Privacy Policy

1. Definitions
   In this Privacy Policy (Privacy Policy), the following words have the meanings set out below:
   
   Content means any text, graphics, user interfaces, visual interfaces, photographs, trade marks, logos, sounds, music, artwork, computer code and other material used, displayed or available on the Website.
   
   Contact Details means contact details set out in section 16 of this Privacy Policy.
   
   Graduates refers to graduate Users of the Website.
   
   Graduate Profile means the profile created by a Graduate in order to access the Services available through the Website, whether through completion of a registration form and the provision of profile information on the Website or through importation of profile information via a third party log-in provider such as (but not limited to) Google and Facebook.
   
   Group means Gradconnection Pty Ltd (ACN 131 597 932) and its related bodies corporate, as defined in the Australian Corporations Act 2001 (Cth).
   
   Organisations means organisations that use the Website to advertise graduate roles or programs or other products or services for graduates.
   
   Organisation Profile means the profile created by organisations using the Website to advertise opportunities, products and services for graduates, whether through registration on the Website or through importation of profile information via a third party log-in provider such as (but not limited to) Google and Facebook.
   
   Parental Consent has the meaning given to it in section 3.4 of this Privacy Policy.
   
   Personal Information means information (including Sensitive Information) that identifies an individual or could reasonably identify an individual, including facts and opinions, whether they are true or not. In certain jurisdictions, the term “Personal Data” is used under applicable Privacy Laws, which means any information relating to an identified person, or a directly or indirectly identifiable individual. References to Personal Information in this Privacy Policy include a reference to Personal Data, where applicable.
   
   Personal Data has the meaning given to it under the definition of Personal Information.
   
   Privacy Laws means the applicable privacy and data protection laws (including any applicable spam laws) as may be in force from time to time in a particular jurisdiction which regulates the collection, use, disclosure, storage of and granting of access rights to Personal Information.
   
   Registered User means any User that has completed the registration or log-in requirements to create a Graduate Profile or an Organisation Profile.
   
   Related Businesses means any 'subsidiary', 'holding company', 'related body corporate' or “related entity” (as defined in the Australian Corporations Act 2001 (Cth)) of GradConnection Pty Ltd (ACN 131 597 932).
   
   Related Sites has the meaning given to it in section 4.1 of this Privacy Policy.
   
   Sensitive Information means certain categories of Personal Information as defined under applicable Privacy Laws that may include information or opinion about an individual’s racial or ethnic origin, political opinion or associations, religious beliefs, trade union memberships or associations, sexual orientation, criminal record including any proceedings for any offence committed or alleged to have been committed by such individual (including the disposal or result of such proceedings), health and genetic information, or government-issued identification, provided the information or opinion otherwise meets the definition of Personal Information.
   
   Services means the products, services, information and resources provided by us to Users through the Website or otherwise.
   
   Third Party Websites means websites, platforms, mobile applications, tools or services not operated by us, including but not limited to public search engines, AI-powered services, automated crawlers, content indexing and aggregation tools, and other online services that may access, index, scrape, cache, process, aggregate or republish content from our Website, whether these services are operated via websites, mobile applications, APIs, or other digital interfaces.
   
   User, you, or your means any user of the Website and any other users (as applicable) who otherwise engage with us and/or utilise our products, services or information (and/or any entity on behalf of whom they are acting).
   
   We, or us, or our (and related terms) means the Group unless otherwise stated and includes any reference to any of our businesses which operate under the SEEK Grad brand in Australia and New Zealand; the Jobstreet Grad brand in Singapore and Malaysia; and the Jobsdb Grad brand in Hong Kong.
   
   Website includes our online websites (au.gradconnection.com, nz.gradconnection.com, hk.gradconnection.com, sg.gradconnection.com and/or my.gradconnection.com, as the context requires), mobile websites, products, services, features and software.
   
   Young User means any User who is under the minimum age provided for under applicable Privacy Laws, including:
   (a) for Users in Singapore, a Young User means a person under the age of 13 years old; and
   (b) for Users in Malaysia, a Young User means a person under the age of 18 years old.
2. General
   1. By registering and creating an account with us, using our Services, visiting, accessing, viewing, browsing or using our Website in any manner or simply engaging with us over the phone, via email, in person or by any other means, the terms contained in this Privacy Policy will apply to you. You confirm that you have read and understood this Privacy Policy, you have the capacity to be bound by this Privacy Policy, and you agree to be bound by it.
   
   
   2. This Privacy Policy covers our businesses which operate under the SEEK Grad brand in Australia and New Zealand; the Jobstreet Grad brand in Singapore and Malaysia; and the Jobsdb Grad brand in Hong Kong. We may modify this Privacy Policy at any time. You should review this Privacy Policy periodically so that you are updated on any changes. In some circumstances, depending on the nature of the changes, you will be notified of the changes to this Privacy Policy prior to them taking effect if required to do so under applicable Privacy Laws. Your continued use of the Website will be deemed as acceptance of this Privacy Policy by you.
   
   
   3. We respect the privacy of your Personal Information.
   
   
   4. Any Personal Information collected from you will be used by us in accordance with and as described in this Privacy Policy.
   
   
   5. Any non-personal information you send to us through the Website (including by way of the blog or forums), such as questions, comments, or suggestions, is not encrypted, nor will it be treated as confidential. You agree that you have provided a non-exclusive, perpetual, royalty free licence to us to use the non-personal information you upload to our Website for any purpose whatsoever.
   
   
   6. You agree that we may disclose any information we, in our absolute discretion, consider we are required to disclose in order to satisfy any applicable rule of law, regulation, legal process or government request.
3. What Personal Information do we collect?
   1. Personal Information that we may collect includes information you have provided to us when:
      i. registering with us and/or setting up your Graduate Profile or Organisation Profile, whether through completion of a registration form on the Website or through importation of profile information via a third party log-in provider such as (but not limited to) Google and Facebook.
      ii. you use any of our products and services (including when you communicate with us);
      iii. applying for specific graduate positions or programs depending on the Organisation, we may collect additional Personal Information from you on behalf of the Organisation, such as any Personal Information that you may include within a resume or cover letters or in response to role requirement questions or selection criteria; or
      iv. otherwise visiting or using the Website.
   2. This type of information includes, but is not limited to, your:
      i. contact details, for example, your name, address, phone number, email address and location; and
      ii. general and background information, for example, you may elect to disclose to us your résumé, work experience, educational background, language skills, other skills, professional qualifications, salary information, résumé;
      iii. university attended;
      iv. graduation date,
      v. gender, work rights and citizenship.
   3. The information collected may also include the frequency with which you use the Services, the graduate positions or courses that you apply for, and any personal correspondence to us or correspondence to Organisations through the Website.
   4. For Young Users who are under the minimum age provided for under applicable Privacy Laws, you represent and warrant that your parent or legal guardian has been informed of and agreed to this Privacy Policy. Where legally required, you are responsible for obtaining valid consent from your parent or legal guardian before providing us with your Personal Information (Parental Consent). We may ask you to provide us with evidence of the Parental Consent and we reserve the right to delete any Personal Information collected from you if we cannot verify that you have the necessary consent to provide us with your Personal Information and/or use our Platforms. We will not be held liable or responsible where you have failed to obtain Parental Consent.
   5. In most cases, we do not need to collect your Sensitive Information when you engage with us. You should not disclose any Sensitive Information to us which is not necessary or relevant to disclose. Graduates should be especially mindful of this during a job application process. We will only collect Sensitive Information where:
      i. you consent to us collecting and processing your Sensitive Information by voluntarily including such information within documents and other information provided by you to an Organisation as part of a job application process;
      ii. where you voluntarily include such information within your Graduate Profile; or
      iii. there is another legal basis permitting us to collect such information.
4. Collecting information on our Users
   1. We collect information on Users and the websites and apps of our Related Businesses (Related Sites), including information you provide to us directly whether via a Website and information we collect automatically through use of software (including cookies, tags, applets, scripts and other similar technologies (referred collectively to as “cookies” below)) that is part of or placed on your browser or on your mobile device. We may also receive or collect your Personal Information from our Related Businesses and partners from time to time in accordance with this Privacy Policy, the privacy policy of those related entities and/or relevant Privacy Laws or other relevant law (as applicable).
   2. IP Addresses
      Our web servers gather your IP address to assist with the diagnosis of problems or support issues with our services, and to monitor the use of our Website, including the monitoring of the location of our Users.
   3. Cookies
      Data collection devices, called “cookies”, are files placed on your hard drive or mobile browser to collect information. Your browser will generally be set to automatically accept cookies. We use cookies to provide Users with a better browsing experience. These cookies collect details such as preferences and click activity for measurement and for features such as remembering your details for ‘Auto Login’ (provided you have chosen this option), and remembering your search criteria for the ‘My Last Search’ function (if applicable).
      We use this information for a variety of purposes, including to assist us in improving website performance, to customise and improve your experience of our services (e.g. by remembering your details if you have selected the ‘Auto Login’ option on one of our apps, if applicable), to analyse, develop and test our services and new functionalities, making business decisions, aiding in error reporting, aiding online payments, and to report to our advertisers and business partners on results achieved through our Services. This information may be received from or shared with our Related Businesses and partners. This is done for the purpose of providing you with improved products and services and to tailor the advertisements from any of our Related Businesses and partners that you see on the Website, Related Sites and other Third Party Websites and apps.
   4. Advertising
      We also use cookies to tailor advertisements from us, our Related Businesses, our business partners and Organisations that appear on the Website, Related Sites or other Third Party Websites and apps (“Advertising Locations”) to your interests, actions and behaviour on those Advertising Locations (which may be collected through the use of cookies on those Advertising Locations), your Graduate Profile, your Organisation Profile and/or information provided as a registered user on the Advertising Locations. Advertisements may be targeted to Graduates, Organisations, or other types of visitors to those Advertising Locations.
      You can limit the use of your information for purposes of targeted display advertising by updating your browser settings to block cookies or by updating the advertising settings in the system settings of your mobile device (see “Your Preferences” below). Even if you apply to opt-out of the use of information of advertisement targeting, we will still use the information we are able to collect for other purposes as set out in this Privacy Policy, and you may still see contextual advertising that is tailored according to other content on the pages you visit.
   5. Your Preferences
      If you do not wish to have cookies active whilst you browse the Website you may be able to “opt out” by modifying the privacy options in your browser. However, doing so will prevent access to some areas of the Website and limit your use of some of our products and services.
   6. Third Party Measurement
      In order to better understand our users, we utilise third party measurement companies to assess Website and mobile Website traffic. A cookie is used to collect the following information on the usage of the Website:
      i. the number of page views (or page impressions) that occur on the Website;
      ii. the number of unique visitors to the Website;
      iii. how long these unique visitors (on average) spend on the Website when they do visit; and
      iv. common entry and exit points into the Website.
      For Website visitors that are not Registered Users, this aggregated information is collated and provided to us to assist in analysing the usage of the Website. For Website visitors that are not Registered Users, this aggregated information is collated and provided to us to assist in analysing the usage of the Website. For Registered Users, this information is connected across different sessions on various devices and platforms to provide a more accurate total of the number of users prior to aggregation. This data is also accessible by media organisations and research companies, for the purpose of conducting industry comparisons with other organisations.
5. Why We Collect Your Personal Information
   1. Our main purpose for collecting your Personal Information is to provide you with our products and services. However, we may also use the information we collect for the following:
      i. to provide, maintain, protect, customise, and improve our Services. We may use your information including through the use of tools which incorporate artificial intelligence and machine learning to tailor features and personalise your experience;
      ii. to develop new services for you;
      iii. for analysis of site usage;
      iv. to improve the Content offered on the Website;
      v. for sending you information about your use of our Services and to provide you with technical and other support; or
      vi. to market and promote our products and services (including of our Related Businesses, and you consent to our Related Businesses sending you emails and other communications for this purpose);
      vii. to track and monitor your usage via data such as cookies, tags, applets, scripts and other similar technologies to personalise, manage and target display advertisements that may be visible to you;
      viii. to conduct market surveys, trials and customer research;
      ix. for research and development of products and services within the Group;
      x. to manage and administer our products and services, verify your identity and to ensure the safety and security of our operations;
      xi. to protect rights of all entities within the Group, its assets, other rights and interests and personnel;
      xii. to comply with our regulatory, compliance and legal obligations; or
      xiii. for any other purpose set out in this Privacy Policy.
   2. You also acknowledge and agree that in providing Services, we will provide some or all of your Personal Information to the entities whom you apply for an opportunity with and to the institution from which you graduated. An application is defined as clicking on the Application Buttons and/or external links which take you to the entity’s own website, external to the Website.
   3. 5.3 By providing your Personal Information, you agree to the use of your Personal Information in this manner. You acknowledge that we request your Personal Information as part of the process of assisting you in obtaining or accessing graduate opportunities, including finding employment and/or internships, and you agree that, in requesting this information, we are not acting in contravention of any applicable laws or regulations relating to equal opportunity, fair employment or anti-discrimination in the markets where we operate, including Australia, New Zealand, Hong Kong, Singapore and Malaysia, as updated from time to time (including any relevant rules, codes or guidelines issued by competent authorities)
6. What happens if we are unable to collect your Personal Information?
   1. It is important for us to process your Personal Information in order to provide our products and services to you. If you do not want your information to be processed for the purposes set out in this Privacy Policy, you may need to cease using our Website, products or services or engaging with us.
   2. You can choose not to share your Personal Information with us. However, if you choose not to provide us with the necessary Personal Information, we may not be able to provide you with some or all of our products or services.
   3. We also require your Personal Information to meet our legal obligations. Where the legal basis for the processing of your Personal Information is to comply with our legal obligations, a failure by you to provide us with certain Personal Information may cause us and/or you to be in breach of these legal obligations.
7. Disclosure of Your Information
   1. We may disclose your Personal Information in several different ways:
      i. to Organisations when you apply to an advertisement on our Website. By applying to an advertisement, you agree that we may share the information in your Graduate Profile and in your application with the relevant Organisation and that your information may be stored in:
      • our Website on behalf of the Organisation;
      • the Organisation’s careers platform; or
      • the Organisation’s chosen recruitment software.
      We do not take responsibility for, and cannot ensure the security of, your Personal Information stored by the Organisation outside of our Website. Any questions you have relating to a job advertised with us, your job applications and/or the status of your job applications should be directed directly to the Organisation;
      ii. to third parties such as service providers, contractors and partners from time to time for the purpose of assisting us to deliver the Services, enabling you access to the products or services they offer or conducting surveys, trials or customer research;
      iii. if required or permitted by law, including to government authorities, law enforcement agencies, regulatory bodies or competent officers which/who have legal authority to request the disclosure of Personal Information;
      iv. if we believe, in our absolute discretion, it is in the public interest;
      v. to seek feedback, or monitor, or improve quality of service;
      vi. to the Group and Related Businesses;
      vii. in the event of a merger, acquisition or restructure, to the transferee or successor of any entity within the Group, or any prospective purchaser of any business or asset within the Group (together with its relevant advisors);
      viii. when enabling you access to some of our products and services, we may make available links to other Third Party Websites which are not owned or controlled by us. This may result in the sharing of your Personal Information with those Third Party Websites. We are not responsible for the privacy practices of those Third Party Websites. Users are strongly recommended to refer to the privacy policies of Third Party Websites before using them;
      ix. for any other purpose set out in this Privacy Policy; or
      x. where we otherwise obtain your permission to disclose the information.
   2. We may also share aggregated, non-personally identifiable information publicly, for example, to show trends about the general use of our Services.
8. Applying for Opportunities
   Where you choose to apply for an opportunity advertised on the Website, including by clicking the “Apply Now” button, you consent to us making your Personal Information available to the Organisation providing the opportunity, as part of the application process.
9. Disclosure to Overseas Recipients
   1. We may disclose your Personal Information to overseas recipients, including connections and potential employers in the following countries:
      i. Australia;
      ii. New Zealand;
      iii. Hong Kong;
      iv. Singapore;
      v. Malaysia;
      
   2. You acknowledge that recipients of your Personal Information in the above and other overseas countries may not be subject to privacy laws that are similar, or equivalent to, the Privacy Laws. Where you have connections in these jurisdictions, or where we are otherwise permitted to do so under this Privacy Policy, you consent to your Personal Information being provided to recipients in these jurisdictions.
   3. You also acknowledge that we may share, transfer or disclose your Personal Information outside of your home location:
      i. to our Related Businesses overseas, including without limitation Gradconnection Pty Ltd (registered in Australia), the Group entity that is responsible for hosting and operating of the Website and the storing of your Personal Information, on secure servers located in Australia and the United States of America;
      ii. to a service provider, partner or other third party who provides services to us from an overseas location including Australia, New Zealand, United States of America, Singapore, Hong Kong and Malaysia;
      iii. where your Personal Information is shared with Organisations located outside of your home location. Organisations located overseas may have access to your Personal Information via your job application; and
   4. iv. where we consider it necessary to comply with any legal or regulatory obligations.
10. Opt out/Unsubscribe
    1. If you provide us with an email address that is considered Personal Information, our use of that email address will be subject to our Privacy Policy.
    2. Without limiting section 3 or anything else in this Privacy Policy, if you provide us with an email address (even if it is not considered Personal Information), you agree that we may share this information with the Group, including our Related Businesses and that we and our Related Businesses may use that email address to send you information, marketing and promotional material related to us and our Related Businesses.
    3. If you do not want to continue to receive marketing and promotional material from us, you may opt out of receiving this type of communication at any time by clicking the ‘unsubscribe’ link provided in the relevant communication; by updating your email preferences via your account settings; by replying ‘stop’ to an SMS that you receive from us; or you can contact us via the Contact Details outlined in section 16 below. Please note that clicking ‘unsubscribe’ in the footer of an email will unsubscribe you from all marketing and promotional emails from us. Opting out of emails will not opt you out of receiving SMS and vice versa. Opting out of marketing messages sent from one of our Related Businesses will not opt you out of receiving marketing messages from our other Related Businesses.
    4. We will comply with any unsubscribe request as soon as reasonably practicable, and in accordance with applicable Privacy Laws.
11. Related Bodies Corporate
    1. We may also disclose your Personal Information to our Related Businesses from time to time as part of the Group’s business operations, including (1) for the purpose of research and development of products and services within the Group, (2) to manage, administer and improve our products and services, verify your identity and ensure the safety and security of our operations and (3) to protect rights of all entities within the Group, its assets, other rights and interests and personnel. This includes (but is not limited to):
       1. data enhancement and parsing to facilitate product functionality and service quality;
       2. to obtain insights about our Users and to help businesses within the Group to improve, tailor and develop their products and services (for example, by conducting trials, analytics and customer research, and by using your information within machine learning and artificial intelligence systems, and to respond to market changes and customer needs and requests);
       3. development and improvement of algorithms servicing product functionality (e.g. Search recommendations);
       4. IT security measures for the benefit of protecting customer data;
       5. data aggregation to support customer experiences, support services, and data analytics;
       6. ensuring the proper and more efficient working of the IT systems and services; and
       7. to verify your identity (and any other information you may provide to us), your accounts and activities, to detect, prevent and respond to potential or actual security incidents and to monitor and protect against other malicious, deceptive, fraudulent or illegal activities.
    2. If you are a User and visit one of our Related Sites, we may track or monitor your behaviour on that site to enable us and our Related Businesses to improve and tailor the products and services offered to you including providing you with relevant content based on your online activity.
    3. We may also receive Personal Information from our Related Businesses from time to time in accordance with the privacy policy of those Related Businesses and/or the Privacy Laws or other relevant law (as applicable).
12. Security
    1. We take reasonable steps to ensure the security of our systems and to protect your Personal Information from misuse, interference and loss as well as unauthorised access, modification or disclosure. Any Personal Information which we hold is stored on secure servers and protected in controlled facilities.
    2. We follow accepted industry standards to protect your Personal Information. However, no method of transmission over the internet, or method of electronic storage, is guaranteed to always be secure. Third parties with whom we share your Personal Information (including Organisations) are asked by us to comply with all relevant obligations relating to the use and disclosure of Personal Information that are outlined in applicable Privacy Laws and any other relevant laws. Where you are asked by a third party to provide your information directly to them (for example, where you apply for a job via an Organisation’s career’s platform), the use of your information by these third parties will be governed by their own privacy policies and is not our responsibility or within our control.
    3. You must also assist us in keeping your Personal Information secure by maintaining the confidentiality of your account password used on the Websites and notifying us immediately if there is any unauthorised use of your account by any other Internet user, or any other breach of security relating to your account.
13. Links
    The Website may contain links to Third Party Websites. We are not responsible for the information on these sites, or their privacy policies. We may keep track of your interaction with links provided on the Website in order to improve services and to aggregate statistics.
14. Accessing and Amending Personal Information
1. Unless you become a Registered User, we do not collect information that identifies you personally. Subject to the exceptions listed in the Privacy Laws, you have the right to access your Personal Information that is in our custody or control. If you become a Registered User, you are able to change, update or clear your Graduate Profile and account settings at any time by logging into your account.
2. If you wish to access, correct, rectify or delete your Personal Information, please contact us via the Contact Details outlined in section 16. You can also contact us to request access to any additional Personal Information rights that may be available to you under applicable Privacy Laws. We will respond to your request as soon as reasonably practicable, and in accordance with applicable Privacy Laws.
3. When contacting us directly and making a request under this section, we may ask you to provide information to verify your identity before proceeding with the request. Depending on the circumstances and requirements under applicable Privacy Laws, we may not be able to fulfill a particular request from you. We will engage with you where we are unable to fulfill a particular request.
4. From time to time your Personal Information may change. It is important that you inform us of changes to your details by keeping the information on your Graduate Profile current and by updating your Graduate Profile if you wish to continue accessing the Services we provide.
5. To delete data in your Graduate Profile you will need to delete your entire account with us. We reserve the right to disable a Graduate Profile at its sole discretion (for example if information is found or believed to be untrue or being stored for improper purposes). Users can delete data in their Graduate Profile by:
   1. Login to your account
   2. Go to Settings
   3. Scroll to the bottom of the page and hit the Delete Account button
   4. Fill out the form and hit the Delete Account button
15. Complaints
    If you believe that the privacy of your Personal Information is not effectively protected, or if you are concerned that your privacy has been compromised through the dissemination of your Personal Information, please contact us via the Contact Details.
16. Contact Details
    If you have any questions or complaints regarding this Privacy Policy or if you wish to contact us regarding our use or handling of your Personal Information, you can do so by contacting us via the below channels. You can also contact us and request a copy of this Privacy Policy in hard copy or in another format that suits your particular needs.
    
    
    Any privacy complaint received by us will be referred for prompt investigation and a response will be provided to you as soon as possible. If you are still unsatisfied with the resolution of any complaints made, you can seek further redress through your local data protection regulator.
    
    

    SEEK Grad Australia	Email: [email protected] Post: Gradconnection Pty Ltd Level 14, 100 Pacific Highway, North Sydney, 2060
    SEEK Grad New Zealand	Email: [email protected] Post: Customer Service SEEK (NZ) Limited PO Box 9184 Newmarket, Auckland, New Zealand
    Jobstreet Grad Singapore	Email: [email protected] Post: GradConnection Pte Ltd Level 14, 100 Pacific Highway, North Sydney, 2060
    Jobstreet Grad Malaysia	Email: [email protected] Post: Agensi Pekerjaan JobStreet.com Sdn Bhd Level 16, Menara AIA Cap Square, No. 10, Jalan Munshi Abdullah, 50100 Kuala Lumpur, Malaysia.
    Jobsdb Grad Hong Kong	Email: [email protected] Post: GradConnection Pte Ltd Level 14, 100 Pacific Highway, North Sydney, 2060

    
    
    
17. Region Specific Information
    If you are a citizen or habitual resident of the applicable jurisdiction described below, the following jurisdiction-specific terms will supplement, and should be read together with, this Privacy Policy. In the event of a conflict between the jurisdiction-specific terms that are relevant to your jurisdiction and the rest of the Privacy Policy, the relevant jurisdiction-specific terms will prevail.
    1. New Zealand
       Some of the third parties to whom we may disclose your Personal Information (as listed above in Section 7) may be 'foreign persons or entities' for the purposes of New Zealand's Privacy Act 2020 (for example, they may be companies incorporated outside New Zealand).
       
       You authorise us to make those disclosures and acknowledge that those recipients may not be subject to Privacy Laws that provide comparable safeguards to those under the Privacy Act 2020.
    2. Singapore
       If you are based in Singapore, then all references to Privacy Laws in this Privacy Policy should be construed as including a reference to Singapore’s Personal Data Protection Act 2012 (PDPA 2012) and any of its related subsidiary legislation, regulations, rules, advisory guidelines, notifications and/or orders as may be amended from time to time.
       
       Reliance on Deemed Consent and/or Various Exceptions under PDPA 2012
       
       All references to consent in this Privacy Policy shall also include a reference to deemed consent by you to the collection, use and/or disclosure of your Personal Information by us when you register and create an account with us, use our products and services, visit our Websites or simply engage with us over the phone, via email, in person or by any other means. Subject to PDPA 2012, we shall be entitled to rely on such deemed consent by you for the collection, use and/or disclosure of your Personal Information for the purposes stated in the sections above.
       
       Apart from deemed consent, we may also rely on other exceptions to the requirement of consent under PDPA 2012 where appropriate, including but not limited to situations where:
       1. The use of the Personal Information (which includes sharing of such Personal Information between entities within the Group) is in relation to (i) improving, enhancing or developing our new goods or services; (ii) improving, enhancing or developing our new methods or processes for business operations in relation to our goods and services; (iii) learning or understanding behaviour and preferences of our customers (including groups of customers segmented by profile); and/or (iv) identifying goods or services that may be suitable for customers (including groups of customers segmented by profile) or personalising or customising any such goods or services for customers (the Business Improvement Exception);
       2. Where the collection, use and/or disclosure of Personal Information is in relation to data obtained from or disclosed by a public agency and is consistent with the purpose of the disclosure by the public agency (Public Agency Exception); and/or
       3. Where the use and/or disclosure of Personal Information is for the purposes of research, including but not limited to market research, provided that (i) the research purpose cannot be reasonably accomplished unless the Personal Information is provided in an individually identifiable form; (ii) there is a clear public benefit to using the Personal Information for the research purpose; (iii) the results of the research will not be used to make any decision that affects you; and (iv) in the event the results of the research are published, we will publish the results in a form that does not identify you. An additional condition applies to the disclosure of Personal Information, where it must be impractical for us to seek your consent for disclosure (the Research Exception).
       For the avoidance of doubt therefore, we may also rely on the Business Improvement Exception; the Public Agency Exception and/or the Research Exception (where appropriate, and subject to the PDPA 2012) in addition to all the legal bases set out in section 5 above, in respect of the processing of your Personal Information for the specified purposes stated in that section.
       
       Collection, Use and/or Disclosure of NRIC numbers (or copies of NRIC)
       
       As set out in section 3.5 above, we will only collect, use and/or disclose Sensitive Information with your explicit consent or if there is another legal basis permitting us to do so.
       
       Where such Sensitive Information pertains to your National Registration Identification Card (“NRIC”) number (or its equivalent, e.g. passport numbers, Foreign Identification Numbers, Work Permit numbers, Birth Certificate numbers etc.), we will only collect, use and/or disclose such NRIC numbers if (a) this is required under law (or an exception under PDPA 2012 applies); or (b) if such collection, use and/or disclosure is necessary to accurately establish or verify your identify to a high degree of fidelity.
       
       We will generally not retain your physical NRIC unless this is required by law, and will also assess the suitability of using alternatives to NRIC numbers where suitable (e.g. using only partial NRIC numbers), taking into account our business needs and provision of goods and services to you.
       
       Right to Withdraw Consent
       
       Subject to PDPA 2012, and in addition to all the rights as set out in section 14 above, you are also entitled to the following right in respect of your Personal Information.
       
       

       Right to withdraw consent

       Where the legal basis for the Processing of your Personal Information is consent, you will be entitled to withdraw any consent given or deemed to have been given under PDPA 2012 at any time, subject to the conditions and limitations stipulated by PDPA 2012. With regard to your Personal Information that is already in our possession, withdrawal of consent would only apply to our continued use or future disclosure of the Personal Information concerned.

       
       
       Transfer of Personal Information outside of Singapore
       
       Further to section 9, where your Personal Information is transferred out of Singapore, we will take reasonable steps to ensure that your Personal Information continues to receive a standard of protection that is at least comparable to that provided under PDPA 2012.
       
       By registering and creating an account with us, using our products and services, visiting our Websites or simply engaging with us over the phone, via email, in person or by any other means, you accept and agree that your Personal Information may be transferred (in or outside Singapore) to third parties including those set out in sections 7 and 9 above, to be used for the purposes stated in those sections. We will implement reasonable security arrangements which may include administrative, physical, and technical measures, such as ensuring that only the appropriate amount of Personal Information is held, restricting access to confidential documents on a need-to-know basis, implementing access limitation and encryption protocols to prevent unauthorised access, compartmentalisation of data, transferring Personal Information only on secure computer networks, and/or other relevant measures to protect your Personal Information.
    3. Malaysia
       Parental Consent
       
       In the event you are agreeing to this Privacy Policy in order for a minor to access and use our Platforms, products or services, you hereby consent to the provision of Personal Information of the minor to be processed in accordance with this Privacy Policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor's compliance with this Privacy Policy.
       
       Right to limit processing of your Personal Information
       
       You may request to limit the processing of your Personal Information by using the contact details provided under the Contact Details section above. However, this may affect our provision of our products and services to you.
    4. Hong Kong
       We intend to use the name and contact details of Registered Users for the purpose of direct marketing in relation to the following products and services, and your consent (which includes an indication of no objection) is required for us to do so:
       i. our products and services including information about our features, job placement and related career information, newsletters, surveys and other event information;
       ii. products and services offered by businesses within the Group; and
       iii. products and services offered by Organisations.
       
       Please refer to section 10 in respect of your options to unsubscribe from direct marketing.
18. Languages
    This Privacy Policy may be translated into the local language in the relevant territory. In the event of a conflict between this Privacy Policy in the English language version and the localised version, the English language version shall prevail. The localised version shall be deemed to be automatically amended to conform with and made consistent with the English language version.