Important updates to our Privacy Policy
Our updated privacy policy applies to users in the following markets: Hong Kong, Indonesia, Malaysia, Philippines, Singapore, and Thailand. For Australia and New Zealand users, the updated policy will take effect on 31 October 2024. You can view the existing policy here.To view the privacy policy in your local language, please click the link below:SEEK Pass Privacy Statement
Last Updated 26 September 2024Our commitment to maintaining your privacy
Privacy, security and user control are core parts of the SEEK Pass offering. Our credential passport aims to provide a secure and convenient way to verify, manage and share your identity, documents and credentials. We believe it is important that you understand how your information is collected, used and protected when you engage with us. Our Privacy Policy explains all of this in detail below.
By registering and creating an account with us, using our products and services, visiting our Platforms or simply engaging with us over the phone, via email, in person or by any other means, the terms contained in this Privacy Policy will apply to you.
Capitalised terms in this Privacy Policy are defined in section 17, unless otherwise stated.
1. Who are we?
This Privacy Policy covers the SEEK Pass business. SEEK Pass operates a verified credential passport platform spanning the Asia-Pacific region with operations in Australia, New Zealand, Malaysia, Singapore, Philippines, Indonesia, Thailand and Hong Kong.
As we operate in different markets across the Asia-Pacific region, aspects of this Privacy Policy address certain region-specific requirements under applicable Privacy Laws (please see section 18 for more information). It is important that you read this Privacy Policy in full to ensure you understand all aspects that apply to you.
2. Who is responsible for your Personal Information?
This section sets out which legal entity is responsible for the Personal Information we collect from you.
To the extent relevant in your region, the relevant data controller (or the equivalent concept in your region) of your Personal Information is as follows:
- a.SEEK Pass Pty Ltd for SEEK Pass Users in Australia and New Zealand.
- b.The Designated Entity and SEEK Pass Pty Ltd either as joint data controllers or as independent data controllers (depending on applicable Privacy Laws) for SEEK Pass Users in Malaysia, Singapore, Philippines, Indonesia, Thailand and Hong Kong.
3. What Personal Information do we collect?
We collect different types of information about you depending on how you interact with us and use our products and services.
The main types of information (including Personal Information) we may collect includes but is not limited to:
- a.If you are a User:
Categories of Personal Information Description Contact Data - Personal Information including your first and last name, email address, mobile phone number, other contact number, contact address, and company details (if applicable).
Identity Data - Any Personal Information (other than Contact Data) relating to your identity including your full legal name, photo, place of birth, date of birth and other information that may appear on identity documents typically issued by government authorities, regulatory and licensing bodies.
Health Data - Any Personal Information relating to your health information that is shared with us where required when you use our products and services. For example, vaccination status appearing on an immunisation history statement or vaccination certificate.
General Data - Any Personal Information (other than Contact Data, Identity Data and Health Data) that is shared with us where required when you use our products and services.
- Examples may include but are not limited to:
- 1.Your work history including your eligibility to work, employer(s), job title, place of work and dates of employment;
- 2.Your educational history (including any skills assessment data) and related education data; and
- 3.Your professional membership history including details appearing on a professional membership certificate or other document used to verify your professional credentials, memberships, or designations.
Usage and Device Data Information on access and visits to our Platform, usage patterns, Cookies, search and click history on a Platform, personalisation of content on a Platform, IP Address, device ID, browser types and forms, referrer page, operating system, date and time stamps and clickstream data retained in log files. This data is automatically collected using Cookies that is part of or placed on your browser or on your devices. - b.If you are a Visitor:We collect Usage and Device Data on our Platform visits by Visitors including, without limitation, which sections of the Platform are most frequently visited, how often, and for how long. See section 11 for more information on how we manage Usage and Device Data.
- c.If you are a Young User:For Young Users who are under the minimum age provided for under applicable Privacy Laws or other relevant law, you represent and warrant that your parent or legal guardian has been informed of and agreed to this Privacy Policy. Where legally required, you are responsible for obtaining valid consent from your parent or legal guardian before providing us with your Personal Information (Parental Consent). We may ask you to provide us with evidence of the Parental Consent and we reserve the right to delete any Personal Information collected from you if we cannot verify that you have the necessary consent to provide us with your Personal Information and/or use our Platforms. We will not be held liable or responsible where you have failed to obtain Parental Consent.
- d.Other categories of Personal Information:We may also collect other Personal Information that you provide through your engagement with us, for example, in connection with surveys or promotions.
4. Do we collect Sensitive Information?
Some of the information we collect from you and handle is considered Sensitive Information (for example, Health Data) and may be subject to special protections in some jurisdictions. Such information will not be collected in every case and will not be collected where prohibited by law.
We will only collect Sensitive Information where:
- a.you consent to us collecting and processing your Sensitive Information, including where you consent to us collecting such information from third parties such as an Authority; or
- b.there is another legal basis permitting us to collect such information.
5. How do we collect Personal Information?
We collect your Personal Information in a few different ways, as outlined below.
- a.Directly from youWe collect your Personal Information directly from you (including but not limited to) when you register and create an account with us, use any of our products and services (including when you communicate with us) or simply visit our Platforms.
- b.IndirectlyWe may also collect your Personal Information via third parties. For example, we may collect your Personal Information via third parties as follows:
- With your consent, when we work with Authorities to provide you with specific services relating to the collection or verification of your documents. Examples may include but are not limited to, the Document Verification Service (DVS) in Australia or the Department of Internal Affairs (DIA) in New Zealand.
- With your consent, when we work with our Partners to provide you with our products and services.
- We may also collect your Personal Information from government, law enforcement and regulatory authorities where necessary and as required. This may include, but is not limited to, police, immigration, customs, and border security agencies.
- c.SEEK GroupWe may also receive or collect your Personal Information from another entity within the SEEK Group from time to time in accordance with the privacy policy of those related entities and/or relevant Privacy Laws or other relevant law (as applicable).
- d.From your online activitiesWe use Cookies to collect your Usage and Device Data when you use the platforms of any entity within the SEEK Group (Related Platforms) and when you interact with our advertisements on Third Party Websites. For more information on Cookies and Usage and Device Data, see section 11 below.
6. How do we use your Personal Information?
We use the Personal Information we collect for the purposes set out below:
- a.To provide Users with products and services
Purposes Categories of Personal Information and Legal Bases To provide you with products and servicesWe use your information to provide our products and services, including but not limited to assisting to verify your claims as a User.As part of this we may use artificial intelligence and machine learning systems to review and verify information you provide to us, either on their own where a reliable automated match is possible or otherwise in conjunction with human reviewers.Categories of Personal Information- Contact Data
- Identity Data
- Health Data
- General Data
- Usage and Device Data
Legal Bases- Contractual Obligations
- Legitimate Interest
- Notification and/or Consent (where required by applicable Privacy Laws)
To customise and improve products and services We use your information to customise and improve our products and services.As part of this we may use artificial intelligence and machine learning systems to improve and tailor our services and features, including but not limited to improving our verification and quality control procedures.Categories of Personal Information- Contact Data
- Identity Data (other than Government Related Identifiers)
- Health Data
- General Data
- Usage and Device Data
Legal Bases- Legitimate Interest
- Notification and/or Consent (where required by applicable Privacy Laws)
To communicate with you about your use of our products and services and to provide you with technical and other supportWe may contact you and provide information relevant to your use of the Platforms, products or services and to provide you with technical and other support.If we speak to you over the phone, we may record the calls for training, verification and quality assurance purposes.Categories of Personal Information- Contact Data
- Usage and Device Data
Legal Bases- Legitimate Interest
- Legal Obligation
- Notification and/or Consent (where required by applicable Privacy Laws)
- b.Marketing and communication purposes
Purposes Categories of Personal Information and Legal Bases To market and promote our products and servicesWe use your information to send you marketing and promotional materials for direct marketing purposes including information about our products and features and survey requests.We may communicate with you via a number of different channels (including by email, SMS, instant messaging and in app and push notifications).See section 13 below on how you can change your communication preferences.Categories of Personal Information- Contact Data
- Usage and Device Data
Legal Bases- Legitimate Interest
- Notification and/or Consent (where required by applicable Privacy Laws)
To conduct market surveys, trials and customer researchWe use your information to obtain insights about our Users and to help businesses within the SEEK Group to improve, tailor and develop their products and services.Categories of Personal Information- Contact Data
- Usage and Device Data
Legal Bases- Legitimate Interest
- Notification and/or Consent (where required by applicable Privacy Laws)
To send you information regarding the products and services offered by businesses within the SEEK Group and PartnersCategories of Personal Information- Contact Data
Legal Bases- Legitimate Interest
- Notification and/or Consent (where required by applicable Privacy Laws)
- c.As part of SEEK Group’s business operations
Purposes Categories of Personal Information and Legal Bases For research and development of products and services within the SEEK GroupWe use your information to obtain insights about our Users and to help businesses within the SEEK Group to improve, tailor and develop their products and services (for example, by conducting trials, analytics and customer research, and by using your information within machine learning and artificial intelligence systems).Categories of Personal Information- Contact Data
- General Data
- Usage and Device Data
Legal Bases- Legitimate Interest
- Notification and/or Consent (where required by applicable Privacy Laws)
To manage and administer our products and services, verify your identity and to ensure the safety and security of our operationsWe use your information to verify your identity (and any other information you may provide to us), your accounts and activities, to detect, prevent and respond to potential or actual security incidents and to monitor and protect against other malicious, deceptive, fraudulent or illegal activities.Categories of Personal Information- Contact Data
- Identity Data
- General Data
- Usage and Device Data
Legal Bases- Legitimate Interest
- Legal Obligation
- Notification and/or Consent (where required by applicable Privacy Laws)
To protect rights of all entities within the SEEK Group, its assets, other rights and interests and personnelWe may use your information to meet our obligations under law and respond to potential or actual litigation.Categories of Personal Information- Contact Data
- Identity Data
- General Data
- Usage and Device Data
Legal Bases- Legitimate Interest
- Legal Obligation
- Notification and/or Consent (where required by applicable Privacy Laws)
- d.To meet our regulatory, compliance and legal obligations
Purposes Categories of Personal Information and Legal Bases To comply with our regulatory, compliance and legal obligationsThis includes, without limitation, to proceed with a request relevant to your rights regarding our use and handling of your Personal Information and to respond to potential requests for information from different regulatory or law enforcement authorities.Categories of Personal Information- Contact Data
- Identity Data (other than Government Related Identifiers)
- Health Data
- General Data
- Usage and Device Data
Legal Bases- Legitimate Interest
- Notification and/or Consent (where required by applicable Privacy Laws)
7. What happens if we are unable to collect your Personal Information?
It is important for us to Process your Personal Information in order to provide our products and services to you. If you do not want your information to be processed for the purposes set out in this Privacy Policy, you may need to cease using our Platforms, products or services or engaging with us.
You can choose not to share your Personal Information with us. However, if you choose not to provide us with the necessary Personal Information, we may not be able to provide you with some or all of our products or services.
We also require your Personal Information to meet our legal obligations. Where the legal basis for the Processing of your Personal Information is to comply with our legal obligations, a failure by you to provide us with certain Personal Information may cause us and/or you to be in breach of these legal obligations.
8. Who do we share your Personal Information with?
We may share your Personal Information in several ways.
- a.PartnersWhere you use our products and services, you may choose to instruct us to share your Personal Information with Partners. Where this occurs, we may share your Personal Information with Partners for the purposes set out in this Privacy Policy.Examples of when this may occur include, but are not limited to, sharing with:
- SEEK, Jobstreet and Jobsdb online employment marketplaces for the purpose of verifying your claims on a job application or to share and display your verified claim on a personal candidate profile that you have created on the platform of those employment marketplaces. Subject to your own personal profile visibility settings, Advertisers using the SEEK, Jobstreet and Jobsdb online employment marketplaces may be able to view your verified credentials which includes your Personal Information.
- Potential employers, recruitment services firms, or background screening providers for the purpose of you providing verified credentials or documents to a potential employer before commencing a new job; and
- Other Partners including other SEEK Group businesses operating under the Jora, Jobstreet Express, and GradConnection brands (and Partners external to the SEEK Group) for the purpose of verifying your identity and credentials.
- b.AuthoritiesWith your consent, we will share your Personal Information with relevant Authorities where required to provide you with any products or services relating to the verification of your documents or information.We may also share your Personal Information with Authorities and other relevant governmental authorities, law enforcement agencies, regulatory bodies or competent officers which/who have legal authority to request the disclosure of Personal Information. This includes any obligation to comply with court orders or other legal obligations that we may have.
- c.Service ProvidersWe may share your Personal Information with our third-party Service Providers from time to time but only for the purposes of:
- assisting us to deliver the products and services we offer to you, including customising and improving our products and services;
- enabling you to access the products or services they offer; or
- conducting surveys, trials and customer research.
- d.SEEK GroupIn addition to where you provide your consent for us to share your Personal Information as set out in section 8(a) above, we may share your Personal Information with any entity or business in the SEEK Group for the purposes set out in this Privacy Policy.
- e.Mergers, acquisitions or restructuresIn the event of any merger, acquisition or restructure, we may share your Personal Information with the transferee or successor of any entity within the SEEK Group, or any prospective purchaser of any business or asset within the SEEK Group (together with its relevant advisors). If required by applicable Privacy Laws, we will notify you in advance of any merger, acquisition, or restructuring.
- f.Links to third-party sitesOn some Platforms, we may make available links to Third Party Websites or mobile applications which are not owned or controlled by us. We are not responsible for the privacy practices of those websites. Users are strongly recommended to refer to the privacy policies of Third Party Websites before using them.
9. When do we share your Personal Information overseas?
We may share your Personal Information outside of your primary place of residence under the following circumstances:
- a.with SEEK Pass Pty Ltd (registered in Australia), the entity responsible for hosting the Platforms and the storing of your Personal Information, on secure servers located in Australia;
- b.with a Service Provider, Authority, Partner or other third party in an overseas location for the purposes set out in this Privacy Policy, including any entity or business within the SEEK Group; including Australia, New Zealand, Singapore, Malaysia, Indonesia, Philippines, Thailand, Hong Kong, United States of America, Netherlands, Germany, France, Ireland, Singapore and India;
- c.where your Personal Information is shared by you with SEEK, Jobstreet and/or Jobsdb online employment marketplaces and accessible by Advertisers based outside of your primary place of residence; and
- d.where we consider it necessary to comply with any legal or regulatory obligations.
10. How do we keep your information secure?
Protecting your information is a key priority for SEEK Pass and we take all reasonable steps to ensure the security of our Platforms and to protect your information from misuse, interference and loss as well as unauthorised access, modification or disclosure.
Examples of the steps taken by SEEK Pass include but are not limited to:
- a.Routine testing of our Platforms via penetration tests and automated infrastructure tests;
- b.Administrative safeguards such as restricted network access and multi-factor authentication for employees; and
- c.Technical safeguards such as secure encryption of your information.
For more information on how we are committed to protecting your information, please refer to our online security practices page.
You can also play an important role in keeping your Personal Information secure, by maintaining the confidentiality of any accounts used on the Platforms. We recommend you enable multi factor authentication when logging into your account on our Platforms, where available. In some circumstances we may mandate the use of multi factor authentication in order for you to use certain services. Please notify us immediately if there is any unauthorised use of your account by any other Internet user, or any other breach of security relating to your account. We will retain certain information associated with your account for the time period required to comply with any legal or regulatory obligations.
11. How do we use Cookies and Usage and Device Data?
- a.IP AddressesOur web servers gather your Internet Protocol (IP) address to assist with the diagnosis of problems or support issues with our products and services, and to monitor the use of our Platforms, including the monitoring of the location of our Users.
- b.CookiesLike many other digital platforms, we use Cookies to obtain information such as the current location of your device, the type and version of your browser, your device ID and other device metrics which we collect when you visit our Platforms. We use Cookies to help with the functionality of our Platforms and to provide Users with a better browsing experience.Cookies provide detailed user behaviour for measurement and analytics purposes, which help us to understand how Users navigate our Platforms, develop and test our products and services and new functionalities, to make business decisions, and aid in the diagnosis of errors.Cookies are also an essential part of the login and authentication flow with our third-party authentication provider Auth0 – without these it would not be possible for Users to access our products and services.If you do not wish to have Cookies active while you browse our Platforms, you may “opt out” by modifying the privacy options in your browser. However, doing so will prevent access to all of the logged in areas of the Platforms and limit your use of our products and services. Please note that it may be necessary for you to opt out separately from each device and browser that you use to access our Platforms.
- c.Our AppsIn addition to the above, where Users access Our Apps we collect information relating to your use of Our Apps, including tracking of app installs and re-engagement. This information is used to help us provide, monitor and improve our products and services, and to assist with user and technical support.
12. Retention of your Personal Information
- a.General RetentionUnless section 12(b) says differently, we retain your Personal Information for as long as is necessary to fulfill the purposes for which it was collected and retained as set out in this Privacy Policy or until such time as you request us to delete your Personal Information, after which we will take reasonable steps to delete your Personal Information (as may be required under applicable Privacy Laws).Subject to applicable Privacy Laws, we may retain your Personal Information even after you have requested that it be deleted if retention is reasonably necessary for us to comply with our legitimate interests, legal and regulatory obligations, store in testing or backup systems (for a period of time) or to enforce this Privacy Policy. Where information is held in testing environments, this information is held in closed and secure environments and the information is only used for the purpose of internal software testing. Information held in backup systems is only held for the purposes of restoring systems in the event of a data loss.
- b.Retention of DocumentsWe take reasonable steps to promptly remove from our Platforms any documentation (which may include Personal Information and Sensitive Information) that you may have provided to us to provide a particular product or service to you once the documentation is no longer required to provide this product or service to you. For example, if you have provided us with a copy of your passport to verify your identity, SEEK Pass will remove the copy of your passport from our Platform once it has been reviewed. However, we will retain your identity verification status for as long as is necessary in accordance with 12(a) above. Please note that if you are using the SEEK Pass mobile application to store documents securely on your device, your documents will be retained by you within the mobile application until you choose to remove them or delete the mobile application from your device.We will retain copies of any documentation you provide that we believe to be fraudulent (including documents or images) for compliance, investigation and training purposes. Documentation or information that is suspected to be fraudulent may be shared with the appropriate authorities.
13. Personal Information Requests
- a.GeneralYou can make certain requests in relation to Personal Information that we hold about you. Some of these requests only apply in certain circumstances, as set out in more detail below.
- Access: To the extent required by applicable Privacy Laws, you have the right to ascertain whether we hold Personal Information about you and request access to such Personal Information that we currently hold. You can request access to the Personal Information that we hold about you by contacting us.
- Correction/Rectification: To the extent required by applicable Privacy Laws, you have the right to correct any Personal Information held about you that is inaccurate or incomplete. You can request that we correct or update your Personal Information by contacting us.
- Deletion: For Users, you can request that we delete your Personal Information held by us within your account by logging in to and requesting that we delete your account in the ‘Settings’ section then selecting “Delete your account”.
- Sharing: For Users, if you have instructed us to share your Personal Information with Partners, in some cases you may be able to manage ongoing sharing permissions in your account. For example, you may instruct us to stop continuous sharing of specific verified credentials with a particular Partner.
- b.Opt-out/Unsubscribe You may opt-out of communications from us, as set out in more detail below.
- For receiving marketing and promotional messages from us, you can click ‘unsubscribe’ in the footer of any marketing or promotional email, or by replying ‘stop’ to an SMS that you receive from us; or
- you can contact us via the contact details outlined in section 15.
We will comply with any unsubscribe request as soon as reasonably practicable, and in accordance with applicable Privacy Laws or other applicable laws.
14. Updates to this Privacy Policy
We may modify this Privacy Policy at any time. You should review this Privacy Policy periodically so that you are updated on any changes. In some circumstances, depending on the nature of the changes, we will notify you of the changes to this Privacy Policy prior to them taking effect if required to do so under applicable laws.
By continuing to use our Platforms, products or services, you agree to any modifications that are made to this Privacy Policy.
15. Contact Us
If you have any questions or complaints regarding this Privacy Policy or if you wish to contact us regarding our use or handling of your Personal Information, you can do so by contacting us via the below channels. You can also contact us and request a copy of this Privacy Policy in hard copy or in another format that suits your particular needs.
Any privacy complaint received by us will be referred for prompt investigation and a response will be provided to you as soon as possible. If you are still unsatisfied with the resolution of any complaints made, you can seek further redress through your local data protection regulator.
SEEK Pass | Email: privacysupport@seekpass.coPost: User Help DeskSEEK Pass Pty Ltd60 Cremorne Street, Cremorne VIC 3121 Australia |
Jobstreet Malaysia | Email: dataprivacymy@jobstreet.comPhone: +60-3-2778-9511Post: Agensi Pekerjaan JobStreet.com Sdn BhdLevel 16, Menara AIA Cap Square,No. 10, Jalan Munshi Abdullah,50100 Kuala Lumpur, Malaysia |
Jobstreet Indonesia | Email: corpcare-id@jobstreet.comPhone: 021-8082 5888Post: PT JobStreet IndonesiaPrudential Tower, 15th Floor Jl. Jend Sudirman Kav. 79 Jakarta 12910, Indonesia |
Jobstreet Singapore | Jobstreet Singapore Data Protection Officer:Email: dpo@seekasia.comPhone: +65-6538 0060Post: JobStreet.com Pte Ltd1 Wallich Street#24-03, Guoco TowerSingapore 078881 |
Jobstreet Philippines | Jobstreet Philippines Data Protection Officer:Email: dataprotectionofficer@jobstreet.comPhone: +632 8286-6222Post: JobStreet.com Philippines, Inc.23rd Floor, Alliance Global Tower,36th Street Corner 11th Avenue,Uptown Bonifacio, Taguig City 1634 |
Jobsdb Thailand | Jobsdb Thailand Data Protection Officer:Email: customerservice-th@seek.com and dataprivacy-th@jobsdb.co.thPhone: +66 2 667 0700Post: JobsDB Recruitment (Thailand) Ltd.127 Gaysorn Tower, Unit A, E, 14th FloorRatchadamri Road, Lumpini, PathumwanBangkok 103330 |
Jobsdb Hong Kong | Jobsdb Customer Service:Email: customerservice-hk@seek.comPhone: +852 2332 8832Post: JobsDB Hong Kong LimitedCustomer Support Executive, Customer Service Department37th Floor, PCCW TowerTaikoo Place, 979 King’s RoadQuarry Bay, Hong Kong |
16. Languages
This Privacy Policy may be translated into the local language in the relevant territory. In the event of a conflict between this Privacy Policy in the English language version and the localised version, the English language version shall prevail. The localised version shall be deemed to be automatically amended to conform with and made consistent with the English language version.
17. Definitions
Term | Definition |
---|---|
Advertiser | An individual or an entity (including employers and recruiters) that post job advertisements on the SEEK, Jobstreet and/or Jobsdb platforms or uses other products or services of SEEK, Jobstreet and/or Jobsdb to source potential candidates for job vacancies. |
Authorities | Third parties who we engage with to provide or verify your information for the purpose of providing our products and services to you. Examples may include but are not limited to government authorities, regulatory and licensing bodies, and public registries. |
Cookies | Cookies, tags, applets, scripts and other similar technologies. |
Designated Entity |
|
DPA | The Philippines Data Privacy Act of 2012. |
EEA | The European Economic Area. |
GDPR | The European General Data Protection Regulation, Regulation (EU) 2016/679. |
Government Related Identifier | Has the meaning as that term is defined in the Australian Privacy Act 1988 (Cth). |
Our Apps | Mobile applications owned or controlled by us and the SEEK Group. |
Parental Consent | Has the meaning given to it in section 3(c) of this Privacy Policy. |
Partners | Any organization (including third parties) who, with your consent:
|
Indonesia PDP Law | Indonesia Law No. 27 of 2022 on Personal Data Protection. |
PDPO | Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong |
Personal Information | Information (including Sensitive Information) that identifies an individual or could reasonably identify an individual, including facts and opinions, whether they are true or not.In certain jurisdictions, the term “Personal Data” is used under applicable Privacy Laws, which means any information relating to an identified person, or a directly or indirectly identifiable individual. References to Personal Information in this Privacy Policy include a reference to Personal Data, where applicable. |
Personal Data | See definition of Personal Information. |
Platform(s) | Includes our online websites such as https://seekpass.co/ and any other website controlled by SEEK Pass, mobile websites, applications, products, services, features and software. |
Privacy Laws | The applicable privacy and data protection laws as may be in force from time to time in a particular jurisdiction which regulates the collection, use, disclosure, storage of and granting of access rights to Personal Information. |
Process, Processing, or Processed | The collection, use, disclosure, transfer, retention or other processing of Personal Information. |
SEEK Group | SEEK Limited and each of SEEK Limited’s related bodies corporate (as that term is defined in the Australian Corporations Act 2001 (Cth)). |
SEEK Pass, we, us, our | Any reference to “SEEK Pass”, “we”, “us” and “our” includes a reference to our SEEK Pass business. |
Sensitive Information | Where relevant under applicable Privacy Laws, certain categories of Personal Information that require higher levels of protection (for example, by virtue of Indonesia PDP Law, it is acknowledged as Specific Personal Data). Depending on the applicable Privacy Laws, this may include information or opinion about an individual’s racial or ethnic origin, political opinion or associations, religious beliefs, trade union memberships or associations, sexual orientation, criminal record including any proceedings for any offence committed or alleged to have been committed by such individual (including the disposal or result of such proceedings), health and genetic information, or government-issued identification, provided the information or opinion otherwise meets the definition of Personal Information. |
Service Providers | Third parties that help us to provide our product and services to you. For example, analytics service providers; cloud service providers; storage service providers; information technology service providers; marketing and advertising service providers; market research providers; accounting, audit, legal and compliance service providers, and other professional advisers; service providers who provide services in event management, electronic payment service providers, and all other vendors. Service Providers do not include Partners. |
Third Party Websites | Websites which are not owned or controlled by us and the SEEK Group. |
UK | The United Kingdom. |
UK GDPR | The UK General Data Protection Regulation. |
Usage and Device Data | Has the meaning given to it in section 3(a) of this Privacy Policy. |
Users | Individuals with a registered SEEK Pass account who use our products and services. |
Visitors | All individuals or organisations accessing the Platform, including Users. |
Young User | Means any User who is under the minimum age provided for under applicable Privacy Laws, including:
|
18. Region Specific Information
If you are a citizen or habitual resident of the applicable jurisdiction described below (or where the applicable laws of a jurisdiction described below otherwise apply to you), the following jurisdiction-specific terms will supplement, and should be read together with, this Privacy Policy. In the event of a conflict between the jurisdiction-specific terms that are relevant to your jurisdiction and the rest of the Privacy Policy, the relevant jurisdiction-specific terms will prevail.
- a.European Economic Area (EEA) and the United Kingdom (UK)If you are based in the EEA or the UK, then in addition to what is set out in this Privacy Policy, the following applies to you in accordance with the GDPR or the UK GDPR (as applicable).You may contact us using any of the methods set out in section 15 above to request that we:
- provide you with a copy of the Personal Information we hold about you in a portable and machine-readable form; or
- share your Personal Information with a nominated third party.
- b.Hong KongIf you are an individual seeking to access our products and services in Hong Kong, then in addition to what is set out in this Privacy Policy, the following applies to you in accordance with the PDPO:Direct MarketingWe intend to use the Contact Data and Usage and Device Data of Users for the purpose of direct marketing in relation to the following products and services:
- our products and services including information about our products and features (including verification features), newsletters, surveys and other event information;
- products and services offered by businesses within the SEEK Group and in particular the SEEK, Jobstreet and Jobsdb online employment marketplaces; and
- products and services offered by Partners.
- c.ThailandIf you are based in Thailand, then in addition to what is set out in this Privacy Policy, the following applies to you in accordance with the Personal Data Protection Act B.E. 2562 (2019) and any regulations, rules, guidelines, notifications and orders issued by virtue of said legislation, as may be amended from time to time (collectively, referred to as “PDPA”).Retention PeriodWe will retain your personal data for as long as is required in order to fulfil the purposes specified in this Privacy Policy or as otherwise required by any applicable law.Data Subject RightsSubject to the limitations and conditions of the PDPA, you are entitled to the following rights in respect of your Personal Information.
Right to access To request to have access to your Personal Information, or to request to have a copy of such Personal Information, as well as to request disclosure of how your Personal Information has been acquired without your consent. Right to data portability To obtain your Personal Information in the format which is generally readable or usable with automatic tools or devices and which can be disclosed or used via automatic means from us, and you are also entitled to request that we transmit your Personal Information in such format to another data controller. Right to object To object to the Processing of your Personal Information, particularly where your Personal Information is Processed for direct marketing purposes. Right of erasure To request that your Personal Information be deleted, destroyed or de-identified. Right to suspension To request that the use of your Personal Information be suspended. Right to rectification To request that your Personal Information be updated, completed or rectified. For Users, you may alternatively edit or amend your Personal Information at any time by logging in to your account and accessing the ‘Account’ section followed by the ‘Settings’ section on the Platforms. Right to withdraw consent Where the legal basis for the Processing of your Personal Information is consent, you will be entitled to withdraw consent at any time, subject to the conditions and limitations stipulated by the PDPA. Withdrawal of your consent shall not affect the Processing of your Personal Information for which you have lawfully granted consent prior to such withdrawal. Right to lodge complaint You are entitled to lodge a complaint to the personal data protection supervisory authorities in the event of our non-compliance or violation of the PDPA. Notwithstanding that, we encourage you to first contact us to resolve any issues or concerns. - d.PhilippinesYou can click the following links to view the National Privacy Commissioner’s Seals of Registration:
Right to be informed To be informed that your personal information is being, or have been processed, including the existence of automated decision-making and profiling. We have done so through this Privacy Policy. Right to object To object to the processing of your personal data, including processing for direct marketing, automated processing or profiling. Right to access To reasonable access to, upon demand, or copies of your Personal Information including the sources from which your Personal Information were obtained, names and addresses of the recipients of your Personal Information, the manner by which such were processed, the reasons for the disclosure of your Personal Information to recipients (if any), information on automated processes where your Personal Information will or is likely to be made as the sole basis for any decision that significantly affects or will affect you, the date when your Personal Information were last accessed and modified and the designation, name of the Personal Information Controller. Right to rectification To dispute the inaccuracy or error in the personal data and have us correct it immediately and accordingly, unless the request is vexatious or otherwise unreasonable. Right to erasure/blocking To suspend, withdraw or order the blocking, removal, or destruction of your personal information from our filing system. Right to damages To be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, taking into account any violation of your rights and freedoms as data subject. Right to data portability To obtain from us a copy of your personal information in an electronic or structured format that is commonly used and allows for further use by you. Right to lodge complaint You are entitled to lodge a complaint to the National Privacy Commission in the event of our non-compliance or violation of the DPA. Notwithstanding that, we encourage you to first contact us to resolve any issues or concerns. - e.New ZealandSome of the third parties to whom we may disclose your Personal Information (as listed above in Section 8) may be 'foreign persons or entities' for the purposes of New Zealand's Privacy Act 2020 (for example, they may be companies incorporated outside New Zealand).You authorise us to make those disclosures and acknowledge that those recipients may not be subject to Privacy Laws that provide comparable safeguards to those under the Privacy Act 2020.
- f.MalaysiaParental ConsentIn the event you are agreeing to this Privacy Policy in order for a minor to access and use our Platforms, products or services, you hereby consent to the provision of Personal Information of the minor to be processed in accordance with this Privacy Policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor's compliance with this Privacy Policy.Right to limit processing of your Personal InformationYou may request to limit the processing of your Personal Information by using the contact details provided under the Contact Us section above. However, this may affect our provision of our products and services to you.
- g.SingaporeIf you are based in Singapore, then all references to Privacy Laws in this policy should be construed as including a reference to Singapore’s Personal Data Protection Act 2012 (“PDPA 2012”) and any of its related subsidiary legislation, regulations, rules, advisory guidelines, notifications and/or orders as may be amended from time to time.Reliance on Deemed Consent and/or Various Exceptions under PDPA 2012All references to consent in this policy shall also include a reference to deemed consent by you to the collection, use and/or disclosure of your Personal Information by us when you register and create an account with us, use our products and services, visit our Platforms or simply engage with us over the phone, via email, in person or by any other means. Subject to PDPA 2012, we shall be entitled to rely on such deemed consent by you for the collection, use and/or disclosure of your Personal Information for the purposes stated in the sections above.Apart from deemed consent, we may also rely on other exceptions to the requirement of consent under PDPA 2012 where appropriate, including but not limited to situations where:
- a.The use of the Personal Information (which includes sharing of such Personal Information between entities within the SEEK Group) is in relation to (i) improving, enhancing or developing our new goods or services; (ii) improving, enhancing or developing our new methods or processes for business operations in relation to our goods and services; (iii) learning or understanding behaviour and preferences of our customers (including groups of customers segmented by profile); and/or (iv) identifying goods or services that may be suitable for customers (including groups of customers segmented by profile) or personalising or customising any such goods or services for customers (the “Business Improvement Exception”);
- b.Where the collection, use and/or disclosure of Personal Information is in relation to data obtained from or disclosed by a public agency and is consistent with the purpose of the disclosure by the public agency (“Public Agency Exception”); and/or
- c.Where the use and/or disclosure of Personal Information is for the purposes of research, including but not limited to market research, provided that (i) the research purpose cannot be reasonably accomplished unless the Personal Information is provided in an individually identifiable form; (ii) there is a clear public benefit to using the Personal Information for the research purpose; (iii) the results of the research will not be used to make any decision that affects you; and (iv) in the event the results of the research are published, we will publish the results in a form that does not identify you. An additional condition applies to the disclosure of Personal Information, where it must be impractical for us to seek your consent for disclosure (the “Research Exception”).
Transfer of Personal Information outside of SingaporeFurther to section 9, where your Personal Information is transferred out of Singapore, we will take reasonable steps to ensure that your Personal Information continues to receive a standard of protection that is at least comparable to that provided under PDPA 2012. By registering and creating an account with us, using our products and services, visiting our Platforms or simply engaging with us over the phone, via email, in person or by any other means, you accept and agree that your Personal Information may be transferred (in or outside Singapore) to third parties including those set out in sections 8 and 9 above, to be used for the purposes stated in those sections. Towards this end, we will implement reasonable security arrangements which may include administrative, physical, and technical measures, such as ensuring that only the appropriate amount of personal data is held, restricting access to confidential documents on a need-to-know basis, implementing access limitation and encryption protocols to prevent unauthorised access, compartmentalisation of data, transferring Personal Information only on secure computer networks, and/or other relevant measures to protect your Personal Information.Right to withdraw consent Where the legal basis for the Processing of your Personal Information is consent, you will be entitled to withdraw any consent given or deemed to have been given under PDPA 2012 at any time, subject to the conditions and limitations stipulated by PDPA 2012. With regard to your Personal Information that is already in our possession, withdrawal of consent would only apply to our continued use or future disclosure of the Personal Information concerned.