1. Introduction
Language Talent Solutions Sdn Bhd Sdn Bhd (“us” or “Company”) respects your privacy. We support the various international and local privacy laws, and has procedures in place to meet the requirements of those laws. This privacy policy (“Privacy Policy”) discloses our privacy principles and our practices for gathering, collecting, storing, using and/or disclosing your personal data. Please read this Privacy Policy so that you may understand how we may collect, use, disclose, process and share your personal data.
2. Definitions
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession). It shall also have the meaning described in the Personal Data Protection Act 2010 of Malaysia (“PDPA”).
Services means the services extended and provided by Language Talent Solutions Sdn Bhd to its clients. These services include but not limited to recruiting and placing individuals for potential work assignments with our customers and/or directly at the Company.
Cookies are small files stored on your device (computer or mobile device).
Data Controller means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.
Data Processor (Or Service Providers) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
DATA SUBJECT is any living individual who is the subject of Personal Data.
3. Information We Collect, Use or Disclose
3.1. In order for us to provide our services and for the operation of our business, provide services of recruiting and placing individuals for potential work assignments (and related services) with our clients and/or directly at the Company, act as employer or hirer of record for individuals employed or engaged by the Company, or provide human resources related services to our customers, we must collect certain personal data from and about individuals who are candidates, employees, contractors, and former employees herein also known as Data Subject.
3.2. The types of personal data collected, used, processed, disclosed and stored by us depends on the circumstances and/or the purposes for which we may need to process your personal data. Hence, subject to the above-mentioned, such personal data may include, but not limited to:
· Name;
· Contact information (address, phone number, e-mail address);
· Personal identification or Passport details;
· Date of birth;
· Employee identification number;
· Contents of any other identification provided to the Company for application or employment purposes;
· Education and employment history;
· Work-related skills and experience;
· Professional credentials or licenses;
· Images (still/recording);
· Membership in professional organizations;
· Any other information contained on an individual’s Curriculum Vitae (CV);
· Citizenship and work authorization status;
· Disability and health-related information;
· Next-of-kin or emergency contact information;
· Information from and related to publicly published profiles you’ve created on job- related social media platforms and job boards (such as JobStreet, LinkedIn, Monster, or Indeed);
· Information provided by references; and
· Information regarding your career interests and preferences.
3.3. In addition, under certain circumstances, we may request types of personal data that are regarded by some countries as “sensitive”:
· National identification, tax identification, passport number or social security number(s);
· Financial or bank account information;
· Results of drug, criminal, and/or background screenings;
· Benefits selections, potentially including health insurance and retirement planning information;
· Biometric data;
· 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).
3.4. Your interactions with our websites may also result in the collection, processing, and storage of the following types of information from you:
· Geolocation data;
· Other information you may provide to us, such as through surveys, interactions with our Social Media, or other mediums used to contact the Company.
4. Purposes of Collection of your Personal Data
4.1. Your personal data collected will be used, disclosed and or processed for one or more of the following purposes:
(a) administering, processing and/or dealing with any transactions between you and the Company and/or any of its related corporations including but not limited to any application by you for employment or work with the Company;
(b) recruiting, assessing and/or matching you with/for potential positions or
assignments with third party organisations (or our clients), and/or dealing with
matters related thereto such as offering you a placement of work or job with such third party organisations (or our clients) or referring you for employment to a third party organisation (or our clients);
(c) administering, managing and/or dealing with the provision of work or job placement services to you. This includes us sharing your personal data with our clients or third party organisations, for your potential placement or employment opportunities with those clients/third party organisations who are seeking employees or workers, or to the organisation to which you have been assigned to work;
(d) contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for the purposes of administering your use of any of the Company’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;
(e) carrying out due diligence 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;
(f) 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;
(g) creating reports 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);
(h) 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 for the purposes of any guidelines issued by regulatory or other authorities, with which we or our related corporations are expected to comply;
(i) 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;
(j) storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Malaysia;
(k) facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of the Company and/or its related corporations;
(l) for marketing, if you have separately indicated that you consent to such purpose. If so, we may/will send you by email, postal mail or other modes of communication marketing and promotional information and materials relating to products and/or services (including products and/or services of third party organisations whom the Company may collaborate or tie up with) that the Company or its related corporations may be selling, marketing or promoting, whether such products or services exist now or are created in the future.;
(m) dealing with and/or facilitating a business asset transaction or a potential business asset transaction, where such transaction involves the Company 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 organisation or a portion of an organisation or of any of the business or assets of an organisation,
(the purposes set out above shall be collectively referred to as the “Purposes”).
5. Use and Disclosure of your Personal Data
5.1. The Company may/will need to disclose your personal data to third parties for one or more of the above Purposes, as such third parties, may/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 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 :
(a) our associated or affiliated organisations or related corporations;
(b) any of our agents, 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;
(c) our customers or third party organisations, who may be your potential employers or hirers or organisations which engage you for your services; and
(d) 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.
5.2. Your consent pursuant to this Privacy Policy is additional to and does not supersede any other consents that you had provided to the Company with regard to processing of your personal data.
5.3. Data that has been anonymized does not personally identify you and is not covered by this Privacy Policy.
5.4. We hold our employees, agents, and suppliers accountable for maintaining the trust that you place in us with your personal data. Your personal data will not be used or shared except as in accordance with applicable law relating to personal data.
5.5. Your personal data may be shared with third party service providers as set out at paragraph 5.1 above.
5.6. Consistent with paragraph 5.1 above, as a result of the scope of the Company’s operations, the sharing of your personal data with our other group entities, service providers, and customers may result in your personal data being sent to countries outside of your country of residence, which may have data protection laws that differ from those in your country of residence. Regardless of the source or destination location of your information, we will at all times protect your personal data as described in this Privacy Policy, and in accordance with applicable data protection laws when transferring your personal data. We are committed to complying with the Personal Data Protection Act 2010, in particular, its policies as well as corresponding guideline and orders.
6. Cookies and Web Beacons
6.1. The Company’s websites use "cookies" to help personalize the online experience. A cookie is a piece of data stored on the user’s computer or mobile device tied to information about that user. They also allow us to identify those devices when they return to a website. You can set your browser to notify you before you receive a cookie, giving you the option of whether to accept it. You can also set your browser to turn off cookies. If you do so, some areas of our websites may not function properly. We use both session ID and persistent cookies. A session ID cookie simply expires once the user closes the browser. A persistent cookie is a small text file stored on the user’s hard drive for an extended period of time. Please refer to your internet browser’s help file for instructions on how to remove a cookie.
7. Rights of Data Subject
7.1 As the Data Subject, you have the following rights and may request for us to:
a) To request access to personal data;
You have the right to request for access to personal data processed by us on with reasonable notice. Access, requests can be made by sending us an email or via phone.
b) To request correction of personal data;
You have the rights to request for correction and/or update of your personal data that is inaccurate, incomplete or outdated . Correction requests can be made by sending us an email or via phone.
c) To limit processing of your personal data;
You are entitled to limit our processing of your personal data by expressly withdrawing the consent given previously, in each case, including but not limited to any direct marketing purposes subject to any applicable legal restrictions , contractual conditions within a reasonable time period
8 Administration of your Personal Data
8.1 We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by the Company to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.
8.2 We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
8.3 We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
8.4 Where your personal data is to be transferred out of Malaysia, we will comply with the in country PDPA. In this regard, this includes us taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Act. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.
9 Children’s Privacy
Our Services are not intended for use by children under the age of 18 (“Child”or “Children”).
We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.
10 Changes to this This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our websites, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
11. Contact Us
If you have any questions, concerns, or comments about this Privacy Policy and/or the handling of your personal data by us, you may contact us by email at jinder@languagetalentsolutions.com
