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Global Privacy Policy (RGF Services)

Last Updated: 1, November, 2023

Effective Date: 1, January 2020

Introduction / Applicability


Recruit Co., Ltd. and its subsidiaries (*), as well as its parent company, Recruit Holdings Co., Ltd., (collectively, “Recruit,” “we,” or “us”) are committed to protecting your privacy and the confidentiality of any personal data provided by you, in accordance with our obligations under applicable data protection laws and best practices.

(*) Japanese subsidiary, RGF Talent Solutions Japan K.K. is excluded. For the privacy policy of RGF Talent Solutions Japan K.K., please visit the website (Executive Search Professional Recruitment)

This privacy policy (“Global Privacy Policy”) governs the data processing of Recruit in relation to the RGF Services (as defined below). Please read this privacy policy carefully in its entirety, including the jurisdiction-specific annexes which apply to you, which depends on your residency/location as well as the location of the employer that offers job positions that you are interested in.

RGF Services (“RGF Service(s)” or “Service(s)”) are total recruitment solutions, which are mainly related to permanent recruitment, but covers contract recruitment, RPO, HR-related market research and advisory for all industries and functions at all positions or levels in the Asian countries and markets where we operate. We provide our Services under three distinct brands, RGF Executive Search (**), RGF Professional Recruitment, and RGF HR Agent.

(**) RGF Executive Search is only available at RGF Talent Solutions Japan K.K. For more information, please visit the website https://www.rgf-executive.com/.

Please see below for the overview of the service brands and applicable jurisdiction-specific annexes.

Name of service Description
RGF HR Agent Fills a range of managerial, specialist and staff positions at mainly Japanese companies that require Japanese language skills. Draws on a deep understanding of Japanese companies with a vast database of Japanese-speaking personnel to find the best candidates.
RGF Professional Recruitment Hiring of personnel for managerial and specialist positions, who:
- are essential to the core business of the employer;
- deal with the public, customers, and the teams that are driving the business cross-functionally; and/or
- may be considered candidates for development for executive senior leadership positions.
For other services, please refer to the jurisdiction-specific annex.

In addition, please note the following regarding application of jurisdiction-specific annexes:

  • In case that more than one annex is applicable to you, if there is any inconsistency between provisions of the applicable jurisdiction-specific annexes, the provisions that imposes stricter obligations on Recruit shall prevail.

  • In the event of any conflict between the provisions of the applicable jurisdiction-annexes, service-specific annexes, and this privacy policy, the provision that imposes stricter obligations shall prevail.

  • In the event of any conflict between this English language privacy policy and its corresponding local language privacy policy, the terms in English shall prevail.

  • Please note that separate specific privacy policies, notices or terms and conditions of the Recruit group companies that oversee or are situated in the jurisdictions about which you have expressly stated your interests may apply to you, and this privacy policy does not replace or revise any such specific privacy policies, notices, or terms and conditions.

- For EEA (European Economic Area) and the UK (United Kingdom): Please refer to "Processing of Personal Data of Persons within the EEA"

- For other jurisdictions:

China

Hong Kong

India

Indonesia

Japan

Singapore

Thailand

Vietnam

Personal Data We Collect


We will only collect personal data that we are permitted to collect by law on a jurisdictional basis.

The personal data we most commonly collect are as below:

Category Description
Identity data Name
Age/date of birth
Social Security Number and/or other ID information (driving license number, passport, Social ID, etc.)
Citizenship and/or residency status
Marital status
Contact data Telephone number
E-mail address
Postal address (home/office)
Resume and affiliation data Candidate’s resume and other materials voluntarily provided by candidates when applying for a position, including:
- Company where the Candidate is working, position (title), and its categories of industries
- Employment history
- Professional and/or educational qualifications
- Salary details (current and/or historical)
- Language proficiency
Activity data How you use our websites, the areas of our websites you frequent, what services you access, and information about your computer hardware and software (such as your IP address, browser and operating system type, domain names, access times, and referring site addresses)

During the recruitment process or in the course of the Service, we may collect personal data that is sensitive or special category in certain countries. We will obtain your explicit consent to handle this type of personal data, in accordance with applicable privacy law.

We may collect your personal data from sources including, without limitation:
  • Receiving personal data directly from you through our websites (when you upload and submit your resume, or fill in an online application for a particular position advertised on our websites) or in person (by providing such personal data to our recruitment consultants in written form or orally);

  • Receiving your personal data indirectly from job boards and other third parties;

  • Automatically recording personal data when Candidates use the Services (by use of cookies and similar technologies); and

  • Acquiring personal data from publicly available sources, such as third party websites, blogs, forums, social media sites, and job-search portals or professional networking sites or on the Internet.

As described in the "How We Share Your Personal Data" section, each company in Recruit may collect personal data from other companies in Recruit.

How We Use Your Personal Data


Legal grounds to process your personal data may change, subject to specific laws and regulations, so please refer to the jurisdiction-specific annex.

Personal data collected by us will be primarily used for providing you with the Services. We use your personal data for the purposes described as below:

  • to provide job-seekers (“Candidates”) with career management or guidance services;

  • to provide employers who wish to hire job-seekers or to consult us for recruitment advice (“Clients”) with recruitment solutions;

  • to allow us to process and respond to any inquiries or feedback from you;

  • to confirm the status after the job placement, job change, or temporary staffing to obtain feedback or requests to improve our Services;

  • to provide Services in future even after your successful job placement(s) through our Services (such as a change of job) (“Future Recruitment Service”);

  • to inform you of any events, industry updates, market developments, promotional information or other information we consider useful to you for marketing or advertising (such information will be sent by post/e-mail, texts or similar communication, and will also contain instructions for unsubscribing);

  • to distribute targeted advertisement by using cookies or other technologies or methods;

  • to generally assist us to manage our relationship with you, or to provide or manage the recruitment and/or HR services we provide, including carrying out of administrative or operational tasks;

  • for verification or reference check as requested by Clients;

  • to generate aggregated statistical reports distributed internally in Recruit;

  • for us to carry out market research and/or market analysis, including, without limitation, conducting research using questionnaires and sharing the aggregate results thereof with third parties;

  • to conduct internal audits;

  • to comply with legal, regulatory and other compliance requirements (including providing assistance to law enforcement, judicial, regulatory or other government agencies and statutory bodies); and

  • as part of a proposed sale, merger, acquisition, joint venture, or transfer of assets, subject to ensuring that the recipient is under suitable confidentiality obligations in respect of your personal data and uses it only for the purposes you have agreed to and as permitted by this privacy policy.

When you refuse to provide or decide to withdraw your personal data, Recruit will be unable to provide you with the Services.

How We Share Your Personal Data


To the extent possible, we aim to minimize disclosure of your personal data to third parties.

However, we need to make certain disclosures from time to time. We may share your personal data as described below:

  • disclosures to prospective employers, when you apply for any specific roles, or otherwise agree that we may disclose your personal data;

  • disclosures to other members of the Recruit group globally (i.e. Recruit Holdings Co., Ltd., and its subsidiaries and affiliates), where such disclosure is necessary for one or more of the purposes set out in the “How We Use Your Personal Data” section above;

  • disclosures to agents, service providers, sub-contractors, and suppliers (both legal entities and natural persons) such as market research service providers, business support service providers, and customer management service providers (e.g. Salesforce), where such disclosure is necessary for one or more of the purposes set out in the “How We Use Your Personal Data” section above;

  • by contacting third parties (including nominated references) to verify your educational or professional qualifications, work experience, or other such information submitted by you in the course of our Services;

  • by preparing and providing aggregated statistical reports on our candidates and/or website users/visitors, to our clients or proposed employer-clients, for marketing or feedback purposes. Such reports (except where consent is specifically obtained) would not include personally identifiable features such as names or contact details of candidates and/or website users/visitors, and would be formatted, encrypted, anonymized or aggregated to ensure your anonymity;

  • disclosures to our professional advisors (such as lawyers, accountants and financial advisors), to the extent necessary and only if they are bound to keep your personal data confidential;

  • disclosure to a third party as part of a proposed sale, merger, acquisition, joint venture, or transfer of assets, subject to ensuring that the recipient is under suitable confidentiality obligations in respect of your personal data and uses it only for the purposes you have agreed to and as permitted by this privacy policy;

  • disclosures required by law, or requested by a government entity, or to prevent crime, or to ensure the rights, property and/or personal safety of Recruit (including its officers, employees, contractors and/or agents), other members ofthe Recruit group, our employer-clients, candidates and other users/visitors of our websites, or any other person; and

  • as otherwise permitted by applicable law.

Data Transfer Outside of Country


Recruit will ensure that any transfers outside of country are minimized as much as possible; however, we may need to transfer your personal data to third parties which may be located in countries outside of your own in the situations described in the "How We Share Your Personal Data" section. We will implement safeguards to protect your personal data, as required under applicable local data protection laws and regulations.

Security


We will use reasonable physical, electronic, and procedural measures to safeguard personal data within our organization against loss, theft, and unauthorized use, disclosure, or modification.

Any personal data held by or on our behalf is stored on secure servers, with modern security measures in place to protect against the loss, unauthorized access or alteration, or misuse of such information. Where such personal data is held by unrelated third parties on our behalf, we have also imposed contractual obligations on such parties to ensure the confidentiality and security of such information.

However, while we will take all reasonable measures (as required by applicable law) to protect the integrity of such information, we cannot guarantee that loss, unauthorized access or alterations, or misuse will not occur.

It is in turn your duty to keep (and take reasonable steps to keep) any usernames and/or passwords issued by or relating to our websites confidential and secure, and to inform us promptly of any possible security breaches (including unauthorized access to your personal data through our websites).

Retaining Personal Data


We will periodically review the personal data held by us to ensure that is accurate and up to date. We will also retain your personal data only for so long as it is necessary to carry out the purposes described in "How We Use Your Personal Data" above (subject only to our internal policies on data retention, or applicable laws and regulations).

Data Subject’s Rights


You have the right to withdraw your consent to the processing of your personal data in cases where consent is required by law to process your personal data. To withdraw your consent, please contact us using the contact details in the "Contact Us" section.

To the extent required by applicable law, you may have rights regarding your personal data, including, without limitation, rights of access, correction, and deletion, and the right to stop the use thereof. To assert your data subjects' rights, please contact us using the contact details in the "Contact Us" section.

We will process your requests above in accordance with applicable law. Where permitted by law, we may also charge a reasonable fee to cover our administration costs when dealing with any requests, of which we will inform you in advance. Any request must include sufficient details to identify you. Upon receipt of your request, we may request for additional information from you (including proof of identity) in order to process your request. Please note that it may also take some time to process the application, although we aim to process all requests as soon as possible.

Cookies and Similar Technologies


We may also use cookies and other similar technologies through our websites to maximize your user experience. Cookies are small text files placed on your computer's memory temporarily or placed on your hard drive by a web page server. By using cookies, our websites can provide you with faster service and a more personal experience, including behavioral targeting advertising. You can at any time set your web-browser to reject cookies, although this may hinder performance and negatively impact the user-friendliness of our websites.

Direct Marketing Communications


If you no longer want to receive direct marketing communications from us, you may opt out by following the instructions contained within each email sent by us for this purpose or by contacting us using the contact details in the "Contact Us" section. Please note that if you opt out from receiving direct marketing communications, we may still send you administrative messages, from which you cannot opt out.

Third Party Services / Websites


Our websites may require you to provide personal data, such as when you create a profile and login credentials. Some functionality may allow you to use third party authentication tools that allow you to share feeds or post content to social media and professional networking sites. Any information that is captured through the use of such functionality is governed by the relevant third party privacy policy and terms, not this privacy policy.

Our websites may also contain links to other websites (whether of other members or affiliates of the Recruit group or third parties). Recruit bears no responsibility for the privacy commitments of these websites, or any disclosures of personal data or other information submitted by you through those websites, or otherwise collected from you by those website operators. It is your duty to ensure that you are satisfied with the extent of your rights and obligations in relation to your personal data when dealing with such websites or their operators. We encourage you to review the privacy policies and any other terms and conditions of those sites.

Contact Us


If you have any questions about this privacy policy or how Recruit processes your personal data, please contact us using the following contact details:

By post: Gran Tokyo SOUTH TOWER

1-9-2 Marunouchi Chiyoda-ku,

Tokyo 100-6640 Japan

Administration Team, RGF International Recruitment

RECRUIT CO., LTD.

By e-mail: admin@rgf-irb.com

By phone: +81-3-6835-3000

Policy Changes


We may update this privacy policy from time to time, in accordance with our internal policies, technological developments, industry practices, or applicable laws and regulations. If we make any changes to our privacy policy, we will post the revised version here, so do review it frequently. If significant changes are made, we may also notify you by other means, such as, but not limited to, a notification by email or on our website.

Please also refer to the list of external transmission on the website and the list of external transmission on the application.

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