We appreciate your interest in working for the Agoda group of companies. We take the protection of your Personal Data (defined below) seriously and we want to make sure that you understand what kind of information we will be collecting from you via our careers platform at careersatagoda.com (“Careers Platform”) and/or through other means during your application process (the “Sources”) and how it will be used. Agoda Company Pte. Ltd., a company registered in Singapore, having its registered address at 30 Cecil Street, Prudential Tower #19-08, Singapore 049712, is the data controller for any Personal Data obtained through the Sources during your job application process. Below is a summary of our privacy practices. Our full Applicant Privacy Statement is available below, or you can click the links on any of the points detailed in the summary table for further details.
|1. Application of this Statement||This Statement applies to any entity within the Agoda group of companies which may process your Personal Data.|
|2. Types of Personal Data processed||We process information which you have provided to us, or which we may have received from a third party, such as recruitment firms or employee referrals.|
|3. Purposes and basis for processing||We will process your information only for those purposes which are known to you or which would typically be within your expectations.|
|4. Disclosures of your Personal Data||We may share your information with our affiliates, service providers, government authorities, courts, external advisors, and similar third parties.|
|5. International transfers of Personal Data||We maintain appropriate protection for cross-border transfers as required by law for international data transfers.|
|6. Security||We maintain reasonable security measures to protect your information.|
|7. Updating or accessing your Personal Data||You may exercise certain rights of access, correction, deletion, portability or restrict or object to certain processing of your information.|
|8. Retention period||We store your information strictly for the time necessary to achieve the purposes for which it is collected.|
|9. Questions or complaints||Please contact us with any questions or complaints about this Privacy Statement or our privacy practices as detailed below.|
|10. Changes to the Statement||We will notify you of any material changes by posting the updated version of this Privacy Statement and taking other steps as needed.|
1. Application of this Statement
This Agoda Applicant Privacy Statement (the “Statement”) applies to Personal Data which Agoda Company Pte. Ltd., Agoda Services Co., Ltd, your hiring entity as well as all related entities (“Agoda”, “we” or “us”) process about you in any form during your job application process.
2. The types of Personal Data we process
The term “Personal Data” refers to information which identifies or is capable of identifying you as an individual. To the extent permitted by applicable laws, we process the following types of Personal Data in relation to your job application with Agoda:
- General Personal information: name and contact information (email address, mailing address and phone number), residency, and other personal information volunteered by you in your resume, LinkedIn profile, or website;
- Work and Education Background information: personal curriculum vitae (educational degrees, education, training history, and previous and/or other relevant work experience or other experience), languages, professional memberships, qualifications/certifications, role applied for, salary/wage expectations and other terms relating to compensation and benefits packages;
- Job Application information: references and referee details, application letters, assessment and test results, information from interviews and phone-screenings you may have (if any), details of how you heard about the position you are applying for, willingness to relocate, other job preferences, or other information you provide to us in support of an application and/or the recruitment process; and
- Background information: any information obtained in accordance with applicable law during the application and/or recruitment process such as gender, information about your citizenship and/or nationality and/or right to work or reside in a specific country, reference information and/or information received from background checks (where applicable), including information provided by third parties, information relating to any previous applications you may have made to Agoda and/or any previous employment history with Agoda, travel information (including travel and meal preferences) if traveling is part of the recruitment process, and work permit/visa details (where applicable).
Most of the Personal Data we process is information that you provide to us. We may also receive your Personal Data from a third party, such as recruitment firms, employee referrals and pre-employment screening service providers. The Personal Data you submitted and any additional Personal Data will be used to assess your skills and interest in career opportunities at Agoda and to process your application.
There may be instances in which the Personal Data that you provide to us is considered “Sensitive Data” under applicable data protection law. We collect such categories of data only to the extent permitted by applicable law. Sensitive Data is Personal Data from which we can determine or infer an individual’s racial or ethnic origin, political opinions, religious beliefs, or other beliefs of a similar nature, membership of a trade union, physical or mental health or condition, sexual life, or judicial data (including information concerning the commission or alleged commission of a criminal offense).
3. Purposes and basis for processing Personal Data
3.1 Agoda will process Personal Data, including Sensitive Personal Data, for the following purposes (“Processing Purposes”):
|Processing Purposes||Categories of Personal Data Involved|
|Recruiting process, in particular to review and assess your job application, communications with you about the recruitment process and/or your application(s), to make a hiring decision, and to complete the hiring process in case you should be offered and accept a position at Agoda (including assisting you with obtaining an immigration visa or work permit where required), and as permitted by applicable law for verifying your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job.||General Personal information, Work and Education Background information, Job Application information and Background information.|
|Informing you via email about other job openings within the Agoda group entities or affiliates, newsletters and information regarding upcoming events of which we believe will be of interest to you||General Personal information, Work and Education Background information, Job Application information and Background information.|
|Complying with applicable laws and employment-related requirements along with the administration of those requirements, such as employment and immigration laws.||General Personal information, Work and Education Background information, Job Application information and Background information.|
|Communicating with you, within Agoda, and/or third parties (such as government officials)|
|Responding to and complying with requests, legal demands and processes from regulators or other authorities in or outside of your home country||General Personal information, Work and Education Background information and Background information.|
|Making improvements to Agoda’s application and/or recruiting process including improving diversity in recruitment practices|
3.2 Agoda relies on the following legal grounds for the collection, processing, and use of Personal Data:
|Personal Data||Sensitive Personal Data|
We will process your Personal Data only for those purposes known to you or which would typically be within your expectations and are relevant to Agoda. Your Personal Data will be retained for as long as it is necessary to meet the purposes for which it has been collected and in accordance with applicable law and, where applicable, in accordance with Agoda’s internal retention policy, as further detailed in Section 8 below. We aim to minimize the amount of Personal Data we collect and keep about you and only to collect and keep Personal Data which is adequate, relevant, and not excessive.
We will process your Personal Data for a different or new purpose only if Agoda has a legitimate basis for doing so, consistent with the applicable data protection law of the country in which the Personal Data was collected or where we have contacted you prior to commencing that processing.
Depending on the vacancy, you may be requested to perform online assessments to establish whether you meet certain job requirements (e.g. language tests, availability to work at given times, job preview and competency tests). Your assessment results shall be automatically transferred to Agoda and will be part of your application file. Your assessment results may be used to provide specific training and/or coaching during your employment with Agoda and your assessment results may be shared with managers and/or coaches for this purpose.
If your application is successful, your Personal Data may be used for a pre-employment screening check by a third party as permitted by applicable law. Depending on the vacancy and applicable law, a pre-employment screening may include verification of skill proficiency, criminal history, financial history and other information that may be necessary for determining your qualifications and suitability for the open position at Agoda. You will be notified of the screening process beforehand separately.
4. Disclosures of your Personal Data
Agoda may transfer your Personal Data, including Sensitive Data as necessary, to third parties for the Processing Purposes as below. Any access to your Personal Data is restricted to those individuals who have a need to receive or access Personal Data in order to fulfill their job responsibilities:
- Within the Agoda Affiliated Group: As part of our global structure, certain support services are carried out by our various Agoda group entities worldwide (the “Agoda Group Entities”). Therefore, the relevant Agoda Group Entities may receive your Personal Data as necessary for the Processing Purposes, in particular to administer the workforce, communicate with you and third parties, and respond to and comply with requests and legal demands. In order to provide adequate protection for such Personal Data transfers, the Agoda Group Entities have entered into data transfer agreements based on – and where required by applicable law conforming to – the EU standard contractual clauses. Agoda is part of Bookings Holdings Group. If you apply for a role with relevance to Booking Holdings Group, your application may be shared with Booking Holdings in Norwalk, Connecticut, United States of America and/or its members.
- With third-parties: We share your information with third parties as permitted by applicable law and as described below. We do not sell or rent your Personal Data.
(a) Service Providers (including suppliers): We share your information with third party service providers, for example to provide our recruitment services, store data and/or maintain the Careers Platform on our behalf. These service providers shall process Personal Data only as instructed by and to provide the services to Agoda.
(b) Travel agencies: If you have to travel as part of the recruitment process, we may share your information, such as your name, contact details and passport number, with travel agencies for making travel arrangements.
(c) Screening: we may share your information with third parties to conduct pre-employment screening as permitted by applicable law.
(d) Compelled Disclosure: when legally required, strictly necessary for the performance of the recruitment services, or to protect our rights, or the rights of Booking Holdings Inc. group of companies or users, we disclose your information to governmental authorities including law enforcement (subject to a lawful request), any of the affiliates part of Booking Holdings Inc. or in legal proceedings.
Agoda may also disclose your Personal Data as required or permitted by applicable law to governmental authorities, courts, external advisors, and similar third parties.
4.2 Sharing and Disclosure of Aggregate Data
We may share information in aggregate form and/or in a form which does not enable the recipient of such information to identify you, with third parties, for example for industry analysis and demographic profiling.
5. International transfers of Personal Data
Agoda may transfer Personal Data, in connection with the Processing Purposes identified in Section 3 and disclosures identified in Section 4 above, within the Agoda Group Entities, service providers, suppliers and external advisers in a territory, such as the United States, that may not provide a level of protection to Personal Data equivalent to that provided by your home country. The Agoda Group Entities have implemented appropriate safeguards to secure any such disclosures of Personal Data. Applicants with questions regarding how Agoda Group Entities handle Personal Data should contact the Agoda human resources representative via the contact information set out in Section 9 below.
Agoda observes reasonable procedures to prevent unauthorized access to, and the misuse of, information involving Personal Data. We use appropriate business systems and procedures to protect and safeguard information including Personal Data. We also use security procedures and technical and physical restrictions for accessing and using the Personal Data on our servers. Only authorized personnel are permitted to access Personal Data in the course of their work.
7. Updating or Accessing Your Personal Data
We rely on you to ensure that your Personal Data is complete, accurate and current. Please do inform us promptly of any changes to, or inaccuracies of, your Personal Data.
If you have declared your consent regarding certain types of processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
Pursuant to applicable data protection law you may also have the right to: (i) request access to your Personal Data; (ii) request rectification of your Personal Data; (iii) request erasure of your Personal Data; (iv) request restriction of processing of your Personal Data; (v) request data portability of your Personal Data; and/or (vi) object to the processing of your Personal Data. Please note that these aforementioned rights might be limited under the applicable national data protection law.
(i) Right of access: You may have the right to obtain from us confirmation as to whether or not Personal Data concerning you is processed, and, where that is the case, to request access to such Personal Data. The access information includes—inter alia—the purposes of the processing, the categories of Personal Data concerned, the recipients or categories of recipients to whom the Personal Data have been or will be disclosed, the sources of the Personal Data, the duration of retention, and the technical security measures put in place to safeguard the Personal Data in case of transfer outside the EEA. However, this is not an absolute right and the interests of other individuals may restrict your right of access. You may have the right to obtain a copy of the Personal Data. For additional copies requested by you, we may charge a reasonable fee based on administrative costs.
(ii) Right to rectification: You may have the right to obtain from us the rectification (i.e., correction) of inaccurate Personal Data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
(iii) Right to erasure (right to be forgotten): Under certain circumstances, you may have the right to obtain from us the erasure of Personal Data concerning you. In such cases, we will to erase, or render permanently unintelligible, such Personal Data.
(iv) Right to restriction of processing: Under certain circumstances, you may have the right to obtain from us restriction of processing of your Personal Data. In this case, the respective data will be marked and may only be processed by us for certain purposes. However, where Agoda processes and uses your Personal Data primarily for purposes of assessing your eligibility for employment, Agoda will in principle have a legitimate interest for the processing which will override your restriction request, unless the restriction request relates to marketing activities (which generally do not apply in the recruitment context).
(v) Right to data portability: Under certain circumstances, you may have the right to receive the Personal Data about you that you have provided to us, in a structured, commonly used and machine-readable format so you can transmit this Personal Data to another entity.
(vi) Right to object: Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Data by us. Where such right applies, we will no longer process the relevant Personal Data. This is not an absolute right and does not apply in certain situations, such as when processing is necessary to assess your eligibility for employment, to comply with applicable laws, or to defend legal claims.
Any requests for access or updates to, or corrections or deletions of, Personal Data should be sent to Agoda in the manner specified in Section 9 below.
8. Retention Period
Your Personal Data is stored by Agoda and/or our service providers, strictly to the extent necessary for the performance of our obligations and strictly for the time necessary to achieve the purposes for which the Personal Data is collected, in accordance with applicable data protection laws. For Personal Data that we collect and process for other purposes, we typically retain such Personal Data for no longer than the period necessary to fulfill the purposes outlined in this document and as otherwise needed to address tax, corporate, employment, compliance, litigation, and other legal right and obligations.
When we employ you: If Agoda employs you, Agoda Company Pte. Ltd. shall share your relevant Personal Data with the employing Agoda entity. Your Personal Data collected during the application and recruitment process will become part of your personnel file. All Personal Data we retain as part of your personnel file will be subject to our internal retention policy for employees.
When we do not employ you: If Agoda does not employ you, Agoda Company Pte. Ltd. may nevertheless continue to retain and use your Personal Data in order to consider you for new positions. Agoda may refer back to an earlier application that you have made, if you should submit a new application in the future. In this respect, Agoda Company Pte. Ltd, may retain your Personal Data for a period of 2 years following termination of the initial job application process, unless otherwise required by applicable law. As part of the communications about other potential career opportunities at Agoda, we will include an unsubscribe link that you can use if you do not want us to send similar messages in the future. In the alternative, you may contact [email protected] if you do not wish to be contacted anymore by Agoda for new job vacancies.
9. Questions or Complaints
Agoda will be receptive to any queries or requests made in connection with our processing of your Personal Data. All queries or request shall be directed to the People Technology team at [email protected].
All questions and complaints reported to Agoda will be investigated. Agoda will attempt to resolve complaints and questions in line with internal policies and in compliance with applicable laws. If you believe that your query or request has not been dealt with appropriately, it can be escalated to the Agoda Data Governance Officer at [email protected] You also have the right to lodge a complaint with the competent data protection supervisory authority.
10. Changes to the Statement
Just as our business changes constantly, this Statement may also change. To assist you, this Statement is dated at the end of this document, and we will obtain your consent for any material changes to the extent required by applicable law.
Effective Date: May 25, 2018