Candidate Privacy Notice

1. Overview

AIRWALLEX is committed to protecting the privacy and security of your personal information. This privacy notice describes how the relevant Airwallex Entity to which you apply for a position as an employee, worker or contractor of (referred to in this notice as “AIRWALLEX”, “we”, “us” or “our”) collect, retain, use, store and transfer (“process”) personal data about you in connection with your job application to us and the recruitment process, in accordance with Data Protection Law (as defined below).

This Privacy Policy sets out the basis on which AIRWALLEX processes any personal data that you provide to us, including information that you provide through our careers page on our official Airwallex website and/or through our recruitment portal available on the internet (collectively or individually, as applicable, the “Website”), and other data we receive from you or third parties (such as referees) in connection with your job application.

Please read this notice carefully. This notice only deals with the personal data that we control: you may submit your information via other third parties (e.g. employer of record, recruitment consultants, third party job portals etc.), and they will process your personal data under their own independent privacy policies. We are not responsible for how such third parties process your personal data.

AIRWALLEX processes personal data of potential candidates to serve our legitimate interests, to complete an employment or contractor/worker agreement with you (if you are a successful candidate), and to meet our legal obligations (where applicable). We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations. This privacy notice does not form part of any contract of employment or other contract to provide services. 

Data protection laws which AIRWALLEX is subject to (depending on the relevant Airwallex Entity and the jurisdiction in which you are/would be based if employed) (“Data Protection Laws”), prescribe the way in which AIRWALLEX processes personal data (including sensitive personal data, although sensitive personal data shall be applied to the stricter requirements under Data Protection Laws). References to personal data or sensitive personal data in this notice does not include information that is de-identified in accordance with applicable law or lawfully made publicly available from government records, the employee, or widely distributed media.

2. Your Data Controller

AIRWALLEX is the data controller for the purposes of the Data Protection Laws. The relevant AIRWALLEX entity includes those as set out in Appendix I. If you have any data privacy inquiries and any questions or concerns about this privacy policy, please contact the Airwallex Talent Acquisition Team at [email protected].

3. Types of Personal Data Which We Process

AIRWALLEX collects and processes, and over the past 12 months have collected and processed, the following personal data about you as part of the recruitment process with AIRWALLEX:

  • identifiers, such as your name, address, email address and telephone number date of birth and gender; 
  • the terms and conditions of your latest employment/engagement;
  • professional or employment-related information, such as details of your education background, qualifications, skills, experience and employment history, including start and end dates, with previous employers; 
  • information about your remuneration at your prior employment/engagement, including any entitlement to benefits such as pensions or insurance cover;
  • government identifiers/information listed under certain laws (e.g., California Customer Records Statute), such as a copy of your identification document and national identification, driving licence;
  • information about your nationality, country of residence, and entitlement to work in the country for which you are applying for employment/engagement at AIRWALLEX;
  • information about your criminal record (only in cases permitted by law);
  • protected classification characteristics under certain laws (e.g., California or US federal law), such as equal opportunities monitoring information, such as ethnicity, religion, disability and sexual orientation; 
  • Internet or other similar network activity, such as information regarding your interaction on our Website.; and
  • 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).


Sensitive information you can provide: 

The information listed above may include “Sensitive Personal Data” which, depending on the applicable Data Protection Law, includes information relating to your: 

  • race or ethnicity;
  • sexual orientation;
  • government identifiers;
  • physical or mental health; and
  • criminal convictions and offences.


Where permitted by law, you may have the option of providing certain Sensitive Personal Data with your consent for the purposes of equal opportunities monitoring. If you decide not to provide this data, your application will not be prejudiced.

In other instances, such as when we perform pre-employment background checks, where permitted and/or required by law, we may contract with a third party to perform background screening or you may be asked to provide us with certain background check information, which may include Sensitive Personal Data.

4. How Do We Collect Personal Data?

AIRWALLEX may collect your personal data in a variety of ways, for example:

  • 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, e-mail 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 organisations 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. 


Personal data will be stored in a range of different places, including in AIRWALLEX’s recruitment systems, applicant tracking system and other IT systems (including AIRWALLEX’s email system or messaging system). 

5. What is Our Legal Basis For Processing Personal Data?

Where local law requires 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 complete an employment contract or agreement with you (if you are a successful candidate). Where personal data is needed in order to perform our contract with you, if you do not provide it, we will not be able to perform our contract with you and may not be able to offer employment/engagement.
  • 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.
  • 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, e.g. we have a legitimate interest in processing personal data to recruit appropriate employees, workers or contractors for current or future roles, and to ensure and improve the success of our recruitment practices.
  • Where we rely on your consent, e.g. we will rely on your 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. You will be allowed to withdraw your consent at any time in which case we will stop processing, unless we have another lawful basis for doing so.

6. Reasons For Processing Personal Data

The reasons for processing personal data are to:

  • identify, evaluate and communicate with candidates for recruitment decisions;
  • determine, validate and verify your qualifications and information;
  • send you notifications about new positions that match your profile; 
  • make a hiring decision, and create an employment record and manage our employment/worker/contractor relationship with you (if you are a successful candidate); 
  • facilitate and ensure effective general HR and business administration;
  • improve recruitment processes, including monitoring and improving diversity in recruitment practices; and
  • comply with applicable laws.


We only process your Sensitive Personal Data for the purposes specified in this notice and in Data Protection Laws. We will use your Sensitive Personal Data in the following ways: 

  • 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, with your consent and where applicable.
  • as part of the application and offer of employment procedure, we may conduct a pre-employment screening (such as criminal records screening). 


We may also de-identify, aggregate, and/or anonymize your personal information. This may include using information in de-identified reports, and analyzing and presenting summaries in order to consider trends and people strategies for the workforce. 

7. Automated Decission Making/Profiling

We do not envisage that any decisions will be taken about you using automated means, however we will notify you if this position changes.

8. How And Where Do We Disclose Your Personal Data

Disclosures and transfers within AIRWALLEX

  1. AIRWALLEX takes precautions to ensure the safety and integrity of personal data that is transferred within its group. The personal data that we collect from you will be primarily stored in Airwallex Data Centres (these are Airwallex managed Cloud Storage facilities) in:
    1. Netherlands
    2. Singapore
    3. Belgium     
    4. United States
    5. Japan; and
    6. Hong Kong.     

These storage locations may change from time to time. 

  1. Your personal data may be disclosed to, accessible, or visible to personnel (such as employees in the Human Resources and compliance departments) of any member of the AIRWALLEX Group, as part of our general management, administration and operation of the business and regular compliance and reporting activities, in the context of a business reorganization or group restructuring exercise, for system maintenance support and hosting of data and for the overall administration of the recruitment process. As a result, your personal data may be transferred to jurisdictions in which AIRWALLEX has an office.
  2. With regards to personal data of EU data subjects only, Airwallex’s data transfers of personal data from the EEA are made in accordance with the relevant module of the standard contractual clauses for the transfer of personal data to third countries set out in Commission Decision of 4 June 2021 (C(2021) 3972), as amended and restated from time to time.
  3. With regards to personal data of UK data subjects only, Airwallex’s data transfers of personal data from the UK are made in accordance with the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses (version B.1.0) (“UK IDTA”) issued by the UK Information Commissioner for transferring personal data to third countries, as amended and restated from time to time. 
  4. For personal data of data subjects in other countries, Airwallex’s data transfers will be made in accordance with local applicable data protection/ privacy law or based on intra-group data transfer agreements that will at least meet the standards required under such local applicable data protection/ privacy laws or standard contracts required or recommended under such laws.

Disclosures and transfers to third parties

Your personal data will, in certain circumstances, be disclosed to third parties for the purposes described in section ‎6. These third parties include:

  1. External employment agents with which you may conclude an engagement contract;
  2. 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;
  3. 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;
  4. 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);
  5. Best of breed and user friendly HR systems, IT service providers and SaaS applications that we procure from third party HR solution providers.  Such third party HR solution providers may be providing their services from various locations including the United States, Australia, the UK, countries within the EU, Singapore, India and Canada.

The circumstances in which we will disclose your personal data with third parties include the following:

  1. Provision of services: AIRWALLEX uses a number of third party suppliers (such as for recruitment support, IT systems providers and contractors etc.) to provide services to AIRWALLEX. Some of these third party suppliers may be located outside of your country. AIRWALLEX will ensure that such suppliers protect your personal data with appropriate security measures and prohibit them from using your data other than as instructed by AIRWALLEX. All suppliers that process personal data outside of the EEA and UK are required to execute the European Commission’s standard contractual clauses and the UK IDTA, respectively, for the transfer of personal data. 
  2. Where we are under a legal obligation or required by law: Where AIRWALLEX is under an obligation to do so by law, we will disclose your personal data with regulators, courts, the police or tax authorities, or in the course of litigation, in particular to those regulators where an Airwallex Entity is licensed and regulated, where we are required to do so to comply with our regulatory obligations. In some cases, in accordance with applicable law, it will not be possible to notify you in advance about the details of such disclosures. AIRWALLEX will use all reasonable efforts to disclose the minimum personal data necessary in such cases. We will disclose your personal data with third parties where we are required to do so by law. For example, we are required to provide tax-related information to government bodies such as HMRC (United Kingdom).
  3. Sale, merger, transfer or reorganization: We may disclose your information to third parties 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, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information 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. 

Where we disclose your personal data with 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.

9. Security of Personal Data

AIRWALLEX takes the security of your data seriously.  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 organisational measures to ensure the security of data. 

10. Accuracy And Keeping Your Information Up To Date

To ensure AIRWALLEX’s files are accurate and up to date, and so that AIRWALLEX is able to contact you, you must notify AIRWALLEX as soon as possible of any change in your personal details (e.g., change of name, address, telephone number, etc).

11. Retention Periods

As a general rule, we will retain your information as follows (subject to the laws of the place of your employment/engagement and any statutory obligations to keep personal data for a longer period, or where we may need your personal data for a longer period in case of a legal claim or to fulfil other legal, accounting or reporting requirements):
Information Retention Period
Successful Candidates: If successful, we will provide you with a separate privacy notice setting out how we process your personal data after a successful application and during the course of your employment or your consulting or temporary contract with us, as applicable.
Unsuccessful Candidates: If unsuccessful, your personal data will be retained for 1 year after the hiring process has ended, as necessary for our legitimate interests, such as to consider and inform you about current and future job opportunities. If you do not want us to retain your personal data for consideration for other opportunities, or want us to update it, please email us at [email protected]. Please note, however, that we may retain some information if required by law or as necessary to protect ourselves from legal claims.

12. Your Rights

As a data subject, depending on your location, you may have a number of rights. You may have the right to: 

  • request access to and obtain a copy of your data; 
  • in certain circumstances, require AIRWALLEX to correct, delete or restrict (stop any active) the processing your data; 
  • object to the processing of your personal data; 
  • limit the use and disclosure of your sensitive personal data;
  • obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format and to ask us to share (port) this data to another organization; and
  • not be subject to automated decisions which produce legal effects or which could have a similarly significant effect on you.

To exercise any of these rights, please email us at [email protected]

Note that in many cases, your rights are not absolute and we may not be required to comply with your request. If you believe that AIRWALLEX has not complied with your data protection rights, you can complain to the relevant data protection authority (as applicable, depending on the jurisdiction you are located in).  

13. The Position If You Choose Not To Provide Personal Data

Certain information, such as contact details, professional and employment-related information, and your entitlement to work in the country for which you are applying for employment / engagement, have to be provided to enable AIRWALLEX to consider your application. If you do not provide other information, this will hinder AIRWALLEX’s ability to process your job application and progress the recruitment process.

14. Changes 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. For all data privacy inquiries and any questions or concerns you have about this notice, you can contact  us at [email protected]  or our Data Protection Officer at [email protected].

Appendix 1

List of Data Controllers

Airwallex Entity (individually or collectively, “AIRWALLEX”) Staff Location
Airwallex (Cayman) Limited Global (for Executive Team Only)
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 Mesico
Airwallex (Malaysia) Sdn. Bhd. Malaysia
Airwallex (Singapore) Pte. Ltd. Singapore
Airwallex Japan K.K. Japan
Airwallex (Israel) Ltd Israel
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 Terms for Candidates in Certain Jurisdictions

      1. Some countries’ laws contain additional terms, or require additional disclosures be made, to you, which are set out in this appendix. 
      2. 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.
      3. The following disclosures supplement the Candidate Privacy Notice.
    1. Disclosure of personal data

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

  1. Identifiers such as name, email address, telephone number, with the Third Party Transferees.

  2. Personal data categories listed in the California Customer Records Statute such as name, signature, social security number*, physical characteristics or description*, address, telephone number, passport number*, driver’s license* or state identification card number* with the Third Party Transferees.

  3. Protected classification characteristics under California or federal law such as race*, color*, religion or creed*, national origin or ancestry*, sex (including gender, pregnancy, sexual orientation* and gender identity*), age, physical or mental disability,* veteran status, and citizenship with the Third Party Transferees.

  4. professional or employment-related information, such as, details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers with the Third Party Transferees.

  5. Government identifiers* such as social security number, driver’s license, state identification card or passport number with the Third Party Transferees.

  6. Health information, such as information about medical or health conditions, including whether you have a disability with the Third Party Transferees.

  7. We do not “sell” personal data or “share” personal data for cross-context behavioral advertising purposes (as each terms are defined in the CCPA), nor have we done so in the preceding 12 months.