Tower Research Capital LLC and its affiliates (collectively, “Tower”, “we”, “our” or “us”) are committed to transparency in the collection and use of your Personal Data (as defined below). This privacy notice sets out the Personal Data we collect, how we use your Personal Data, the circumstances under which we may share your Personal Data, and your individual rights. It applies to recruitment applicants, former employees, professional contacts, visitors to our website, visitors to our offices or others with whom we may communicate. 

How we obtain your Personal Data

We may collect personal information from you that personally identifies you (“Personal Data”) when you use our website or otherwise engage in communication with us, for example, submitting an employment application, entering into a contractual relationship with us, visiting our offices or contacting us when you use the email address on our website.

We collect Personal Data from a variety of sources, which may include:

• any documents you submit to us, including application forms, CVs or resumes, your passport or other identity documents; 
• your use of our website (including job application information submitted via our website, usage data through the use of browser cookies or other commonly used technologies such as web beacons and IP information); 
• your use of the Tower Guest Wi-Fi services on your personal device(s) at our offices;
• our communication or correspondence with you, such as when you contact us by email or by post; 
• from third parties in connection with potential employment such as recruiting agencies, employers, online platforms including professional and social networks and forums, employment background check providers, identity verification services, criminal records check providers, educational institutions, the references you provide to us, financial institutions, service providers and other individuals; or
• from other third parties in connection with your use of our website;
• CCTV devices at our offices for safety and security purposes.

The Personal Data we collect

• your name, title, address and contact details, including email address and telephone number;
• identification numbers, such as your passport number or government-issued ID number;
• your LinkedIn profile information;
• details of your qualifications, skills, experience and employment history, such as your CV or resume;
• where permitted by applicable law and regulation, information about your current level of remuneration, including benefit entitlements;
• whether or not you have a disability for which the company needs to make reasonable adjustments during the recruitment process;
• information about your nationality and entitlement to work; 
• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or beliefs; 
• other personal information you or others may provide to us during your communications with us;
• recruiting evaluations;  
• CCTV images and, where applicable, audio or video recordings collected during recruitment assessments; and 
• your browser, device type, IP address, and user session information.

Where we collect your Personal Data as part of a recruitment process, you are under no statutory or contractual obligation to provide that Personal Data to us, However, if you do not provide the information, we may not be able to process your application properly or at all. Further, we will seek information from third parties only once a job offer to you has been made and will inform you that we are doing so.

You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.

When we interact with you outside of a recruitment process, you have no statutory or contractual obligation to provide Personal Data to us but if you do not provide contact information, it will be difficult for us to communicate with one another.

As our offices are protected by CCTV, you may be recorded when you visit. We use CCTV to provide a safe and secure environment for those who work in and visit our offices.

Our use of your Personal Data

We process your Personal Data where we have a legitimate interest (e.g., for recruiting purposes), if it is required for contractual or operational reasons, if required by applicable laws or regulations or on the basis of your consent. 

We may use Personal Data to operate and secure our website and offices; communicate with you and respond to inquiries; evaluate and administer job applications and recruitment processes; verify information provided by candidates; manage our relationships with professional contacts and other third parties; comply with legal and regulatory obligations; prevent and investigate fraud, security incidents and misconduct; establish, exercise or defend legal claims; and for other legitimate business purposes consistent with the context in which the Personal Data was collected.

Where we process “special categories” of Personal Data about you (such as information about your health, race or sexual orientation), we do so on one of the following bases: your explicit consent, legal or regulatory requirements, health and safety, monitoring of equality and diversity, prevention or detection of crime or similar misconduct, management of occupational pension schemes, or because the processing is necessary for the establishment, exercise or defense of a legal claim.

We may use artificial intelligence (AI) tools in many aspects of our business, including to support parts of the hiring process, such as reviewing applications, analyzing resumes, scheduling interviews or assessing responses and identifying potential inconsistencies or verification signals in application materials based on available information. These tools may access and process Personal Data maintained in our recruiting systems, including information contained in candidate profiles, applications, resumes, interview materials and related recruiting records. These tools assist our recruitment team but do not replace human judgment. Tower may also use AI and data analytics, including video analysis in online exams, to protect exam integrity. We do not reject candidates or make other significant recruitment decisions based solely on automated processing without meaningful human review. Please contact us if you have questions about how your Personal Data is processed or would like to request a reasonable accommodation.

How we share your Personal Data

We may share your Personal Data within the Tower family of companies, with our third party service providers, and other third parties for the purposes set out below. 

• Within Tower: Your Personal Data will be shared internally for the purposes of the recruitment exercise. We may share your Personal Data within Tower. This includes members of the Tower human resources and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles. 
• Third party service providers: We will share your Personal Data with third parties who perform services on our behalf.  For example, we share Personal Data with our vendors (e.g., IT services providers, cloud providers, background check vendors, online platforms, recruiting agencies and platforms), partners and consultants. We may also share Personal Data with companies that operate our website. Our service providers may include providers of AI and related technology services that process Personal Data on our behalf.
• Legal reasons: We will share Personal Data if we think we have to in order to comply with the law or to protect ourselves such as responding to court orders or subpoenas. We may also share your Personal Data if a government agency or investigatory body requests. We may also use your Personal Data when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.

Privacy Notice for California Residents

For purposes of California Data Protection Law, California residents should also note the following:

We may collect and use the following categories of Personal Data for the business purposes described in this Privacy Notice: Identifiers; Personal Information Categories Listed in the California Records Statute; Characteristics of Protected Classifications under California or Federal Law; Commercial Information; Internet or Other Network Activity Information; Geolocation data; Professional or employment-related information; Non-public education information; and Sensitive Personal Information.  We may collect these categories of Personal Data from certain sources, including directly from you, automatically from your device(s), our affiliates, and service providers.

We may disclose these categories of Personal Data to the following categories of third parties, as more fully described above: Our affiliate, service providers, and agencies or law enforcement for legal compliance purposes.

We do not “sell” or “share” your Personal Data. We do not sell or share the Personal Data of consumers under 16 years of age.

We do not use or disclose Sensitive Personal Data for purposes other than those specified under applicable California Data Protection Law.

Subject to applicable limitations and exceptions, California residents may have the right to request access to and information about Personal Data we collect about them, request correction or deletion of their Personal Data, and obtain a copy of certain Personal Data. California residents also have the right not to receive discriminatory treatment for exercising applicable privacy rights. Requests may be submitted using the contact information below.

Privacy Rights in Certain U.S. States

Residents of certain U.S. states may have additional rights under applicable privacy laws, which may include rights to access, correct or delete Personal Data, obtain a copy of Personal Data, and appeal certain decisions regarding privacy requests. These rights are subject to applicable limitations and exceptions. To exercise an applicable right, please contact us using the information below.

Privacy Rights in Certain Jurisdictions

Depending on where you reside and applicable law, you may have some or all of the following rights in relation to your Personal Data:

• Right of subject access: The right to access and obtain a copy of your Personal Data on written request;
• Right to rectification: The right to have incorrect or incomplete Personal Data rectified;
• Right to erasure: The right to have certain Personal Data about you erased; 
• Right to restriction of processing: The right to require we delete or stop processing your Personal Data, for example where the data is no longer necessary for the purposes of processing;
• Right to object to processing: The right to object to the processing of your Personal Data; 
• Right to data portability: The right to ask for Personal Data you have made available to us be transferred to you or a third party; and
• Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your Personal Data, provided that this will not affect the lawfulness of our use of your data prior to the withdrawal of your consent. 

These rights are not absolute; they do not always apply and exemptions may be applicable. 

If you would like to exercise any of these rights, please contact our Head of Compliance EMEA (compliance@tower-research.com). 

For the purposes of relevant data protection laws in certain countries, Tower is the controller of your Personal Data.

You may have the right to lodge a complaint about the processing of your Personal Data with your local data protection authority.

If you are unhappy with the way we have handled your Personal Data, you have a right to complain to your local data protection regulator.

• In the UK, your local regulator is the Information Commissioner, whose website is available at https://ico.org.uk
• In the Netherlands, your local regulator is the Dutch Data Protection Authority, whose website is available at https://www.autoriteitpersoonsgegevens.nl/en
• In France, your local regulator is the Commission nationale de l’informatique et des libertés, whose website is available at https://www.cnil.fr/
• In the DIFC, your local regulator is the Commissioner of Data Protection at DIFC, who can be contacted at commissioner@dp.difc.ae
• In Jersey, your local regulator is the Jersey Office of the Information Commissioner: https://jerseyoic.org/
• In Singapore, your local regulator is the Personal Data Protection Commission (PDPC), whose website is available at https://www.pdpc.gov.sg 
• In Hong Kong, your local regulator is the Office of the Privacy Commissioner for Personal Data, whose website is available at https://www.pcpd.org.hk  
• In China, your local regulator is the Cyberspace Administration of China (CAC), whose website is available at http://www.cac.gov.cn 
• In Québec, your local regulator is the Commission d’accès à l’information du Québec: https://www.cai.gouv.qc.ca/
• In the Cayman Islands, your local regulator is the Office of the Ombudsman of the Cayman Islands: info@ombudsman.ky

Security and retention of Personal Data

We maintain reasonable security procedures and practices but the internet is not 100% secure.  We cannot promise that your use of our website will be completely safe.  We encourage you to use caution when transmitting Personal Data over the internet. 

We will hold your personal information on our systems for the longest of the following periods: 

• as long as it is necessary or relevant for the practices described in this Privacy Notice; 
• the length of time it is reasonable to keep records to demonstrate compliance with professional or legal obligations;
• any retention period that is required by law; or
• the end of the period in which litigation or investigations might arise in respect of your use of our website or the services that we provide to you.

How we transfer your Personal Data

Due to the global nature of our business, your Personal Data may be transferred to jurisdictions outside your home jurisdiction (which may be the UK, EEA, the DIFC or APAC). The level of information protection in countries outside your home jurisdiction may be less than or different to that offered in your home jurisdiction. Where we transfer your Personal Data outside of your home jurisdiction, we will ensure that personal information is protected and transferred in accordance with applicable legal requirements, which can be done as follows:

• the country to which we send Personal Data may be approved in your home country (e.g., by the European Commission or under the UK or DIFC or under APAC data protection laws (as applicable)) as having adequate data protection laws; or
• the recipient may have signed a contract based on standard contractual clauses approved in your home jurisdiction (e.g., by the Information Commissioner’s Office in the UK, the European Commission, the Commissioner of Data Protection of the DIFC or the Cyberspace Administration of China in People’s Republic of China), obliging them to protect your Personal Data.

Contact us

If you have any questions about this Privacy Notice or other privacy concerns, please contact us at:

Tower Research Capital LLC
120 Broadway
38th Floor
New York, NY 10271
Attn: Data Protection Officer
DPO@tower-research.com 

We may update this Privacy Notice

We may update this Privacy Notice from time to time. When we do, we will post the updated Privacy Notice on our website and update the effective date above.