SG Applicant Privacy Policy

Effective date: January 28, 2020

Smaato Singapore Applicant Personal Data Protection Policy

1. Applicability and Purpose

This Policy is intended to clarify and inform you of how Smaato manages Personal Data in accordance with the Personal Data Protection Act 2012 (“the Act”, “PDPA”).

You agree and consent to Smaato Pt Ltd, Singapore, and our Group Companies (collectively referred to herein as “Smaato” , “us”, “we” or “our”) as well as our respective agents, authorized service providers and relevant third parties collecting, using, disclosing and/or sharing your Personal Data in the manner set forth in this Policy. In this Policy, “Group Companies” refers to Smaato, Inc. and/or any of its affiliates, subsidiaries, associated entities and any of their branches and offices, such as Smaato, Inc. (Hamburg/Germany branch).

This Policy supplements but does not supersede nor replace any other consents which you may have previously provided to us nor does it affect any rights that we may have at law in connection with the collection, use and/or disclosure of your Personal Data. Please note that this Policy outlines how your Personal Data will be managed in connection with your prospective employment with Smaato only.

Smaato will attempt to update this Policy in a timely manner, to ensure that this Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. As and when the contents of this Policy are updated or amended, the changes will be uploaded onto our website https://www.smaato.com/sg-applicant-privacy-notice/. It is your duty to keep yourself updated as to the latest version of the Policy.

2. Your Personal Data

In this Policy, “Personal Data” refers to any data or information, whether true or not, about an individual who can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide to us include (depending on the nature of your interaction with Smaato), but are not limited to:

Name, contact information (address, phone number, e-mail address, SkypeID);
Date of birth;
Education and employment history;
Work-related skills and experience;
Income levels and Salary expectation;
Professional credentials or licenses;
Citizenship and work authorization status;
Information from and related to publicly published profiles you’ve created on job-related social media platforms and job boards (such as LinkedIn, Monster, Indeed or SmartRecruiters);
Information provided by references;
Information regarding your career interests, preferences, and qualifications and
Any other information contained on an individual’s Curriculum Vitae (CV).

Your interactions with our websites and mobile applications may also result in the collection, processing, and storage of the following types of information from you:

Geolocation data and information about your device hardware information;
Other information you may provide to us, such as through surveys, interactions with our Social Media, or other mediums used to contact Smaato.

Some of our websites require you to provide your personal data, such as when you create a profile and log-in credentials. Instead of having to type in your personal data, some of these functionalities may allow you to use third-party authentication tools such as Facebook, Twitter, LinkedIn, SmartRecruiters and Google to populate certain fields. By authenticating through one of the social media options, you allow us to receive your personal data and other information that is accessible through these tools. This information may be incorporated into your profile. For any such tool you choose to use, we encourage you to also review the tool provider’s privacy policy and any terms and conditions.

We may provide you with access to third-party functionality that allows you to post content to your social media account(s). Any information that you provide to your social media account(s) through use of such third-party functionality is governed by the applicable third party’s privacy policy, and not by this Policy. For the avoidance of doubt, we are not responsible for any personal data that you provide to such third party.

3. Collection of Personal Data

From time to time it may be necessary to supply us with Personal Data about yourself and other individuals for purposes in connection with your prospective employment. Where Personal Data is submitted by you on behalf of another individual or concerns another individual other than yourself, you represent and warrant to us that all the necessary consents (procured in accordance with all applicable data protection legislation, including without limitation the PDPA, for such purposes stated in the relevant sections of this Policy) have been obtained from the relevant individuals and that you have retained proof of these consents, such proof to be provided to us upon our request.

Generally, Smaato may collect your Personal Data in the following ways:

when you submit forms or applications to us, including via our job applicant registration portal;
when you submit requests to us;
when you respond to our request for additional Personal Data;
when you respond to our initiatives;
when you ask to be included in an email or other mailing list;
when you submit your Personal Data to us for any other reasons.

4. Purposes for the Collection, Use and Disclosure of your Personal Data

We collect, use, disclose and process Personal Data to offer, provide, manage and administer our internal services and data collection in accordance with Smaato’s policies. Your Personal Data may be collected, used for and/or disclosed for purposes including but not limited to:

Recruiting, assessing and/or matching you with/for potential positions or assignments at Smaato and/or dealing with matters related thereto such as offering you a job, including for future positions that Smaato believes you may be suitable for;
to maintain a talent pool of job applicants in order to match you to future job vacancies;
to send you job advertisements and information on our job vacancies using the methods of communication specified;
responding to your queries and requests;
managing your prospective employment relationship with Smaato;
conducting internal investigations and proceedings;
monitoring compliance with our internal rules and policies;
human capital consulting, human resources business process outsourcing;
managing our infrastructure and business operations and complying with internal policies and procedures;
facilitating business asset transactions (which may extend to any merger, acquisition or asset sale) involving Smaato;
matching any Personal Data held which relates to you for any of the purposes listed;
purposes including analytical and statistical studies for our internal business processes;
preventing, detecting and investigating offences, crimes and breaches including identity, fraud, credit, money laundering and conflict checks, and handling and investigating complaints or security threats;
analyzing and managing our commercial risks;
protecting and enforcing our contractual and legal rights and obligations;
facilitating any proposed or actual assignment, transfer, participation or sub-participation in any of our rights or businesses;
complying with internal policies and procedures and any applicable local or foreign statute, rule, law, regulation, judgment, decree, directive, sanctions regime, court order, agreement between Smaato and an Authority, agreement or treaty between Authorities, which may apply to Smaato or to which any Smaato Group Company is subject;
complying with requirements or arrangements with local or foreign regulatory or tax authorities imposed by law or assumed by us for the protection of our financial, commercial or other legitimate interests;
to assist in any investigation by an Authority where there is a reasonable suspicion of the commission of a crime under any written law in any jurisdiction in which Smaato operates;
enforcing, defending and protecting the property or rights of Smaato and its affiliates;
any other purpose reasonably related to the aforesaid.

We may also collect, use and/or disclose your Personal Data for other purposes where you have provided us with your consent.

The purposes listed in the above clauses 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).

5. Disclosure of Personal Data

Personal Data will be protected and kept confidential but, subject to the provisions of any applicable law, may be disclosed, for the purposes listed above (where applicable), to the following parties:

Smaato Group Companies
agents, contractors or authorized third-party service providers who provide services such as telecommunications, information technology, employee management, payment, payroll, benefits program, processing, training, storage and archival, to Smaato and its Group Companies;
Smaato recruiters from our Group Companies and our third-party human resource consultants and service providers;
any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving Smaato and its Group Companies;
anyone to whom we transfer or may transfer our rights and duties;
our professional advisors such as our auditors and lawyers;
any judicial, administrative or regulatory body, any government or public or government agency, instrumentality or Authority, any domestic or foreign tax, revenue, fiscal or monetary Authority or agency, court, law enforcement body or any agents thereof, having jurisdiction over any Smaato Group Company;
any other person or company in connection with the purposes set forth above.

In connection with the purposes set out in this Policy, Smaato may from time to time transfer your Personal Data to service providers in other countries working on our behalf in accordance with applicable laws (e.g. payroll company, employee management software provider, benefits program administration, insurance agencies, tax companies, server hosted overseas to store data), Group Companies and their service providers and third parties who are situated overseas. Smaato has put in place contractual agreements to ensure that these third parties will abide by the requirements under the PDPA in collecting, using or disclosing your personal data. Where it is necessary for these parties to further disclose personal data onward to other third parties, Smaato will endeavor to ensure that these parties also abide by the PDPA. In some instances, however, your personal data may have to be disclosed to organizations in countries or territories which do not have standards of protection comparable to that under the PDPA.

For the avoidance of doubt, your Personal Data may also be processed by Employees or by other third parties operating outside of Singapore who work for Smaato, or by the representatives and Employees of Smaato’s Group Companies in connection with the purposes set forth above.

6. Marketing Purposes

Smaato may contact you via mail, electronic mail, telephone (call or SMS-text), and/or social media platforms to inform you about our survey, benefits, services, events and industry trends that we think may be of interest to you; this may include employer-employee related third-party marketing materials that is not directly or indirectly produced by Smaato. Smaato will not be selling your Personal Data for any purposes.

You may withdraw your consent for these purposes at any time by sending written request to datarights@smaato.com and we will remove your details.

7. Security of Your Personal Data

To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate 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, and disclosing Personal Data both internally and to our authorized third party service providers and agents only on a need-to-know basis.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure and Smaato shall not be held liable for any unauthorized disclosures or loss of your Personal Data arising from such risks. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

8. Accuracy of Personal Data

We generally rely on Personal Data provided by you (or your authorized representative). You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability or in delay to provide you with services, benefits and entitlement you have requested or are entitled to. Smaato may disregard or delete Personal Data which seems, on a reasonable basis, to be inaccurate or out of date by reason of the time which has elapsed since it was collected or by reason of any other information in its possession.

9. Retention of your Personal Data

You understand and agree that should your job application be unsuccessful, Smaato may retain documents containing your personal data for such period as Smaato considers in its reasonable discretion necessary for legal or business purposes, including (where applicable) for the purposes listed in section 4 above.

10. Withdrawal, Access or Correction of your Personal Data

If you wish to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy, or if you have any questions, complaints relating to your Personal Data, or you would like to obtain access and make corrections to your Personal Data records, please contact Smaato’s Data Protection Officer by sending a written request to datarights(at)smaato.com.

By filing your application with Smaato,

you acknowledge that you have read, understood and agreed to Smaato’s Singapore Applicant Personal Data Protection Policy (the “Policy”), and consent to the collection, use and disclosure of your Personal Data by Smaato and Smaato Group Companies as well as their authorized third-party service providers for the purposes set out in the Policy. You may withdraw consent for such collection, use and disclosure, and make an access or correction request in respect of your personal data, in accordance with the Policy; and
in the event that we have received your job application or Personal Data from any third party pursuant to the purposes set out in the Policy, you warrant that such third party has been duly authorized by you to disclose your Personal Data to us for the purposes set out in the Policy.