This privacy policy (“Privacy Policy”) governs the data collection, processing, and usage made by Seazone Innovative Sdn Bhd. (“Company”, “we” or “us”).
This Privacy Policy concerns the data we collect from individuals:
· who access and use our website available at: https://seazone.com.my/ (respectively “Website” and “Visitors”);
· who are looking for a job on our Website (“Job Candidate”).
Each of the Visitors and Job Candidate, shall also be referred to herein as “you”.
This Privacy Policy constitutes an integral part of the Terms of Use (“Terms”). Definitions used herein but not defined herein shall have the meaning ascribed to them in the Terms.
If you have any questions about this Privacy Policy, please contact us at: ask.kl@seazone.com.my .
AMENDMENTS
We reserve the right to periodically amend or revise the Privacy Policy, which will immediately affect the implementation of the revised Privacy Policy on our Website. The last revision date will be reflected in the “Last Modified” heading located at the top of the Privacy Policy. We will make a reasonable effort to notify you if we implement any changes that substantially change our privacy practices. We recommend that you review this Privacy Policy periodically to ensure that you understand our privacy practices and to check for any amendments.
Questions, comments, requests and complaints regarding this Privacy Policy and the information we hold are welcome and should be addressed to us by using the contact details above. All requests will be dealt with promptly and efficiently.
COLLECTION OF NON-PERSONAL DATA
We may collect aggregated, non-personal and non-identifiable information which may be made available or gathered via your use of our Website or System (“Non-Personal Data“). We are not aware of the identity of the individual from which the Non-Personal Data is collected.
Also, we may sometimes process and anonymize or aggregate personal data and identifiable information in a manner that shall create a new set of data that will be Non-Personal Data. Such a new data set can no longer be associated with any identified person.
Non-Personal Data may be used by us without limitation and for any purpose, including for commercial, research, or statistical purposes, without further notice to you.
COLLECTION OF PERSONAL DATA
During your use of the Website or the System, we will collect individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data” or “Personal Information” as defined under applicable law). This may include online identifiers, name, emails, etc., subject to applicable law.
If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data.
PROCESSING OF PERSONAL DATA – PURPOSES AND LAWFUL BASIS
We have included in the table below information about which data is processed, how we process and use your data and the lawful basis for which we do so subject to the GDPR.
Type of Data | Purpose of Processing | Lawful Basis | Processing Operations |
Becoming a general User of the Seazone System: | |||
If you are or wish to become a user of the Services, you will be required to provide us with certain information such as: · Identification and contact data: Full name, Email address, Username and password, etc. · Demographic data: Date of Birth, Gender, etc.
| We will use the identification data to designate your account and allow you to use the System. Further, we will use the demographic data to allow you to use our System, in the best way for your needs and current situation.
Also, your email address will be used to send you needed information related to our System (e.g., notify you regarding any updates to our System, etc.) and promotional and marketing emails.
| Our lawful basis under the GDPR for collecting this information is the performance of a contract (i.e., providing you the Services as per your request).
When we use your email for providing you with further information of marketing nature, i.e., regarding our products and services, we will do that under the necessity of processing for our legitimate interests, after ensuring that your rights and interests are being ensured and protected. | For opening of an Account and subscribing to our Services: Collection of your data, storage, analysis of the data and customizing the System, and Seazon’s Services for your characteristics and needs. We will also archive and save that data to allow the continuity of the Services to you.
For providing you with information we will use your data for email delivery.
We are encrypting the data in our systems for security and confidentiality purposes. |
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Recruitment Data if you are a Job Candidate using the Seazone System for job seeking | |||
Suppose you are looking a job Position through Seazone System and subscribing to the System as Job Candidate. In that case, and in addition to any other we may collect information regarding your job status, education, CV, requested salary, face photo and other information to be collected as part of any recruitment process. In addition, in the system we will process records and reviews data which will be collected in our feedback system, as provided by other users. | We will use such information for presenting you with job opportunities, and allowing other Users to search for relevant recruiters. Also, we may keep it afterward as part of our business records. | The lawful basis for such processing will be the contract between us – we process your data as per your application to a position within our Company. After the recruitment process, we may keep your information under our legitimate interests as part of our ongoing business records and for future protection from any potential legal suit. | Collection of data, analysis of such data, correspondence with you through the means of contact you have provided us with, record keeping of data.
Also we may provide your details, upon your will as a job seeker, to other Users as potential employers. |
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Seazone’s Website |
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Contact us information: If you voluntarily contact us in any manner, whether for partnering or to submit a request or for other inquiries, whether by sending us an email or through the means of communications on our Website, e.g., any online form available on the Website, such as “Contact us” form, you may be asked to provide us with your contact information such as your full name and email address. In addition, you can choose to provide us with additional information as part of your correspondence with us. | Addressing your inquiries and/or checking the option to provide you with services. | We will collect and process this data, store it in our systems, and check it with our contact history solely to respond to your inquiries and provide you with the support or information you have requested. We will retain our correspondence with you for as long as needed, subject to applicable law. Note that such correspondences can be retained in databases we use for this purposes and which we bought from third parties (i.e., SaaS platform such as CRM). In such cases, your data may be shared and transferred to such third parties. For more information regarding data transfer and sharing see below. | In case you contact us as a Customer or User -the lawful basis for processing your information will be the contract between you and us, meaning we will use the data for addressing your requests and inquiries. After completing any such request, we will retain your information as part of our business records under our legitimate interest. In the event you contacted us as a prospect customer or partner we will also do so under our legitimate interest. In such cases, where we rely on our legitimate interest, you are entitled to object such processing based on our legitimate interests if you believe that your rights are overridden by our interests. |
Online identifiers and other Technical Data | |||
When you access our Website, we may collect certain online identifiers, including your IP address, Advertising ID, and IDFA. We may also collect technical Non-Personal Data transmitted from your device (e.g., actions in the Website, your browser type, language used, type of operating system, type of device, etc.) and approximate geographical location (country).
*** please see the following paragraph regarding Cookie usage | We use this data for our legitimate interests of (I) operating, providing, maintaining, protecting, managing, customizing, and improving the Website and how we offer it; (ii) enhancing your experience; (iii) auditing and tracking usage statistics and traffic flow; (iv) protecting the security of the Website, as well as our and third parties’ rights (subject to applicable law requirements); and (v) advertising purposes
| Such processing is part of our legitimate interests as a commercial business. If we use third-party cookies on the Website or collect online identifiers, we will obtain your consent if required under applicable law. | Collection of data, aggregation and statistical analysis, report generation, record keeping and storage. |
Joining our team – Applying for a position in Seazone via our website | |||
If you apply for any position in our Company through the Website or elsewhere. In that case, we will collect your first and last name, email address, phone number, CVs and additional information at your choice, such as a URL to your LinkedIn profile or a personal note you added. | We will use such information for the recruitment process for checking your suitability for job opportunities in our team. Also, we may keep it afterward as part of our business records. | The lawful basis for such processing will be the contract between us – we process your data as per your application to a position within our Company. After the recruitment process, we may keep your information under our legitimate interests as part of our ongoing business records and for future protection from any potential legal suit. | Collection of data, analysis of such data, correspondence with you through the means of contact you have provided us with, record keeping of data. |
COOKIES USAGE
Like many other websites, the Website and parts of our System use cookies to improve your experience while you navigate the Website. We may use various types of Cookies:
· Essential Cookies – which are necessary for the site to work properly (usually appears under our name/cookie tag);
· Functional Cookies – designated to save your settings on the site – your language preference or other view preferences (also, under our name/cookie tag);
· Session Cookies – used to support the Website’s functionality – such Cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser.
· Targeting Cookies – these cookies are used to collect information from you to help us improve our products and services and serve you with targeted advertisements that we believe will be relevant to you (e.g., Google’s Cookies).
· Social networks Cookies – Social Plug-In Cookies (e.g., Facebook, Twitter, LinkedIn Cookies, or pixels, etc.) enable sharing your usage information with your social network’s accounts.
· Analytics Cookies – give us aggregated and statistical information to improve the Website and System and further developing it e.g., Google analytics, Google Firebase Catalytic, etc.
· Third-party services used by us – for example, an external service supporting our recruiting options through the Website (e.g., Comet or Workday), or an external service which allows us to screen short videos on our Website (e.g., YouTube or Vimeo).
Please note that the data collected by the use of Cookies may be linked to and combined with any other data, including Personal Data.
Also note, that Cookie’s data is usually collected through third-party services, like Google, Facebook, etc. In those cases, your Personal Data might be transferred to those third parties, which might use it, as a “joint controller” of the data, meaning that the data is also “owned” and processed by them under their terms and conditions. Under those terms and conditions and the direct accounts or subscriptions you have with those third parties, your Personal Data might be linked to other data collected by the relevant third party and processed in its systems, for its purposes, and under its management. For example, suppose you have a Facebook account, the Personal Data collected through Facebook’s Cookies in Our Website might be linked to other data Facebook collects and might be used by Facebook per the independent agreements between you and Facebook.
What Are Your Choices Regarding Cookies?
If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser, or use the designated Cookies Bar in the Website.
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
For the Chrome web browser, please visit this page from Google
For the Internet Explorer web browser, please visit this page from Microsoft
For the Firefox web browser, please visit this page from Mozilla
For the Safari web browser, please visit this page from Apple
For any other web browser, please visit your web browser’s official web pages.
Where Can You Find More Information About Cookies?
You can learn more about cookies and the following third-party websites:
– All About Cookies: http://www.allaboutcookies.org/
– Network Advertising Initiative http://www.networkadvertising.org/
SHARING DATA WITH THIRD PARTIES
We do not share any Personal Data collected from you with third parties or any of our partners except in the following events:
· Legal Requirement: We will share your information in this situation only if we are required to do so to comply with any applicable law, regulation, legal process, or governmental request (e.g., to comply with a court injunction, comply with tax authorities, etc.);
· Policy Enforcement: We will share your information, solely to the extent needed to (I) enforce our policies and agreements; or (ii) to investigate any potential violations thereof, including without limitations, detect, prevent, or take action regarding illegal activities or other wrongdoings, suspected fraud or security issues;
· Company’s Rights: We will share your information to establish or exercise our rights, to prevent harm to our rights, property, or safety, and to defend ourselves against legal claims when necessary, subject to applicable law;
· Third Party Rights: We will share your information, solely to the extent needed to prevent harm to the rights of our users, yourself, or any third party’s rights, property, or safety;
· Business Purpose – we may disclose your personal information to a third party for a business purpose, as detailed above.
· Service Providers – we share your information with third parties that perform services on our behalf (e.g. customer service, tracking, servers, service functionality, marketing, and support, etc.) these third parties may be located in different jurisdictions.
· Corporate Transaction – we may share your information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy;
· Authorized Disclosures –we may disclose your information to third parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices.
It shall be clarified that we will never transfer nor share your payment method (e.g., full credit card details) with any third party other than our payment services providers.
YOUR DATA SUBJECTS’ RIGHTS UNDER PRIVACY PROTECTION LAWS
We may not always be able to do what you have asked. Also, not all those rights apply in every jurisdiction. Yet, we encourage you to contact us with any such request, and we will be happy to assist you.
You have the right to lodge a complaint at any time before the relevant supervisory authority for data protection issues. However, we will appreciate the chance to deal with your concerns before you approach the authorities, so please feel free to contact us in the first instance.
DATA RETENTION
Unless you instruct us otherwise and subject to applicable laws, we retain the information we collect for as long as needed to provide our services and to comply with our legal obligations, resolve disputes and enforce our agreements if applicable. Basically, and as a minimum, that means that your data will be retained as long as you have an Account in our Systems and use our Services.
Also, and after the termination of your Account, we may keep some of your Personal Data as a user of our Services for more extended periods for protecting our legal interests or under any safety or other legal requirements.
As for Cookies data and technical marketing data, usually the data will be retained in an identified manner for periods of 14-36 months, subject to the relevant system. However, note that as explained before, once you delete the Cookies from your computer or otherwise restrict the use of cookies, we will have no linkage between your identity and your Cookies data (yet, the third-party provider may have such data relating to you, under the separate terms between you and any such third party, e.g., Facebook’s terms of use as a user of Facebook).
Recruitment data will be retained up to 7 years after the last recruitment activity, for allowing to protect ourselves from any potential legal suit, in accordance with Israel’s statute of limitations.
Please note that where we act as a Processor on behalf of an Account Owner, the retention periods are under the sole discretion of the Account Owner, as the Data Controller.
SECURITY
We use physical, technical, and administrative security measures for the services that we believe comply with applicable laws and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed or accidentally lost.
However, unfortunately, the transmission of information via the internet and online data processing cannot be 100% secure. As such, although we will do our best to protect your Personal Data, we cannot guarantee the security of data transmitted via the Website, Seazone System and any transmission of your data shall be done at your own risk.
DATA PROCESSING LOCATION
We may store or process your Personal Data in a variety of countries, including the United States.
Any transfer of data that originates in the European Union (“EU”) to a country outside of the European Economic Area (EEA), shall be made in compliance with the provisions of chapter 5 of the GDPR, e.g.:
· transfer to a country that is recognized as providing an adequate level of legal protection;
· transfer under a proper agreement containing the Standard Contractual Clauses published and authorized by the relevant EU authorities;
· where we can be satisfied that alternative arrangements are in place to protect your privacy rights through the use of any other mechanism under the GDPR.
It is important to note that we are headquartered in Israel, a country that the European Data Protection Board considers offering an adequate level of Personal Data protection regulation.
Suppose you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent. In that case, your consent to this Privacy Policy includes your express consent for such transfer of your data.
LINKS TO OTHER SITES
Our Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every Website you visit.