This Policy does not form any contractual relationship between you and us, and we may amend it from time to time.
1. LAWFUL PROCESSING
We will only process your personal data:
(a) where you have given your consent (you may withdraw your consent at any time, by making a request using the contact details set out below);
(b) where the processing is necessary to provide our services to you;
(c) where the processing is necessary to respond to a request from you;
(d) where the processing is necessary to maintain our relationship with you;
(e) where the processing is necessary for compliance with our legal and regulatory obligations
2. WHAT PERSONAL DATA WE COLLECT ABOUT YOU
2.1 We process the following types of personal data about you:
(a) Your name, email address and other contact details and country of residence;
(b) Professional details, such as CV, details of your qualifications, relevant experience and skills, professional and educational backgrounds;
(c) Your current role, position and/or job title;
(d) Details of your preferences for types of marketing events or materials;
(e) Details of your access to our systems and websites; and
(f) Your messages, feedback or contributions to surveys and questionnaires.
2.2 It may be mandatory for you to provide us with your personal data, to enable us to manage our business and operations, to maintain our relationship with you, to provide our services to you or to comply with our legal and regulatory obligations. If you fail to provide your personal data, we might be unable to maintain our relationship with you or to provide our services to you.
2.3 We make every effort to maintain the accuracy and completeness of your personal data which we store and to ensure all of your personal data is up to date. However, you can assist us with this considerably by promptly contacting us if there are any changes to your personal data or if you become aware that we have inaccurate personal data relating to you. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
3. HOW WE COLLECT PERSONAL DATA
We usually collect your personal data from the information you submit during the course of your relationship with us. This will typically be through the forms and documents used when you create your account with us or sign up to marketing or market data news lists.
We may also collect your personal data from other sources such as magazine publishers, PR firms, fraud prevention agencies, credit reference agencies, the records of governmental agencies and social media.
4. HOW WE USE PERSONAL DATA
We will process your personal data for the following purposes:
(a) to provide you with requested services;
(b) to respond to your messages or posts to us;
(c) to provide you with promotional and marketing materials about our services that we think you may be interested;
(d) to manage, develop and improve our services, information technology systems and websites;
(e) for research and marketing purposes;
(f) for monitoring and assessing compliance with law and our policies and standards;
(g) to comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies;
(h) to carry out money laundering, financial and credit checks and for fraud and crime prevention and detection purposes;
(i) for administrative purposes in relation to the security of and access to our systems, premises, platforms and websites and applications;
(j) to comply with court orders and exercise and/or defend our legal rights;
(k) for any other legitimate business purpose; and
(l) as otherwise permitted or required by any applicable law or regulation.
5. INTERNATIONAL TRANSFERS OF PERSONAL DATA
We will process your personal data in Japan which is outside the EEA. Although the EU Commission has not confirmed that Japanese law offers the same level of protection of personal data as are enjoyed within the EEA, we will process your personal data with the same level of protection as in the EEA and recognise your rights on your personal data you would hold under the General Data Protection Regulation 2016/679 ("GDPR").
In addition, we will transfer your personal data to the potential Japanese employers you selected on "My Page" so that those potential employers can have access to your personal data (such as CV) and these potential employers will be required to process your personal data in accordance with Japanese data protection law. However, the European Commission has not confirmed that Japanese law offers the same level of protection of personal data as are enjoyed within the EEA and no safeguards that are provided for in the GDPR will not be in place to protect your personal data. Therefore, these potential Japanese employers may not process your personal data by the same standard as in the EEA and you may not be able to exercise the same rights on your personal data as in the EEA.
6. WHEN WE MAY DISCLOSE YOUR PERSONAL DATA
We do not and will not sell, rent out or trade your personal data. We will only disclose your personal data to the following recipients:
(a) to the potential employers you selected on "My Page" so that those potential employers can have access to your personal data (such as CV);
(b) to third parties who process your personal data on our behalf (such as our systems providers including cloud providers);
(c) to companies providing services for money laundering checks, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such information is shared;
(d) to any third party to whom we assign or novate any of our rights or obligations;
(e) to any prospective buyer in the event we sell any part of our business or assets; and
(f) to any government, regulatory agency, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request.
We may sell or provide aggregated and anonymised information and analytics about the users of our websites and services to third parties. Before we do so, we will make sure that such information does not identify you.
7. HOW WE PROTECT YOUR PERSONAL DATA
We are committed to safeguarding and protecting your personal data and will implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect your personal data from accidental or unauthorised destruction, loss, alteration, disclosure or access.
8. YOUR RIGHTS IN RELATION TO THE PERSONAL DATA WE COLLECT
8.1 If you wish to:
(a) update, modify, or delete your personal data, or obtain a copy of your personal data that we hold; or
(b) restrict or stop us from using any of your personal data which we hold, you can request this by contacting us using the contact details set out below.
8.2 In any of the situations listed above, we may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorised disclosure of data.
9. HOW LONG WE WILL HOLD YOUR PERSONAL DATA FOR
We will only retain your personal data as long as necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.
10. DIRECT MARKETING
If you tell us that you do not wish we or any of our group companies to provide you with information about our services and other marketing materials, we will not contact you further for the purpose of direct marketing. You can contact us using the contact details set out below.
A "cookie" is a small text file that is stored on a user's hard drive or mobile device. Cookies are generated by web servers when the user enters an internet page, and are passed to the user's computer or mobile device and stored for subsequent future access. They perform a number of functions associated with browsing websites and are used for a variety of different purposes, such as tracing users from page to page on an internet site. This can enhance a user's experience on a website, enabling the site to be personalised according to e.g. a user's preferences and browsing activities.
12. HOW WE UPDATE OR CHANGE THIS FAIR PROCESSING POLICY
We may change or update parts of this Policy in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. We will do this by updating this Policy. You will not necessarily be directly notified of such a change. Therefore, please ensure that you regularly check this Policy so you are fully aware of any changes or updates.
13. HOW YOU CAN CONTACT US
If you have any queries about the contents of this Policy or your personal data, or wish to make a request in relation to your personal data, please contact us using the details set out below:
14. HOW TO LODGE A COMPLAINT TO THE REGULATOR
You are entitled to lodge a complaint with a competent data protection regulator if you consider that we have breached your data protection rights.
Date Updated: [4th June 2018]