Privacy policy
Last Updated: January, 2022
Core-Tenure Ltd. (TenureX) collects and processes personal data relating to Users in relation to the services we provide. The data we process differs depending on your interactions with us, as detailed more fully below.
The expression “User” (and “you”/”your”) in this privacy notice shall mean any person accessing the TenureX website, using TenureX products and services, or about whom we collect and use any information in the course of providing our products and services.
Where we act as a processor of personal data, the following items apply:
Details of the processor and data protection officer: the controller of the personal data we process are our customers which are all regulated financial institutions, and in a case of cookies and details collected on the website, the controller is Core-tenure Ltd. (trading as TenureX) (referred to as “TenureX”/“we”/“us”), located at the 40 Tuval Street, Ramat-Gen, Israel. Our data protection officer can be contacted by email at dpo@tenurex.com.
Our representative in the EU is Mr. Noel Galea from Essentials Compliance Ltd., with its registered office at 95, Matteolo Saliba, Zurrieq ZRQ 2022, Malta.
Transfers outside of the EEA: As part of our group operations and to help us manage the personal data that We process, we transfer personal data of Users outside of the EEA subject to appropriate safeguards including European Commission adequacy decisions and model clauses approved by the European Commission on the basis of Art. 26(4) of Directive 95/46/EC.
Your rights
You can request that we correct, erase, or grant you access to the personal data we hold relating to you, or (where processing is based on your consent) withdraw your consent to our processing of your personal data. In many cases, the most effective way to exercise these rights will be to mail our dedicated inbox at info@tenureX.com.
If you are concerned that we are handling your personal data improperly, you also have the right to make a complaint to our data protection regulator, the Maltese Information Commissioner’s Office.
Information collection and use
The information we collect, and the ways in which we use it, varies in line with the use cases below (click the headings to view the relevant portions of the policy):
- Visitors to tenurex.com
- When you provide us with information by completing forms
- Candidates for jobs with TenureX
- Our anti-money laundering, sanctions and adverse media data
- Business contacts
- Information we collect from publicly available sources
Visitors to TenureX.com
When you browse this website
| What we collect |
Data on how you use the site The pages you visit, the means you use to visit (browser version, time zone, operating system, etc.), how long your visit and pageviews last, the frequency of your visits, and information on how you navigate the site. Data that identifies you Your IP address, unique identifiers tied to cookies. |
| What we do with your data |
Site optimisation Analysing aggregated data to update our site’s content and layout to improve relevance for visitors |
| Our basis for processing this data |
Legitimate interests Using insights from visitor behavior to improve the way we market our services. |
| How long we hold this data | Data holding periods are determined by cookie expiry times. |
| Recipients of data |
Within TenureX group companies
Outside of TenureX
|
When you provide us with information by completing forms
| What we do with your data |
We use this information to contact you for the purpose specified in the form and in accordance with any marketing or engagement preferences you submit to us, or as part of Our onboarding, customer acceptance processes. This information is added to, and managed through, our contact and onboarding databases. A member of our team may contact you if we determine through your submission that you may be interested in our services. We analyse our contact database data to understand, track, and improve how we market, sell, and grant our services. |
| Our basis for processing this data |
Taking steps at your request prior to entering into a contract If you request that we contact you to provide more information on our services to you, or complete your onboarding process, we’ll process your data and contact you on this basis. Legitimate interests We will send you our email newsletters, and other messages being necessary for our legitimate interests to give you information about our products and services (unless you have opted-out) and complete your onboarding process. We’ll also retain and analyse information gained from our interactions with you as part of understanding, tracking and improving how we market, sell and grant our service. We retain a record of your marketing preference and communication channels choices in order to demonstrate our historic compliance with data protection law. |
| How long we hold the data |
Email newsletters We’ll keep your details on this list until you unsubscribe, at which point we’ll move your details to an opted-out list to ensure that we don’t send you marketing emails from other sources in future. Sales process We retain information relating to our sales interactions with you for up to five years following our determination that we’re not an appropriate sales fit. We use this period as service contracts in our industry often last for 3-5 years, so a new opportunity may arise during the retention period. Onboarding process We retain information relating to your onboarding as long you your are our customer and up to five years following the termination of our contract. We use this period as service contracts in our industry often last for 3-5 years, so a new opportunity may arise during the retention period. General We retain historic information relating to any marketing preference choices that you provided, or other bases for processing that have since lapsed, for six years from the date that the basis for processing lapsed. |
| Recipients of data |
Within TenureX Personal information will be available for our marketing, sales and onboarding success personnel, as well as compliance and customer success and other teams as necessary to fulfil the purposes set out above. Outside of TenureX Our cloud storage providers, customer database, and marketing providers. |
Job candidates
Recruitment information you provide to us
| What we do with your data |
We use your data to:
|
| Our basis for processing this data |
Taking steps at your request prior to entering into a contract: If you send us your personal information in response to a vacancy advertised by us, we need to process it in order to consider your application. Legitimate interests: We want to build the best team we can, and we carry out this processing as part of the hiring process that enables this. Compliance with a legal obligation For roles where we conduct a resident labor market test to enable us to apply for visas, and subsequently hire someone who needs a visa on this basis, we retain unsuccessful applicant information as part of the related record-keeping requirements. |
| How long we hold the data |
General Your information is stored in our applicant tracking system 12 months after we disqualify your candidacy for the role applied for. Successful candidates’ information becomes subject to our employee privacy policy. Legal record-keeping If we hire someone subject to a resident labor market test for a role you applied for, we’ll retain your personal data until the expiry of the applicable record-keeping requirement (currently one year following the end of our sponsorship of the visa in question). |
| Recipients of data |
Within TenureX Personal information will be available for the hiring and recruitment teams. Outside of TenureX
|
Recruitment-related data we collect
| The data we process |
|
| What we do with your data |
We use your data to:
assess your suitability for vacancies. |
| Our basis for processing this data |
Legitimate interests
Compliance with a legal obligation If you are actively involved in our recruitment process for roles where we conduct a resident labour market test and subsequently hire someone who requires a sponsored visa, we retain unsuccessful applicant information as part of the related record-keeping requirements. |
| How long we hold the data | Your information is stored in our applicant tracking system 1 year after final interview if unsuccessful, or subject to our legal record-keeping requirements if needed for our compliance with immigration law. |
| Recipients of data |
Within TenureX
Outside of TenureX
|
Our anti-money laundering, sanctions and adverse media data
| The data we process |
Sanctions, warnings, fitness & probity Information related to and available on publicly available government lists covering sanctions, the prevention and detection of unlawful acts, and other protective functions. This will generally include a full name, a year or date of birth, nationality, reasons for appearing on the list, and the period covered by the data subject’s appearance on the list, but depends on the information contained in the list. Politically exposed persons We collect publicly available information relating to individuals in prominent public positions, and their family members, close associates, and business interests. Names, dates or years of birth, position(s) held or connection(s) that we think may give rise to a PEP designation, country of nationality, residence and service, photographs (if available) and the period for which that designation would have been active (e.g. active service dates). Adverse media We collect links to publicly available news articles that our systems determine to name individuals in connection with financial crime, terrorist financing, other relevant unlawful acts, improper conduct, dishonesty, etc. We will also extract information relating to age from these articles to determine approximate years of birth. Corporate registry information We collect data from data providers and publicly available corporate registries or from third parties, relating to individual’s shareholdings and directorships (or such analogous positions). |
| What we do with this data |
Consolidated profiles: We collect, process and structure the data collected into profiles consolidating the information outlined above. Sharing with clients: Where one of our customer request to use our services, we search for a name on our databases, we share with that customer any profiles that match the given search parameters. |
| Our basis for processing this data |
Legitimate interests Our existing and prospective customers have legitimate interests in gaining access to high-quality and easily manageable data of the type we process in order to optimize compliance with obligations concerning sanctions, anti-money laundering, know-your-client and counter-terrorist financing. We also pursue our own legitimate interests in developing and improving products and services to serve this market (e.g. corresponding banking). |
| How long we hold the data |
AML Database: We retain the information in our AML databases indefinitely. Backups Where we remove personal data from this database (for example, where we become aware that the information is not, or is no longer, relevant), it will remain in our backups for 30 days. |
| Recipients of data |
|
Business contacts
Information we receive from you (e.g. business cards, correspondence during the sales process)
| What we do with your data |
A member of our sales team may contact you if we determine through your submission that you may be interested in our products and services. This information – along with details of our interactions including phone calls and correspondence – is added to, and managed through, our CRM. We analyse our CRM data to understand, track, and improve how we market and sell our services. We save some correspondence to provide precedents and examples to other members of the team, and add your personal information to our e-signing and billing systems if appropriate. We may make recordings of telephone calls with clients and prospective clients. |
| Our basis for processing this data |
Taking steps at your request prior to entering into a contract: If you request that we contact you to provide more information on our services to you, we’ll process your data and contact you on this basis. Legitimate interests We’ll retain and analyse information gained from our interactions with you as part of understanding, tracking and improving how we market and sell our services. We process data in relation to billing and contracting in order to operate the legal and financial elements of our business. We retain records of consent-based and other processing in order to demonstrate our historic compliance with data protection law. |
| How long we hold the data |
Email newsletters: We’ll keep your details on this list until you unsubscribe, at which point we’ll move your details to an opted-out list to ensure that we don’t send you marketing emails from other sources in future. Sales process We retain information relating to our sales interactions with you for up to five years following our determination that we’re not an appropriate sales fit. We use this period as service contracts in our industry often last for 3-5 years, so a new opportunity may arise during the retention period. General We retain historic information relating to any consent you provided, or other bases for processing that have since lapsed, for six years from the date that the basis for processing lapsed. |
| Recipients of data |
Within TenureX Personal information will be available for our marketing and sales personnel, as well as customer success and other teams as necessary to fulfil the purposes set out above. Outside of TenureX Our cloud storage providers, CRM, sales and marketing automation tools, customer support/servicing tools, debt collection service providers. |
Information we collect from publicly available sources
| The data we process |
|
| What we do with your data |
A member of our sales team may contact you to understand more information about your organisation’s anti-money laundering and sanctions compliance operations, and gauge your organisation’s potential interest in our services. This information – along with details of our interactions including phone calls and correspondence – is added to, and managed through, our contact database. We analyse our contact database data to understand, track, and improve how we market and sell our services. |
| Our basis for processing this data |
Taking steps at your request prior to entering into a contract: If you subsequently request that we contact you to provide more information on our services to you, we’ll process your data and contact you on this basis. Legitimate interests:
|
| How long we hold the data |
Sales process We retain information relating to our sales interactions with you for up to five years following our determination that we’re not an appropriate sales fit. We use this period as service contracts in our industry often last for 3-5 years, so a new opportunity may arise during the retention period. General We retain historic information relating to any consent you provided, or other bases for processing that have since lapsed, for six years from the date that the basis for processing lapsed. |
| Recipients of data |
Within TenureX: Personal information will be available for our marketing and sales personnel, as well as customer success and other teams as necessary to fulfil the purposes set out above. Outside of TenureX: Our cloud storage providers, CRM, sales and marketing automation tools, and customer support/servicing tools. |
