Last modified: January 2024
We collect personal data from Employers and Applicants in order to provide recruitment services. Personal data here refers to any information which is related to an identified or identifiable natural person ("Personal Data"). Depending on the purposes of collection of personal information and the nature of the individuals, Personal Data includes data that directly identifies you — such as your name, address, contact information, identification document, date of birth, place of birth, gender, nationality, occupation, marital status, employment history (including contact information of former employers/employees), background information, education, income, financial information, and other information that is not otherwise publicly available.
- Personal Data We Collect
- How We Use Your Personal Data
- Sharing of Your Personal Data
- Cross Border Data Transfer
- Access to or Correction of Your Personal Data
- Removal of Your Personal Data
- Retention of Your Personal Data
- Protection of Your Personal Data
- Links to Other Websites
- Our Contact Details
1. Personal Data We Collect
This section sets out the categories of Personal Data that we may collect and the source of that Personal Data. We may collect the following categories of Personal Data.
a. Data Collected Whenever You Use the Site
When you use the Site as a user, we need to collect Personal Data which identifies or can be used to identify, contact, or locate the person to whom that information pertains. Without it, we may not be able to provide you with all services requested. This information includes (but is not limited to) your name, address, contact information, identification document, date of birth, place of birth, gender, nationality, occupation, marital status, employment history (including contact information of former employers/employees), background information, education, income, financial information, as well as your reviews/feedback. This information can be obtained by phone, direct meetings, email and submitting information through our website.
b. Data Automatically Collected from Your Device by Using Our Site
Whenever you use the Site, we may collect Personal Data in the form of technical data regarding your device and device usage such as information about web pages viewed and session duration. The information we collect may also include:
- Geographic location: we may collect information about your approximate location from your IP address and other information provided from your mobile device.
- Log Information: when you are using the Site, we may collect information which we refer to as "log information". This log information may include (but is not limited to) IP address, browser type, operating system, nationality, pages visited, your mobile carrier, device information as well as other Internet usage related information. We use the log information to provide you with a better experience using the Site.
c. Data We Collect from Third Parties
We may also collect your Personal Data from third parties (including agents, vendors, suppliers, contractors, partners and any others who perform any process on our behalf, provide services in the Site, provide services to us or whom we collaborate with). In such cases, the collection will be conducted upon your acknowledgement/direction to the relevant third party.
d. Third Party Personal Data You Provide to Us
You may provide us with Personal Data relating to other third-party individuals (including when you add any third-party individual data as additional users). In that case you undertake and warrant that you have already obtained properly documented consent from the relevant third-party individual(s) and hereby give approval on behalf of such individuals to the collection, use, disclosure and processing of his/her Personal Data by us.
If we are unable to collect your Personal Data, we may not be able to provide our services to you.
2. How We Use Your Personal Data
Pinkcollar takes your privacy and confidentiality seriously. To provide our services to you and improve your experience on our Site, we may collect, hold, use and disclose your Personal Data for the following reasons and as permitted by applicable laws. We gather information to better understand our client’s needs and requests, to advertise candidate availability, publish job openings and to assist in the processing of visa applications for clients who engage us in services. We will not disclose any information to a third party for commercial purposes unless we have permission from you. We do also reserve the right to use any information collected for research purposes, provided we shall not disclose any private information in such research unless we first have permission from you.
For added clarity, the purposes for which your personal information are used include:
- internal assessment and potential candidate matching;
- to market job openings and potential candidates to attract suitable employers and applicants;
- to conduct research on the domestic worker industry;
- to provide training to domestic workers;
- for submission of required information to relevant authorities when processing the employment application;
- to arrange for insurance for domestic workers; and
- for direct marketing (subject to your consent).
Marketing and use by Us:
- digital marketing which includes, however is not limited to, social media, display advertising, Search Engine Optimization (SEO) and Search Engine Marketing (SEM); and
- conventional marketing purposes which include, however is not limited to, sending you emails about new products, special offers, and surveys or other information which we think you may find interesting; and
- inform you of events and to deliver news, reports, market analyses, promotions, and other information, products and services relating to the domestic helper industry.
Please note that you may opt out of receiving marketing materials from us by following the unsubscribe instructions set out in our marketing materials or by contacting us on the contact details set out below and we will respect your wishes. However, please note that:
- we may still send you non-promotional messages or information such as employment renewal reminders, payment receipts or other service-related correspondence; and
- notwithstanding anything in the foregoing, the opt-out will take into effect within one (1) day after you successfully unsubscribe from the service.
3. Sharing of Your Personal Data
Pinkcollar will keep your Personal Data confidential. Only authorised staff members of Pinkcollar and local or overseas partner agencies of Pinkcollar will have access on a "need-to-know" basis to and handle your personal information. To the extent necessary, we may disclose your personal information to the following parties in or outside Malaysia (each a "Third Party") solely for the purposes set out in this policy:
- potential employers of domestic workers and domestic workers who use our service;
- government authorities; and
- domestic worker agencies.
We may also disclose your personal information when authorised or required by law and in response to requests from law enforcement agencies, government departments or regulatory authorities.
We may also share your personal information within Pinkcollar and with third parties including our partner organisations and agencies and service providers, such as IT contractors, as necessary for any of the purposes as stated above. Where personal information is provided to third parties, the personal information will only be transferred to such third parties that are under a duty of confidentiality to Pinkcollar.
Other than as provided for in this Policy, we may disclose or share your Personal Data if we notify you and we have obtained your consent for the disclosure or sharing.
Please note that we may disclose your Personal Data subject to the following conditions:
- Consent: We will only share your Personal Data with the Third Parties when we have your consent to do so. You agree that your use of our services will constitute your consent and that the sharing of your Personal Data will be subject to this Policy.
- For Legal Reasons: We may also, in our absolute discretion, share your Personal Data with Third Parties (including government agencies, law enforcement, and lawyers and other advisers) if we consider this is necessary to: i) comply with the law or applicable regulations; ii) protect and defend our brand, rights and property; or iii) protect the personal safety or property of our users or the public.
4. Cross Border Data Transfer
Services provided through the Site can be used only in Malaysia for the time being. To make that possible, your Personal Data may be transferred to or accessed by entities around the world. We commit reasonable commercial efforts to comply with laws on the transfer of Personal Data between countries to help ensure your data is protected, wherever it may be.
We may also transfer your Personal Data located overseas including to any Third Party. The countries in which these Third Parties may be located include Indonesia, the Philippines and other countries where We may operate through agents or affiliates. In any case, we will take appropriate steps to ensure that your Personal Data remains subject to a standard of protection comparable to the requirements under the laws of the relevant country.
5. Access to or Correction of Your Personal Data
When you provide us with your Personal Data, please ensure that it is accurate, up-to-date and complete. If you believe that any of your Personal Data held by us contains errors or omissions, please contact us based on the contact details below to make those changes accordingly.
You acknowledge that we may be unable to provide the Services to you if Personal Data required by us is not provided in accordance with this Policy.
If mandated by applicable law, you may request certain copies and/or access of your Personal Data, that you have provided to us in a structured, commonly used, and machine-readable format. If you wish to obtain a copy of your Personal Data, please contact firstname.lastname@example.org.
- we will notify you of any such amendments by means of a general notice published on the Site, or otherwise to your e-mail address set out in your account,
Where we have obtained your consent for any collecting, use or disclosure as indicated above, you may withdraw your consent to our collection, use or disclosure of your Personal Data by submitting a request at our contact details listed below. Upon your request, we will promptly cease to collect, use or disclose your Personal Data, unless required by law or if we have legitimate business or legal purposes for collecting, storing, using or disclosing such Personal Data. Depending on the circumstances and the nature which you are withdrawing, please note that by withdrawing your consent to our collection, use or disclosure of your Personal Data, we may not be able to continue providing you with some of our services and you agree that we will not be liable to you for any losses or damages arising out of or in relation to such termination of services.
7. Removal of Your Personal Data
To the extent permitted by applicable law, you may have the right to request us to remove your Personal Data that we store on our systems. You may submit a deletion request to us at our contact details listed below.
We, without undue delay or within time period as stipulated under the applicable law, shall use reasonable effort to erase your Personal Data, or will use reasonable efforts to remove the means or personal identifiers by which the Personal Data can be associated with you as an individual, if:
- the purpose for which Personal Data was collected is no longer being served by the retention of that Personal Data;
- we are not otherwise permitted or required by applicable law to retain the Personal Data; and/or
- In case it is mandated by applicable law, based on your request to delete your Personal Data.
Please note that by requesting us to remove your Personal Data, we may not be able to continue providing you with some of our services and you agree that we will not be liable to you for any losses or damages arising out of or in relation to such termination of services.
8. Retention of Your Personal Data
Unless you give explicit consent for your personal information to be retained for a longer period or there is a subsisting reason that oblige us to retain your data for a longer period to comply with our obligations in law, we will not retain your personal information for longer than necessary.
9. Protection of Your Personal Data
We will protect your Personal Data by maintaining reasonable security arrangements, including physical, technical, and organisational procedures, to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. It is important to remember that even though we have several safeguards in place to protect your information, nothing within the internet is 100% secure and we cannot guarantee the safety of your Personal Data. If we are subject to a data breach that relates to your Personal Data, to the extent required by applicable law, we will notify you through our channels, whether directly or indirectly, to give you sufficient information regarding such data breach and will work to protect against the misuse of your Personal Data.
10. Links to Other Websites
If you have a complaint regarding the treatment of your Personal Data, please contact us at our Contact Details listed below. We will treat your complaint in a confidential manner. We will contact you within a reasonable time after receipt of your complaint to discuss it and to outline options regarding how your complaint may be resolved. If you have a complaint regarding the treatment of your Personal Data that is not resolved by us, you may be able to make a complaint to the relevant regulatory authority. Any Personal Data that we collect while processing or resolving your complaint will be used solely for that purpose.
12. Our Contact Details