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Fraud checks aren’t just for payments. Find out how to verify an Airwallex job or recruiter before you share your details.

Recruitment Privacy Notice

1. Introduction

This Recruitment Privacy Notice (“Privacy Notice” or “Notice”) explains how Airwallex (“Airwallex”, “we”, “us” or “our”) collects, uses, stores, transfers and otherwise processes your personal data in connection with your job application and the recruitment process, in accordance with applicable data protection laws. Airwallex is committed to protecting the privacy and security of your personal data. “Personal data” means any information that identifies you (whether directly or indirectly), such as your name, address, telephone number, email address, date of birth, salary, cover letter, and any other data that is associated with you as an individual.

This notice applies to personal data you provide directly to us, including through our careers page or recruitment portal (“Website”), as well as information we receive from third parties in connection with your application or the recruitment process. It applies only to personal data controlled by Airwallex. If you submit your information through third parties, such as recruiters, employers of record providers or job portals, they will process your personal data under their own privacy policies.

2. Data controller

Airwallex is the data controller for the purposes of applicable data protection laws. The relevant Airwallex entity responsible for your personal data depends on your location and/or the entity you contract with, as set out in Appendix I.

3. Types of personal data we process

We may process the following personal data about you as part of the recruitment process with Airwallex:

  • Identifiers such as your name, address, email address, telephone number, as well as demographic information, such as nationality, country of residence, date of birth and gender; 
  • Professional or employment-related information, such as details of your education background, qualifications, skills, professional experience,  employment history and  entitlement to work in the country for which you are applying for employment/engagement at Airwallex ; as well asInformation about your remuneration at your prior employment/engagement, including any entitlement to benefits such as pensions or insurance cover (provided with your consent if required under applicable law);
  • Government identifiers/information as listed under applicable laws, such as a copy of your national identification document and/or national identification, driving licence;
  • Internet or other similar network activity, such as information regarding your interaction on our Website, or in connection with our job postings; 
  • Geolocation information, including approximate location from IP address information;
  • Education information, such as transcripts, degrees, certifications, and other educational qualifying information;
  • Information about your criminal record (only in cases where permitted or required by law);
  • Protected classification characteristics under certain laws (e.g., California or US federal law), such as equal opportunities monitoring information, such as race, ethnicity, religion, disability, veteran status, and sexual orientation; 
  • Any other information you choose to submit to us and/or upload to the Website (such as information from a CV or cover letter) or disclose to us (such as during interviews).
  •  

Some of the categories of personal data listed above may constitute “sensitive personal data” under applicable data protection law, such as information relating to your race or ethnicity, sexual orientation, government identifiers, physical or mental health, or criminal convictions and offences.

We process sensitive personal data in connection with: 

  • Equal opportunities monitoring. Where permitted by law, you may be invited to provide certain sensitive personal data on a voluntary basis, with your explicit consent, for the purposes of equal opportunities monitoring. Providing this data is entirely optional and a decision not to do so will not affect or prejudice your application in any way.
  • Pre-employment background checks. Where permitted or required by law, such checks may be carried out by a third-party screening provider or may require you to supply certain background check information directly.

We use and disclose sensitive personal data only for necessary or required purposes reasonably expected by candidates, and therefore do not offer opt-outs of our use of sensitive data under applicable laws.

4. Purposes for which we process your personal data

The reasons for processing your personal data are to:

  • Recruit, screen, evaluate, interview, and select candidates;
  • Assess, manage and communicate with you in connection with your application and the recruitment process and/or current and future opportunities;
  • Verify the information you provide to us and assess your qualifications, skills, eligibility and suitability for a role;
  • Make hiring decisions and, if your application is successful, take steps to establish and manage the relevant employment, worker or contractor relationship;
  • Carry out related human resources, business administration and record-keeping activities;
  • Review, improve and monitor our recruitment processes and practices, including, where appropriate, diversity and equal opportunity initiatives; 
  • Defend and exercise our legal rights; and
  • Comply with applicable laws.

5. How we collect your personal data

Airwallex may collect your personal data directly from you, or from third parties:

  • From you when you provide information as part of your application and during the recruitment process. You will provide us information about you by using the Website to apply for a role or by corresponding with us by phone, email or otherwise. This includes information you provide when you submit application forms and CVs to us on our Website; from correspondence with you; or when you attend interviews and assessments.
  • From third parties and publicly available sources, such as references supplied by referees, information from recruitment consultancies/agencies, information from third party organizations you use to apply to Airwallex or where you are introduced to us, and information from employment background check providers, credit reference agencies, information from criminal record checks, governmental agencies and public registries as permitted by law. 

6. Our legal basis for processing personal data

Where applicable law requires so in certain countries, we are only permitted to use your personal data if we have a legal basis for doing so. We rely on the following legal bases to process your personal data:

  • Where we need your personal data to perform the necessary activities to recruit and hire you, e.g. to make you a job offer or to enter into an employment contract or agreement with you (if you are a successful candidate). 
  • Where we need to comply with a legal obligation, e.g. we are required to check your right to work status in the country in which you have applied for a position or perform background checks.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we rely on your consent, e.g. we will ask for your (explicit) consent to provide us with information for example, on your race, sex, age and disabilities for the purposes of equal opportunities monitoring, as this information is voluntary. 

7. Use of Artificial Intelligence (AI) and automated technologies

We may use AI-enabled tools during the recruitment process to support administrative and organisational tasks, such as recording interviews and generating interview notes or summaries for our hiring team. These tools are used to assist human reviewers and do not make hiring decisions. All hiring decisions are made by Airwallex personnel with human review and judgment. 

Where required by law, we ask for your consent prior to our use of such tooling. In all other cases, you may opt out of the use of such tools at any time upon notification of this use or by contacting the hiring team directly or through the channels communicated to you during the recruitment process. In general, we do not make any decisions about you solely using automated means, however we will notify you prior to any automated decision-making if this position changes.

8. When and how we disclose your personal data

Disclosures and transfers within Airwallex group

Your personal data may be disclosed to, or accessed by, personnel within any member of the Airwallex group, including employees in the Human Resources department. This may occur for a number of purposes, including the general management, administration, and operation of our business and recruitment processes; regular compliance and reporting activities; business reorganisations or group restructuring exercises; system maintenance and support; data hosting; and the overall administration of the recruitment process. As a result, your personal data may be transferred to any jurisdiction in which Airwallex maintains an office.

Disclosures and transfers to third parties
Your personal data will, in certain circumstances, be disclosed to third parties for the purposes described in section ‎4. These third parties include:

  • External employment agents with which you may conclude an engagement contract;
  • External advisors, professionals and consultants that we use in relation to employment, working and other regulations and practices and matters, work visa, obtaining pre-employment references from other employers, background checks and other employment or engagement related issues;
  • Referees, including your previous or current employers and any professional contacts that have been provided to us, to identify you so they can provide a reference;
  • Recruitment agencies (where one was used, including certain information about your application) and other third party service providers acting on our behalf (for example, some personal data will be available to third parties who provide applicant selection/vetting services);
  • Providers of HR systems, IT services and SaaS applications that we procure from those third party providers;
  • Where Airwallex is under a legal obligation to do so by law, we will disclose your personal data with regulators, courts, the police or tax authorities; and
  • A prospective buyer, new owner, or other third party involved in a change to, sale or transfer of our business. If we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business; or (b) sell or transfer any of our assets, in which case the personal data we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.


When we disclose your personal data to third parties we take appropriate measures designed to safeguard your personal data and to ensure that it is solely used for legitimate purposes in line with this Privacy Notice, including the use of mandated appropriate transfer mechanisms as required by applicable laws. In certain situations, we may be required to disclose your personal data pursuant to lawful requests from local law enforcement or government authorities.

9. Security of personal data

Airwallex takes the security of your data seriously. We implement and update technical and physical security measures to safeguard your personal information against loss, misuse or unauthorized access, use of disclosure on an ongoing basis. Safeguards used to protect your information include firewalls, data encryption, and access controls. Where Airwallex engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organizational measures to ensure the security of data.

10. How long we retain your personal data

We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected. In determining the appropriate retention period, we consider the nature and sensitivity of the data, the purposes for which we process it, and any applicable legal, regulatory, tax, accounting, or reporting requirements.

At the end of the applicable retention period, your personal data will be securely deleted or anonymised. In certain circumstances, we may retain your data for longer where necessary to comply with a legal obligation or to establish or defend legal claims. 

If you accept a position with us, the personal data collected during recruitment will be transferred to your personnel file and retained in accordance with our Employee Privacy Notice.

11. Your privacy rights

As a so-called data subject (an individual), and depending on your location, you may have a number of rights. Under applicable law, you may have the right to: 

  • Request access/know to and obtain a copy of your data; 
  • Require Airwallex to correct, delete or restrict the processing of your data; 
  • Object to the processing of your personal data; 
  • Obtain the personal data you provide to us (e.g. data portability) in a structured, machine-readable format and to ask us to share (port) this data to another organization; 
  • Withdraw your consent where we have processed your personal data based on your consent; 
  • Right to non-discrimination/non-retaliation for exercising rights;
  • Right to launch a complaint with the data protection authority in the country or (EU Member) state in which you live or work where you think we have infringed applicable data protection laws; and
  • Not be subject to automated decisions which produce legal effects or which could have a similarly significant effect on you.


Note that in many cases, your rights are not absolute and we may not be required to comply with your request (in full or part), as these rights are subject to legal exceptions and circumstances. 

To exercise any of these rights, please email us at [email protected]. Clearly state in your request that you are exercising your privacy rights as a job applicant.  

12. Contact & complaints

If you want to reach out to our Data Protection Officer, please contact [email protected].

If you have questions or concerns about this Privacy Notice or wish to make an inquiry regarding how we process your personal data, please contact us at [email protected] and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country or (EU Member) state in which you live or work where you think we have infringed applicable data protection laws.

You have the right to lodge a complaint with the competent supervisory authority in your country or your (EU Member) state of residence, place of work, or where the alleged infringement occurred.

13. Language

Except as otherwise set out by law, in the event of any inconsistency between the English version and local language version of this Privacy Notice (where applicable), the English version shall prevail.

14. Updates to this Privacy Notice

We will post any future changes to this privacy notice on this page. Please check back frequently to see any updates or changes to this privacy notice. 

Appendix 1

List of Data Controllers

Airwallex Entity (individually or collectively, “AIRWALLEX”) Staff Location
Airwallex Pty Ltd or Airwallex SVF Pty Ltd or Airwallex Capital Pty Ltd (as applicable, depending on the employment details and line of business) Australia
Airwallex (Hong Kong) Limited Hong Kong
Airwallex US, LLC United States of America
AW Tecnología México, Sociedad Anónima de Capital Variable Mexico
Airwallex (Malaysia) Sdn. Bhd. Malaysia
Airwallex (Singapore) Pte. Ltd. Singapore
Payment Telecom Informatics Post A Member of Company Limited (CTIN Pay) Vietnam
PT Skye Sab Indonesia Indonesia
Airwallex Korea Co., Ltd. South Korea
Airwallex Japan K.K. Japan
Airwallex (Israel) Ltd United Arab Emirates
Airwallex Middle East Innovation in Financial Solutions LLC United Arab Emirates
Airwallex (Netherlands) B.V. or Airwallex Lithuania, UAB or Airwallex (UK) Limited (as applicable, depending on the employment details, eventual location of role and line of business) EEA/ UK

Appendix II

Supplemental information for candidates in certain jurisdictions

Purposes of this Appendix

  • Some countries’ laws contain additional terms, or require additional disclosures be made, to you, which are set out in this appendix. 
  • If you are located in one of the countries or regions listed below, then the terms set out below under the name of your country apply to you.
  • The following disclosures supplement the Recruitment Privacy Notice.

 

US
CALIFORNIA

If you are a California resident applying for a role with an Airwallex entity, the disclosures in this Section supplement the Recruitment Privacy Notice and apply to you. Defined terms used in this Section have the meanings given in the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, ‘CCPA’). Capitalized terms not defined here have the meanings given in the Notice.

  • Disclosure of personal data

In the past 12 months, we disclosed the categories of personal data described in Section 3, including Sensitive Personal Data , about you, for the business purposes described in sections 6 and 8, to the third parties described in Section 8 above (the “Third Party Transferees”).

  • Sale, Sharing, and Cross-Context Behavioral Advertising – Right to Opt-Out

Sharing for recruiting-promotion purposes / Your right to opt out. Airwallex does not ‘sell’ your personal information for monetary consideration. However, we may ‘share’ your personal information (as that term is defined under the CCPA) – including identifiers such as name and email address – with advertising platforms and similar third parties for the purpose of promoting Airwallex recruiting and reaching candidates with similar professional profiles (for example, lookalike or matched-audience campaigns on professional networking and social-media platforms). This activity may also constitute ‘targeted advertising’ or a ‘sale’ under certain other US state privacy laws.

California residents – as well as residents of other states with applicable US privacy laws – have the right to opt out of this sharing/sale at any time. To opt out, please email [email protected] with the subject line ‘Do Not Sell or Share My Personal Information.’

We do not knowingly sell or share the personal information of consumers under 16 years of age.

  • Right to Limit Use of Sensitive Personal Information

California residents have the right to limit our use and disclosure of Sensitive Personal Information to the purposes specified in CCPA §1798.121(a) and 11 CCR §7027(m). As described in the Global Notice, we already limit our use and disclosure of SPI to those purposes.

  • Shine the Light

California residents may request information regarding our disclosure of personal information to third parties for those third parties’ direct marketing purposes during the prior calendar year. Airwallex does not disclose candidate personal information to third parties for their direct marketing purposes.