A. Introduction

Elabram and its’ associate companies (collectively “Elabram Group”, “we”, “us” “our”) is committed to protecting the confidentiality of information and privacy of our candidates, clients and other users (“Data Subject”) of our websites and services.

Elabram Group considers your right to privacy and the careful handling of your Personal Data to be of the utmost importance. We make every effort to ensure that the information you provide us will remain private and is only used strictly in accordance with this Privacy Policy.

This Privacy Policy among other clarifies how Elabram Group:-

• Process your data from the point of we collect, use, share and dispose of;

• The type of Personal Data processed;

• Your rights as Data Subject; and

• The security measure that we established to ensure that your Personal Data is managed with due care and attention.

This Privacy Policy may be reviewed from time to time taking into account new laws and technology, changes to our operations and practices and ensure it remains appropriate to the developing environment. Any information we hold will be governed by the most current version of the Elabram Group Privacy Policy as displayed in our website.

B. Definitions

Throughout this Privacy Policy, the following terms shall have the following meanings:

C. Collection Of Personal Data

In order to use our website and to carry out our service as recruitment agency and HR application provider, Elabram Group may collect your personal information from you, including but not limited to:

• Personal details such as your name, identification number, gender, race, date of birth, age, marital status and nationality.

• Contact details including postal address, telephone number and email address.

• Education background, qualifications, work history, professional qualification & membership, licences, salary information and your right to work in a particular country.

• Language skills.

• Photograph.

• Social media profile & online identifier such as email address and password upon registration with our website.

• Your work objectives and other information from your Curriculum Vitae (“CV”) or resumé. If you are to be considered for a particular position, we may also collect references from your nominated referees.

• Website usage & preference, browsing usage, cookies and search history.

Elabram Group will obtain your consent before the collection and processing of sensitive Personal Data such as medical records and religion as required under the applicable data protection laws.

D. Source Of Personal Data Collection

Elabram Group collects Personal Data directly from you by telephone, email, our website or otherwise. Data will be collected from you when you:

• Supply CV, resume or application form through the website or directly to us.

• Fill out and submit a registration form

• Subscribe to job alerts emails.

• Apply to a job posting on our website.

• Submit any other information in connection with your application for registration.

• Directly or indirectly supply information to us to be registered on Axdif HR application

To the extent that you access our website, read or click on an email from us, we may also collect certain data automatically or through you providing it to us, such as browser cookie.

We may also collect your data from publicly available source, government agencies, other service provider, partner or contractor, referee or former employers.

Elabram Group requires you to provide consent to enable us to collect Personal Data from you or third parties. Such consent should only be given after you have read and understood this Privacy Policy failure of which will affect your ability to engage in our service

E. Purpose Of Use

Elabram Group uses your personal information in order to enable us to provide you with our recruitment services and help you find a new job that might be suitable for you. We use your personal information so that we can understand your skills, experience and qualifications in order to find new job opportunities that match your profile. More specifically, Elabram Group may use your information for the following reasons:-

• To communicate and/or provide you with our recruitment services;

• To match your details against job vacancies which we feel may be appropriate for you;

• To apply for jobs on your behalf by sending your data to clients;

• To market our recruitment services to you;

• To inform you about any relevant industry developments;

• To send you details of any events or promotions;

• To comply with applicable legal and regulatory requirements;

• To maintain and promote Elabram Group's business relationships; and

• To be able to use Axdif HR application

F. Disclosure Of Personal Data

Whilst we strive to keep your Personal Data secure and confidential, we may disclose your Personal Data for the foregoing purposes of which such disclosure will only be affected for the specified purposes. Elabram Group may disclose your Personal Data to third parties as follow:

• To introduce you to potential employers within Elabram Group's clients, for them to assess your suitability as an applicant for a position within their organisation;

• In order to comply with any requests from regulatory or law enforcement authorities for the release of such Personal Data if they so require;

• To share your information with other consultants within the Elabram Group with the purposes of providing you with recruitment services in other locations;

• To utilise third party service providers who perform functions on our behalf including external consultants and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants to carry out testing and development work on our IT systems where we have an appropriate processing agreements (or similar protections) in place;

• To third party service provider to undertake reference checks, qualification checks, verification of details you provided or to conduct psychometrics or skills evaluation;

• To data processor, business partners or any person whom we work with to deliver the recruitment services to you;

• Third party outsourced IT and document storage providers where we have an appropriate processing agreements (or similar protections) in place;

• Marketing technology platforms and suppliers;

• If Elabram Group or its business merges with or is acquired by another business or company, we may share personal information with the new owners of the business or company. You would be sent notice of such event; or

• To enhance our HR application service.

G. Transfer Of Information Internationally

Elabram Group is an international company, headquartered in Malaysia. Our databases are located in Singapore. Upon receipt of your personal information, it will be transferred quickly and securely to our systems hosted in Singapore. In ensuring that your data is secure, when we transfer data outside of Singapore for the purpose specified under this Privacy Policy, we will only transfer to those locations where the target location is compliant with data protection legislation and by means of transfer which have adequate safeguards applied.

In addition, our consultants in Malaysia, Indonesia, Thailand, Philippines and Singapore office may offer to share your information with consultants in another country. In such an event, the consultant will contact you to confirm that you consent to having your information shared with another Elabram Group branch.

H. Personal Data Security & Maintenance

Elabram Group take reasonable steps to protect your Personal Data from unauthorized access, disclosure, alteration, and destruction. We have developed and/or adopted systems for the storage of Personal Data that feature appropriate mechanisms and technologies, including limited access by our employees, staff members, officers, representatives, shareholders, authorized persons, directors, and agents so that they can access Personal Data on a need-to-know basis, to prevent unauthorized use, disclosure, deletion or access to your Personal Data.

Our aim is to make sure that the personal information that we hold is accurate and up to date. Should your details change, please contact your consultant to inform them. If you have created a profile with Elabram Group through our website, then you are able to update or delete your personal information whenever you want. In order to do this, log into your profile and edit or delete the information you have submitted.

I. Privacy On Our Websites

You have the option to submit your CV to Elabram Group through our websites for either general consideration by our recruitment consultants or towards an application for specific advertised position. Upon submission of your CV it will be sent to the relevant recruitment consultants who will review the details of your submission and who will advise you accordingly. Your CV can be updated at any time by following the same procedure to submit a new CV on our websites.

You may agree to opt in to receive emails that alert you to new jobs on our website. To subscribe to such alert you will need to provide your email address, which will be used for the purpose of keeping you informed by email of the latest jobs and/or news in your nominated industry. If you no longer wish to receive such emails, unsubscribe links are provided in every such email that you receive from us.

Elabram Group gathers statistics about all visitors to our websites worldwide. We only use such data in aggregate so that the information we gather does not identify individual traits. We use such information to monitor the most effective parts of our websites in order for us to be able to improve our online offering for the benefit of our users.

A cookie is a simple text file that is stored on your computer or mobile device by a website's server. Each cookie is unique to your web browser. It will contain some anonymous information, such as a unique identifier and the site name.

Elabram Group also uses 'analytical' cookies in order to enable us to improve the way our website functions, for example, by making sure users are able to find what they need easily.

When you visit Elabram Group's website, upon your consent, we will access your browser cookies. We use them to remember your login details, to track overall web traffic and to access information in cache about your session in order to assist you in the use of our website. Information such as your last search will be cached. However, this kind of information will be deleted each time you close your web browser. Most browsers will allow you to block access to your cookies. However, by blocking Elabram Group's access to your cookies, your use of our websites will be restricted.

J. Retention Period

Elabram Group will retain your Personal Data for the period as necessary to carry out the purpose of such collection including during the period that you remain as our candidate wishing to receive our recruitment services or user of HR application. Our relationship with you as a candidate may continue for several years but at any time, should you wish for your data to be erased, Elabram Group will act promptly to delete your data from all of our databases in a timely manner upon receipt of such request for erasure.

K. Rights Of Data Subject

1. To request access to personal data

   You have the right to request access to personal data processed by us upon reasonable notice.

2. To request correction of personal data

   You have the right to request for the correction and/or update of your Personal Data that is inaccurate, incomplete or outdated.

3. To limit processing of personal data

   You are entitled to limit our processing of Personal Data by expressly withdrawing your consent given previously, including for direct marketing purpose subject always to any applicable legal restrictions, contractual obligations and within a reasonable time period.

L. Enforcement Of Rights

All requests regarding individual rights should be sent to the contact detail as specified. Elabram Group shall act upon any Data Subject request for access or any request relating to rectification, erasure, restriction, data portability or objection or automated decision making processes or profiling within one month of receipt of the request. Elabram Group may extend this period for two further months where necessary, taking into account the complexity and the number of requests.

Where Elabram Group considers that a request is manifestly unfounded or excessive due to the request's repetitive nature then we may either refuse to act upon the request or may charge a reasonable fee, taking into account the administrative costs involved.

M. Changes To Policy

Elabram Group may amend, modify, add, delete or make corrections to this Privacy Policy at any time without prior notice, which shall become effective upon posting. You are recommended to periodically review this Privacy Policy for any amendments. Your ongoing usage of this Website and/or our Services subsequent to the publication of any modifications shall be construed as your acknowledgment and consent to such changes.

N. Contact

Should you require further information about the Personal Data we hold or the way in which your information is being collected or used which are not addressed by the Privacy Notice, please contact us at [email protected] or at the following address:-

Or for Malaysia

O. Region Spesific Rights

1. GDPR

   Under GDPR, the data subject has certain important rights. These include (but are not limited to) the following:

   1. The right for access to data and data portability

      • You have the right to receive your Personal Data, which you have provided to us previously, in a structured, commonly used and machine-readable format. Further you have the right to request us to transmit your Personal Data to another data controller in circumstances where:

        • The processing is based on your consent or a contract; and

        • The processing is carried out by automated means.

      • Where feasible, Elabram Group will send the Personal Data to a named third party upon your request.

   2. The right to have data rectified

      • You may request Elabram Group to rectify any inaccurate or incomplete Personal Data concerning yourself. If Elabram Group has given your Personal Data to any third parties we will inform the third parties that we have received a request to rectify your Personal Data unless this proves impossible or involves disproportionate effort. Such third parties will further rectify the Personal Data they hold. However, Elabram Group is not in a position to audit those third parties to ensure that the rectification has occurred.

   3. The right to "be forgotten"

      • This refers to your right to have your Personal Data completely deleted from our database, including from any third parties who may have access to that data.

      • You may request, at any time, to have your Personal Data deleted completely from all Elabram Group's databases. Upon receipt of such a request, we will request confirmation of whether you require complete erasure of your Personal Data or alternatively you are agreeable for us to keep your details a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). We cannot keep a record of individuals whose data has been erased completely so you may be contacted again by Elabram Group should we come into possession of your Personal Data at a later date.

      • If Elabram Group has disclosed the Personal Data to any third parties, we will inform the third parties of your request for erasure unless this proves impossible or involves disproportionate effort. The third parties will also completely erase the Personal Data they hold. However, Elabram Group is not in a position to audit those third parties to ensure that the erasure has occurred.

      • It should be noted that where there are legal requirements for Elabram Group to store data for a certain period of time, related to our business, which includes elements of your Personal Data, we will not be able to delete that data until after the statutory retention period.

   4. The right to restrict the processing of your data

      • You have the right to ask Elabram Group to restrict its processing of your Personal Data where:

        • You challenge the accuracy of the Personal Data we are storing;

        • The processing is unlawful but you oppose its erasure;

        • Elabram Group no longer needs your Personal Data for the purposes of the processing, but your Personal Data is required for the establishment, exercise or defence of legal claims; or

        • You have objected to processing (on the grounds of a public interest or legitimate interest) pending the verification of whether the legitimate grounds of Elabram Group override those of the individual.

      • If Elabram Group has given your Personal Data to any third parties we will inform the third parties that we have received a request to restrict the Personal Data, unless this proves impossible or involves disproportionate effort.

   5. The right to lodge a complaint

      • You have the right to object to your Personal Data being processed based on a public interest or a legitimate interest. You also can object to the profiling of your data based on a public interest or a legitimate interest.

      • Upon receiving a claim from you, Elabram Group shall cease processing unless it has compelling legitimate grounds to continue to process the Personal Data which override the individual's interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

      • You also have the right to object to your Personal Data being used for direct marketing.

   6. The right to object to automated decision making

      • Elabram Group will not subject individuals to decisions based on automated processing that produce a legal effect or a similarly significant effect on the individual, except where the automated decision:

        • Is necessary for the entering into or performance of a contract between the data controller and the individual

        • Is authorised by law; or

        • The individual has given their explicit consent.

      • Elabram Group will not carry out any automated decision-making or profiling using the Personal Data of a child.

2. THAILAND

   1. Right of Access

      You have the right to request access to and obtain a copy of your Personal Data collected, used, or disclosed by us, or to disclose the acquisition of your Personal Data that has been collected without your consent.

   2. Right to Data Portability

      You have the right to request your Personal Data held by us in a structured, machine-readable format. This right includes the following:

      • The right to request that we transfer your Personal Data held by us, in a structured, machine-readable format, to another data controller, where such transfer can be done automatically; and

      • The right to obtain a copy of your Personal Data that we have transferred in a structured, machine-readable format to another person unless this is not technically possible.

   3. Right to object

      You have the right to object to our processing of your Personal Data in certain circumstances as described in this Privacy Policy.

   4. Right to request erasure or destruction of Personal Data

      You have the right to request that we erase, destroy or anonymize your Personal Data that we hold and no longer require.

   5. Right to restrict processing

      You have the right to ask us to restrict the processing of your Personal Data if you believe that your Personal Data is incorrect, or that the processing of such Personal Data is unlawful, or where your Personal Data no longer needs to be held by us for any purpose.

   6. Right of rectification

      You have the right to request that we correct your Personal Data that is incorrect, misleading, or not up to date.

   7. Right to withdraw your consent

      You may withdraw your consent at any time unless otherwise specified by law or by a contract under which you benefit.

   8. Right to complain

      You have the right to complain to a competent authority in cases where you believe that our processing of your Personal Data is unlawful or contrary to the applicable Data Privacy Act.