EURON PARTNERS LIMITED (“Euron Partners”, the “Company“, “we“, “us” and “our“) recognizes and values the protection of your personal information. This Privacy Policy (“Policy“) sets out the ways that we may collect, use, disclose and protect your personal information. All Personal Information collected by us is treated in accordance with the Company’s Personal Information Collection Statement (“Collection Statement”) notified to you at the time that your personal information is collected by the Company and the provisions of the Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance“) and the Personal Data Protection Act 2012 (the “PDPA“).
Personal Data (Privacy) Ordinance (Cap. 486)
Collection of Personal Information
We may require certain personal information about you, including without limitation your:
- name;
- email address;
- postal address;
- telephone number; and
- Hong Kong residency status,
when you register with the Company. In the event that you wish to submit and/or upload your curriculum vitae for the purpose of applying for a job vacancy, we may also require information relating to your:
- age;
- gender;
- place of residence;
- education;
- work experience;
- qualifications; and
- employment history.
All of the above categories of information shall be collectively referred to as “Personal Information“.
We may also collect aggregate data that does not allow you to be identified (e.g. the date and time that you visited the Company’s website (the “Website”), your internet protocol address, the documents you access, the type of browser/operating system you are using and referring website address). This data helps us understand your needs and better adapt the Website and our services. We may share aggregate data about you with third parties, including for marketing and advertising purposes.
We may collect Personal Information from you in a range of ways including:
- when you register with the Company for job seeking or recruitment purposes;
- when you submit and/or upload your curriculum vitae for the purpose of applying for a job vacancy; and
- when you contact us in person, by phone, post, facsimile, email or online.
Use and Disclosure of Personal Information
We may use your Personal Information for the following purposes:
- register you with the Company and manage your registration;
- manage and process all transactions and dealings with you;
- provide you with information relating to job vacancies, the Company, and/or prospective employees;
- contact you and provide you with customer service;
- introduce you to employers and otherwise facilitate job applications; and
- perform research and statistical analysis.
We may disclose your Personal Information to third party service providers (including without limitation, lawyers and other third party service providers who provide administrative, telecommunications, technological or other services to us to enable us to operate our business), for the purposes outlined in this paragraph.
We may disclose your Personal Information if required to satisfy applicable legal or regulatory requirements. We may also transfer your Personal Information in connection with a merger, acquisition, transfer or sale of all or part of our business, with or to another company.
All of the transfers referred to above may occur within or outside Hong Kong.
Consequence of Failing to Provide Personal Information
It is voluntary for you to provide the Personal Information requested by us. However, in the event that sufficient Personal Information is not provided by you, we may not be able to provide you with our services or carry out the activities outlined in the foregoing paragraph.
Transfer of Personal Information / Use of Personal Information for Direct Marketing
We may disclose job seekers’ Personal Information to employers for the purpose of providing recruitment and/or related intermediary services to you. We may also use your Personal Information to provide you with information relating to job vacancies and/or the Company. If, at any time, you do not wish for your Personal Information to be transferred and/or used as outlined in this paragraph, you may communicate your objection in writing to your respective Euron Partners’ consultant, upon receipt of which, we will cease such transfers and/or use at no cost to you.
Cookies
When you use www.euronpartners.com, information may be collected about your preferences via the use of “cookies”. Cookies are pieces of information stored on your hard drive which allow www.euronpartners.com to be tailored to you on subsequent visits. Cookies do not allow you to be identified personally. If you would prefer not to receive cookies, you may disable this function in your browser. However, in doing so, you may not be able to take full advantage of the services provided at www.euronpartners.com.
Retention of Personal Information
We will not retain your Personal Information for longer than is necessary to provide you with the services requested from us and/or to comply with applicable legal requirements. In the event that we no longer require your Personal Information, we will take steps to ensure that it is securely destroyed or deleted.
Security of Personal Information
We will take all reasonable steps to ensure that your Personal Information is protected from unauthorised access, processing, erasure or other use, including restricting access to such information to authorised staff of the Company and password protecting the area for registered users of www.euronpartners.com.
However, no system is impenetrable. Accordingly, we cannot guarantee that the information transmitted via www.euronpartners.com is completely secure, and make no warranties or representations regarding the security of Personal Information transmitted using www.euronpartners.com.
Links to Third Party Websites
www.euronpartners.com may contain links to websites operated by third parties, over which we have no control. You should review the privacy policies and terms of use of any such linked websites to understand the ways in which these third parties may use your Personal Information.
Amendments
If we decide to amend this Policy, we will post such amendments on our website at www.euronpartners.com so our users are always aware of what information we collect and how we use it. If at any point we decide to use Personal Information in a manner different from that stated (in this Policy and the Collection Statement) at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their Personal Information in this different manner.
Access and Correction Rights
Under the Ordinance, you have the right to access and correct any Personal Information that you provide to us. You may exercise this right to access and correct your Personal Information at any time, by logging into your registered account with www.euronpartners.com. Alternatively, you may request access to and correction of any Personal Information that you provide to us by writing to your respective Euron Partners’ consultant. In accordance with the Ordinance, we have the right to charge a reasonable fee for the processing of any Personal Information access or correction request.
Personal Data Protection Act 2012
We take its responsibilities towards Singapore’s PDPA seriously. We recognize the importance for us to safeguard, manage and protect the personal data you have provided to us. Our Data Protection Policy is meant to give you a clear view on how we collect, use and disclose your personal data.
PDPA Introduction
“Personal Data” is defined by the PDPA as data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access. We will only collect your personal data in accordance with the PDPA either directly from you or your authorized representatives, and/or through our third-party service providers (e.g. partners, resellers). We will obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
Purpose for Collection, Use, Disclosure and Processing of Personal Data
The personal data we collect may be used, disclosed and/or processed for various purposes, depending on the circumstances, which include but are not limited to:
- Administrative matters on your product, service purchases and/or subscriptions, managing your accounts, processing your signups/registrations for mailing lists, etc.
- Facilitating Euron Partners & its partners’ ability to provide you with the products and services which you use
- Communicating with you on your enquiries, and/or sending you marketing, and/or promotional information and materials relating to products and/or services that we may be selling or marketing.
- Conducting market research and/or customer satisfaction surveys; and
- Any other purposes that we notify you of at the time of obtaining your consent. (collectively, the “Purposes”)
As the purposes for which we may collect, use, disclose or process your personal data depend on the circumstances at hand, the purposes above are not an exhaustive list. However, we will notify you of any other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
In order for us to run our business operations more efficiently and to fulfill the above-said Purposes, we may disclose your personal data to our third-party service providers, and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third-party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.
Specific Issues for the Disclosure of Personal Data to Third Parties
We respect that the personal data you have provided us is confidential. With that in mind, we will not disclose your personal data to other third parties without obtaining your permission first. However, we may disclose your personal data to other third parties without obtaining your permission first in certain situations which include but are not limited to:
- situations in which the disclosure is required or authorized based on the law and/or regulations and/or permitted by the PDPA or law
- situations in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of any individual;
- situations in which the disclosure is compulsory for any investigation or proceedings
- situations in which the personal data is disclosed to an officer of a prescribed law enforcement agency, upon production of written authorization signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer
- situations in which the disclosure is to a public agency and such disclosure is necessary in the public interest;
If we disclose your personal data to third parties with your consent, we will ensure the best efforts are taken said third parties to protect your personal data
Request for Access and/or Correction of Personal Data
You may request to access and/or correct your personal data that is in our possession by submitting a written request to us. Please submit your request to us. When you make a request to access your personal data, we will request certain information from you in order to determine your identity with certainty. Once we have sufficient information, we will seek to provide you with the relevant personal data within 30 days. Please note that the PDPA exempts certain types of personal data from being subject to your request to access it.
When you make a request to correct your personal data we will request certain information from you in order to determine your identity with certainty. Once we have sufficient information, we will seek to correct your personal data within 30 days. If we are unable to make the correction within 30 days, we will notify you of the earliest time within which we can make the correction. Please note that the PDPA exempts certain types of personal data from being subject to your request to correct it.
There will be a reasonable charge for the handling and processing of your requests to access and/or correct your personal data. We will provide you with a written estimate of the charges, and we are not required to respond to or deal with your request unless you have agreed to pay the charge.
Request to Withdraw Consent
You may withdraw your consent for the collection, use, disclosure and/or processing of your personal data that is currently under our possession. Please do so by submitting your request to us. We will try to process your request within 30 days after which your request for withdrawal of consent was made. If we are unable to make the withdrawal within 30 days, we will notify you of the earliest time within which we can make the withdrawal. After this, we will not collect, use and/or disclose your personal data in the manner stated in your request. However, please note that withdrawal of consent could result in certain legal consequences arising from such withdrawal. Depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us.
Administration and Management of Personal Data
If your personal data is to be used by us to take a decision that affects you, or disclosed to a third-party organization, we will take efforts to ensure that it is accurate and complete. However, this means that you should update us of any changes to the personal data that you had initially provided us. We will not be responsible for personal data that is inaccurate due to your not updating us about the changes to the personal data you had initially provided us.
We will also ensure that your personal data is adequately protected and secured. We will place reasonable security arrangements to prevent any unauthorized access, collection, use, alteration, disclosure, loss and/or damage of your personal data. However, we do not take responsibility for unauthorized access or use of your personal data by third parties that are wholly due to factors that are beyond our control.
If your personal data is to be transferred outside of Singapore, we will comply with the PDPA laws in this matter, including:
- Obtaining your consent, unless an exception under the PDPA or the law permits us to do so otherwise
- Taking the necessary steps to ensure that the foreign organization receiving your data is legally bound by enforceable laws that require them to maintain a standard of protection that is comparable to the protection under the PDPA
Updates of Data Protection Policy
In our efforts to ensure that we manage and protect your personal data properly, we will actively review our policies and procedures from time to time. We reserve the right to change the terms of this Data Protection Policy at our discretion. The latest policy will be updated and available on our website.
Cookie Policy
In our efforts to improve your browsing experience, we use cookies on our website. These cookies are text file that store or record information about your use of our website. These cookies help us collect information about your browsing habits, and improve your browsing experience, remember your preferences, understand our website performance. You can control which cookies you want to allow or disallow via your web browser’s settings. If you disallow the cookies on our website, you should note that you might not be able to access the full range of functions that our website offers. Personal data (if any) that we collect via cookies may be passed onto third-party service providers, for one or more of the purposes listed above, for managing and administering our website, or for the purpose of data hosting, storage or backup. Your usage of our website constitutes consent to our use of Cookie Policy.
If you wish to exercise one of the abovementioned rights and/or raise questions or complaints, please contact us at the following address:
Data Protection Officer
Euron Partners Limited
Suite 2302, New World Tower I
18 Queen’s Road Central
Hong Kong
Contact No.: +852 9788 6312
Email Address: [email protected]
In the event of any inconsistency between the English and Chinese versions of this Policy, the English version shall prevail.
Last update: June 2021