1. INTRODUCTION

1.1. Welcome to the Smartfren Careers website (“Smartfren”, “we”, “us” or “our”). We take responsibilities under applicable privacy laws and regulations (“Privacy Laws”) seriously and is committed to respecting the privacy rights and concerns of all job applicants, prospective employees, and all users of our Smartfren Careers website and related recruitment systems and services (collectively, the “Site”). We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data.

1.1. “Personal Data” or “personal data” means 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 organisation has or is likely to have access. Common examples of personal data could include name, identification number and contact information.

1.2. By visiting or accessing the Site and/or by submitting an application for employment or other employment related query to us via any channel, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT SUBMIT AN APPLICATION FOR EMPLOYMENT OR OTHER EMPLOYMENT QUERY, AUTHORIZE ANY THIRD PARTIES TO SUBMIT SUCH INFORMATION ON YOUR BEHALF, VISIT AND/OR ACCESS THE SITE OR OTHERWISE PROVIDE YOUR PERSONAL DATA TO US. We reserve the right to amend this Privacy Policy at any time. To the fullest extent permissible under applicable law, your continued use of the Site and other interactions with us in relation to any prospective employment shall constitute your acknowledgment and acceptance of the changes made to this Privacy Policy.

1.4. Any personal information that is collected in relation to your application or via our Site is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time.

1.5. This Policy applies in conjunction with other notices, contractual clauses, consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override those notices or clauses unless we state expressly otherwise.

2. WHEN WILL SMARTFREN COLLECT PERSONAL DATA?

2.1. We will/may collect personal data about you:

• when you submit any job application or form, including, but not limited to, application forms or other forms relating to any of our job postings;
• when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, interviews, social media platforms, emails or through the Site. This includes, without limitation, through cookies which we may deploy when you access and/or visit our Site;
• when recruiters, employment agents, or other parties referring you for employment submit any materials on your behalf, in which case we understand that you have provided the necessary consent to the relevant third-party providing such personal data to us;
• when you provide documentation or information in respect of your interactions with us;
• when you provide us with feedback or respond to surveys; or
• when you submit your personal data to us for any reason.

The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.

2.2. We may collect personal data about you from you, our affiliates, third parties, and from other sources, including without limitation business partners (such as logistics or payment service providers), credit bureaus or scoring agencies, marketing services providers or partners, referral or loyalty programs, other users of our Services or publicly available or governmental sources of data.

2.3. In some situations, you may provide personal data of other individuals to us (such as your family members or friends or persons in your contact list). If you provide us with their personal data, you represent and warrant that you have obtained their consent for their personal data to be processed in accordance with this Policy.

3. WHAT PERSONAL DATA WILL SMARTFREN COLLECT?

3.1. The personal data that Smartfren may collect includes but is not limited to:

• name;
• email address;
• date of birth;
• home address;
• telephone number;
• gender;
• images and biometric data, including photographs or audio or video recordings;
• education, employment and/or salary history, where applicable;
• other information contained in and collected over the course of your employment application and related materials, including any referral information provided to us;
• marketing and communications data, such as your preferences in receiving marketing from us and third parties, your communication preferences and history of communications with us, our service providers, and other third parties;
• geographic or location data;
• any other information about you provided when you access, visit and/or interact with us or the Site; and
• aggregate data on content you engage with.

3.2. You agree not to submit any information to us which is inaccurate or misleading, and you agree to inform us of any inaccuracies or changes to such information. We reserve the right at our sole discretion to require further documentation to verify any information provided by you.

4. HOW DO WE USE THE INFORMATION YOU PROVIDE US?

4.1. We may collect, use, disclose and/or process your personal data for one or more of the following purposes:

• to consider and/or process your application with us;
• to present you with career opportunities that you might be interested in, including with Smartfren and/or its affiliates or related corporations;
• to manage, operate, provide and/or administer your use of and/or access to the Site;
• to tailor your experience by providing a faster method for you to submit information to us and allowing us to contact you, if necessary;
• to enforce our Terms of Service or any applicable end user license agreements;
• to protect personal safety and the rights, property or safety of ourselves, our staff, and others;
• for identification and/or verification;
• to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of the Site; to deal with or respond to any enquiries from (or purported to be from) you;
• to contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise regarding employment opportunities and/or for the purposes of administering and/or managing the Site, such as but not limited to communicating administrative information to you relating to the Site. You acknowledge and agree that such communication by us could be by way of electronic communication or by 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;
• to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, technology development and/or profiling), to analyse how you use the Site, to improve and/or to enhance the Site;
• to allow for audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with the Site;
• for marketing and in this regard, to send you by various mediums and modes of communication such as postal mail, email, location-based services or otherwise, information and materials relating to job offerings that Smartfren (and/or its affiliates or related corporations) may have, whether such job listings exist now or are created in the future
• to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
• to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
• where applicable, to establish an employment relationship with you and/or carry out and administer any related obligations, benefits, and/or policies;
• to audit our Site; to prevent or investigate any fraud, unlawful activity, omission or misconduct, whether relating to your use of the Site or any other matter arising from your relationship with us, and whether or not there is any suspicion of the aforementioned;
• to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction;
• to deal with and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves Smartfren as a participant or involves only a related corporation or affiliate of Smartfren as a participant or involves Smartfren and/or any one or more of Smartfren’s related corporations or affiliates as participant(s), and there may be other third party organizations who are participants in such transaction. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal or financing of an organization or a portion of an organization or of any of the business or assets of an organization; and/or
• any other purposes which we notify you of at the time of obtaining your consent. (collectively, the “Purposes”).

4.2. As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws and/or other applicable laws.

4.3. You acknowledge, consent and agree that we may access, preserve and disclose your personal information and Content if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over Smartfren or its affiliates or in a good faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with a request from any governmental or regulatory authority having jurisdiction over Smartfren or its relevant affiliates; (c) enforce our Privacy Policy; (d) respond to any threatened or actual claims asserted against Smartfren or its relevant affiliates or other claim that any Content violates the rights of third parties; (e) respond to your requests for assistance; or (f) protect the rights, property or personal safety of Smartfren or its relevant affiliates, its users and/or the public.

5. WHAT INFORMATION DO WE RETAIN AND HOW DOES SMARTFREN PROTECT USER INFORMATION?

5.1. We implement a variety of physical, administrative and electronic security measures to ensure the reasonable security of your personal data on our systems. User personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems.

5.2. We will retain personal data in accordance with the Privacy Laws and/or other applicable laws, including as necessary to fulfil the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws, including to maintain accurate employment, payroll, tax or other records. That is, we will destroy or anonymize your personal data when we have reasonably determined that (i) we no longer have a relationship with you, (ii) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (iii) retention is no longer necessary for any legal or business purposes. If you withdraw your application for employment, cease using the Site, or your permission to access or use the Site is terminated, and/or otherwise terminate your relationship with us, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws and/or other applicable laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.

5.3. Our Site does not have the capability to respond to “Do Not Track” signals received from various web browsers.

6. DISCLAIMER REGARDING SECURITY AND THIRD-PARTY SITES

6.1. WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We do implement a variety of security measures to maintain the safety of your personal data that is in our possession or under our control. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the personal data confidential. When you access your personal data, we offer the use of a secure server. All personal data or sensitive information you supply is encrypted into our databases to be only accessed as stated above.

6.2. In an attempt to provide you with increased value, we may choose various third-party websites to link to, and frame within, the Site. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by such third-party web sites (even if offered on or through our Site) may not be received by us.

6.3. We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for your convenience and you therefore access them at your own risk. To protect your information we recommend that you carefully review the privacy policies of all third-party services that you access. Nonetheless, we seek to protect the integrity of our Site and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).