General Privacy Policy

Links International (the “Company“) recognises 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 available here and the provisions of the Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance“), the General Data Protection Regulations and the Personal Data Protection Act 2012.

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 Links International’s consultant, upon receipt of which, we will cease such transfers and/or use at no cost to you.

Cookies
When you use linksinternational.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 linksinternational.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 linksinternational.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 linksinternational.com.

However, no system is impenetrable. Accordingly, we cannot guarantee that the information transmitted via linksinternational.com is completely secure, and make no warranties or representations regarding the security of Personal Information transmitted using linksinternational.com.

Links to Third Party Websites
linksinternational.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.linksinternational.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 linksinternational.com. Alternatively, you may request access to and correction of any Personal Information that you provide to us by writing to your respective Links International’s 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.

In the event of any inconsistency between the English and Chinese versions of this Policy, the English version shall prevail.

 

Links EU General Data Protection Policy

General Data Protection Regulation (GDPR) regulates how EU citizens’ data can be used by entities including service providers and is effective from May 2018.  Links processes personal data in order to perform our payroll, immigration, recruitment and other HR services as per our contracts with our clients and candidates and therefore processes and stores your personal data as long as it is necessary for the performance of our contractual and statutory obligations.  Secure processing of all individual’s information (regardless of whether they are EU citizens) is critical to Links’ business as an HR services provider.

Under the GDPR, individuals have a number of rights in respect of your personal information which can be found on the GDPR website.  The purpose of this policy is to provide an overview of how we process your personal data and your rights under data protection law. Which specific data are processed and how they are used depends largely on the services requested or agreed in each case.

1. Who is responsible for the data processing and who can I contact in this regard?
Responsibility for Links data processing lies with our Data Protection Officer who can be reached at privacyenquiry@linksinternational.com or alternatively by making a request at http://info.linksinternational.com/exercise-your-rights-under-gdpr-request-form

2. What sources and data do we use?
We process personal data which we receive from our clients and candidates in the context of our business relationship. To the extent necessary in order to provide our services, we also process personal data which we lawfully (e. g., from tax departments, pension providers, banks) receive from other entities.  We also process personal data from publicly available sources (e.g. registers of associations, press, media, Internet) which we lawfully obtain and are permitted to process.

Relevant personal data collected may be:

Academic Qualification, Address, Age, Alias, Bank Account Number, Beneficiary Name, Certifications/Degrees/Education Level, Contact/Residential Addresses, Contact Numbers, Country of Birth, Current Company, Currently Hourly/Day Rate/Salary/Compensation, Date Join Company, Date of Birth, Company Department, Dependent Name, Dependent Date of Birth, Dependent Gender, Personal E-mail/Office E-mail, Emergency Contact/Family Contact, Employee ID, Ethnicity/Race, Names (multiple languages), Gender, Passport Number, Identity Card Number/Identity Type/Identity Effective Date, Marital Status, Pension Member Numbers, Insurance ID Numbers, Nationality, Originality, Position, Probation Period, Recent Employers, Religion, Spouse, Spouse’ ID, Status, Tax ID Numbers, Terminated Date, Title, Years of Experience

When additional products/services from the product categories listed above are used, additional personal data may be collected, processed and stored in addition to the aforementioned data.

3. Why do we process your data (purpose of the processing) and on what legal basis?
We process the aforementioned personal data in compliance with the provisions of the EU General Data Protection Regulation (GDPR).

a. for the performance of contractual obligations (article 6 (1) b) GDPR)
The processing of personal data is carried out in order to provide our HR services pursuant to contracts with our clients or to take steps at your request prior to entering into a contract.

The purposes of the data processing are primarily dependent on the specific product and may include, among other things, an end to end payroll calculation and execution, immigration advice and processing, recruitment advice and services,. For further details on the purpose of the data processing, please refer to the respective contractual documentation and terms and conditions.

b. for the purposes of safeguarding legitimate interests (article 6 (1) f) GDPR)
Where necessary, we process your data above and beyond the actual performance of our contractual obligations in order to safeguard the legitimate interests pursued by us or by a third party.

c. on the basis of your consent (article 6 (1) a) GDPR)
Insofar as you have granted us consent to the processing of personal data for specific purposes, the lawfulness of such processing is based on your consent. Any consent granted may be revoked at any time.

d. for compliance with a legal obligation (article 6 (1) c) GDPR) or in the public interest (article 6 (1) e) GDPR)
Links provides HR services and is subject to various legal obligations, i.e. statutory requirements in respect of payroll and tax records.

4. Who receives my data?
Within Links, employees are given access to your data in order for to perform our contractual and statutory obligations. Service providers and agents employed by us may also receive data for these purposes if they observe non-disclosure agreements and our written instructions under data protection law.

Under these conditions, recipients of personal data may be, for example:

  • Public authorities and institutions (e. g. tax departments, superannuation, and pension providers) insofar as a statutory or official obligation exists.
  • Banks and financial institutions (e.g. in order to execute payments to you)

Other recipients of data may be those to which you have given your consent to the transfer of data to.

5. Is data transferred to a third country or to an international organisation?
As Links does not have a presence in the EU, Links processes data outside of the EU and in line with our client’s requirements of adequate safeguards per GPDR.  Measures that Links takes to ensure data security includes complying with ISO27001, server, and application penetration testing, hosting on Microsoft Azure.

6. How long will my data be stored?
We process and store your personal data as long as it is necessary for the performance of our contractual and statutory obligations. If the data are no longer required for the performance of our contractual and statutory obligations, data is regularly deleted, unless further processing (for a limited time) is necessary including the following purposes:

  • Compliance with records retention periods under commercial and tax law
  • Preservation of evidence within the scope of statutes of limitations.

7. What data protection rights do I have?
Every data subject has a right of access (article 15 GDPR), a right to rectification (article 16 GDPR), a right to erasure (article 17 GDPR), a right to restriction of processing (article 18 GDPR), a right to object (article 21 GDPR) and a right to data portability (article 20 GDPR). The right of access and right to erasure are subject to the restrictions under sections 34 and 35 BDSG. Data subjects also have a right to lodge a complaint with a supervisory authority (article 77 GDPR in conjunction with section 19 BDSG).

All requests will be processed within a reasonable time period upon receipt of request.

You may revoke your consent to the processing of personal data at any time. This also applies to the revocation of declarations of consent that are granted prior to the entry into force of the EU General Data Protection Regulation, i.e., prior to 25 May 2018. Please be advised that the revocation will only take effect in the future. Any processing that was carried out prior to the revocation shall not be affected thereby.

8. Am I under any obligation to provide data?
Within the scope of our business relationship, you must provide personal data which is necessary for the initiation and execution of a business relationship and the performance of the associated contractual obligations or which we are legally obligated to collect. As a rule, we would not be able to enter into any contract or execute the order without these data or we may no longer be able to carry out an existing contract and would have to terminate it.

If you do not provide us with the necessary information and documents, we will not be allowed to enter into or continue your requested business relationship.

9. To what extent is automated decision-making (including profiling) carried out?
As a rule, we do not make decisions based solely on automated processing as defined in article 22 GDPR to establish and implement the business relationship.

10. Is “profiling” used?
In some cases, we process your data automatically with the aim of evaluating certain personal aspects (profiling). For instance, we use profiling in the following cases:

  • In order to provide you with targeted information and advice on products, we use evaluation tools. These enable demand-oriented communication and advertising, including market and opinion research.

Information on your right to object under article 21 of the EU General Data Protection Regulation (GDPR)

1. Ad hoc right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on article 6 (1) e) GDPR (processing in the public interest) and article 6 (1) f) GDPR (processing for the purposes of safeguarding legitimate

interests); this includes any profiling based on those provisions within the meaning of article 4 (4) GDPR.

If you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or unless the processing is for the establishment, exercise or defence of legal claims.

2. Right to object to the processing of data for marketing purposes

In certain cases, we process your personal data for direct marketing purposes. You have the right to object at any time to processing of personal data concerning yourself for such marketing, which includes profiling to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, we will no longer processes your personal data for such purposes.

Personal Data Protection Act 2012

Dear valued Links clients and candidates,

This Personal Data Protection Policy notice for personal data (“Notice”) is issued to all our valued clients and candidates of Links HR Singapore Pte Ltd  (“[Links]”, “us”, “we”, “our” or “ours”), pursuant to the statutory requirements of the Personal Data Protection Act 2012 (“PDPA”).

We at Links take our responsibilities under Singapore’s PDPA seriously. We also 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.

During your course of dealing with us, we may have, and / or will collect, use, disclose and process your personal data for purposes, including, to communicate with you, provide services to you, respond to your enquiries or complaints, provide you with information and/or updates, services and/or promotions offered by Links and selected third parties and other purposes required to operate and maintain our business as set out in our Personal Data Protection Policy (collectively referred to as “Purposes”).

In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents 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.

PDPA

Please contact us at privacyenquiry@linksinternational.com for more information on the Purposes for which we collect, use, disclose or processes your personal data and how we will protect your personal data.

It is necessary for us to collect and to retain your personal data. If you do not provide us with your personal data, or do not consent with this Notice or our Personal Data Protection Policy, we will not be able to effectively provide products and/or services to you, if at all.

We are committed to ensuring that your personal data is stored securely. You have the right to request for access to, to request a copy of and to request to update or correct your personal data held by us. You have the right at any time to request us to limit the processing and use of your personal data. (for example, requesting us to stop sending you any marketing and promotional materials or contacting you for marketing purposes).

Your written request should be addressed to:

Data Protection Officer
Links HR Singapore Pte Ltd
EA License No: 09C5322
17 Hong Kong Street #03-01
Singapore 059660

Contact No.: +65 6536 4438
Email Address: privacyenquiry@linksinternational.com

By submitting your personal data to us, you consent to us collecting, using, disclosing and processing your personal data in accordance with this Notice. We will also take it that all personal data provided by you is accurate and complete, and that none of it is misleading or out of date. You will promptly update us in the event of any change to your personal data.

In some circumstances, you may have provided personal data relating to other individuals (such as your spouse, family members or other third party including minors). You represent and warrant that you are authorised to provide their personal data to us and you have obtained their consent to the collection, use, disclosure and processing of their Personal Data in accordance with this Notice.

We reserve the right to update and amend this Notice and our Personal Data Protection Policy from time to time. We will notify you of any amendments to this Personal Data Protection Notice or our Personal Data Protection Policy via announcements on our website or other appropriate means. If we amend this Personal Data Protection Notice or our Personal Data Protection Policy, the amendment will only apply to personal data collected after we have posted the revised Personal Data Protection Notice or Personal Data Protection Policy.

Personal Data Request Forms
Personal Data Request Forms Links HR Singapore Pte Ltd aims to comply with the requirements of the Personal Data Protection Act (PDPA). We will respond within 30 (thirty) working days upon the receipt of your Request. Thank you for your understanding.

Data Access Request Form
To submit a request for access to your personal data, email privacyenquiry@linksinternational.com