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Last Updated: 1 June 2022

This AnyTalent Privacy Policy (“Privacy Policy”) applies to the information collected and received from the user (“you”) through AnyTalent Platform. AnyTalent Platform is Human Resource software that enables an employer to have a Human Resources management system which includes the function of an applicant tracking system, online payroll system, online employees attendance system, online leave request management system, employee data base and future functions (“AnyTalent Services”) operated by AnyMind Group Pte. Ltd and its subsidiaries (“We”). We are committed to transparency, protect the privacy of you, and foster your confidence on the internet, in conserving your data in AnyTalent. We want you to fully understand what personal data we collect, why we collect it, how we protect your personal data, how long do we keep your personal data and what are your rights. If you have any questions please do not hesitate to contact us by sending an email to info@anymindgroup.com

First, please have a look and be familiar with our specific cookie types used for AnyTalent here below.

SPECIFIC COOKIE TYPES USED

Authentication Cookies: We use Authentication Cookies to storage the authentication token for handling user authentication under the following flow.
1. We call the API to log in the user
2. The server authenticates the user and does the following:
  - a. Generates an access token that uniquely identifies the user’s session.
  - b. Stores the access token and keeps it until the user logs out.
  - c. Attaches the access token to an authentication cookie (.ASPXAUTH) that it returns to us in the HTTP header of the API authentication call. (Note that the server generates additional cookies that it returns to us as well.)
  - d. Attaches and returns a CCSID cookie in the HTTP header of the API authentication. Centrify uses this when evaluating policy rules, to determine if the client device that is executing the endpoints has been used before.
3. The server validates the user session for each call to the API by inspecting the token passed by the client in the HTTP header cookie, and verifying that it is identical to the token that the server generated and saved in Step 2.
4. When the user logs out, the server removes the cookies for that user.

WHAT PERSONAL DATA DO WE COLLECT AND HOW DO WE COLLECT IT?
“Personal Data” means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier. We as a data controller here to inform you all information you may need to know about using AnyTalent.

“Non-Personal Data” means any information which does not contain personally identifiable information which we may collect from your employer.

For any visitor who is not a user, we may collect Non-Personal Data to identify a computer that has previously seen our advertisement but is not an identifiable person since we generally do not know who is using a computer at any particular time.

You might refuse to provide us your personal data, but if you choose not to do so, we will not be able to provide you AnyTalent, but you may at anytime choose to opt-out by simply sending us an email to info@anymindgroup.com or dpo@anymindgroup.com.

We collect your Personal Data when you register user account on AnyTalent or your employer registered you to Employee Data Base in order to use AnyTalent (Personal Data we collect from third parties). We may collect some or all of your following personal data depends on AnyTalent’s functions that your employer use as follows:
- Name;
- Identification Number/ Passport Number;
- Date of Birth;
- Email;
- Phone Number;
- Bank Account Number;
- Address;
- Photographic Image;
- Sex; and
- Biometics (finger print for recording your time attendance).
We may collect some or all of your non-personal data depending on AnyTalent’s functions that your employer use as follows:
- Information about your salary;
- A record of vacation and any leave types;
- details of your visit to AnyTalent; and
- Your location (when you use clock-in or clock-out function from your device) and traffic data.
WHY DO WE COLLECT YOUR PERSONAL DATA?
We collect your personal data to provide our Services to you and your employer. Your personal data is necessary to accomplish the purpose of using the Services, response to your inquiry, handle any complaints, to fix system issues, to develop and improve our Services, functionality of our Services and to communicate with you. Moreover, we will use your personal data to the following purposes.
- To verify the authority of the user for the access to AnyTalent.
- To provide to the specific company based on the prior acknowledgement.
- To aggregate anonymized data for statistics to offer a better service.
WHO DO WE SHARE YOUR PERSONAL DATA AND NON PERSONAL DATA WITH?
We know that your personal data is confidential therefore, except as set forth in the Privacy Policy, your personal data will never be shared with third parties without your consent. Furthermore, we will not use your personal data for any purpose other than to accomplish the purpose of using the Services, response to your inquiry, handle any complaints, to fix system issues, to develop and improve our Services, functionality of our Services and to communicate with you.

However, it may be necessary for us to share or disclose your personal data with affiliated companies, so that they may contact you in connection with the objective of your inquiry.

Furthermore, it may be necessary for us to disclose your personal data during investigations, or in compliance with regulations, or as required by law, or as requested by government agencies or authorities, including the National Credit Bureau, for purposes of preventing fraud or corruption.
HOW DO WE PROTECT YOUR PERSONAL DATA?
We follow generally accepted industry standards to protect against the unauthorized access to, retention of, and disclosure of information. This includes undertaking necessary physical, electronic, and management activities required to protect information integrity, access, and use. Any information that is stored on our server is treated as confidential information. Please keep in mind, however, that despite these reasonable efforts to protect information on our servers, no method of transmission over the Internet is guaranteed to be secure. Therefore, while we strive to protect your information at all times, we cannot guarantee its absolute security.
WHERE DO WE KEEP YOUR PERSONAL DATA?
We keep your personal data in our database which is held by Amazon Web Services, only assigned software developers which are our employees shall have the permission to edit/check the production environment, such permission is managed by Amazon Web Services. We, every time of updating tested our system to ensure the security of personal data protection.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
It is necessary for us to retain your personal data throughout the period of your employment or throughout the period that your employer uses our Services. Furthermore, in compliance with the law, we may retain your personal data after your employment ends or your employer stop using our Services. We will retain your personal data in the form of soft copy under appropriate security measure of Amazon Web Services. When the retention period has expired or when we are no longer entitled to retain your personal data, we will delete and destroy your personal data in accordance with its data retention policy and applicable laws and regulations.
WHAT ARE YOUR RIGHTS?
We follow generally accepted industry standards to protect against the unauthorized access to, retention of, and disclosure of information. This includes undertaking necessary physical, electronic, and management activities required to protect information integrity, access, and use. Any information that is stored on our server is treated as confidential information. Please keep in mind, however, that despite these reasonable efforts to protect information on our servers, no method of transmission over the Internet is guaranteed to be secure. Therefore, while we strive to protect your information at all times, we cannot guarantee its absolute security.

Your rights for your personal data are as follows:
- Right to be informed; You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. Therefore, we’re providing you with the information in this Privacy Policy. We also will inform you if we collect your personal data for other purposes rather than what we described above.
- Right to access/ right to rectify; You always have the right to access, correct or update your personal data at any time. We understand the importance of this and should you want to exercise your rights, please contact us at info@anymindgroup.com
- Right to data portability; The personal data you have provided us with may be portable. This means it can be moved, copied or transmitted electronically under certain circumstances.
- Right to object; you have the right to object to certain types of processing, including processing for direct marketing (i.e., receiving emails from us notifying you or being contacted with varying potential opportunities).
- Right to erasure / right to be forgotten; You have the right to request that we delete your data. If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements. If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it.
- Right to restrict of processing; you have the right to restrict the processing of your personal data.
- Right to withdraw the consent; you have the right to withdraw your consent that you gave to us anytime by contact us at info@anymindgroup.com. Or dpo@anymindgroup.com, we will take reasonable steps to respond to your request in accordance with legal requirements.
HOW TO CONTACT US?
If you have any questions about this Privacy Policy, please contact us at 3 Anson Road, #20-03 Springleaf Tower, Singapore 079909 or via email at info@anymindgroup.com, or dpo@anymindgroup.com.