Privacy Policy

Introduction / Applicability

This privacy policy governs the data processing of Recruit Co., Ltd. and its subsidiaries, as well as its parent company, Recruit Holdings Co., Ltd., (collectively, "Recruit," "we," or "us") in relation to the RGF Services (as defined below) and our personnel recruitment (collectively, “services”) Please read this privacy policy carefully in its entirety, including the jurisdiction-specific annexes which apply to data subjects in certain jurisdictions.

The annexes for the jurisdictions where you are residing or located and the Recruit group company that processes your personal data (not only the Recruit group company that provides services to you but also the Recruit group companies your personal data are shared as explained in How We Share Your Personal Data section) are located shall be applicable. Thus, more than one annex may be applicable if you and the Recruit group company that processes your personal data to you are residing or located in different jurisdictions. In this case, if there is any inconsistency between the provisions of the applicable jurisdiction-specific annexes, the provisions that imposes stricter obligations on Recruit shall prevail.

For residents in China, Hong Kong, Japan, Malaysia, Singapore, Taiwan, and Vietnam: Please read the applicable jurisdiction-specific annexes below.
For residents in India, Indonesia and Thailand: Please just read this “Global Privacy Policy”
For residents in the Philippines: https://www.philippines.rgf-executive.com/privacy-policy

Please note that separate specific privacy policies / notices or terms and conditions may apply to you, depending on the specific services and jurisdiction, and this privacy policy does not replace or revise any such specific privacy policies / notices or terms and conditions.

RGF Services are total recruitment solutions, which are mainly related to cross-border permanent recruitment, but covers contract recruitment, RPO, and HR related market research and advisory, for all industries and functions at all position level in Asian countries and markets we operates through our distinctive three brands of RGF Executive Search, RGF Professional Recruitment and RGF HR Agent, and consist of the following services:

Name of the services	Description
RGF HR Agent	Fills a range of managerial, specialist and staff positions at 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. (i) JCS: Japan Career Square Japan Career Square, also called JCS, is the name of a service under RGF HR Agent, which provides permanent recruitment solutions to primarily Japanese speaking job seekers who are currently living in other Asian countries (i.e., Asia excluding Japan) to find job opportunities, relocate, and work in Japan. (ii) KMM（Kamome） Kamome, is the name of a service under RGF HR Agent, which is an Asia-wide job board and online human resources service to provide job opportunities primarily for native Japanese who are seeking career advancement opportunities in other Asian countries and at subsidiaries of Japanese companies in such countries. https://kamome.cn/ https://kamome.asia/ (iii) JJ：Japanese-Jobs.com Japanese-Jobs.com, is the name of a service under RGF HR Agent, which is an Asia-wide job board and online human resources service to provide job opportunities primarily for Japanese speaking job seekers who are seeking career advancement opportunities where they can utilize Japanese language capabilities in other Asian countries https://jp.japanese-jobs.com/ja
RGF Executive Search	Focus on senior executives to middle management search to fulfill organizational goals, strategic planning development and overall decision making that affects the entire business organization.
RGF Professional Recruitment	Hiring of personnel for managerial and specialist positions, who are essential to the core business of the employer, dealing with [the public], customers, and the teams that are driving the business cross-functionally. They can also be considered candidates for development for executive senior leadership positions.
Other RGF services provided by each subsidiary in each country	Contract Recruitment provides our clients with a flexible solution to meet immediate, short term or project requirements. RGF XXXX(i.e. Professional Recruitment Japan) handles staff payroll and social insurance, and contractor management by complying with Labour Laws and the Worker Dispatching Act in respective market we operate. Market Mapping provides our clients with a bespoke in-depth market intelligence analysis of the candidate pool in their sector through comprehensive research by utilizing methodology of executive search. It is a part of process of retain search, or as a respective service to assist our client to utilize it for organizational and hiring strategy development. Except for the above services, please refer to the jurisdiction-specific annex.

Recruit is 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.

Personal Data We Collect

The personal data we collect are as below:

Name;
Company where you are working, your position (title), and its categories of industries;
Telephone number;
E-mail address;
Postal address (home/office);
Employment history;
Professional and/or educational qualifications;
Salary details (current and/or historical);
Language proficiency;
Citizenship and/or residency status;
Marital status;
Age;
Date of Birth
Health Condition;
SSN;
Other information that may be obtained from the customer’s resume or online application;
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); and
Other personal data necessary for the purposes specified in【How We Use Your Personal Data】section (If required in applicable law, we will notify you the categories of such personal data separately).

Personal data may be collected by us directly from you, including, without limitation, 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 when you sign up to RGF Talent Community (which refers to different medium we use to collect candidate personal data such as RGF Network events , RGF Blogs etc.), by e-mail correspondence, by postal mail or fax, or in person (by providing such personal data to our recruitment consultants in written form or orally), or by use of cookies and other similar technologies. (For cookies and other similar technologies, please see here.

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

We may also obtain personal data relating to you from publicly available sources, such as third party websites, blogs, forums, social media sites, and professional networking sites.

How We Use Your Personal Data

We use your personal data for the purposes described as below.

Legal grounds to process your personal data may change, subject to specific laws and regulations, so please refer to the jurisdiction-specific annexYou hereby expressly consent to processing of your Health Condition.

For RGF Services

Personal data collected by us will be primarily used for providing you with recruitment services. This means that such personal data may be reviewed and analyzed by us for suitability for any particular roles you have applied for (or wish to apply for), or (if you have joined the 'RGF Talent Community, elected to receive job alerts, or have otherwise requested us to do so), provide you with job matching services by evaluating your suitability for and informing you (using your contact information) of, other roles that we may become aware of from time to time, or for verification of information.

When you refuse to provide or decide to withdraw your Personal Data, RGF will be unable to provide you with its recruitment, executive search, and other related services.

In addition, we may also use your personal data:

to provide you with career management or guidance services;
to allow us to process and respond to any inquiries or feedback from you;
to inform you of any events, industry updates, or market developments, or other information we consider useful to you (such information will be sent by post/e-mail, texts or similar communication, and will also contain instructions for unsubscribing);
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 generate internal reports;
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;
to analyze the use of resources, troubleshoot problems, prevent fraud, and generally improve our services and your user experience by using cookies or other technologies or methods; and/or
to distribute behavioral targeting advertising by using cookies or other technologies or methods.

For Our personnel recruitment

to process your application and to assess your capability and qualifications for a job;
to conduct reference checks; and/or
to conduct background checks if we offer you a position.

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 it;
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 belows;
disclosures to companies or individuals including but not limited to agents, sub-contractors, and suppliers such as Salesforce, where such disclosure is necessary for one or more of the purposes set out in the “How We Use Your Personal Data” section below;
by contacting third parties (including nominated references) to verify your educational or professional qualifications, work experience, or other such information submitted by you when obtaining 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 names or contact details of candidates and/or website users/visitors, and would be formatted 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;
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 of the 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 situation described in “How We Share Your Personal Data” section. We will implement safeguards to protect your personal data 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 and 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 provide our services to you (subject only to our internal policies on data retention, or applicable laws and regulations).

Data Subject’s Rights

You have the rights to withdraw your consent for 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, deletion, cease of use, or correction. 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 and, where permitted by law, may charge an appropriate fee to cover the costs of responding to the request. 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. We may also charge a reasonable fee to cover our administration costs when dealing with any requests, which we will inform you of in advance.

Cookie 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 via 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:

Ai Inamura (In-Charge):

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: ai_i@r.recruit.co.jp

By phone: ＋81-80-3246-306

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.

Jurisdiction-specific annexes

JAPAN

You hereby consent that Recruit may transfer your personal data to third parties outside of Japan (e.g. China, Hong Kong, India, Indonesia, Malaysia, Singapore, Taiwan, Thailand, the Philippines and Vietnam) in the situation described in “How We Share Your Personal Data” section.

You have a right under the Act on Protection of Personal Information (“APPI”) to make a request for (i) getting informed of a utilization purpose of the retained personal data, (ii) disclosing the retained personal data, (iii) correction, addition or deletion of the retained personal data, and (iv) ceasing utilization or the like of and a third-party provision of the retained personal data if you meet the requirements under APPI. You may make such requests by contacting us using the contact details in the “Contact Us” section.

Hong Kong

How We Use Your Personal Data

With your consent, we may send you direct marketing communications by e-mail, postal mail, and/or text message to inform you of any events, industry updates, or market developments, or other information we consider useful to you in relation to the following subjects:

RGF HR Agent Services (described in the paragraph of 【Introduction / Applicability】in the “Global Privacy Policy”) provided by RGF HR Agent Hong Kong Limited
RGF Executive Service (described in the paragraph of 【Introduction / Applicability】in the “Global Privacy Policy”) provided by Bo Le Leaders Limited

Data Subject’s Rights – Hong Kong

You have a right under the Personal Data (Privacy) Ordinance (Cap. 486) to make a data access or correction request concerning your personal data. You may make such requests by contacting us using the contact details in the “Contact Us” section.

We will not charge you any fees to process a request to remove you from our direct marketing lists.

Taiwan

A. The paragraph of Data Transfer outside of Country in the "Global Privacy Policy" shall be amended to read as follows: “

Recruit will ensure that any transfers outside of the 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 or regions outside of your own (e.g. China, Hong Kong, India, Indonesia, Japan, Malaysia, Singapore, Taiwan, Thailand, the Philippines and Vietnam) in the situation described in “How We Share Your Personal Data” section. We will implement safeguards to protect your personal data required under applicable local data protection laws and regulations.”

B. The paragraph of Data Subject’s Rights in the "Global Privacy Policy" shall be amended to read as follows: “

You are under no obligation to provide your personal data. However, not providing personal data that is required for business operation of Recruit may be disadvantageous for you in the administration of your employment. Also, 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, deletion, cease of collection, processing or use, or supplement or correction. To assert your data subjects’ rights, please contact us using the contact details in the “Contact Us” section.

Vietnam

By visiting Recruit’s website, disclosing any personal data to Recruit and/or using RGF Services, you are consenting to (without limitation or qualification) and accept the Recruit’s collection, use, storage, transfer, disclosure, and publication of such data in accordance with this privacy policy. You can withdraw your consent at any time (see “Data Subject’ Rights” section). When you visit Recruit’s website and use RGF services, you agree to grant a separate permission and consent for Recruit to transfer and share your personal data to third parties. By providing your e-mail address for Recruit, you are consenting to receive any commercial information from Recruit to such e-mail address. You may cancel your subscription at any time (see “How We Use Your Personal Data” section and “Direct Marketing Communications” section).
By continuing to use our services after any changes and updates of this privacy policy in accordance with “Policy Changes” section, you express your acceptance of and consent to revised version of the privacy policy.
Notwithstanding rules under “Retaining Personal Data” section, upon the expiration of the data retention period (if any), or when it is no longer necessary to retain your personal data, we will delete your personal data and notify you of such deletion (where practicable).
By disclosing any personal data to Recruit, you represent that none of such personal data is:

a State secret under Vietnamese law of which collection or disclosure is generally prohibited, unless approved by competent State agencies;
family secret of your family which have not been permitted to disclose to us by all members of your family; and
trade secret of another company or entity.

Should you have any claim regarding our use of your personal data, please send your request to the contact details in “Contract Us” section. We will process your request in accordance with rules under “Data Subject’ Rights” section and with Recruit’s internal procedures from time to time.

Malaysia

Obligatory Personal Data

All information requested for is obligatory to be provided by you to us unless stated otherwise. Should you fail to provide the obligatory information, we would be unable to pursue one or more of the purposes set out in the “How We Use Your Personal Data” section for you.

Consent for Data Processing

You agree that your personal data may be collected, used and disclosed by Recruit Co., Ltd. and its subsidiaries or related corporations (including Agensi Pekerjaan RGF Executive Search Malaysia Sdn. Bhd) and their service providers and agents (or any other parties specified in this Global Privacy Policy) for the purposes set out in this Global Privacy Policy. You warrant that where you have disclosed personal data of third parties (e.g. next-of-kin, friends or referees) to Recruit Co., Ltd. and/or its subsidiaries or related corporations (including Agensi Pekerjaan RGF Executive Search Malaysia Sdn. Bhd) in connection with the purposes set out in this Global Privacy Policy, you have obtained the prior consent of such third parties for Recruit Co., Ltd. and its subsidiaries or related corporations (including Agensi Pekerjaan RGF Executive Search Malaysia Sdn. Bhd) and their service providers and agents (or any other parties specified in this Global Privacy Policy) to collect, use and disclose such personal data for such purposes, in accordance with any applicable laws, regulations and/or guidelines.

Data Transfers

You hereby consent that Recruit may transfer your personal data to third parties outside of Malaysia (e.g. China, Hong Kong, India, Indonesia, Japan, Singapore, Taiwan, Thailand, the Philippines and Vietnam) in the situation described in “How We Share Your Personal Data” section.

China

Data Transfer Outside of Country

In addition to those described in the “Data Transfer outside of Country” section of the Privacy Policy, we will conduct security evaluation and file its result to the governmental authority and carry out other procedures if required by applicable laws and regulations when we transfer your personal data to outside of the Country.

Measures to be Adopted When Security Incidents Occurred

In the case of any unfortunate incident in respect of personal data security, we will, in accordance with requirements set out in laws and regulations, inform you promptly of the particulars, including basic information about the security incident and the likely impact, what measures we have taken or will take to respond to this incident, suggestions on what measures you may take yourself to guard against and lower risks, remedial actions we offer to you, etc. We will brief you on the progress of the incident by email, correspondence, or phone or by sending notifications, and we will release announcements for this purpose in a reasonable and effective manner even when it is difficult to notify personal data subjects one by one.

Meanwhile, we will voluntarily report how the personal data security incident is handled, as required by the regulator.

We will not Deal with Children’s Personal Data

Our services are designed mainly for adults, not for children. We will not knowingly collect personal data of children as per age defined by laws and regulations. If we learn that we have collected personal data of a child, we will take steps to delete such information from our files as soon as possible.

Singapore

Consent: You agree that your personal data may be collected, used and disclosed by Recruit Co., Ltd. and its subsidiaries or related corporations (including RGF Talent Solutions Singapore Pte. Ltd.) and their service providers and agents (or any other parties specified in this Global Privacy Policy) for the purposes set out in this Global Privacy Policy. You warrant that where you have disclosed personal data of third parties (e.g. next-of-kin, friends or referees) to Recruit Co., Ltd. And/or its subsidiaries or related corporations (including RGF Talent Solutions Singapore Pte. Ltd.) in connection with the purposes set out in this Global Privacy Policy, you have obtained the prior consent of such third parties for Recruit Co., Ltd. and its subsidiaries or related corporations (including RGF Talent Solutions Singapore Pte. Ltd.) and their service providers and agents (or any other parties specified in this Global Privacy Policy) to collect, use and disclose such personal data for such purposes, in accordance with any applicable laws, regulations and/or guidelines.

Data Protection Officer: If you have any enquiries, comments or suggestions about our collection or use of your personal data or our privacy policy, please contact our Data Protection Officer by email at: Privacyofficer@rgf-hragent.asia

Person responsible for management of the personal information

CEO, RGF International Recruitment Holdings Limited. For any inquiries concerning personal information please contact HERE .

1st November, 2019 Revised