Senior Fraud Risk Consultant

Effective as of 19 December, 2024

Feedzai – Consultadoria e Inovação Tecnológica, S.A. and its group companies (“Feedzai”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.

The purpose of this Candidate Privacy Policy is to provide candidates for job opportunities with information about how and why we process their personal data and to tell them about their privacy rights and how the law protects them.

With that in mind, this Candidate Privacy Policy is designed to describe:

• Who we are and how to contact us
• Your rights relating to your personal data
• What personal data we collect
• Personal data from Third-Party Sources
• How we use your personal data and why
• Who we share your personal data with
• Data transfers
• How we keep your personal data secure
• How long we store your personal data

Important notes:

• This Candidate Privacy Policy is intended to meet our duties of transparency under applicable data protection laws, namely the General Data Protection Regulation 2016/679 (the “EU GDPR”), the EU GDPR as it forms part of the laws of the United Kingdom (the “UK GDPR”) (together, the “GDPR”), the Brazilian data protection law no. 13709/2018 (Lei Geral de Proteção de Dados Pessoais or “LGPD”), and others.
• It is important you read this Candidate Privacy Policy so that you are aware of how and why we are using your personal data, your rights and how the law protects you.
• This Candidate Privacy Policy does not form an operative part of any future contract you may have with Feedzai and is not intended to create any employment relationship or other engagement between you and Feedzai.
• You should be aware that if you fail to provide certain personal data when requested, we may not be able to perform steps necessary to enter into a contractual relationship with you or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

We may update this Candidate Privacy Policy from time to time. You will be able to see all prior versions in the link provided at the beginning of the policy.

Who we are and how to contact us

Who we are.

Feedzai is the Controller (as defined in the applicable data protection laws, namely the GDPR) for the purposes of the processing of your personal data described in this Candidate Privacy Policy. Where you are applying for a job opportunity with a Feedzai group company, certain other of our group companies may also act as a Controller. For a full list of controllers, see Annex 1.

How to contact us.

To contact us, you can either:

• email us at privacy@feedzai.com; or
• write to us at the postal address noted above.

Your rights relating to your personal data

Your rights in connection with your personal data

Under certain circumstances, by law you have the right to:

• Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data. This right exists where we are relying on a Legitimate Interest (defined below) as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data (data portability). We will provide to you, or a third party you have chosen, your personal data which you have provided to us, in a structured, commonly used, machine-readable format. Note that this right only applies to personal data we process by automated means which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent. This right only exists where we are relying on consent to process your personal data.

How to exercise your rights

If you want to exercise any of the rights described above, please contact us using the contact details shown in the “Who We Are and How to Contact Us” section above.

We may need to request specific information from you to help us confirm your identity and verify your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information to assist us in responding to your request.

Typically, you will not have to pay any fee to access your personal data (or to exercise any of the other rights). However, except in relation to withdrawal of your consent (see above), we may charge a reasonable fee if your request is clearly unfounded or excessive, or we may refuse to comply with your request in these circumstances.

Please also note that in certain circumstances the rights above will not apply and/or in certain circumstances some categories of personal data will be exempt from the scope of those rights. We will notify you where this is the case.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

If you would like to make a complaint regarding this Candidate Privacy Policy, you can contact us using the contact details shown in the “Who We Are and How to Contact Us” section above. We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, please note that applicable data protection laws also give you the right to make a complaint directly to the data protection regulator in your habitual place of residence.

What personal data we collect

All the personal data we collect, both from you and from third parties about you, is outlined in the table below.

Identity Data

First name, middle name(s), surname, title, national identification and/or passport details, national insurance / social security number or other tax-related information, driver’s licence, photographs.

Contact Data

Your home address, work address, email address and telephone numbers.

Biographical Data

First name, middle name(s), surname, maiden name, marital/civil partnership status, title, date of birth, gender (if you choose to provide this information), ethnicity (if you choose to provide this information), education history, professional history, professional qualifications and memberships, references, information relating to references such as referees’ names and contact details, information contained within letters of application and CVs, language proficiencies and other skills, certifications, certification expiration dates and information necessary to complete background checks.

Immigration Data

National identification and/or passport number, details of residency and/or work permit and other information that would allow us to verify your eligibility to work for us in your relevant role.

Professional Data

Title and description of your prior roles, department, work location, dates of prior employment/engagement, employment/engagement status and type (e.g., full-time/part-time), terms of employment/engagement, contracts, work history (current, past, or prospective), training and learning program participation, termination date(s) and reason, length of service, current salary, desired salary, employment/engagement preferences, information necessary to complete background checks, licenses, permits, memberships, and certifications. May also include job preferences, such as desired position and compensation, location preferences and willingness to relocate.

Facilities Data

Information about your access to Feedzai offices and facilities.

Data from the application process

Phone-screens, interviews, evaluations and outcomes of recruiting exercises

Other Data

This might include data not listed above that you provide to us, such as your feedback and survey responses where you choose to identify yourself.

Personal data from Third-Party Sources

In addition to the personal data that we collect from you directly, in certain circumstances, we may also collect personal data from third-party sources. Please see below for a list of the types of third-party sources from which we may collect your personal data (including whether the source of that personal data is publicly available):

• Agencies or recruiters that refer you to us.
• Job board websites you may use to apply for a job with us.
• Prior employers, companies or persons, when they provide us with references.
• Professional references that you authorise us to contact.
• Your educational institutions.
• Providers of background check, credit check, or other screening services (where permitted by law).
• Your social media profiles, such as LinkedIn or other publicly-available sources (information gathered from these sources is publicly-available).
• Other Company personnel.

How we use your personal data and why

In respect of each of the purposes for which we use your personal data, applicable data protection laws require us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:

• Where we need to take steps at your request prior to entering into a contract with you (“Contractual Necessity”).
• Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each purpose we use your personal data for is set out in the table below.

The table below shows at a very high-level how we may use your personal data and the relevant legal bases we rely upon for that use.

Pre-contractual performance. We may process your personal data (including sharing it with third parties, where appropriate) where necessary to take pre-contractual steps relating to your potential employment or engagement, including managing the recruitment process and taking any associated steps you may request prior to entering into any contract with you.

Contractual Necessity.

Talent management. We may process your personal data (including associated sharing with third parties, where appropriate) for talent management purposes, including for the purposes of considering you for current or future job application and determining whether, and on what terms, to make an offer to employ or engage you.

Legitimate Interests.

Facilities management. We may process your personal data (including sharing it with third parties, where appropriate) to operate, manage and secure our premises and facilities.

Legitimate Interests.

Compliance and protection. We may process your personal data (including sharing it with third parties, where appropriate) for compliance and protection purposes (including the establishment, exercise or defence of legal claims).

Depending on the circumstances: Compliance with Law or Legitimate Interest.

Privacy Protective Steps. We may create aggregated, de-identified and/or anonymised data from your personal data.

Legitimate Interests.

Further uses. In some cases, we may use your personal data for further uses, in which case we will ask for your consent to such use of your personal data for those further purposes in so far as they are not compatible with the initial purpose for which information was collected and where consent is necessary.

Consent or the original legal basis where the relevant further use is compatible with the initial purpose and where consent is necessary.

In addition to establishing a legal basis, where we use any ‘special categories’ of personal data (e.g., your health-related data), we also have to satisfy an additional condition to process such personal data, because it is considered to be more sensitive in nature. The condition that may apply will depend on the circumstances and the purposes of the relevant processing. However, as examples of the conditions that we may rely upon:

• We may need to process that data because it is necessary for reasons of substantial public interest (e.g., for equal opportunities monitoring, preventing or detecting unlawful acts etc).
• We may need to process that data because it is necessary for the establishment, exercise or defence of legal claims (including regulatory, administrative or any out-of-court procedure, and seeking advice).

Who we share your personal data with

As part of our business and in relation to your application, we may share your personal data with certain third parties – please see the list below for information about the categories of such third-party recipients:

Affiliates. Our affiliates. For example, this may occur to enable our organisation to operate shared infrastructure, systems and technology.

Service Providers. Providers of services to Feedzai or our group that provide us with services that help us manage the recruiting process and operate our business, such as job boards, recruiters, interviewing and testing, IT systems and support, information and physical security, pre-employment screening, interview travel booking and expense reimbursement (where applicable), relocation (where applicable), and recruitment analytics.

Professional advisers. Accountants, auditors, lawyers, immigration advisors, insurers, bankers, and other professional advisors.

Compliance and protection related sharing. We may need to or may have a legitimate interest in, sharing your personal data with entities that regulate or have jurisdiction over us (such as regulatory authorities, public bodies and judicial bodies). We may also share your personal data in the context of protecting our, your or others’ rights, privacy, safety or property (including by establishing, making and defending legal claims).

Business transfer participants. Parties (and their advisors) to transactions and potential transactions pursuant to which we sell or transfer some or all of our business or assets, including your personal information, such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Data transfers

We may share your personal data with third parties who may be based outside of the EU/UK. In such circumstances, those parties’ processing of your personal data will involve a transfer of your personal data outside of the EU/UK where privacy laws may not be as protective as those in the EU/UK. In such a case, we will endeavour to implement appropriate safeguards designed to give personal data effectively the same protection as it has in the EU/UK.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information using the contact details shown in the “Who We Are and How to Contact Us” section above.

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