Last updated: [PUBLICATION DATE]
This policy explains how companies within the Caladan group and its affiliates (Caladan) collect, use and disclose personal data through https://caladan.xyz and related enquiries. In this policy, we, us and our mean the company responsible for the relevant processing, identified below or in the notice accompanying the relevant form.
The company responsible for personal data collected through this Website and general enquiries is [WEBSITE DATA CONTROLLER LEGAL NAME], of [CONTACT ADDRESS]. Where another company is responsible for your enquiry or recruitment process, we identify it in the relevant form or privacy notice before its processing begins.
Contact our data protection contact at [DPO OR PRIVACY EMAIL] if you have questions, wish to exercise a right or want to make a complaint. You may also write to the address above, marked for the attention of the data protection contact.
This policy covers website visitors, people who contact us and applicants using the recruitment links on the Website. Separate notices may apply to onboarding, trading, employment or other relationships; we will provide them where relevant.
Enquiries and API access requests. We collect the information you submit, including your first and last name, company, job title and company email address. The contact form also allows you to select areas of interest and provide an optional message. Where requested, we also collect your country of residence or business and your counterparty category to assess whether we can respond to a product enquiry. If you contact us by email or another linked channel, we receive the contact details, correspondence and other information you provide.
Job applications. We collect application information you provide through our recruitment platform or by email. This may include your name, email address, telephone number, CV, cover letter, LinkedIn profile, website and correspondence about your application. The application form identifies required fields. Any additional recruitment checks and their purposes will be explained when relevant.
Technical information. When you visit the Website, our hosting and technology providers may process information such as your IP address, browser and device details, pages requested, referring page, and the date and time of access. The technologies actually used, their purposes and available choices are explained below.
Please provide only information relevant to your enquiry or application. Avoid including identity documents, payment details or sensitive personal information in a general enquiry. If you provide someone else’s personal data, ensure you are entitled to share it with us.
We use personal data to respond to enquiries and API access requests, direct them to the appropriate team and manage related correspondence. A request for information may involve follow-up about that request.
We use application information to assess suitability for a role, arrange interviews, communicate with applicants and administer recruitment. We explain any proposed retention for future opportunities and obtain consent where required.
We also use relevant information to operate and secure the Website, prevent spam and misuse, maintain necessary records, comply with legal obligations and establish, exercise or defend legal claims. Any additional uses involving analytics or marketing are described below and are subject to applicable requirements.
Where applicable law requires a legal basis, we rely on our legitimate interests in responding to business enquiries, managing business relationships and operating and securing the Website, where that basis is available and our interests are not overridden by your rights. We process information to take steps at your request before entering into a contract, including assessing an application for employment, and to meet applicable legal obligations. We rely on consent for optional marketing, cookies and other uses where consent is required. For processing subject to Singapore law, we rely on consent or an applicable statutory basis or exception, subject to its conditions.
[Confirm the legal basis for each actual purpose and responsible entity, including recruitment, any talent pool, profiling and third-party sources. Identify any additional regional requirements in the relevant notice.]
If we propose a materially different purpose, we will give the required notice and obtain consent where necessary.
Responding to an enquiry does not automatically subscribe you to general marketing communications. Where we send marketing, we do so in accordance with applicable law and obtain consent where required. You can unsubscribe using the instructions in the communication or contact us at the address above. Withdrawing from marketing does not prevent us from sending necessary communications about an application, enquiry or existing relationship.
The Website may use cookies or similar technologies to support its operation. Optional analytics, advertising or tracking technologies, if used, are subject to the choices and consent requirements that apply to them. We will ask for consent before using technologies for which consent is required and provide a way to change that choice. Browser settings also allow you to manage cookies, although blocking some cookies may affect functionality.
[Insert verified cookie and technology details or a link to the completed cookie notice: identify each provider and technology, its purpose, information collected, duration, whether it is necessary or optional, and how visitors can change their choices. State expressly if no optional analytics or advertising technologies are used.]
The Website loads fonts from Google. These requests disclose technical information, including your IP address and browser request details, to Google so it can deliver the fonts. Google explains this processing in its Google Fonts privacy information. We use Greenhouse to collect and manage applications on behalf of the relevant Caladan recruiting company. That company remains responsible for its use of your application information, as explained in its recruitment privacy notice. Where an external provider processes personal data for its own purposes, its privacy notice explains that processing. Please review the notices presented with those services.
We share relevant information with the Caladan group company and personnel responsible for your enquiry or recruitment process. We also use service providers for website hosting, form handling, email, recruitment, security and any other functions identified in our cookie and technology information. They receive the information needed for their role, subject to appropriate restrictions and safeguards.
We may disclose information to professional advisers, regulators, courts, law enforcement or other persons where required or permitted by law, or where reasonably necessary to establish, exercise or defend legal claims. If a business transfer or reorganisation affects your data, we may disclose it to the relevant parties, subject to applicable law and appropriate safeguards.
Group companies and service providers may process personal data in countries outside your home country, where data protection laws may differ. The relevant processing locations are [CONFIRMED COUNTRIES OR LINK TO PROVIDER AND LOCATION DETAILS].
When personal data is transferred internationally, we apply the safeguards required by the law governing that transfer. Depending on the applicable law, these may include a finding that the destination provides adequate protection, contractual safeguards or another permitted transfer mechanism, together with any additional safeguards required. Contact us for information about the safeguards relevant to your data.
[Identify the actual transfer arrangements for each relevant destination, including how a person can obtain information about or a copy of the safeguards where applicable law requires this.]
We keep personal data only for as long as reasonably needed for the purposes for which it was collected and for applicable legal or business requirements. In deciding the period, we consider the nature of the enquiry or application, the ongoing relationship, record-keeping obligations, security needs and relevant limitation periods. We then delete or anonymise it when retention is no longer justified.
[Insert confirmed retention periods or precise criteria for enquiries and API leads, unsuccessful applications, any talent pool, website and security logs, marketing records and backups.]
We use reasonable organisational and technical measures to protect personal data against unauthorised access, use or disclosure and accidental loss. Internet transmissions and storage systems cannot be guaranteed to be completely secure.
Depending on the law that applies, you may request access to your personal data and information about its use and disclosure, correction of inaccurate data, or withdrawal of consent. We will explain any likely consequences of withdrawing consent, including where it prevents us from responding to an enquiry or continuing an application. Withdrawal does not affect processing that was lawful before withdrawal or processing otherwise permitted by law.
Where applicable law gives you further rights, you may also request erasure, restriction or portability of your data, or object to certain processing. These rights are subject to the conditions and exceptions in that law. We may need to verify your identity before responding and will explain any lawful reason for refusing a request or any permitted fee before charging it.
You may raise a complaint with our data protection contact. You may also complain to the authority responsible under the law that applies to your data. This may include Singapore’s Personal Data Protection Commission, the Cayman Islands Ombudsman, an EEA supervisory authority or the UK Information Commissioner’s Office. Where applicable law provides another complaint or appeal route, we will explain it in the relevant notice or our response.
[Add any required regional contact or representative details, specific rights and response procedures once the responsible entities and applicable laws have been confirmed.]
We may update this policy to reflect changes to our practices or legal requirements. The date above identifies the latest version. We will give additional notice and obtain any consent required by law for material changes.
Trading products and services are for eligible institutional and professional counterparties only, subject to applicable law. They are not offered or directed to persons in Singapore. Important Disclosure.