We collect, use, disclose, transfer or process your personal data by fair and lawful means to the extent necessary to achieve our purposes. The lawful basis includes:
- obtaining your consent to use your personal data;
- believing that the use of your personal data is of vital interest or to prevent or avoid danger to a person’s life, body or health;
- believing that the use of your personal data is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
- believing that the use of your personal data is necessary for the performance of our task carried out in the public interest or in the exercise of official authority vested in us;
- believing that the use of your personal data is necessary for the legitimate interests pursued by us or by a third party, unless the interests are overridden by your interests or fundamental rights and freedoms;
- believing that the use of your personal data is necessary for the establishment, complaint, exercise or defence of legal claims against you; and
- believing that the use of your personal data is necessary for compliance with a legal obligation to which we are subject.
We may use your personal data for purposes as follows:
4.1 Our contract with you
We will rely on the performance of contracts to which you are a party to use your personal data. Depending on the nature of each contract with us, we may use your personal data for the following reasons:
- Processing recruitment and selection, evaluate the qualification of candidates;
- Procuring, issuing or executing contracts, registering your account with us; and/or
- Exercising rights or performing obligations under executed contracts.
4.2 Our legitimate interests
We may rely on the purpose of legitimate interests pursued by us or by a third party which require us to use and process your general personal data, except where such interests are overridden by your interests or fundamental rights and freedoms.
For instance, we have legitimate interests which allow us to process your collected personal data in the following circumstances:
- Business communication;
- Maintaining security and safety of persons and properties on our premises e.g. using of CCTV surveillance, recording your entry and exit information from the Company;
- Contacting relatives or contact persons in emergency cases e.g. emergency contact persons of employees; and/or
- Designating a beneficiary for life insurance.
4.3 Our legal compliances and legal claims
We will rely on the purpose of legal compliances when it is required or allowed by any applicable laws to which we are subject. For instance, we rely on legal compliance or legal obligation grounds to process your collected personal data in the following circumstances:
- Performing obligations under the laws with government authorities such as the Revenue Department, Social Security Office, Department of Skill Development, Department of Labour Protection and Welfare, Empowerment for Person with Disabilities Fund, Department of Legal Execution and Student Loan Fund; and/or
- Complying with the applicable laws, notifications, and orders, or for litigation proceedings, processing data under subpoenas including the exercise of rights relating to personal data.
We may rely on the legal claims basis to process your sensitive personal data to establish, comply, exercise or defend legal claims against you or initiate litigation action to protect our interests.
We will process your collected personal data on grounds of consents; especially, in the case where our processing activities have potential impact on your sensitive personal data.
We may inform you of the objectives of our personal data usage and request your consent or explicit consent to process your collected personal data in the following circumstances:
- When we do not have other lawful grounds to process your general personal data or sensitive personal data, e.g. processing criminal records for your recruitment and selection process, processing copies of ID cards containing sensitive personal data for contract execution;
- When we intend to transfer your collected personal data overseas and the destination country has lesser data privacy standards; or
- When you are classified as a minor, quasi-incompetent or incompetent of which the consent will be requested from your legal representatives, guardians or curators, as the case may be.