Job Applicant Privacy Policy

Overview

This privacy notice (the "Notice") informs you about how MyFunded Futures LLC, and each of their affiliates (collectively, "MFF," "we," "us," "our") (as data controllers) process Personal Data about you during your relationship with MFF and after it ends. This Notice is not an employment contract or offer.

This Notice explains the manner in which MFF collects, uses, and maintains nonpublic personal information about job applicants, including job applicants based in the United Kingdom ("UK"), the European Union ("EU"), or the European Economic Area ("EEA") as required under the General Data Protection Regulation (EU) 2016/679 ("GDPR") or the GDPR and the Data Protection Act 2018, as applicable.

Representatives:

  • UK Representative: DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom
  • EU Representative: DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland

Key Definitions

Applicant means an individual who has applied for employment or an internship with MFF.

Consent means any freely given, specific, informed and unambiguous indication of your wishes, by which you, by a clear affirmative action, signify agreement to the Processing of your Personal Data.

Personal Data means any information that reasonably can be used to directly or indirectly identify you or another living natural person, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Process means any operation or set of operations which is performed on Personal Data, whether or not by automated means, including accessing, retrieving, collecting, recording, organizing, structuring, storing, adapting or altering, consulting, modifying, using, disclosing by transmission, transferring, disseminating or otherwise making it available, aligning or combining, restricting, erasing or destroying.

Acknowledgements

By making available your Personal Data, you acknowledge that:

  • You have reviewed this Notice and understand how we may Process your Personal Data
  • If you are submitting an application from outside of the United States ("US"), your Personal Data may be Processed by MFF in the US. You understand that in some locations, the information you submit may not be subject to the same legal protection as is mandated in your home country and that the laws regarding privacy, data protection, and confidentiality of Personal Data may not be accorded the same protection as in your home country. MFF will ensure that any Personal Data it transfers will be handled in accordance with good practice and any applicable laws and/or regulations
  • You have received Consent from your references/referees and other individuals whose Personal Data you provide to us

Types of Personal Data We Process

We may collect and otherwise Process the following types of Personal Data as part of the application Process:

Basic Information

  • Identification data such as name, photos, videos, and recordings, digital or ink signatures, date of birth and gender
  • Contact details such as email, postal address, and phone number

Professional Information

  • Education and professional background information, such as:
    • Academic/professional qualifications
    • Licenses and skills
    • Languages spoken
    • Work history
    • Dates of employment
    • Experience
    • Education
    • Degree status
    • Professional licenses
    • Other CV/resumé data
    • References/referee information
    • Compensation history (where legally permitted)
    • Desired pay

Additional Information

  • Any other information provided through recruiting initiatives, such as information you provide through a CV, resumé, cover letter, social media (e.g., LinkedIn), interviews, references, and willingness to relocate
  • Demographic information (where legally permissible)
  • Historical compensation information (in certain jurisdictions where legally permissible or where you chose to give us voluntarily at the application stage)
  • Optional data, including any data you chose to give us voluntarily at the application stage, which could include race, ethnicity, gender, and disability

Pre-Employment Information

We may further collect the following information before making a final decision to recruit:

  • Right to work information, which may differ by location, including your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information
  • Government identifiers, such as passport number and government issued identification
  • Background check information, such as criminal and credit history, sanctions screening results (where legally permitted), government affiliation, political contributions, and fingerprints (if you are offered a position of employment or an internship with us)

When We Collect and Process Personal Data

When We Collect Personal Data

We collect Personal Data when:

  • You apply for a role in response to a position listing
  • You speak with us as part of your application
  • You respond to recruiting-related inquiries
  • We or our service providers perform background or reference checks, or other pre-screening (where legally permitted)

Why We Process Personal Data

We may process Personal Data to:

  • Process your application
  • Assess your skills, qualifications and interests against our career opportunities and determine your suitability for a role
  • Decide whether to offer you a position of employment or internship and to set your compensation
  • Verify your information and carry out reference and other background checks (where legally permitted)
  • Communicate with you about your application and where relevant, to inform you of other potential opportunities
  • On-board you should we offer, and you accept, a role
  • Help you to obtain a visa or work permit where required or to relocate you
  • Manage our business, through recruiting, management reporting and administration
  • Comply with applicable law, regulation, legal process, or government requests
  • Exercise and defend our legal rights, and to protect our and others' property and safety
  • Respond to unusual activity and to prevent illegal activity
  • As part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets
  • Other purposes reasonably required by MFF

Where you are offered and accept a position, the Personal Data collected during the recruitment process may become part of your personnel record.

Sources of Personal Data

We collect Personal Data you voluntarily provide to us during the application process or when you otherwise contact us. We may combine Personal Data you voluntarily provide to us with information we collect from other sources, such as:

  • Recruiters
  • Prior employers and professional references
  • Educational institutions
  • Pre-employment screening and background check services
  • Credentialing and licensing organisations
  • Publicly available sources, such as public social media profiles
  • Other sources as directed by you

To Whom We Disclose Your Personal Data

We may disclose Personal Data to the following:

  • Our affiliates and their or our successors and assigns
  • Our service providers such as:
    • Data hosting services
    • Background check providers (if you are offered a position of employment or an internship with us)
    • Recruiters
    • Our legal, accounting, and financial advisers
  • Our prospective business partners
  • Regulators, law enforcement and other government agencies
  • Other third parties where we determine the disclosure is necessary to protect health and safety, our business interests, our regulatory or legal obligations, pursuant to a court order, government request or other demand, or as otherwise required by law

MFF will not disclose your Personal Data to any other third party (other than specified herein) without your Consent unless required to do so by law or regulators and will comply with all applicable local laws.

Legal Basis for Processing Personal Data

Where a legal basis or other reason is required by applicable law, Processing Personal Data is:

  • Based on your Consent, which may be withdrawn at any time by contacting us in accordance with the How to Exercise Your Rights section of this Notice. Withdrawal of Consent will not necessarily affect the legality of data Processing prior to the withdrawal
  • Necessary for our legitimate interests in recruiting, which do not override your privacy interests or fundamental rights and freedoms where you are entitled to such protections under applicable law
  • To take steps to undertake an employment contract with you
  • Necessary to comply with our legal and regulatory obligations, such as background screening and records retention
  • For reasons of substantial public interest (i.e., equality of opportunity or treatment, promoting or retaining racial and ethnic diversity at senior level, or preventing or detecting unlawful acts)
  • To establish, exercise and/or defend any legal claims that may be brought by or against us in connection with your recruitment

Sensitive Personal Data and Criminal Records

If you are located in the EEA or the UK, MFF will only Process Sensitive Personal Data if we have a lawful basis for doing so (as set out in Legal Basis for Processing Personal Data above) and if one of the special conditions for Processing Sensitive Personal Data applies:

  • You have given explicit Consent
  • Processing is necessary for the purposes of exercising the employment law rights or obligations of MFF or you
  • Processing is necessary to protect your vital interests, and you are physically incapable of giving Consent
  • Processing relates to Personal Data which is manifestly made public by you
  • Processing is necessary for the establishment, exercise, or defence of legal claims
  • Processing is necessary for reasons of substantial public interest

International Transfers of Personal Data

If you apply for a position at MFF from outside of the US, your Personal Data will be Processed by MFF in the US. You understand that in some locations, the information you submit may not be subject to the same legal protection as is mandated in your home country and that the laws regarding privacy, data protection, and confidentiality of Personal Data may not be accorded the same protection as in your home country. MFF will ensure that any Personal Data it transfers will be handled in accordance with any relevant law and/or regulations, as applicable.

Data Retention

We keep the Personal Data that we obtain about you during the recruitment process for as long as:

  • It is needed to fulfil the purposes stated in this Notice
  • We have a legitimate business purpose that does not outweigh your privacy interests or fundamental rights and freedoms, where protected by law

If your application is successful, we will keep the recruitment information that is necessary in relation to your employment. We will provide you with a further employment related documents which details how long we retain your Personal Data as an employee.

Are You Required to Provide Personal Data?

Providing your Personal Data to us or permitting us to collect it as part of the application process is voluntary. However, should you not provide or permit access to all or part of the information MFF requests, it may not be possible for us to recruit or retain you.

Your Rights

Your EEA and UK Rights

If you are located in the EEA or the UK, you may have the following Personal Data rights under the GDPR:

  • The Right to Access: You have the right to be provided with a copy of the Personal Data that we hold about you
  • The Right to Rectification: You have the right to request that we correct any errors, outdated information, or omissions in Personal Data that we hold about you
  • The Right to Erasure (also known as the right to be forgotten): You have the right to require us to delete your Personal Data in certain situations
  • The Right to Restriction of Processing: You have the right to require us to restrict Processing of your Personal Data in certain circumstances (e.g., if you contest the accuracy of the data)
  • The Right to Data Portability: You have the right to receive the Personal Data that we hold about you in a structured, commonly used, and machine-readable format and/or transmit that data to a third party in certain situations
  • The Right to Object to the Processing: You have the right to object at any time to your Personal Data being Processed for direct marketing (including profiling) and in certain other situations to our continued Processing of your Personal Data (e.g., Processing carried out for the purpose of our legitimate interests)
  • The Right not to be Subject to Automated Individual Decision Making: You have the right not to be subject to a decision based solely on automated Processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

If you are an EEA or UK resident, you have the right to bring complaints with any relevant data protection or privacy authority (see below for details). In addition, where you have given your Consent, you have the right to withdraw your Consent at any time by contacting us as described in the How to Exercise Your Rights section below, or where applicable, by unsubscribing from any communications to which you have subscribed.

To make any requests as listed above, please contact DataRep at [email protected], quoting "MyFunded Futures LLC" in the subject line. You may also contact DataRep through its online webform at www.datarep.com/data-request.

Your California Rights

If you are resident of California, you may have the following Personal Data rights under the California Consumer Privacy Act of 2018 ("CCPA"), as amended by the California Privacy Rights Act of 2020 ("CPRA"):

  • Right to Know: You have the right to request that we disclose certain information to you about the Personal Data we collected, used, disclosed, sold and shared about you in the past twelve (12) months. This includes a request to know any or all of the following:

    • The categories of Personal Data collected about you
    • The categories of sources from which we collected your Personal Data
    • The categories of Personal Data that we have sold or disclosed about you for a business purpose
    • The categories of third parties to whom your Personal Data was shared, sold or disclosed for a business purpose
    • Our business or commercial purpose for collecting or selling your Personal Data
    • The specific pieces of Personal Data we have collected about you
    • The retention period or criteria used for retention
  • Data Portability: You have the right to request a copy of Personal Data we have collected and maintained about you in the past twelve (12) months

  • Right to Correct: You have the right to correct inaccurate Personal Data about you. Once we receive and verify your request, we will use commercially reasonable efforts to correct the inaccurate Personal Data about you

  • Right to Deletion: You have the right to request that we delete Personal Data we collected from you and maintained, subject to certain exceptions

  • Right to Opt-Out/In: You have the right to opt-out of the "Sale" or "Sharing" of your Personal Data as defined by the CCPA. However, we do not "Sell" or "Share" your Personal Data

  • Right to Limit the Use of Sensitive Personal Data: You have the right to request us to limit the use and disclosure of a certain Sensitive Personal Data. However, we do not use your Sensitive Personal Data in such a manner that would permit such limitation

  • Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of your California privacy rights

You may exercise your rights as described in the How to Exercise Your Rights section below.

How to Exercise Your Rights

If you would like to exercise your rights regarding your Personal Data please contact:

We may need additional information to verify your request. All requests will be responded in compliance with laws.

Keeping Your Personal Data Secure

We have appropriate security measures in place with respect to data security and incident response to prevent Personal Data from being accidentally lost or used or accessed in an unauthorised way. We limit access to your Personal Data to those who have a genuine business need to know it. Those Processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

Your Obligations

It is critical that you inform us of changes to your Personal Data as soon as possible by contacting your recruiter or us in accordance with the Contact Information section below. Further, we rely on you to obtain any necessary Consents from your references and/or referees for the Personal Data you provide to us about them.

How to Make a Complaint

Please contact us if you have any query or concern about our use of your information (see Contact Information below).

You also have the right to lodge a complaint with:

Contact Information

If you have any questions or concerns about this Job Applicant Privacy Notice and/or how we process your Personal Data please contact:


Effective: May 30, 2025