Data Protection Policy

Data Protection Policy

1. INTRODUCTION

Your privacy is important to us. This Data Protection Policy (“Policy”) sets out how Talent Trader Group Pte Ltd and its related entities within the TTG Group of Companies (collectively referred to herein as “TTG”, “Company”, “us”, “we” or “our”) comply with the provisions of the Personal Data Protection Act 2012 of Singapore (“PDPA”).

The TTG Group of Companies refers to Talent Trader Group Pte Ltd and all its subsidiaries, affiliates, and related entities that are from time to time part of the group.

We also want you to understand the way in which we collect, use, disclose and/or retain your Personal Data. This Policy sets out:

(a) our policies on how we manage your Personal Data;

(b) the types of Personal Data we collect, use, disclose and/or retain;

(d) the purpose(s) for which we collect, use, disclose and/or retain your Personal Data; and

(e) how Personal Data may be shared between entities within the TTG Group of Companies for recruitment and related purposes.

You agree and consent to us, the Company, our related entities within the TTG Group of Companies, and our clients to collect, use, disclose and/or retain your Personal Data in the manner set forth in this Policy.

This Policy supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any right that we may have at law in connection with the collection, use, disclosure and/or retention of your Personal Data.

From time to time, we may update this Policy to ensure that it is consistent with developments, regulatory changes, and changes to the TTG Group structure. Should any revision(s) be made, updates will be published on our public site (https://talenttradergroup.com/pdpa). Subject to your legal rights in Singapore, the prevailing terms of this Policy shall apply.

This Policy forms a part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions (“Terms and Conditions”). In the event of any inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail.

2. YOUR PERSONAL DATA

In this Policy, “Personal Data” refers to any data and/or information about you from which you can be identified by, either (a) from that data; or (b) from that data and other information to which we may have legitimate access to. Examples of such Personal Data include but are not limited to:

(a) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided in any forms you may have submitted to us, or in other forms of interaction with you;

(b) your photographs;

(d) Personal Data of your family members, such as next of kin, spouses, and children;

(e) information relating to payments, such as your bank account number;

(f) information about your usage of and interaction with our website and/or services including computer and connection information, device capability, bandwidth, statistics on page views and traffic to and from our website.

3. COLLECTION OF YOUR PERSONAL DATA

Generally, we may collect your Personal Data through the following ways:

(a) when you submit a job application to us or to any entity within the TTG Group of Companies, whether directly or through a third-party job portal (such as JobStreet, LinkedIn, or similar platforms);

(b) when you engage us or any entity within the TTG Group for job search arrangements;

(d) when you ask to be included in an email or other correspondence;

(e) when you interact with any employee of any entity within the TTG Group of Companies;

(f) when you request that we contact you;

(g) when you submit your Personal Data to us for any other reason; and

(h) when your Personal Data is provided to us by a third-party job portal, recruitment platform, or referral source.

4. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA

Generally, we may collect, use, disclose and/or retain your Personal Data for the following purposes:

(a) to manage your job application needs including recruitment, processing and termination with us / our clients;

(b) to assess and evaluate your suitability for employment in any current or prospective position with our clients, within any entity in the TTG Group of Companies, or with any affiliated entity within the TTG Group;

(d) to provide you with insurance coverage services;

(e) to provide you with work pass application services;

(f) to assist you with your enquiries;

(g) to process payment for damages (if any);

(h) to improve customer services, such as resolving complaints and handling requests and enquiries;

(i) to conduct research, surveys and interviews;

(j) to keep you updated on our events; and

(k) to comply with applicable laws and regulations.

5. SHARING OF PERSONAL DATA WITHIN THE TTG GROUP OF COMPANIES

As the TTG Group of Companies operates as an integrated recruitment and human resource solutions group, your Personal Data may be shared between entities within the TTG Group for the purposes described in this Policy. This means that if you submit a job application or resume to one entity within the TTG Group, your Personal Data may be accessed, used, and processed by other entities within the TTG Group for the purpose of identifying suitable job opportunities, recruitment, job matching, and employment placement.

Specifically, your Personal Data may be shared within the TTG Group for the following purposes:

(a) to match your profile with job opportunities managed by different entities within the TTG Group;

(b) to enable any entity within the TTG Group to contact you regarding suitable employment opportunities;

(d) to provide you with a broader range of employment opportunities across all entities within the TTG Group; and

(e) to perform internal administrative functions related to recruitment across the TTG Group.

Each entity within the TTG Group that handles your Personal Data holds its own Employment Agency (EA) licence issued by the Ministry of Manpower (MOM) and operates in compliance with the Employment Agencies Act and its subsidiary legislation. Personnel from any TTG Group entity who contact you will be registered EA Personnel under their respective entity’s EA licence.

6. DISCLOSURE OF YOUR PERSONAL DATA

In addition to the sharing within the TTG Group described in Section 5, we may disclose your Personal Data to the following parties for the purposes mentioned above, subject to the requirements of applicable laws:

(a) our clients, for the purpose of job placement and recruitment services;

(b) hospitals, clinics or insurance companies in connection with work pass application needs;

(c) third-party service providers who provide services such as telecommunications, mailing, information technology, payment, data processing, training, storage and archival to the TTG Group;

(d) our professional advisers such as our auditors and lawyers;

(e) relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any government authority;

(f) your prospective or previous employment companies for reference checks;

(g) any other person in connection with the purposes set forth above.

From time to time, we or any entity within the TTG Group may contact you via mail, electronic mail, telephone (call or SMS-Text), facsimile or social media platforms, to inform you about job opportunities that we think may be of interest to you.

7. DEEMED CONSENT

By submitting your job application, resume or Personal Data to any entity within the TTG Group of Companies — whether through our website, a third-party job portal (such as JobStreet, LinkedIn, or similar platforms), email, or any other channel — you are deemed to have consented to the collection, use, and disclosure of your Personal Data by all entities within the TTG Group of Companies for the purposes set out in this Policy, including the sharing of your Personal Data between TTG Group entities as described in Section 5.

Where we intend to collect, use or disclose your Personal Data for purposes that differ from those stated in this Policy, we will notify you through appropriate means and provide you with a reasonable period to opt out.

Before relying on deemed consent by notification, we will assess and determine that the collection, use and disclosure of the Personal Data will not likely have an adverse effect on you.

8. RELIANCE ON LEGITIMATE INTERESTS EXCEPTION

In compliance with the PDPA, we may collect, use or disclose your Personal Data without your consent for the legitimate interests of us or another person. In relying on the legitimate interests exception, we will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.

In line with the legitimate interests exception, we will collect, use or disclose your Personal Data for the following purposes:

(a) fraud detection and prevention;

(b) detection and prevention of misuse of services.

9. ACCURACY OF YOUR PERSONAL DATA

We take all reasonable measures to ensure that your Personal Data remains accurate, complete and up to date. You may also keep us informed when there are any updates to your Personal Data by contacting us directly.

10. WITHDRAWAL OF CONSENT

If you wish to withdraw your consent to any use or disclosure of your Personal Data as set out in this Policy, you may contact us via dpo@talenttradersg.com.

You may withdraw your consent for the sharing of your Personal Data between entities within the TTG Group. Upon such withdrawal, only the specific entity that originally collected your Personal Data will continue to process it; other TTG Group entities will cease access to your Personal Data.

Please note that if you withdraw your consent to any or all use or disclosure of your Personal Data, depending on the nature of your request, we may no longer be in a position to continue to provide employment and employability services to you. Such a withdrawal may therefore result in the termination of any job application that you may have with us.

11. ACCESS AND CORRECTION OF YOUR PERSONAL DATA

You may request access to or make corrections to your Personal Data records by writing to our Data Protection Officer via email at dpo@talenttradersg.com.

Please note that a reasonable fee may be charged for access requests. If so, we will inform you of the fee before processing your request.

12. RETENTION OF PERSONAL DATA

We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes.

13. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

We may need to disclose your Personal Data to third parties, whether located within or outside Singapore, as such third parties would be processing your Personal Data for one or more of the purposes stated in this Policy.

Where your Personal Data is to be transferred out of Singapore, we will comply with the PDPA in doing so, including taking appropriate steps to ascertain that the foreign recipient organisation is bound by legally enforceable obligations to provide a standard of protection that is at least comparable to the protection under the PDPA.

14. PROTECTION OF PERSONAL DATA

To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of Personal Data, authentication and access controls, data anonymisation, up-to-date antivirus protection, regular patching of operating systems and software, and secure erasure of storage media before disposal.

15. DATA PROTECTION OFFICER

If you have any questions or complaints relating to the use or disclosure of your Personal Data, or if you wish to know more about our data protection policies and practices, please contact our Data Protection Officer:

Name: Zack

Email: dpo@talenttradersg.com

Postal Address: 152 Beach Road, #10-01/02, Gateway East, Singapore 189721

For more information about PDPA generally, please visit the Personal Data Protection Commission’s website at http://www.pdpc.gov.sg

Please note that for any resumes or job applications sent to this mailbox will NOT be attended as this mailbox is solely for purposes of personal data protection related feedback. For submission of resumes or job applications, please send to us at recruitment@talenttradersgroup.com, or visit our website at www.talenttradergroup.com for more details.

16. EFFECT OF POLICY AND CHANGES

This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us or any entity within the TTG Group of Companies.

We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.