This Policy applies to personal data in our possession or under our control, including personal data in the possession of third parties which we have engaged to collect, use, disclose or process personal data for the purposes set out in the Policy.
This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use, disclosure, and Processing of your personal data by us.
Consent & Withdrawal
- By visiting our Website, registering as a Registered User or as an attendee at any of our events hosted on our Platform, or using any of our Services, you acknowledge that you have read and understood this Policy, and consent to the collection, use, disclosure and Processing of your personal data by us for the purposes set out in the Policy. If you do not agree with this Policy, you should not access our Website, register as a Registered User, or use our Services.
- We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our Services constitutes your acknowledgement and acceptance of, and consent to, such changes.
- The consent that you provide for the collection, use, disclosure, and Processing of your personal data will remain valid until such time it is withdrawn by you in accordance with this section. You may withdraw consent and request us to stop using or disclosing your personal data for any or all of the purposes listed below by submitting your request via email to our Data Protection Officer, or any of our representative and/or employee, at the contact details provided below.
- Upon receipt of your request via email to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on the provision of our Services to you) to process your request and to notify you of the consequences of us acceding to your request, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
- Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be able to continue providing our Services to you and we shall, in such circumstances, notify you before completing the processing of your request.
- Should you decide to cancel your withdrawal of consent, please inform our Data Protection Officer via email at the contact details provided below.
- Please note that withdrawing consent does not affect (a) the lawfulness of any collection, use, disclosure or Processing of your personal data prior to your withdrawal, or (b) our right to continue to collect, use, disclose, and Process personal data where such collection, use, disclosure and Processing without consent is permitted or required under applicable laws.
Collection of Personal Data
- Depending on the nature of your interaction with us, we may collect data from you which may constitute personal data, including:
- Technical data, which includes the URL from which you came to our Website, your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website;
- Identity data, which includes your first and last name, username or similar identifiers;
- Profile data, which includes your username and password, feedback and survey responses, career preferences, work experiences, interests, and results from personality tests, and any other items of information that you provide to us for the purposes of using or participating in our Services;
- Usage data, which includes information about how you use our Website and Services; and
- Marketing and communications data, which include your preferences in receiving marketing materials from us and third parties, and your communication preferences.
- You agree that your data shall, unless otherwise stated, be stored in our data centres in Singapore. Any such data centre utilised by us shall be monitored for compliance with the ISO/IEC 27001:2013, 27017:2015, and 27018:2019, or any other reasonable equivalent information security management standard.
- User Registration
If you wish to register with us as a Registered User, you will have to provide us with the following data about you, which may constitute personal data in our User Registration Form:
- Full name;
- Email address;
- Country of residence;
- Institution and course of study;
- Which country/jurisdiction in which you are legally able to commence employment in;
- The type of certification you are pursuing;
- Your discipline(s) of study;
- Your expected/past year of graduation;
- Your current employer;
- Any work experience or previous employment history;
- Additional qualifications or certifications;
- Relevant past times, hobbies or activities of interest;
- Your password; and/or
- Any other data which we may need to collect for the purposes of us providing the Services to you.
You will be required to consent to this Policy in any form which you may be required to fill in, including our User Registration Form. Further and in addition to this Clause 11, take note that your data may be stored and used pursuant to the PDPA.
- Collection by Client Organisations
Client Organisations may collect your personal data through our Website in the following ways:
- they may insert tracking code(s) into our Website, which will enable them to track your activity across their websites (for example, their corporate and careers websites or their online job application portal) to measure the effectiveness of their attraction and recruitment activities;
- they may send you “Net Promoter Score” surveys after hosting engagement events to collect your feedback or information that is relevant to such engagement events;
- they may view your Talent Profile; and/or
- they may download your CV.
We do not control or have access to any information that you may provide the Client Organisations, save for the anonymisation (via the removal of unique identifiers) and transfer of the information from the surveys conducted under Clause 12(b) which shall be conducted in accordance with the PDPA and/or any other applicable law, and will not be responsible or liable to you for the same.
- Third Party Websites
Our Website may include links to third party websites, plug-ins and applications (“Third Party Websites”). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control Third Party Websites and are not responsible for the information they collect or for their privacy or data protection policies, and will not be responsible or liable to you for the same. Therefore, we recommend that you read their privacy policies in detail.
Purposes and Uses of Personal Data
- We may collect and use your personal data for any or all of the following purposes, which in any event shall not extend beyond what is reasonable for us to provide you with our Services:
- to perform our obligations in the course of or in connection with the provision of our Services as requested by you;
- to register you as a Registered User;
- to verify your identity;
- to send you emails in relation to our Services;
- to enable you to engage with Client Organisations, and vice versa, through our Services;
- to facilitate engagement events involving Registered Users and Client Organisations;
- to obtain, respond to, handle, and process queries, requests, applications, complaints, and feedback from you;
- to manage your relationship with us (including notifying you about changes to our Policy or Terms of Service);
- to administer and protect our business and Website (including troubleshooting, data analysis, testing, system maintenance and support, reporting and hosting of data);
- to comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental or regulatory authority;
- for any other purposes for which you have provided the information;
- for any other incidental business purposes related to or in connection with the above; and
- to transmit to any unaffiliated third parties including our Third Party Service Providers and agents, or relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes.
- The purposes listed above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
- Aggregated data
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. For example, we may use such aggregated data for data analytics purposes to improve our Website, Services, marketing, customer and User relationships and experiences. Such aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. In the event such aggregated data is combined with or connected to your personal data such that it can directly or indirectly identify you, we will treat such combined data as personal data, which will be used in accordance with this Policy.
Disclosure of Personal Data
- We may disclose your personal data:
- where such disclosure is required for performing our obligations in the course of or in connection with the provision of our Services as requested by you;
- to Client Organisations, where such disclosure is in relation to the provision of our Services;
- to Third Party Service Providers, agents and other organisations we have engaged to perform any of the functions listed in Clause 14 above for us;
- to other Registered Users participating in common engagement events, or
- to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
- Disclosure to Client Organisations
By default, your Talent Profile is open, meaning that the data within will be disclosed to Client Organisations. You may request to hide your Talent Profile so Client Organisations can only view limited information about you.
Client Organisations may be able to see or search Registered Users by name, contact information, country, job title, function, preferences, year of graduation, and such other search criteria as we may reasonably introduce.
- Disclosure to Third Party Service Providers
Our Website and certain Services we provide require the services/products of Third Party Service Providers, who may require you to disclose your personal data to them through our Website.
As we use an external mailing service provided by Third Party Service Provider(s) to deliver you our emails, we may disclose your name and email address to the said Third Party Service Provider(s). We will, however, insofar as it is commercially reasonable, contractually ensure that your data and/or information is protected by such Third Party Service Provider(s) in accordance with the PDPA or any other legislation.
By using our Services, you expressly acknowledge and consent to the disclosure of your personal data to the Third Party Service Providers for the purposes listed above in Clause 14.
- Disclosure upon Sale of Business
If the Company’s business is sold, transferred or merged with another business, your personal data or information may be disclosed to our advisers and any prospective purchasers and their advisers, and the new owners may collect, use or disclose your personal data in the same way as set out in this Policy.
- We will not use any of the content you create within our Website and/or during the course of using our Services for external marketing purposes unless your prior consent has been obtained.
Transfer of Personal Data Overseas
- In order to provide you with our Services, we and/or our Third Party Service Providers may need to transfer your personal data to countries outside of Singapore. For example, if you join a chat on our Website while you are out of Singapore, your data will need to be transferred to servers outside Singapore. By visiting our Website, registering as a Registered User, or using our Services, you consent to the transfer of your personal data to countries outside of Singapore. In the event such transfers are necessary, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the applicable law(s) and regulation(s).
Protection of your Personal Data
- To safeguard your personal data from unauthorised access, collection, use, disclosure, Processing, copying, modification, disposal, accidental loss, or similar risks, we have put in place appropriate security, administrative, physical and technical measures, such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us.
- We also limit the disclosure of personal data both internally and to our agents, contractors, Third Party Service Providers and other third parties to a need-to-know basis. We require all third parties to respect the security of your personal data and to treat it in accordance with the law and in accordance with their own privacy policies.
- We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
Retention of your Personal Data
- We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable laws, including satisfying any legal, accounting, or reporting requirements.
- We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
Access and Correction [and Deletion] of your Personal Data
- Subject to the exceptions referred to in section 21 of the PDPA, you have the right to request access to a copy of your personal data which we hold about you or information about the ways in which we use or disclose your personal data.
- You also have the right to request for the correction or update of any personal data of yours which we hold. We generally rely on personal data provided by you. We want to ensure that your personal data is current, complete and accurate. Please update us if there are changes to your personal data.
- If you are a User from the EU, you may also have the following rights under the GDPR, within and subject to the conditions provided in the GDPR:
- to request that we erase your personal data;
- to request that we restrict the processing of your personal data;
- to object to our processing of your personal data;
- to request that we transfer the data that we have collected from you to another organisation, or directly to you;
- to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
- If you wish to make (a) an access request; (b) a correction request; or (c) deletion request, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
- We will respond to your request as soon as reasonably possible or practicable. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of receiving your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
- We may need to request specific information from you to help us confirm your identity. 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 need to verify the accuracy of any new data you provide us.
- You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if (a) your request unreasonably interferes with our operations due to its repetitious or systematic nature; (b) the burden or expense of providing access would be unreasonable to us or disproportionate to your interests; (c) the information is does not exist, cannot be found, or is trivial; or (d) your request is otherwise frivolous or vexatious. Alternatively, we may refuse your request in these circumstances.
- You may contact our Data Protection Officer if you have any enquiries or feedback on this Policy, our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
SeeMeCV Pte. Ltd.
39 Woodlands Close
- “Client Organisation” means prospective employers, educational institutions and course providers, clubs, associations, and any other organisation which may be granted access to your personal data for the purposes of us providing the Services to you;
- “Company“, “we“, “us” or “our” means SeeMeCV Pte. Ltd.;
- “CV” means the curriculum vitae of a Registered User, and curricula vitae shall be construed accordingly;
- “Data Protection Officer” means the data protection officer of the Company, appointed to oversee data protection responsibilities and ensure compliance with the PDPA, with contact details found in Clause 36.
- “PDPA” means the Personal Data Protection Act 2012 of Singapore;
- “personal data” means data, whether true or not, about a User who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
- “Processing” means any operation or set of operations performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, holding, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction;
- “Registered User” means any User who has registered with the Company through the UserRegistration Form;
- “Services” means the services, information and resources provided by the Company to Registered Users through our Website, including but not limited to:
- facilitating engagement events with Client Organisations; and
- matching and sharing with you appropriate jobs, courses, events and/or Client Organisations;
- “Talent Profile” means the profile created by the Registered User, which includes the data collected within the Registration Form, and if so provided by the Registered User, may include inter alia the Registered User’s career preferences, work experiences, interests, and results from personality tests;
- “Talent Seekers” means the profile created by the Registered User, which includes the data collected within the Registration Form, and if so provided by the Registered User, may include inter alia the Registered User’s career preferences, work experiences, interests, and results from personality tests;
- “Third Party Service Providers” means external service providers who have entered into service agreements with us to assist us in (a) operating our Website; (b) providing our Services to you; or (c) conducting our business generally, and include the following companies:
- MailChimp (https://mailchimp.com/);
- SurveyMonkey (https://www.surveymonkey.com/);
- Such other external service provider who we may contract with for the abovementioned purposes.
- “Third Party Websites” means websites which are not owned or controlled by the Company;
- “User” or “you” means any visitor, user or Registered User of the Website;
- “User Registration Form” means the form on our Website which Users register to become Registered Users;
- “Website” means https://www.seemecv.com, its sub-domains, sub-directories, or associated web-portals;
- Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).