Effective Date: October 18, 2024

Paxos Trust Company, Paxos Global Pte. Ltd., Paxos Technology Limited, and each of its affiliates and subsidiaries (collectively, “Paxos,” “we,” “us,” “our”) is committed to protecting the privacy and security of the personal information we collect about job applicants. This applicant privacy policy (the “Applicant Privacy Policy”) sets out our policies and practices with respect to the personal information we collect from you if you apply for a job at Paxos via our Careers site, or otherwise submit an application to work for us, whether directly or indirectly (for example, via a recruiting agency).  

If you have any questions about this Applicant Privacy Policy or want more information, please contact us at [email protected] or as otherwise indicated in the “Contact Us” section below.  

I.  INFORMATION WE COLLECT

• Information you provide directly to us.

When you apply for a position on our Careers site, we ask you to provide your first name, last name, email address, and phone number, as well as to upload a copy of your résumé/CV and a cover letter explaining your background and interest in the position.  You may also voluntarily provide a link to your LinkedIn account, if applicable.  Your résumé/CV contains a range of information about you that you choose to disclose so that we can consider your candidacy for a position at Paxos, such as your:  

• Name;
• Contact details (e.g., physical address, phone number, email address);
• Education, skills, certifications obtained, trainings attended, languages spoken, etc.;
• Work history, dates of prior employment, role(s), title(s), promotion(s), etc.;
• Government identification document or number, such as a drivers’ license;
• Citizenship and/or permanent legal residence, as well as eligibility to work, including documentation of immigration status (if applicable);
• Job references (if you provide information regarding other individuals, you must obtain their consent before providing their data to Paxos); and
• Any other information that you may choose to provide as part of your application.

When submitting your application, you have the option to self-identify your ethnicity, gender, veteran status, and disability information, as applicable.  Your disclosure of such information is entirely voluntary, and your decision to provide or withhold such information will not negatively impact how we consider you for employment.  

Please note that such information or other information you provide to us in the course of submitting an application may be considered “sensitive” under applicable privacy laws.  When processing sensitive personal information, we comply with applicable restrictions or limitations (including seeking your consent, if required by law and appropriate), and we will not infer other characteristics about you when using such information.  

• Information we may receive about you indirectly.

We may receive any or all of the categories of personal information listed above indirectly, such as from a recruiting agency, prior employer, or other third party, or by accessing it online if you have a profile on a social media career site or other platform that is publicly accessible.    

• Information we collect automatically.  

When you submit an application via the Careers site, we may also collect information through the use of cookies or similar tracking technologies, such as device type; Internet protocol (IP) address; device and advertising identifiers, and other unique personal or online identifiers; time zone setting and general location; browser type and version; browser plug in types and versions; operating system and platform; Internet service provider; and pages you access or content you interact with on our website.  

II.  HOW WE USE YOUR INFORMATION

We may process the personal information identified above for purposes that include:

• to enable you to apply for employment at Paxos and evaluate your application, including without limitation, arranging for and conducting phone screening, interviews, and other applicable assessments;
• to contact you about your application and/or invite you to apply for a role at Paxos, as well as consider you for other opportunities that may be or become available;
• to validate reference checks and conduct background checks, as appropriate and in accordance with applicable law;
• to make an employment offer, facilitate your hiring, and administer your employment contract if you are hired;
• to comply with legal and regulatory requirements for employers with respect to job applicants;
• to provide you with opportunities to offer feedback on your experience, such as through a survey;
• to conduct analysis on applicant trends to understand and improve Paxos’s recruitment practices;
• to verify your identity to ensure security for one of the other purposes listed here; and
• to maintain or enhance the security of Paxos’s systems, protect against fraud, and, conduct internal investigations and comply with related legal obligations.
• Where applicable law requires a legal basis to process personal information, we will generally process your information on the basis of our legitimate interests to operate our business and enable interested parties to apply for a role at Paxos.  If you receive a job offer, we also process your personal information to enter into a contract with you and fulfill our obligations to you under that contract, as well as to comply with applicable legal obligations (for example, tax, accounting, and employment laws).  

Where appropriate and we have no other valid legal basis to process your information, we will obtain your consent (for example, to provide non-selected candidates with information about future vacancies or share certain information with third parties), which may subsequently be withdrawn at any time by contacting us. Withdrawing consent does not affect the lawfulness of processing based on consent before it was withdrawn.

Where we need to collect certain information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may be unable to perform the contract we have or are seeking to enter into with you.

III. WITH WHOM WE SHARE YOUR INFORMATION

When processing your personal information for the purposes listed above, we may share your data with:

• Our corporate affiliates and subsidiaries –  for example, if you apply for a job at a particular Paxos affiliate, we may share your information with that affiliate to enable them consider you for the role;
• Authorized third-party vendors and service providers – we may share your information with third-party vendors and service providers who support us in the recruitment and hiring process, including recruitment agencies, HR software-based tools and services provided by third parties, and other third-party vendors.  
• Legal purposes. Where required by law, we may disclose certain information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of Paxos, our affiliates, users, or the public.
• With your consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.  
  
  
  IV.  ADVERTISING, COOKIES AND SIMILAR TECHNOLOGIES

When you use the Careers site, we use cookies, pixel tags, local storage, and other similar technologies (collectively, “cookies”) to collect information from your browser or device. In particular, the following types of cookies are used on our website:

• Essential cookies – These cookies enable you to use our website. They are essential to enable you to browse our website and use certain features. Disabling them may prevent you from using certain parts of the website. These cookies also help keep our website safe and secure.
• Preference cookies – These cookies store information such as your preferred country and language selection, login data and website preferences. Without these cookies, our website may not be able to remember certain choices you’ve previously made (such as a saved country / language preference) or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.
• Performance cookies – These cookies collect information about how you use our website, such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages.
• Content / advertising cookies– These cookies gather information about your use of our website so we may improve your experience and provide you with more relevant content and advertising on our website and elsewhere online and across your devices.

Do-Not-Track Signals and Similar Mechanisms. Some mobile and web browsers transmit “do-not-track” signals. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

V. PERSONAL INFORMATION RIGHTS

Under applicable data protection laws, you (or an authorized agent acting on your behalf) may be entitled to request access to, rectification, erasure, and portability of your information, to know more information about our privacy practices, or to object to or request restriction of processing of your information. Requests should be submitted in writing as set out below. If you become aware of changes or inaccuracies in your information, you should inform us of such changes so that the information may be updated or corrected.

Once we receive your request, we may verify it by requesting information sufficient to confirm your identity and/or the identity and authorization of the agent you have designated to act on your behalf.   We will not discriminate against you for exercising your rights.  

We do not sell or share your personal information as defined in applicable law because we will only use third party advertising tools for the purpose of cross-contextual behavioral advertising with your consent. You can manage the consent that you have provided through our cookie manager.  

Please note that when you interact with other parties, including when you leave our Service or click embedded videos or links on our Site, those parties may independently collect information about you and solicit information from you, including through the use of advertising technologies such as cookies. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

You may also have the right to lodge a complaint with a supervisory authority.

VI.  INTERNATIONAL TRANSFERS

To enable you to apply for a vacancy at Paxos, we may need to transfer and store your information outside your resident jurisdiction, including in the United States.  For example, some of the entities (such as third-party vendors) who support us in the recruitment and hiring process may be located outside of your resident jurisdiction, including in countries that may not provide the same level of data protection as your home country.  We comply with applicable laws when transferring personal information, including by implementing measures such as standard data protection contractual clauses to ensure that any transferred information, remains protected and secure. A copy of these clauses can be obtained by contacting us where indicated below.  

VII.  DATA RETENTION, SECURITY, AND INTEGRITY

Information will be retained only for so long as reasonably necessary and proportionate for the purposes set out above and consistent with our retention policies, in accordance with applicable laws.

We maintain reasonable security measures to safeguard information from loss, theft, interference, misuse, unauthorized access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete, and current.

You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure, accurate, complete, or current.  Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

VIII.  CHANGES TO THE APPLICANT PRIVACY POLICY

We may modify this Applicant Privacy Policy from time to time. When we update the Applicant Privacy Policy, we will revise the “Effective Date” date above and post the new Applicant Privacy Policy.  We recommend that you review the Applicant Privacy Policy each time you visit the website to stay informed of our privacy practices.

IX.  CONTACT US

If you have any questions about this Applicant Privacy Policy or our practices or would like to exercise a right under applicable law, please contact us via [email protected].