Effective Date: January 28, 2020
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.
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:
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:
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:
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:
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).
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:
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.
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 firstname.lastname@example.org and we will remove your details.
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.
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.
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.
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 email@example.com.
By filing your application with Smaato,