Neufast
Privacy Policy
Neufast Limited ('Company') is committed to respect and protect the personal data of our users and is committed to comply with the data protection principles and all relevant provisions of the Personal Data (Privacy) Ordinance ('Ordinance') issued by the Privacy Commissioner for Personal Data (PCPD). Data is collected by The Company’s website service Neufast.com ('the Site'). The Company’s PPS is a general statement about the privacy policies and practices in relation to the personal data it handles.
1. Statement of Practices
The following personal data is collected.
Personnel records which include the name, email, phone number and resume of the users.
Assessment records which include performance of the users, including videos and answers in texts, audios and video format.
Operational parameters including IP address, device type, browsers, OS, country, operation records and logs.
In the course of using the Site, users may disclose or be asked to provide personal information and/or data. In order to have the benefit of and enjoy various services offered by the Site, it may be necessary for Users to provide the Company with their personal information and/or data. Although Users are not obliged to provide the information and/or data as requested on the Site, the Company will not be able to render certain services on the Site in the event that Users fail to do so.
Users hereby agree that any Information supplied by users to the Company is on a voluntary basis, and is accurate, true, current and complete. If this is not the case or the Company has reasonable grounds to suspect as such, the Company has the right to cancel and/or refuse the Service to the user.
2. Purpose of Collection
The Company’s purposes for collecting and using the information and data on the Site include but are not limited to the following
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for the daily operation of the services provided to users;
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to assist Employers to assess the suitability of candidates for job vacancy for a wide spectrum of jobs and industries;
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to help users to enhance their interview skills;
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to handle and follow up on enquiries, requests and complaints from Users;
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to contact users regarding administrative notices and communications relevant to his/her use of the Site and to respond to users’ inquiry or request;
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to assist the Company with developments for future marketing and promoting purposes or other internal purposes;
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to facilitate the Company and/or Affiliates to use the Users’ personal data for the purposes relating to the provision of services offered by the Company;
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to obtain statistics about Users to analyze usage of the Site in order to help its further development for internal use; and
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to help improve the Service provided by the site for the stated related purpose.
If a User is under the age of 18, the Company would strongly recommend him/her to seek prior consent from a person with parental responsibility for him/her, e.g. parent or guardian, who may contact the responsible Customer Support Executive whose contact details are set out under the section headed “Enquiries” for registering the User as member of the Site.
The Company strives to only collect personal data which are necessary and adequate but not excessive in relation to the purposes set out hereinabove.
If the Company requires the use of your personal data for a purpose other than those set out hereinabove, we will request your prescribed consent to the same. If you are a minor, the prescribed consent should be given by your parent or guardian.
3. Data Protection Principles
All processing of personal data shall be conducted according to the data protection principles as follows:
Personal data must be processed lawfully, fairly and transparently.
Personal data can only be collected for specific, explicit and legitimate purposes.
Personal data must be relevant and limited to what is necessary for processing.
Personal data must be accurate and kept up to date with every effort to erase or correct.
Personal data must be kept in a form such that the data subject can only be identified if it is necessary for processing.
Personal data must be processed in a manner that ensures the appropriate security.
4. Data Inventory
We have also kept a data inventory and data flow process to determine various aspects of our data processing including:
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Business processes that use personal data.
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Purposes for collecting and/or using the personal data.
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Source of personal data.
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Processing activities.
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Any data transfer, and to whom.
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Any data access, correction or opt-out request. Such data inventory would facilitate
Neufast Limited in tracking its data and the related processing activities, and put us in a better position to comply with the relevant privacy and other laws and regulations.
5. Security
We have also kept a data inventory and data flow process to determine various aspects of our data processing including:
The security of Users’ personal information and data is important to Neufast Limited. We will always strive to ensure that Users’ personal information and data will be protected against unauthorized access. We have implemented appropriate electronic and managerial measures in order to safeguard, protect and secure Users’ personal information and data.
All personal information and data provided by Users are only accessible by the authorized personnel of the Company or its authorized third parties, and such personnel shall be instructed to observe the terms of this Privacy Statement when accessing such personal information and data. Users may rest assured that their personal information and data will only be kept for as long as is necessary to fulfill the purpose for which it is collected. Registered User should safeguard his/her unique Username and Password by keeping it secret and confidential and never share these details with anyone.
The Company follows generally accepted industry standards to protect the personal information and data submitted by Users to the Site, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to protect Users’ personal information and data against unauthorized access, the company cannot guarantee its absolute security.
6. Legal Basis of Data Processing
We ensure that there is legal basis for our processing of personal data.
Such legal basis includes: (i) legitimate business interests of Neufast Limited in processing personal data; (ii) if required by applicable laws or regulations, seeking your specific consent to process such personal data; and/or (iii) any other relevant basis under applicable laws and regulations.
Legitimate Interests
Neufast Limited processes personal data under the “legitimate interests” legal basis which means that the processing of the personal data is necessary for the legitimate interest pursued by Neufast Limited except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which requires the protection of personal data
Legitimate Interests Assessment
In each relevant situation, we assess: (i) what these legitimate interests are; (ii) whether it is necessary to process such data to attain the objective; and (iii) the relevant rights of the data subjects; and balance such rights against our interests in achieving such objective, and ensure that such rights do not override Neufast Limited’s legitimate interests before we conclude that Neufast Limited can process the personal data on the basis of legitimate interests.
Communicate with the Data subjects
All data subjects will be informed that we are collecting their personal data, the Categories of Personal Data concerned and the purpose of processing. This is to ensure that the data subjects are clear about our collection and processing of personal data and such collection and processing are within the data subjects’ reasonable expectations. Please be informed that all data subjects can object to our collection and processing of their personal data at any time, in addition to their rights of requesting for accessing and/or correcting their personal data in our possession.
Data Security Mechanisms
We have also implemented appropriate mechanisms, policies and procedures to protect the confidentiality and security of the personal data that we collect and process, as we respect the privacy and related rights of the data subjects relating to such personal data by reducing the risks or potential negative impact of processing including but not limited to data minimisation, de-identification, encryption, restricted access and all other technical security methods and efforts to protect personal data. Such protection of the privacy and related rights of the data subjects would enable Neufast Limited in processing personal data under the legitimate interest legal basis.
Having conducted the above assessment thoroughly, Neufast Limited concludes that it is collecting and processing personal data under legitimate interest as follows:
a. Serving Customer and Operational Needs The main purposes for processing the Categories of Personal Data have been set out above.
There are legitimate interests for Neufast Limited to process the same because all such purposes are essential to Neufast Limited serving its customers and its operational needs as a corporation and technology organisation.
A corporation like Neufast Limited needs employees to work for its business (and hence Personnel Records) and service providers to keep it running (and therefore Other Operational Records).
A technology organization like Neufast needs to develop technology that further enhance the technology required to enhance service to serve the clients in the HR and Education Domain.
b. Inform the Public
As a recruitment organisation – Neufast Limited respects the public’s right to know about what is happening in our community and the world. Neufast Limited has a duty both under law and journalistic ethics to inform the public of such happenings (“duty to inform”).
These recommendations do not prohibit or restrict anyone from viewing all of the other articles or content on such websites which they can access at any time as available.
Consent
Where applicable legal requirement demands specific consent must be obtained before we can process personal data including conducting direct marketing, we will ensure that such specific consent will be obtained as follows:
(A) the consent has to be clear, explicit and specific;
(B) data subject is fully aware of the types of the personal data that we intend to use; and the purposes of such usage (such as improving our services to the data subject or direct marketing); and
(C) the name/identity of the transferee (if we ever intend to transfer your data) and how the transferee shall use your personal data.
7. Rights of the Data subjects
Neufast Limited respects that data subjects have the following rights about the data processing, and the data which is recorded about them:
(1) To request for access regarding the nature of information held and to whom it has been disclosed.
(2) To prevent processing likely to cause damage or distress.
(3) To prevent processing for purposes of direct marketing.
(4) To be informed about the mechanics of automated decision-making process (if any) which will significantly affect them.
(5) Not to have significant decisions that will affect them taken solely by automated process.
(6) To take action to rectify, block and erase including the right to be forgotten or destroy inaccurate data.
(7) To request the supervisory authority (eg. a privacy commissioner or a data protection officer) to assess whether any provision of the relevant privacy and other laws has been violated.
(8) To have personal data provided to them in a structured, commonly used and machine-readable format, and the right to have such data transmitted to another data controller.
(9) To object to any automated profiling which is occurring.
8. Transfer of Personal Data
We will keep confidential the personal data that we hold, which may be transferred to the following parties for the purposes as stated above.
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Cloud service providers, contractors or third parties which/who provide administrative, technology or other services to Neufast Limited for its operations;
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to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
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in connection with any proposed purchase, reorganisation, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
Any affiliates of Neufast Limited.
In the event of such transfer, Neufast Limited shall use contractual or other means to ensure that the data transferees shall keep the transferred personal data confidential and comply with all relevant personal data privacy laws and regulations.
As stated above, if you are a Candidate, Employee or Trainee and we are collecting your personal information through the Services, we will be collecting it on behalf of our customers, in accordance with the agreements that we have with them. For further information about how your personal information is shared with third parties, you should contact the relevant Potential Employer or refer to that Potential Employer’s Privacy Policy/Privacy Notice.
Regarding the situation as described under sub-clause (iv) above – If such intra-group transfer among Neufast Limited affiliates involves cross-border data transfer, Neufast Limited may adopt binding corporate rules for safeguarding the security of such personal data; and ensuring that all affiliates involved shall comply with the relevant privacy and other laws.
9. Retention of Personal Data
Once Neufast Limited has obtained a User’s personal information and/or data, it will be maintained securely in the Company’s system for the period necessary to fulfill the purposes for which the data was collected as set out under the section headed “Statement of Practices”. Once registered, users can get their personal information removed from the site or terminate his/her membership of the Site by contacting the Data Controller, i.e. the Employer/Trainer that the user is using our site for. The Company may retain User’s personal information even after User has closed his/her account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between Users, prevent fraud and abuse, or enforce this Privacy Statement and the Terms and Conditions.
10. Changes in this Privacy Statement
The Company reserves the right to update, revise, modify or amend this Privacy Statement at any time as the Company deems necessary, so Users are strongly recommended to review this Privacy Statement frequently. If the Company decides to update, revise, modify or amend this Privacy Statement, the Company will post those changes to the Site and/or other places The Company deems appropriate so that Users would be aware of what information The Company collects, how we use it, and under what circumstances, if any, the Company discloses it.
If the Company makes material changes to this Privacy Statement, we will notify Users on this webpage, by email, or by means of a notice on the home page of the Site. Such changes to this Privacy Statement shall apply from the time that the Company posts the same on the site. Users’ continued use of the Site and services on the Site shall constitute acceptance of the changes to this Privacy Statement.
11. Use of Cookies
Cookies are items of information that a web site transfers to an individual's hard drive for record-keeping purposes while at the site. Cookies make Web-surfing easier by, among other things, saving your passwords, purchases, and preferences for you. The use of cookies is an industry standard, and you'll find cookies at most major web sites.
The cookie itself does not contain any personally identifying information although it may enable the Company to relate a user's use of the Service to personally identifying information that has previously been submitted by the user, if any.
Most browsers are initially set to accept cookies. If you do not want the above information to be disclosed, you should set yours to refuse cookies. However, it is likely that most areas of the site will not function properly if you do so.
12. Outsourcing Arrangements
The Company has been using its in-house resources to develop and maintain its IT systems. When the Company engages a third-party vendor to provide certain services relating its IT systems, the vendor does not have access to the personal data stored in the IT systems under usual circumstances.
In the exceptional case where such vendor has such access, The Company uses reasonable measures to ensure that: (i) such vendor is contractually bound to keep such personal data confidential and adopt appropriate means to prevent any unauthorised access, use, loss, retention, modification, transfer or otherwise.
13. Enquires, Withdraw Consent, Data Access Request and Data Correction
Any individual has the right to withdraw consent for us to process their data, make enquiries, request access to and correction of his or her personal data held by us. Please contact the employer or trainer to access and correct the data.
If you wish to make enquires, access or correct your persona data held by us, please send your request to:
Data Privacy Officer
Dr. Dennis Lee
Address: Unit 2, 3/F, Building 2W, No.2 Science Park Avenue West, Shatin, N.T., Hong Kong
Tel: (+852)59876904
Email: customer-service@neufast.com
14. International Data Transfer
The user’s personal information may be transferred to, and processed in, countries other than the country in which the user is resident. These countries may have data protection laws that are different to the laws of the user’s country. Specifically, unless otherwise required by local law, our website, system and third-party service provided are processed in the EEA, Singapore and Hong Kong SAR.
However, we have taken appropriate safeguards to require that user’s personal information will remain protected in accordance with this Privacy Notice and applicable laws. If the user is from the EEA or the UK, these include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, and with our third-party service providers and partners. The Standard Contractual Clauses require non-EEA companies to protect EEA and UK personal information they process in accordance with European Economic Area data protection law.
15. Removal of Personal Data
The employer or trainer acts as the data controller who have the control of the personal data on the system. The personal data such as name, email, phone numbers, resume, images, original videos, audios can be removed on the platform by the employer or the trainer. If you are the users that have provided your data, please contact the company that you use our platform for to have your personal information removed. Also, the personal information of the user will be deleted from our system three months after your user account has been closed. Non-personal information such as job information, interview questions, redacted videos, scores and answers will be aggregated and stored in our system for the purpose of improving the assessment and service quality only. Redacted Videos and other information can also be removed subject to our agreement when we are notified by the employer/trainer by emailing to customer-service@neufast.com
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