Privacy Policy

Your privacy is of great importance to us. We treat all the information we receive as good and as accurate as possible. How we do this and for what purposes we use your information is described in this Privacy Notice.

Who we are
This Privacy Notice is published on behalf of all entities within the Positive Moves group of companies, namely Positive Moves Ltd., India, Positive Moves Hong Kong, Positive Moves Dubai.

What is Personal Data?
Personal Data concerning this Privacy Notice includes any information that can identify you as a specific individual such as your name, your contact details, e.g. email address and phone number, but also an identification number, location data and online identifiers can be Personal Data. Other information that does not relate to you as an individual is not Personal Data.

Responsibility of your Personal Data
Positive Moves is the controller of the Personal Data collected from you within the meaning of the legislation and regulations in the area of privacy for the processing of your Personal Data. The obligations of a controller is to provide you with information of what, why and how we process your information when requested. This is what we do with the Privacy Notice.

What and why we collect data about you
The type of Personal Data we may collect about you is primarily the Personal Data you provide us with. However, we also collect data which is publicly available, e.g. through social media channels. Moreover, we collect data through phone and fax, through job applications and in connection with in-person recruitment and in connection with our interactions with customers and vendors.

We may collect the following types of personal information as long as local laws permit this:

  • contact information (such as name, postal address, email address and telephone number);
  • Information you provide about friends or other people you would like us to contact. (Positive Moves assumes that the other person previously gave an authorization for such communication);
  • other information you may provide to us,
  • other information that is publicly available, e.g. through your social media profiles
  • In addition, if you are an associate or candidate, or if you apply for a position, we may collect the following types of personal data (as permitted under local law) :

  • employment and education history;
  • language proficiencies and other work-related skills;
  • Social Security number, national identifier or other government-issued identification number;
  • date of birth;
  • gender;
  • bank account information;
  • citizenship and work authorization status;
  • information on benefits and compensation;
  • tax-related information;
  • information provided by references;
  • information contained in your resume or C.V.;
  • information you provide regarding your career interests,
  • other information about your qualifications for employment.
  • We may also collect information you provide to us about other individuals, such as information related to emergency contacts.

    We will only process information about you when we have a lawful ground to do so. In general we rely on the following legal grounds to process your data:

  • Consent;
  • Performance of a contract – when we enter a contract with you;
  • To comply with legal obligations;
  • Legitimate interest after balancing your interests and rights.
  • When we rely on legitimate interest such legitimate interest can be e.g. legitimate business processes and activities, including the generation of management information and reports and the performance of market analyses.
    If required by law we may need to disclose your personal data to authorities or as otherwise required by law or court order.

    How do we use your Personal Data
    We will usually use your Personal Data for purposes such as:

  • Providing you with job opportunities and work;
  • Manage our relationship with you e.g. provide services and respond to inquiries;
  • assessing your suitability as a job candidate and your associate qualifications for positions;
  • Processing employment applications;
  • To enter into a job placement relationship with you and put you in a job position with our customers;
  • To put you in contact with one or more (potential) customers, or to make a proposal to you.
  • To make you available to customers and to put you in a position to carry out activities for customers;
  • to conclude an agreement on the provision of services, permanent and temporary employment, secondment, employment or similar agreement with you;
  • to enter into and maintain an employment relationship with you and to have a personnel, financial, absence and / or payroll accounting;
  • Business development, including newsletter, updates, publications and event details unless you indicated that you do not appreciate this;
  • Fulfilment of statutory or other regulatory requirements;
  • How do we protect your Personal Data
    We have taken strong efforts in regard of organisational and technical measures to protect your personal data against unlawful processing and/or loss and we keep on reviewing and improving them. Employees of Positive Moves who have access to your Personal Data are, of course, also bound by confidentiality clauses.

    Transfer and sharing of Personal Data
    In providing services we may need to share your Personal Data within our group of companies. In case of a job placement situation your personal data is included in our central database and the persons within our company (including our group companies) engaged in job placement have access to this Personal Data.

    We also share your personal data – in the degree necessary for the respective lawful purpose – with third parties. This sharing will take place mainly with potential new employers.

    The sharing of Data does not adversely affect your rights. The original lawful ground and purpose described above will remain solid and we will take all reasonable steps necessary to ensure that the transferred information is kept secure as required by applicable data privacy laws.

    If your Personal Data is shared outside the jurisdiction of the European Union then Positive Moves will use EU standard contractual clauses to ensure your Personal Data is processed with adequate safeguards for such transfers.
    By submitting your personal information to Positive Moves you agree that you do not object to any such transfer, processing or storage.

    Automated decision-making
    We do not use automated decision-making.

    Retention of your Personal Data
    We will retain the data as long as the same is required and will destroy the same after the time. The same information will be retained in case of any legal requirement. Kindly contact data.safety@positivemoves.com for more information regarding retention time.

    Accuracy of your Personal Data
    We want to keep your Personal Data correct and updated. If your Personal Data changes, please inform us by sending us an email to data.safety@positivemoves.com.

    Your rights
    Since we process your Personal Data you have rights to exercise in specific circumstances. So when authorized by applicable law, you may exercise certain such as:

  • Right of access: You may access your Personal Data in order to verify that the Data is correct and processed in accordance with law
  • Right to rectification: You may request the rectification of any inaccurate or incomplete data held about you, in order to protect the accuracy of such information and to adapt it to the data processing.
  • Right to erasure: You may request that Positive Moves erases Personal Data about you and to no longer process that data.
  • Right to restriction of processing: You can request us to limit the personal data that we process about you.
  • Right to data portability: You may request data portability, meaning that you can receive your originally provided Personal Data in a structured and commonly used format or that you can request the transfer of the Personal Data to another data controller.
  • Right to object: You can object to the manner that we handle your personal data. E.g. if you do not want to receive information from us about our services (e.g. via email newsletters). You can do so without needing to justify your decision.
  • Right not to be subject of automated individual decision-making: Positive Moves does not use automated individual decision-making. However if we were then you would be able to request not to be subject to a decision based solely on automated processing, including profiling, if such profiling produces a legal effect for you or if it produces a similarly significantly effect for you.
  • Right to information: you have the right to obtain from Positive Moves the confirmation as to whether or not your Personal Data is being processed in in which way.
  • concerning him or her are being processed
  • Whenever data processing is based on consent as described in Article 7 of the European General Data Protection Regulation then you may withdraw your consent at any time.
  • You can also file a complaint to the local data protection authorities in the jurisdiction of the office in which services are being provided.
  • If you have questions, comments or complaints with regard to this Privacy Notice or the manner that we register, use or process your Personal Data, please, contact our Data Protection Officer at: data.safety@positivemoves.com .

    For concerns regarding our collection and use of your Personal Data you may raise your concern also directly to the lead supervising authority.

    Agreement to terms of privacy policy
    By providing information to us, you accept and agree to the collection and use of your personal data for the purposes described.

    Changes to this Privacy Notice
    This Privacy Notice may be changed or updated by Positive Moves at any time and in due course to comply with any further requirements of law, especially in regard of the European General Data Protection Regulation. This Privacy Notice was last reviewed and updated on 15th January 2018.

    Contact details
    For any requests, updates or questions you might have, please contact us using data.safety@positivemoves.com

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