Super Resume Company Limited (the “Company”), as a data controller of the personal data of the user, (the “User“) on the Company’s platforms, www.superresume.com, www.jobtopgun.com and www.saywana.com (collective referred to as the “Platforms”), has announced this Privacy Notice (“Notice”) with the objective to define the conditions in relation to the collection, storage, usage and disclosure of the User’s personal data by the Company for the performance of the Platforms. The Company may review and update this Notice from time to time as appropriate to ensure that the Notice shall comply with relevant laws or the change in services provided, provided that the Company will notify the amendment of this Notice via the Platform and such amended Notice shall be effective from the date the announcement is made on the Platform.

Acceptance of the Notice. Upon the visit, contact and/or the registration of the User’s account, the Company shall deem that the User acknowledges and agrees to comply with this Notice (including all of the amendments hereof). If the User does not permit the Company to process the personal data in accordance with this Notice, the Company reserves the right to refuse to provide the services to User since the processing of the personal data as defined under this Notice is a necessity to the Platform function.

Scope of Application. This Notice shall only be applicable to the process of the personal data directly undertaken by the Company. In case the User connect to the third-party website that may connect or link to the Platform, the User acknowledge and agree that the process of personal data by such third-party is beyond the Company’s control and the Company shall not bear any responsibility in the process of those personal data by the third party and it is recommended that the User study the relevant privacy notice announced by those third party.

Personal Data being Processed. In providing the Platforms services, the Company will need to collect personal data of the User on each Platform as follows. The Company may obtain the User’s personal data that is necessary for the operation of the Platform from 2 sources, including: (1) directly obtained from the User upon the registration for the User’s account or from the use of the Platform; or (2) indirectly obtained from other sources or referrer that the Company will notify the User of those indirect sources.

1.	Any personal data that the User has provided in the Super Resume questionnaire i.e., name, address, contact number, email, nationality, height, weight, date of birth, photo, educational background, working experience and any other transactional information or data of those Users on the Super Resume Platform;
2.	Any personal data of the individual user who register for the user account as the job seeker on JobTopGun platform, including the information required for the account registration, the working experiences, including resume, that the User disclose and share directly on JobTopGun Platform or link the information from SuperResume;
3.	Any personal data of any individual within the corporate user of JobTopGun registered as the Job Hunter includes name, contact number or email address of the representative and any other information collected from the registration and use of the platform by such representative;
4.	Any personal data that the User of Saywana Platform may additionally provide during the process of creating profiles or sharing stories which includes pictures, information, interests, overview of the working experience and educational background that will be uploaded through the Saywana Platform;
5.	Online Identifiers that will be collected while the User is using the services on the Platforms i.e., IP Address, username and password, and the use of cookies for tracking the User's use of the service;
6.	Platform usage information, including without limitation the login to the user account, the execution of any transaction or undertaking of any activities;
7.	Any other personal data that the User may give to the Company during the communication, event participation or other coordination, including without limitation feedback, interest, complaints or other information provided in the event, either online or offline, participation and the personal data that the User give consent to the Company to process.

Personal Data Processing by the Company

1.	Personal Data Processing for the Performance of SuperResume Platform shall include (1) the use of the personal data obtained to compose the Super Resume based on the information given that the Company shall store such data within the Company; (2) the disclosure of the Super Resume to any use on JobTobGun platform in case the User gives explicit consent for the Company to do so on the case-by-case basis; (3) the use of the personal data to contact the User (Job Seeker) when a Job Hunter is interested in requesting for the User’s information through the JobTopGun Platform or when the Company considers that there is any job advertisement that matches with the User’s interests as indicated in the questionnaire on the Super Resume Platform;
2.	Personal Data Processing for the Performance of JobTopGun Platform that is the platform to connect and contact between the Job Seeker and the Job Hunter shall include the share and exchange of the personal data between the Users for the purpose of recruitment and hiring, in particular the Company would need to share the personal data of the Job Seekers to the Job Hunter for the purpose of qualification check and coordinate further for the interview or employment and in some circumstances, the Company would need to use the User’s personal data to contact and coordinate in Services delivery;
3.	Personal Data Processing for the Performance of Saywana Platform that is intended to be the communication and sharing platform between the User network for the self-improvement between the Job Seekers shall include the case that the Company would need to compile and disclose the personal data that the User gives on the Platform to other users for the purposes of (1) grouping the User that shares the same interest and background; (2) disclosing the personal data of the User to other users on the same Platform based on the privacy setting that each User set that may also include the disclosure of the personal data to the public if the User agrees to do so; (3) notifying the User of any activities that will be hosted that match the interest of the relevant User; provided that the User may select not to be notified and the Company will respect that. Since the key objective of Saywana Platform is to share the experiences and interests among the relevant users, there would be the case that other user may get access to the User’s personal data from the Platform and such user may use such personal data to contact with you further. For those further communication, even though the Company intend to prohibit the use of personal data for other purposes outside of the scope defined for the Platform performance, the Company would not be able to control all uses by all the users. In case any user misuse other user’s personal data, the Company does not involve in such action and shall not be held liable. The disputing users shall resolve the issues among themselves.
4.	Personal Data Processing for the Service and Platform Improvement, especially through the online channel, the Company needs to collect and use the User’s online identifier to analyze the User behavior with the purpose to improve the service to respond to the User’s needs; provided that the Company represent not to cause excessive impact on your rights as the data subject and for the use of cookies, the Company will only use cookies with the consent given;
5.	Personal Data Processing for Other Purposes, in addition to the personal data processing for the key performance of each Platform, shall include the process of the personal data for the following purposes: (a) to build a good relationship between the Company and the User in responding to questions, giving information, managing complaints, feedback or any comments; and (b) to protect the legitimate right of the Company in the case of disputes or complaints of the legitimate right between the Company and the User, between the Users, or the User and any other persons that may file complaint to the Company.

For all the purposes defined above, the Company would need to retain the personal data for throughout the service term of each Platform, in particular throughout the time that the User still have the user account with the Company and for the legitimate purposes of service and relationship improvement as well as protecting the legitimate rights, the Company reserve the right to retain the User’s personal data for the period of time that is deems necessary for the Company’s business operation and throughout the time that may be necessary to protect their legitimate rights; provided that the Company represent not to cause any excessive impact on the data subject.

Disclosure of Personal Data The Company shall use the best effort to limit the disclosure of the User’s personal data to third party as necessary and avoid directly revealing the identity of the User. However, in some cases the Company may have the necessities to disclose and transfer the User’s personal data in the following case: (1) disclosure of the User’s personal data to other users within the scope of services defined for each Platform, in particular for the function of JobTopGun and Saywana Platform; (2) to perform and operate efficiently in providing services on the Platform, the Company may need to disclose the personal data to their consultant, auditor or processor; provided that the Company will enter into the data processing agreement with those who receives the data and will disclose the personal data on a need-to- know basis only; and (3) in case the Company have the obligations under the law, judgement, or under the order of government, the Company may have the necessity to disclose the personal data to the relevant government authority on the necessary basis.

Security Measure of the Personal Data. The Company give priority to the security and safety of the User’s personal data that are processed by the Company; provided that the Company undertake to operate the following procedures, and comply with the industrial standard, and related law. In case of violation of personal data arises in any case, the Company shall operate every procedure to solve such a problem and if the data breach is likely to result in a high risk to your rights and liberty of you as a Data Subject, the Company will notify you of the data breach and the remedial measures without delay.

Data Subject right. The Company acknowledges and respects the User’s right under the law relating to personal data that are under the Company’s control based on the provision in the applicable laws as follows: the right to request for access to personal data that are in the Company’s possession and request for the copy, in a readable or commonly used by way of automatic tools or equipment including the right to request to send or transfer the personal data in such formats to other data controllers, the right to object the processing of personal data, the right to request the Company to erase or destroy the personal data, or anonymize the personal data to become anonymous once the personal data is no longer necessary or when the data subject withdraws consent, the right to request for suspension to use personal data in case the personal data must be erase, destroy or is no longer necessary or the right to withdraw consent to the processing of personal data under intended objective.

You can contact to the Company’s officer to submit a request for action under the above rights and the Company will consider and notify the result of the consideration according to your request within the period under the relevant laws.

Company’s Contact Information