Released on May 2020
Overview of Policy
Asporea and our affiliated companies in other countries are a global professional services firm focused on human resource management services are committed to protecting the confidentiality of information and privacy of our talents (Job seekers/Job Candidates), talent seekers (Employers), talent factories (Universities, Colleges & Skill Development Centers) and recruitpool (Employment Agencies) and other users of our websites and services.
If you do not agree to our processing of your data in the manner outlined in the Policy or in any manner then please do not submit any personal data to us via any means.
This policy is applicable directly or indirectly to:
- Our talents (Job seekers/Job candidates) and recipients of our services;
- Parents/Legal Guardian of talents (Job seekers/Job candidates) and recipients of our services;
- Our talent seekers (employers) and associate third parties, as applicable;
- Our talent factories (Universities, Colleges & Skill Development Centers) and associated third parties, as applicable;
- Our recruitpool (employment agencies) and associated third parties, as applicable;
- Our Personal Career Advisor ‘PCA’, who are individual people and refer talents (Job seekers/Job candidates) with one of our Branch Office for services offered by us listed in our website;
- Users of the our websites and applications;
- Our employees, business partners, freelancers, consultants, advisors and associated third parties, as applicable; and
- Representatives of our business partners, clients and vendors.
Where you provide Asporea with your personal data, in person, by email, through websites, mobile app, social media, messengers, job portals or offices, we will use our best efforts to ensure that the information you submit to us remains private and are only used in accordance with this policy. By providing us with your personal data, you also consent for us to collect, store, hold, share, transfer, process, use, disclose and protect your personal data in accordance with this policy.
Asporea must comply with the applicable privacy laws and similar laws in the countries in which we have affiliated with.
Information We Collect
In order to carry our business as Human Resource Management Consultants, Asporea may collect your personal data in one of the following ways:
- If you are an talents (Job Seekers/Job Candidates), talent factories (Universities, Colleges & Skill Development Centers) or recruitpool (employment agencies), you apply for job/position/Services or create an account to apply for job/position/Services, Through by person, references, our sites, applications, social media channels, communication app like whatsapp, facebook messengers, skype, job portals; at our events, career seminars, webinars; job/career fairs; through phone/mobile and fax; through job applications; through email; in connection with in-person recruitment; or in connection with our interactions with talent seekers (employer), talent factories (universities, colleges & skill development centers), recruitpool (employment agencies) and associates, vendors, PCA etc… we may collect the following types of personal data (as permitted under local law):
- Your name, contact details, email address, industry and details or the inquiry on the page titled Start Journey, Contact Us, Apply For Job, Grievance and forms titled Inquiry Form, Enrollment Form, Assessment Form, CV Form, Health Information Form, Personal Information, Reference, Feedback Form etc…;
- User names or passwords when you registered on our sites and app;
- Information you provide about friends or other people you would like us to contact. (The Controller assumes that the other person previously gave an authorization for such communication);
- Employment, travel and education history & proof;
- Previous and present business details & proof if any;
- Language proficiencies and other work-related skills & proof;
- Professional qualifications, license and memberships & proof;
- Information regarding your career interests, preferences, and qualifications;
- Contents of any other identification provided to the Company for application or employment purposes;
- Information from and related to publicly published profiles you’ve created on job-related social media platforms, career sites and job boards (such as facebook, LinkedIn, monster.com, timesjob.com, shine.com or indeed.com etc…);
- Trade test/assessment and training history & proof;
- Information regarding your career interests and preferences;
- Citizenship and your right to work in particular country;
- National identifier or other government-issued identification number like PAN, Aadhar number, Passport, Driving License or any other photo ID or address proof;
- Date of birth;
- Biometric data;
- Geo-location data;
- Bank account information;
- Benefits information;
- Insurance details;
- Tax-related information;
- Family details, guardian details, nominee details, spouse & children details if any;
- Next-of-kin or emergency contact information (relative and friends details live in your permanent and current residential area);
- Relative and friends details work/live in middle east, south east Asia or Europe;
- Marriage certificate & birth certificate of children if any;
- Medical history, disability & health related information, physical fitness, psychological/mental fitness, medical reports;
- Alcohol, tobacco, gutka, drug and other cosmetic substance consumption details;
- Rehabilitation, major & minor surgery, accidental, acute/chronic diseases, critical illness and metal implant information;
- Character report, criminal records and background screenings;
- Political, social and religious information (PEP, SEP & REP);
- Information contained within your personnel file with the Company, such as performance reviews, disciplinary action, and other payroll related information; and Health information, including that related to a work-related claim (e.g. workers’ compensation claim);
- In some jurisdictions, in order to comply with statutes, rules, and regulations pertaining to equal employment opportunities or to assist us or its related corporations in compiling data for its equal opportunities practices and reporting, we may also ask you to provide gender, race/ethnicity, religious or disability information. The provision of this type of information will be voluntary, unless it is required by law, and failure to provide this information will not hinder your employment or project opportunities;
- Other information you may provide to us, such as through surveys, interactions with our Social Media, or other mediums used to contact us;
- information provided by references; and
- Your work objectives and information contained in your resume or C.V., information you provide regarding your career interests, hobbies and other information about your qualifications for employment.
How We Use and disclose the Information We Collect
All the personal data we collect is held, used and disclosed for the following purposes set out below (as permitted under local law):
- talents (Job Seekers/Job Candidates), talent seekers (employer), talent factories (Universities, Colleges & Skill Development Centers) or recruitpool (employment agencies), we collect, use, disclose and/or process the above personal data for the following services:
- Providing you with job opportunities and work;
- Providing HR services to you, including administration of benefit programs, payroll, performance management and disciplinary investigations or actions;
- Providing additional services to you, such as training, assessment, certification, career counseling and career transition services;
- Assessing your suitability as a job candidate and your associate qualifications for positions;
- Providing workforce solutions and connecting people to work;
- Creating and managing online accounts;
- Processing payments, refunds and taxes;
- Submitting reports of recruitment and placement to the government authorities;
- Processing for skill training, assessment and certifications;
- Processing pdot training session;
- Processing for employment matching, short listing, interviewing and selection;
- Processing for travel itinerary, travel ticket, insurance, emigration/labor clearance, visa, work permit, temporary residence card, job offer, employment contract, medical test, physiological test like personality test, psychometric test, aptitude test, behavioral test etc…, dmit test, career test, trade/skill test etc…
- Processing for hostel, labor camp, accommodation for training and employment;
- Managing our business partner, client and vendor relationships;
- Where permitted under law, for communicating about, and administering participation in, special events, promotions, programs, offers, surveys, contests and market research;
- Responding to individuals' inquiries and claims;
- Operating, evaluating and improving our business (including developing, enhancing, analyzing and improving our services);
- Managing our communications; performing data analytics;
- Performing accounting, auditing and other internal functions;
- Protecting against, identifying and seeking to prevent fraud and other unlawful activity, claims and other liabilities;
- Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies;
- Administering, processing and/or dealing with any transactions between you and the Asporea and/or any of its related corporations including but not limited to any application by you for employment or work with the Asporea;
- Recruiting, assessing and/or matching you with/for potential positions or assignments with talent seekers, third party organisations (or our customers), and/or dealing with matters related thereto such as offering you a placement of work or job with talent seekers, such third party organisations (or our customers) or referring you for employment to a third party organisation (or our customer);
- Administering, managing and/or dealing with the provision of work or job placement services to you. This includes us sharing your personal data with talent seekers or third party organisations, for your potential placement or employment opportunities with those talent seekers/third party organisations who are seeking talents (employees or workers), or to the organisation to which you have been assigned to work;
- Administering, facilitating, processing and/or dealing in any matters relating to your use of any of the Asporea’s or its related corporations’ websites, any functionalities on the websites or any transactions or activities carried out by you on or through any of the Asporea’s or its related corporations’ websites, such as but not limited to live social media feeds;
- Monitoring, processing and/or tracking your use of any of the Asporea’s or its related corporations’ websites in order to provide you with a seamless experience, facilitating or administering your use of any of the Asporea’s or its related corporations’ websites, and/or to assist us in improving your experience in using any of the Asporea’s or its related corporations’ websites;
- Contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail, mobile app (whatsapp, viber, skype, messengers etc…) for the purposes of administering your use of any of the Asporea’s or its related corporations’ website or any transactions you have with us, or for the provision of our services to you. You acknowledge and agree that such communication;
- By us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
- Carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations applicable to us, the requirements or guidelines of governmental authorities which we determine are applicable to us, and/or our risk management procedures that may be required by law or that may have been put in place by us;
- To prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with conflict of interests; or dealing with and/or investigating complaints;
- Creating reports with respect to our transactions with you, and/or producing statistics and research of such transactions for internal and/or statutory reporting and/or record-keeping requirements for us or our related corporation(s);
- Complying with or as required by any applicable law, governmental or regulatory requirements of any jurisdiction applicable to us or our related corporations, including meeting the requirements to make disclosure under the requirements of any law binding on us or our related corporations, and/or for the purposes of any guidelines issued by regulatory or other authorities, with which we or our related corporations are expected to comply;
- Complying with or as required by any request or direction of any governmental authority which we are expected to comply with; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities. For the avoidance of doubt, this means that we may/will disclose your personal data to the aforementioned parties upon their request or direction;
- Storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside country;
- Facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of the Asporea and/or its related corporations;
- Dealing with and/or facilitating a business asset transaction or a potential business asset transaction, where such transaction involves any the Asporea and/or its affiliate(s) as a participant, and there may be other third party organisations who are participants in such transaction. The term “business asset transaction” means the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organization or a portion of an organisation or of any of the business or assets of an organisation;
- We may use your personal data to permit you to participate in live social media feeds. If you choose to participate, your public username may be displayed on the sites along with your post, including, but not limited to, comments, images and video.
- We may/will need to disclose your personal data to third parties, whether located within or outside country, for one or more of the above Purposes, as such third parties, would be processing your personal data for one or more of the above Purposes. In this regard, you hereby acknowledge, agree and consent that we may/are permitted to disclose your personal data to such third parties (whether located within or outside India) for one or more of the above Purposes and for the said third parties to subsequently collect, use, disclose and/or process your personal data for one or more of the above Purposes. Without limiting the generality of the foregoing or of the immediately preceding paragraph setting out the Purposes, such third parties include:
- Our associated or affiliated organisations or related corporations or clients or recruitpool (employment agencies) or talent factories (universities, colleges & skill development centers) or assessment & certification agencies;
- Any of our contractors or third party service providers that process or will be processing your personal data on our behalf including but not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies and data centres;
- Our customers or third party organisations, who may be your potential employers or hirers or organisations which engage you for your services; and
- Third parties to whom disclosure by the Company is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.
- You may see certain Asporea ads on other websites or media because we engage third-party advertising networks. Through such advertising networks, we can target our messaging to users through demographic, interest-based, behavioral and contextual means. Through the ad networks, we can track your online activities over time by collecting information through automated means, including through the use of third-party cookies, web server logs, pixels and web beacons. The networks use this information to show you advertisements that may be tailored to your individual interests and previous activity. The information our advertising networks may collect on our behalf includes data about your visits to websites that serve Asporea advertisements, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Sites and on third-party websites that participate in these ad networks. This process also helps us track the effectiveness of our marketing efforts. To learn how to opt out of this ad network interest-based advertising (If any), please visit aboutads.info/choices/. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.
Our Legitimate Interest for Processing Personal Data
Asporea shall process personal data for certain legitimate business purposes, which includes some of all of the following:
- Where the process enables us to perform, enhance, modify, personalize or otherwise improve our services/ communications for the benefits of our (Job Seekers/Job Candidates), talent seekers (employer), talent factories (Universities, Colleges & Skill Development Centers), recruitpool (employment agencies), pca, associates, vendors and employees;
- To identify & prevent fraud;
- To enhance security of our network and information systems;
- To Better understand how people interact with our websites;
- To provide postal communications to you which we think will be of interest to you;
Whenever we process data for these purposes we will ensure that we keep your rights in high regard and take account of these rights.
How We Process and Protect Personal Information
We process the personal data we collect, also by automated means, for the purposes defined above and for a specific period of time, which complies with our internal data retention policy, in order to ensure that the personal data are not kept longer than necessary. We maintain administrative, technical and physical safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. In order to ensure adequate security and confidentiality of the personal data, we may apply the following security measures as appropriate:
- Restriction of access to your personal data to Asporea employees strictly on a need to know basis, such as to respond to your or companion inquiry or request;
- Implementation of appropriate physical, electronic, administrative, technical and procedural safeguards that comply with all applicable laws and regulations to protect your personal data from unauthorized or inappropriate access, alteration, disclosure and destruction. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when you are done using a shared computer;
- Asporea employees who misuse personal data are subject to strict disciplinary action, as it is a violation of the Integrity Policy of Asporea;
- Encryption of personal data in transit;
- Hardened network infrastructure; and
- Network monitoring solutions.
International talent seekers (employers), recruitpool (employment agencies), affiliates or associates transfers of personal data
Our core business is to provide human resource services align with recruitment services and talent management services to the talent seekers (employers), recruitpool (employment agencies), affiliates or associates who are located in overseas countries and as part of the processing of employment visa, work permit, selection, interview, screening etc…, as such, transfer, share personal data concerning you to overseas countries. We transfer personal data between talent seekers (employers), recruitpool (employment agencies), affiliates or associates and data centers for the purposes described above. We may also transfer personal data to our third party suppliers outside the country as described above. Your personal data may be stored in databases located outside of the EU including in India. The database is controlled by talent seekers (employers), recruitpool (employment agencies), affiliates or associates outside of the EU including in India and can be accessed electronically.
- Within or Outside the Middle East ‘GCC’ countries;
- Within or Outside the South East Asia;
- Within the European Union;
- Outside the European Union: When we transfer personal data from within the European Union to countries or international organizations that are based outside the European Union the transfer takes place on the basis of:-
- An adequacy decision by the European Commission; or
- In the absence of an adequacy decision, other legally permitted grounds:
- a legally binding and enforceable instrument between public authorities or bodies;
- Standard data protection clauses (formerly called the Model Clauses) promulgated by the Commission.
Where we transfer personal data outside of EU, we either transfer personal data to countries that provide an adequate level of protection (as determined by the European Commission) or we have appropriate safeguards in place. Appropriate safeguards to cover these transfers are in the form of standard contractual/data protection clauses adopted by the European Commission. Where we transfer personal data between our talents (job seekers/job candidates), talent seekers (employers), recruitpool (employment agencies), affiliates or associates we have covered these transfers by entering into standard contractual clauses adopted by the European Commission.
Cookies and Web Beacons
- When you visit Asporea’s web site, upon your consent, we will access your browser cookies. We use them to remember your login details, to track overall web traffic and to access information in cache about your session to assist you in the use of our website. Information such as your last search will be cached however, this kind of information is deleted each time you close your web browser. Asporea also uses 'analytical' cookies to enable us to improve the way our website functions, for example, by making sure users can find what they need easily. Most browsers will allow you to block access to your cookies. However, by blocking Asporea's access to your cookies, your use of our websites will be restricted.
- A "cookie" is a file that websites send to a visitor's computer or other Internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser;
- As you click through our sites, a record of the action may be collected and stored. We link certain data elements we have collected through automated means, such as your browser information, with other information we have obtained about you to let us know, for example, whether you have opened an email we sent to you. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Your browser will allow you to block cookies, however, you may not be able to use all of the features of our Sites without cookies.
- More information about cookies can be found here.
- You can also view how to control your cookie settings from the following links:
- Internet Explorer
- Mozilla Firefox
- Google Chrome
- UC Browser
- Providers of third-party apps, tools, widgets and plug-ins on our sites, such as social media sharing tools, also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. Subject to applicable law, Asporea is not responsible for these providers' information practices.
- On our sites, we may collect information about your online activities to provide you with advertising about products and services tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our ads are served.
- Our sites are not designed to respond to "do not track" signals from browsers. Information collected through third-party plug-ins and widgets on the Sites (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets, and Asporea is not responsible for those providers' information practices.
- For your convenience and information, our sites may provide links to third-party sites, apps and services that may be operated by companies not affiliated or not associated with Asporea. These companies may have their own privacy notices or policies, which we strongly suggest you review. We are not responsible for the privacy practices of any non-Asporea sites, apps or services
- E-mail Communications: If you are a recipient of our marketing communications, we will track whenever you receive, open, click a link, or share an e-mail you receive from Asporea.
- Information from Other Sources: We might receive information about you from other sources to ensure the accuracy and completeness of your profile.
Asporea shall only process the received information pursuant to pursue our legitimate business interests for example screening CV's and relevant documents of prospective talents (job seekers/job candidates), establishing communication with prospective talent seekers (employers), affiliates or associates (whom you represent), establishing and receiving services from talent factories (universities, colleges & skill development centers) and recruitpool (employment agencies).
You may have certain rights relating to your personal data provided for under applicable law. These are the right to:
- Request access to your personal data and request details of the processing activities conducted by Asporea.
- Request that your personal data is rectified if it is inaccurate or incomplete;
- Request erasure of your personal data in certain circumstances;
- Request restriction of the processing of your personal data in certain circumstances;
- Object to the processing of your personal data in certain circumstances;
- Receive your personal data provided to us as a controller in a structured, commonly used and machine-readable format in certain circumstances;
- Lodge a complaint with a supervisory authority;
- Object to, and not to be subject to a decision based solely on, automated processing (including profiling), which produces legal effects or significantly affects you;
- Withdraw your consent provided at any time by contacting us and
- Right of access to your personal data in order to verify that his or her personal data is processed in accordance with law.
If you require more information about the processing of your personal data, please refer to the How to Contact Us section below.
If you have any concerns as to how your data is processed or you want to execute your rights, you can contact us at firstname.lastname@example.org
Notice to Singapore Residents
Subject to certain limitations, Singapore residents may ask us to provide them with
- I. a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and
- II. the identity of those third parties. To make this request, the residents may contact us as specified in the "How to Contact Us" section below or by sending email at email@example.com