Privacy Policy

  • Updated and Effective as of 11th April, 2023
1 Introduction

HeadHunters HQ recognizes the fundamental legal and ethical importance of the privacy and security of personal information. We commit to conducting business in accordance with all relevant Data Protection and Privacy laws in Singapore with the highest standards of ethical conduct. When you use our services, you’re trusting us with your information. We understand that this is a big responsibility and we work hard to protect your information and put you in control.

This Privacy Policy concerns the collection, processing, retention and disposal of personal data of HeadHunters HQ customers, suppliers, employees, contractors, and other third parties and is organised around three underlying commitments:

  1. Collecting and processing Personal Data fairly and lawfully
  2. Respecting Individual rights and choices
  3. Managing Personal Data responsibly

This Privacy Policy doesn't apply to:

  • The information practices of other companies and organisations that advertise our services
  • Services offered by other companies or individuals, including products or sites that may include HeadHunters HQ services or be linked from our services

This policy sets out the approach to data privacy within the HeadHunters HQ. The objectives of this policy are to:

  • Specify the controls for effective & transparent management of data privacy within HeadHunters HQ;
  • Have a document to demonstrate data privacy accountability to HeadHunters HQ board, shareholders, investors, clients, regulators, business partners and insurers;
  • Be transparent on how privacy risks are satisfactorily managed;
  • Define and promote best practice personal data processing;
  • Promote and embed a strong data privacy culture within HeadHunters HQ;
  • Encourage justifiable trust in HeadHunters HQ operations and services.
2 Coverage

At HeadHunters HQ, we develop a range of solutions that help many individuals daily for their Job Search and Recruitment needs. Our fleet of solutions currently includes:

  • AI-Powered Recruitment Chatbot Services built into Telegram and WhatsApp
  • Events Management System
  • Applicant Tracking System
  • Analytics
  • Job Portal

If you have any concerns or questions about our Privacy Policy, feel free to contact us via dpo@headhuntershq.com.

3 Collecting, Sharing, Removing and Processing of Personal Data Fairly and Lawfully
3.1 Being open about the personal data we collect

HeadHunters HQ informs individuals about the use of their Personal Data. When collecting Personal Data, HeadHunters HQ informs clearly, honestly and transparently about the nature of the Personal Data it collects and what it intends to do with it.

The use of Personal Data by HeadHunters HQ for a different purpose than initially communicated is not authorised, unless adequate information is provided to the concerned individuals, and where applicable, consent for the intended use is given to HeadHunters HQ.

In general, HeadHunters HQ is authorised to use Personal Data for secondary purposes when implementing internal controls and audits and complying with its statutory and regulatory obligations.

3.1.1 Information that is collected

HeadHunters HQ collects information to ultimately offer a better service to all of our valued users - from figuring out basic information such as usage rates to more complex information such as matching suitable job opportunities to you. The information that we collect, and how that information is used, depends on how you use our solutions and how you manage your privacy controls.

When you create an account with us, we will ask for your Name, Contact Number, Email. Additionally, for Direct Employers and Recruiters, we will ask for your Company Name.

When you complete your account setup with us as a Job Seeker, we will ask for the following additional information:

  • Gender
  • Highest Qualification
  • Date of Birth
  • Employment Status
  • Citizenship
  • Preferred Work Location
  • Preferred Job Position
  • Preferred Job Industry
  • Residential Postal Code
  • Notice Period
  • Employment History
    • Position Title
    • Employer Name
    • Start Date
    • End Date
    • Role Description
  • Education History
    • Course Title
    • Institution Name
    • Start Date
    • End Date
    • Course Description
  • Resume
  • Profile Image

When you complete your account setup with us as a Recruiter, we will ask for the following additional information:

  • Recruiter Licence Number
  • Employment Agency License Number

We collect contents that you have created or uploaded through our solutions - this includes content such as Job Details that you share on our platform etc.

Email Address is collected for our newsletter.

We utilise 3rd Party Services (i.e. Google Analytics) to better understand our users so that we can deliver more personalised and extraordinary solutions for you. Please refer to Google's Privacy Policy here.

Information about your activity in our solutions is collected, which we use to perform various activities such as recommending a job that might be suitable for you. The activity information that we collect may include but not limited to:

  • Jobs and events searched
  • Clicks interactions
3.2 Using Personal Data for lawful and specific purposes only

HeadHunters HQ collect and process Personal Data only if we have a lawful reason to do so. We collect and process Personal Data only to the extent that either

  1. a valid and informed consent was given or
  2. if it is required by HeadHunters HQ legitimate business interests, such as providing services, software development and enhancement, strategic planning, data analytics, carrying out contractual obligations, corporate communication and complying with statutory or regulatory commitments.

HeadHunters HQ allows consent given to be subsequently withdrawn. Any consent given by individuals to the collection and use of their Personal Data must be given freely and in response to clear information by HeadHunters HQ about the intended use of the data. Such consent can be withdrawn anytime by the individual without undue complications. The date, content and validity of such consent must always be documented. We’ll ask for your consent before using your information for a purpose that isn’t covered in this Privacy Policy.

When processing Personal Data on behalf of a client or another third party (a Data Controller), HeadHunters HQ will comply with the guidelines and instructions of the Data Controller in addition with this policy.

3.2.1 Personal Data Sharing

Most of our solutions allow you to share your information with others such as with Employer when you submit your Job Application, and you have control over it. HeadHunters HQ may share non-personally identifiable information publicly. For example, we share information publicly to show trends about the general usage of our solutions.

If HeadHunters HQ is involved in a merger, acquisition or sale of assets, we’ll continue to ensure the confidentiality of your personal information and give affected users notice before personal information is transferred or becomes subject to a different Privacy Policy.

3.3 Ensuring data quality

HeadHunters HQ collect and keep Personal Data which is adequate, relevant, not excessive and up to date. We collect and store the minimum amount of Personal Data required for the intended initial purpose for which the data is used and ensures that, at all times, Personal Data in its possession remains relevant and adequate for its intended purpose.

Personal Data is kept by HeadHunters HQ only for the period of time required by its intended purpose. After which such data will be either deleted, destroyed or de-identified.

4 Respecting Individual rights and choices
4.1 Respecting individuals’ rights

HeadHunters HQ responds to any requests or complaints made by individuals in connection with their Personal Data. We recognises the rights of individuals such as:

  • The right to access
  • The right to correction
  • The right to withdraw consent
  • The right to request cessation of use or disclosure
  • The right to request deletion
  • The right to limit use or disclosure
  • The right to data portability
  • The right to object
  • The right to be informed of the consequences of not providing personal data

HeadHunters HQ will respond to requests made by individuals exercising their rights within a reasonable period of time after the individual’s request or within any specific period that may be required by applicable laws in the Republic of Singapore. We will handle and investigate complaints made by individuals about any breach of these rules or data privacy laws and will respond to such complaints in a timely manner.

4.1.1 Personal Data Removal

HeadHunters HQ allows all users to remove your stored personal data through self-serve. Personal data can be removed via the web-based Dashboard or through the individual Recruitment Chatbots in Telegram and WhatsApp.

4.2 Respecting individuals’ choices

HeadHunters HQ respect customers’ rights to object to the use of their Personal Data or to opt out of receiving direct marketing communications. When using Personal Data for marketing purposes, HeadHunters HQ will inform individuals in a clear and plain language about the use of their data for marketing purposes. HeadHunters HQ respects the right of its existing and prospective customers to:

  1. only receive marketing communications from HeadHunters HQ if an explicit and specific prior consent has been provided, when required by applicable laws, or if HeadHunters HQ can demonstrate that it is authorised to send such communications for its legitimate business purposes
  2. no longer receive any marketing communications if a specific preference setting, an opt-out or an objection to use such data for marketing purposes has been received by HeadHunters HQ
5 Managing Personal Data responsibly
5.1 Taking appropriate security measures

HeadHunters HQ adheres to appropriate technical and organisational security measures to protect Personal Data. We implement adequate security measures to ensure the confidentiality, integrity and availability of Personal Data and to prevent the risk of unauthorised or unlawful access, alteration, destruction or disclosure of such data. The measures for protection are based on impact assessments taking into account the risk to the individual related to the specific Personal Data stored by HeadHunters HQ. These measures include security and organisational measures adapted to the type of processing and the nature of the data to be protected, such as:

  • We use encryption to keep your data private while in transit;
  • We offer a range of security features, like 2 Factor Authentication to help you protect your account;
  • We review our information collection, storage and processing practices, including physical security measures, to prevent unauthorised access to our systems;
  • We restrict access to personal information to HeadHunters HQ employees, contractors and officers who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

HeadHunters HQ will inform individuals promptly of any privacy breach that has compromised their Personal Data and will report such incidents to the relevant authorities as required by applicable laws.

HeadHunters HQ ensures that our suppliers or partners also adopt appropriate and equivalent security measures. We require from its suppliers or subcontractors that they fully comply with HeadHunters HQ Privacy Policy, with any applicable data protection and privacy legislation and maintain adequate technical and organisational security arrangements to protect Personal Data.

HeadHunters HQ ensures that our employees maintain the confidentiality of personal data processing. We limit access to Personal Data to those of its employees or suppliers who need to perform specific tasks in relation to such Data. Adequate awareness, training, and confidentiality undertakings are in place to ensure that Personal Data is not shared or disclosed to unauthorised persons, including any other HeadHunters HQ employees who do not need to access such Personal Data.

5.2 Ensuring adequate protection for international transfer

When Personal Data is transferred, HeadHunters HQ ensures that we have taken steps to protect the Personal Data before transfer. We transfers Personal Data across national boundaries within the HeadHunters HQ or outside the organisation only when

  1. this is justified for business purposes and
  2. safeguards exist to ensure that Personal Data will continue to be protected at a minimum with the same level of protection required in the jurisdiction of origin.
5.3 Minimising risk impacts to individuals

If the processing is likely to result in a high risk to individuals, HeadHunters HQ will conduct a Privacy Impact Assessment. We conduct Privacy Impact Assessments to identify risks that the processing of Personal Data by HeadHunters HQ may cause to the privacy rights of individuals in order to eliminate or reduce such risks.

Such prior Privacy Impact Assessments will be part of any development of new services or business opportunities and acquisitions by HeadHunters HQ.

6 Changes to this policy

HeadHunters HQ regularly reviews this policy and makes sure that we process your information in ways that comply with regulatory requirements. We change this Privacy Policy from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We always indicate the date when the last changes were published. If changes are significant, we'll provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes).

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