Job Applicant Privacy Policy
1. PURPOSE
This Job Applicant Privacy Notice (“Notice”) describes what personal data Heaven Media Ltd. And its local affiliates relevant
to the job in question (“Heaven Media”, “we”, “our” or “us”) collect and process on our job candidates and applicants
(“candidate(s)” or “you”) with respect to your application and recruitment process, why we collect it and how we use it. It
also describes how candidates may exercise their rights to such data held with us.
We strongly urge you to read this Notice and make sure that you fully understand and agree to it. If you do not agree to
this Notice, please avoid providing us with your data.
You are not legally required to provide us with any personal data, but without it, we may not be able to process your
application.
2. WHAT DATA DO WE COLLECT, HOW DO WE COLLECT IT, AND HOW DO WE USE IT?
Throughout the application and recruitment process, you may provide us (or we may otherwise have access to) personal data
about you, such as your identifying data, contact details, resume/CV, work-related data, education and qualifications, salary
expectations, social media activity, etc. We may collect this data directly from you, as you provide it voluntarily through your
application and candidacy review process, or from other sources such as recruitment agencies, background check services
(where relevant and subject to applicable law), or your references.
We may use such data to evaluate your skills and qualifications, as well as to review, assess and process you application for
any of our suitable positions. This also includes communicating with you about these processes. Additionally, your data will
be used to manage risk, enhance our security and anti-fraud measures, and create aggregated or inferred statistical data
about our candidates to continually improve and develop our recruitment strategies.
In addition, we may use your personal data to act as permitted or required by any legal or regulatory requirements. Should
we wish to conduct any additional activities that may require the use of your data, we will notify you in advance and, if
required by applicable law, request your prior specific consent.
In some regions, we may also require you to submit sensitive data relating to your ethnicity, gender, and whether you have a
disability, to ensure our compliance with our obligations under applicable law. We may also collect sensitive data about your
prior criminal convictions and offences as part of our background checks for specific roles, if permitted or required by law. To
the extent legally required, we will obtain your explicit consent prior to any such collection and use.
3. FOR WHAT PURPOSES DO WE USE YOUR DATA?
We will use and process your personal data as part of the employment application process at Heaven Media for the following
purposes and in reliance on the lawful bases detailed below:
| Purpose | Lawful Basis for Processing |
|---|---|
| To evaluate your suitability for a role at Heaven Media, and progress your application | Pre-Contractual Measures |
| To contact you about other suitable roles within Heaven Media in the future | Legitimate Interests Consent (where applicable) |
| To maintain our internal records of recruitment and employment applications | Legal Obligations Legitimate Interests |
| To create your employee personnel file, if hired | |
| To comply with applicable legislation and industry codes | |
| To manage risk and enhance our security and anti-fraud measures | Legitimate Interests |
| To further develop and improve our recruitment processes | |
| To protect the rights and interests of Heaven Media and its affiliates |
If you reside in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the
processing of personal data as described herein, then your application will be deemed as your consent to the processing of
your personal data for all purposes detailed in this Notice. If you wish to revoke such consent, you may do so at any time by
contacting [email protected]. However, please note that revoking your consent will not affect the lawfulness of our
use of your personal data up to that point, and we will be required to delete it only if no other legal basis exists to justify its
continued processing at the time of withdrawal.
4. WHERE DO WE STORE YOUR DATA?
Your personal data will be maintained, processed and stored by Heaven Media and our Service Providers (as defined in
Section 6 below) in the applied position’s location(s), in the relevant Heaven Media offices worldwide (including in the
European Union (EU), United Kingdom (UK), and United States (US)), and other jurisdictions as necessary for the proper
handling of your candidacy.
While privacy laws may vary between jurisdictions, Heaven Media, its affiliates and Service Providers processing personal
data on our behalf are each committed to protecting personal data in accordance with this Notice, customary industry
standards, and such protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such
data is transferred.
To the extent we transfer candidates’ personal data originating in the European Economic Area (EEA), or the UK to countries
that have not been recognised as offering an adequate level of data protection based on the adequacy decisions published by
the European Commission (and associated) or the UK, as relevant, we rely on appropriate contractual undertakings and data
transfer mechanisms as established under applicable law, such as the standard contractual clauses adopted by the EU and
the UK (available here). You can obtain a copy by contacting us as indicated in Section 11 below. For data transfers to
countries that been recognised to be providing an adequate level of data protection, we rely on such adequacy findings
regarding the level of data protection offered by the recipient country.
5. FOR HOW LONG MAY WE KEEP YOUR DATA?
We may retain candidates’ data even after the applied position has been filled or closed. This is done so we may reconsider
candidates for other positions and opportunities at Heaven Media; so that we may use their personal data as reference for
future applications submitted by them; in case the candidate is hired, for additional employment and business purposes
related to their work; and as reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud
and abuse, enforce our agreements or otherwise protect our legitimate interests.
6. HOW DO WE SECURE YOUR DATA?
Heaven Media has implemented physical, procedural and electronic security measures designed to protect the personal data
of our candidates, including encryption as appropriate. These measures provide sound industry standard security. However,
please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and
security of any personal data stored with us.
7. WHO WILL HAVE ACCESS TO YOUR DATA?
Heaven Media will disclose your personal data to several selected third-party service providers, whose services and solutions
complete, facilitate and enhance our own. These include any recruitment firms that have referred you to us (or vice versa),
candidate evaluation centres, applicant tracking and recruitment software providers, background checks providers (where
permitted by applicable law), data storage and cybersecurity services, web analytics, and out business, legal, compliance and
financial advisors (collectively, “Service Providers”).
Such Service Providers may receive or otherwise have limited access to our candidates’ personal data, depending on each of their particular roles and purposes in facilitating and enhancing our recruitment process, and may only use it for such purposes.
Additionally, we may disclose or otherwise allow competent public authorities access to any candidate’s personal data
pursuant to a binding legal request, such as subpoena search warrant or court order, or in compliance with applicable laws,
with our without notice to you, if we have good faith belief that (a) we are legally compelled to do so; (b) such disclosure is
appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity,
fraud or other wrongdoing; or (c) such disclosure will help protect the rights, personal safety or property of Heaven Media, any
of our employees, or any member of the general public.
In addition, we may disclose your personal data internally, for the purposes described above. Finally, should Heaven Media
undergo any change in control, including by means of merger, acquisition or purchase of all parts of its assets, your personal
data may be disclosed to the parties involved in such event.
8. WHICH COOKIES AND TRACKING TECHNOLOGIES DO WE USE?
Heaven Media uses certain monitoring and tracking technologies, such as “cookies” and other downloaded data files,
including ones offered by our Service Providers. These technologies are used to maintain, provide and improve our processes
and operations on an ongoing basis, and in order to provide a better experience to our website visitors, including our
candidates. For example, these technologies enable us to better secure our website and services and detect abnormal
behaviours, to identify technical issues, and to monitor and improve the overall performance of our services and processes.
To learn more about our cookie practices, please visit our Cookie Policy.
9. HOW CAN YOU EXERCISE YOUR RIGHTS?
If you wish to exercise your privacy rights under any applicable law (including the EU or UK General Data Protection
Regulation (GDPR), or other US state privacy laws), you may do so by contracting us at [email protected] and we will
respond within a reasonable timeframe and in accordance with applicable law.
Such rights may include – each to the extent available to you under the laws that apply to you – the right to know or request
access to specific pieces of personal data collected, categories of data collected, and sources from whom it was collected, as
well as the purpose of collecting it and categories of third parties to whom we have disclosed it; the right to request
rectification or erasure of your personal data held with us; the right to port it or to restrict its processing; the right to to object
at any time to any processing of your data which is based on our legitimate interests, or to withdraw at any time your consent
to any processing of your data on the basis of such consent, (each as detailed in Section 2 above); or the right to equal
services and process (e.g., freedom from discrimination). If you are a GDPR-protected individual, you also have thr right to
lodge a complaint with the relevant supervisory authority in the EEA or UK, as applicable.
You may designate an authorised agent, in writing or through a power of attorney to request to exercise your privacy rights on
you behalf. The authorised agent may submit a request to exercise these rights by emailing us. In such cases, we may request
further information to verify such power of attorney and authorisation.
Please note that we may require additional information, including certain personal data, in order to authenticate and process
your request. Such additional information, along with any communications and records related to your request, may then be
retained by us for legal purposes (e.g, as proof of the identity of the person submitting the request), in accordance with
Section 4 above.
10. WHO IS RESPONSIBLE FOR YOUR DATA?
Certain data protection laws and regulations, such as the EU and UK GDPR, the CCPA and other US state privacy laws,
typically distinguish between two main roles for parties processing personal data: the “Data Controller” (or under CCPA,
“business”), who determines the purpose and means of processing; and the “Data Processor” (or under CCPA, “service
provider”), who processes the data on behalf of the Data Controller.
Heaven Media’s local affiliates relevant to the role of which you apply is typically the Data Controller of your personal data,
and with respect to which, assumes the responsibility of a Data Controller – solely to the extent applicable under the law and
as set forth in this Notice. In such instances, our Service Providers processing such data will assume the role of Data
Processors.
11. WILL THIS NOTICE BE UPDATED?
We may update this Notice to reflect changes in our privacy practices. If we make any changes that we deem as “material”,
and affect how your personal data may be processed, we will provide you with notice via the communication means available
to us prior to the change becoming effective.
12. WHAT IF YOU HAVE ANY QUESTIONS?
If you have any comments or questions regarding our data practices or your privacy, or if you have any concerns regarding
your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by
Heaven Media, you can contact [email protected].
