an employee, contractor or in any other capacity (an Application). It is intended to make you aware of how and why your personal data will be used as part of an Application process.
Luno will comply with the following data protection principles:
When you make an Application, we will collect, store, and use certain personal data about you. This will include the following types of personal data from the following sources:
As part of your Application, we may also need to collect, store, and use certain sensitive personal data about you. This will only happen under the following circumstances and for the following limited purposes:
We use your personal data (other than sensitive personal data, which is used exclusively for the reasons set out in the above section) to evaluate and hire candidates for the relevant role or services and, in particular, to decide whether to appoint you to the role or the services. This may include any of the following specific purposes:
As part of your Application, you have consented to us using your personal data including, where necessary, your sensitive personal data for the purposes set out in the sections above. We acknowledge that your consent has been given for these purposes only. We will not use your personal data for any other purpose whatsoever without your approval.
You have the right to withdraw your consent for us to process your personal data for any of the aforementioned purposes at any time. To withdraw your consent, please send a written request to [email protected]. Upon receipt of such request, we will no longer process your Application and, subject to our retention policy, will dispose of your personal data securely.
If you fail to provide any personal data we have requested, we may not be able to process your Application. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your Application further.
For the purposes of processing your Application, we may share your personal data with:
All our third-party service providers and other entities in the Luno group are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow third-party service providers to use your personal data for their own purposes and only permit the processing of your personal data for specified purposes and in accordance with our instructions.
Luno places great importance on data security and has 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. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need-to-know in the hiring process. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will retain your personal data for a period of 12 months after we have communicated to you our decision about whether to appoint you to the role, unless required by law to retain your personal data for a longer period of time. We retain your personal data for the purposes of recording and establishing that our appointment process is fair and transparent as well as for internal data analytics, internal auditing and talent mapping.
If we wish to retain your personal data for a further period of time, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal data for a further period.
After the relevant retention period, we will securely destroy your personal data in accordance with applicable laws.
The personal data we collect may be transferred to, stored and processed outside of the jurisdiction in which you reside, and the laws of those countries may differ from the laws applicable in your own country. For example, data collected in the European Economic Area (EEA) may be transferred to, stored and processed at a destination(s) outside of the EEA. By providing us with your personal data in accordance with this Privacy Notice, you agree to the transfer, storing or processing of it outside of your jurisdiction.
Your right to access, update, or remove your personal data: Depending on the country in which you live, you may have certain rights under data protection law, including the right to object to the processing of your personal data or to request that we (i) provide you with a copy of your personal data; or (ii) correct, delete, or restrict the processing of your personal data. If you would like to exercise any of the above rights, please send a written request to [email protected].
Contacting Luno in relation to personal data: Should you have any query in relation to this Privacy Notice or how we handle your personal data, please contact us in writing at [email protected].