Website Privacy Policy

SafeGuard World International Ltd. (“SGWI”), is committed to protecting the online privacy of the users of this website (“Website”). As such, this Privacy Policy has been written in order to allow you to understand SGWI’s policy regarding your privacy, as well as how your personal information will be handled when using the Website. This Privacy Policy will also provide you with information so that you are able to consent to the processing of your personal data in an explicit and informed manner, where appropriate.

In general, any information and data which you provide to SGWI over the Website, or which is otherwise gathered via the Website by SGWI, in the context of the use of SGWI’s services (“Services”), will be processed by SGWI in a lawful, fair and transparent manner. To this end, and as further described below, SGWI takes into consideration internationally recognised principles governing the processing of personal data, such as purpose limitation, storage limitation, data minimisation, data quality and confidentiality.

CONTENTS

1. Data controller and Data Protection Officer
2. Personal Data processes

a. Name, contact details and other Personal Data
b. Job applications
c. Other persons’ Personal Data
d. Browsing data
e. Cookies

3. Purposes of processing
4. Grounds for processing and mandatory or discretionary nature of processing
5. Recipients of Personal Data
6. Transfer of Personal Data
7. Retention of Personal Data
8. Data subjects’ rights
9. Amendments

1. Data controller and Data Protection Officer

SGWI, as identified at the top of this Privacy Policy, is the data controller regarding all personal data processing carried out through the Website.

To get in touch with SGWI’s Data Protection Officer, please contact: privacy@safeguardworld.com

2. Personal Data processed

 When you use the Website, SGWI will collect and process information regarding you (as an individual)which allows you to be identified either by itself, or together with other information which has been collected. SGWI may also be able to collect and process information regarding other persons in this same manner, if you choose to provide it to SGWI.

This information may be classified as “Personal Data”, and can be collected by SGWI both when you choose to provide it (e.g., when you subscribe to SGWI’s eNewsletter) or simply by analysing your behaviour on the Website.

Personal Data which can be processed by SGWI through the Website are as follows: 

a. Name, contact details and other Personal Data

In order to access some of SGWI’s Services made available over the Website – such as subscribing to SGWI’s eNewsletter, or contacting SGWI to request further information – you will be asked to provide Personal Data, such as your name, contact details and the company you work for or represent.

b. Job Applications

When registering to apply for a position within SGWI, in the “Careers” section of the Website, you will also be asked to provide various types of Personal Data, including your name, your e-mail address and professional / employment details (e.g., current job title and employer, salary expectations, notice period, language skills, CV / resume, etc.).

SGWI asks you not to disclose any sensitive Personal Data in files you upload to the Website (such as your CV / resume), unless you consider this to be strictly necessary. In this case, it is important that you provide explicit consent to process this sort of Personal Data (e.g., by declaring that you consent to the processing of data contained in the uploaded files), or SGWI will not be able to lawfully process it for any purpose.

c. Other persons’ Personal Data

SGWI allows users to nominate SGWI employees for a Service Excellence Award, by filling out an appropriate on the Website. You will be asked to provide information on yourself, such as your name, company and contact details, but also to provide the name of the specific employee you wish to recommend, and a reason why.

Additionally, in the “Careers” section of the Website, you are able to nominate other persons for a vacancy, instead of applying yourself – here, you will be asked to provide information on yourself, such as your name and e-mail address, but also Personal Data related to the person being nominated, such as their name, contact details and relationship with you (friend, family, colleague, work contact or other).

In any situation where you decide to share Personal Data related to other persons, you will be considered as an independent data controller regarding that Personal Data, and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify SGWI against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, brought by the third parties whose information you provide through the Website.

As SGWI does not collect this information directly from these third parties (but rather collects them, indirectly, from you), you must make sure that you have these third parties’ consent before providing any information regarding them to SGWI; if not, then you must make sure there is some other appropriate grounds on which you can rely to lawfully give SGWI this information.

 d. Browsing data

The Website’s operation, as is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While SGWI does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information must also be considered Personal Data.

This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on.

These data are used to compile statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website.

e. Cookies

– Definitions, characteristics, and application of standards

Cookies are small text files that may be sent to and registered on your computer by the websites you visit, to then be re-sent to those same sites when you visit them again. It is thanks to these cookies that those websites can “remember” your actions and preferences (e.g., login data, language, font size, other display settings, etc.), so that you do not need to configure them again when you next visit the website, or when you change pages within a website.

Cookies are used for electronic authentication, monitoring of sessions and storage of information regarding your activities when accessing a website. They may also contain a unique ID code which allows tracking of your browsing activities within a website, for statistical or advertising purposes. Some operations within a website may not be able to be performed without the use of cookies which, in certain cases, are technically necessary for operation of the website.

When browsing a website, you may also receive cookies from websites or web servers other than the website being visited (i.e., “third-party cookies”).

There are various types of cookies, depending on their characteristics and functions, which may be stored on your computer for different periods of time: “session cookies”, which are automatically deleted when you close your browser, and “persistent cookies”, which will remain on your device until their pre-set expiration period passes.

According to the law which may be applicable to you, your consent may not always be necessary for cookies to be used on a website. In particular, “technical cookies” – i.e. cookies which are only used to send messages through an electronic communications network, or which are needed to provide services you request – typically do not require this consent. This includes browsing or session cookies (used to allow users to login) and function cookies (used to remember choices made by a user when accessing the website, such as language or products selected for purchase).

On the other hand, “profiling cookies” – i.e., cookies used to create profiles on users and to send advertising messages in line with the preferences revealed by users while browsing websites – typically require specific consent from users, although this may vary according to the applicable law.

  • Browsing or session cookies, which are strictly necessary for the Website’s operation, and/or to allow you to use the Website’s content and Services.
  • Analytics cookies, which allow SGWI to understand how users make use of the Website, and to track traffic to and from the Website.
  • Function cookies, which are used to activate specific Website functions and to configure the Website according to your choices (e.g., language), in order to improve your experience.
  • Profiling cookies, which are used to observe the preferences you reveal through your use of the Website and to send you advertising messages in line with those preferences.

SWGI also uses third-party cookies – i.e. cookies from websites / web servers other than the Website, owned by third parties. These third parties will either act as independent data controllers from SGWI regarding their own cookies (using the data they collect for their own purposes and under terms defined by them) or as data processors for SGWI (processing personal data on SGWI’s behalf). For further information on how these third parties may use your information, please refer to their privacy policies:

– Cookie settings

You can block or delete cookies used on the Website via your browser options. Your cookie preferences will be reset if different browsers are used to access the Website. For more information on how to set the preferences for cookies via your browser, please refer to the following instructions:

CAUTION: If you block or delete technical and/or function cookies used by the Website, the Website may become impossible to browse, certain services or functions of the Website may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Website.

3. Purposes of processing

SGWI intends to use your Personal Data, collected through the Website, for the following purposes:

  • To respond to your requests for further information, to allow you to receive best practices in HR outsourcing and new HRIS technologies related to multinational payroll and managing contingent labour on a global scale (SGWI’s eNewsletter) and to provide any other Services which you may request (“Service Provision”);
  • To examine applicant’s resumes / CVs and to get in contact with applicants who have submitted their application via the Website (“Recruitment”);
  • For future marketing, promotional and publicity purposes, including to carry out direct marketing, market research and surveys, via (“Marketing”);
  • For compliance with laws which impose upon SGWI the collection and/or further processing of certain kinds of Personal Data, as well as, where necessary, for establishment, exercise or defence of legal claims (“Compliance”);

4. Grounds for processing and mandatory / discretionary nature of processing

SGWI’s grounds for processing your Personal Data, according to the purposes identified in Section 3, are as follows:

  • Service Provision: processing for these purposes is necessary to provide the Services and, therefore, is necessary for the performance of a contract with you. It is not mandatory for you to give SGWI your Personal Data for these purposes, and providing some of the Personal Data requested in the respective forms is purely optional; however, if you do not provide all mandatory information requested, SGWI will not be able to provide any Services to you.
  • Recruitment: processing for this purpose is needed in order for SGWI to be able to consider offering you (or someone you nominate) a position and, therefore, is necessary to take steps at your request before (potentially) entering into a contract. It is not mandatory for you to give SGWI your Personal Data for these purposes, and providing some of the Personal Data requested in the respective forms is purely optional; however, if you do not provide all mandatory information requested, SGWI will not be able to consider your candidacies.
  • Marketing: processing for these purposes is generally based on your consent. It is not mandatory for you to give consent to SGWI for use of your Personal Data for these purposes, and you will suffer no consequence if you choose not to (aside from not being able to receive further marketing communications from SGWI). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
    • Additionally, if you provide your e-mail address when acquiring any products or services from SGWI, that e-mail address may be used to send you direct marketing communications regarding SGWI’s own similar products or services. You will be given the opportunity to object to this processing when you provide your e-mail address, and with each marketing communication you are sent (please see Section 8  for more information).
  • Profiling: processing for this purpose is based on your consent, given by accepting the use of profiling cookies. It is not mandatory for you to give consent to SGWI for use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to (aside from not being able to benefit from greater personalisation of your user experience regarding the Website). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
  • Compliance: processing for this purpose is necessary for SGWI to comply with its legal obligations. When you provide any Personal Data to SGWI, SGWI must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations. Additionally, SGWI may process Personal Data where necessary to establish, exercise or defend any legal claims.

5. Recipients of Personal Data

Your Personal Data may be shared with the following list of persons / entities (“Recipients”):

  • Entities engaged in order to provide the Services (e.g., marketing agencies, customer relationship managers, recruiting platforms);
  • Persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks);
  • Persons authorised by SGWI to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of SGWI);
  • Other companies within the SGWI Group; and
  • Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;

6. Transfer of Personal Data

Considering SGWI’s worldwide presence and business operations, your Personal Data may be transferred to Recipients located in several different countries. SGWI implements appropriate safeguards to ensure the lawfulness and security of these Personal Data transfers, such as by relying on adequacy decisions from the European Commission, standard data protection clauses adopted by the European Commission, or other safeguards or conditions considered adequate to the transfer at hand.

7. Retention of Personal Data

Personal Data processed for Service Provision will be kept by SGWI until you withdraw your consent, or object to further processing. In this case, your Personal Data will no longer be

 

will be kept by SGWI for the period deemed strictly necessary to fulfil such purposes – in any case, as these Personal Data are processed for the provision of the Services, SGWI may continue to store this Personal Data for a longer period, as may be necessary to protect SGWI’s interests related to potential liability related to the provision of the Services.

Personal Data processed for Recruitment will be kept by SGWI for as long as the vacancy for which the CV was submitted is still available or, in case of open positions, for up to 1 year. SGWI may contact applicants before the expiration of this period to request an extension of the retention period.

Personal Data processed for Marketing and Profiling will be kept by SGWI from the moment you give consent until the moment you withdraw the consent given. Once consent is withdrawn, Personal Data will no longer be used for these purposes, although it may still be kept by SGWI, in particular as may be necessary to protect SGWI’s interests related to potential liability related to this processing.

Personal Data processed for Compliance will be kept by SGWI for the period required by the specific legal obligation or by the applicable law, or as long as may be required in order to establish, exercise or defend legal claims.

8. Data subjects’ rights

As a data subject, are entitled to exercise the following rights before SGWI, at any time:

  • Access your Personal Data being processed by SGWI (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;
  • Correct or update your Personal Data processed by SGWI, where it may be inaccurate or incomplete;
  • Request erasure of your Personal Data being processed by SGWI, where you feel that the processing is unnecessary or otherwise unlawful;
  • Request the restriction of the processing of your Personal Data, where you feel that the Personal Data processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing;
  • Exercise your right to portability: the right to obtain a copy of your Personal Data provided to SGWI, in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller;
  • Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent SGWI from processing your Personal Data; or
  • Withdraw your consent to processing (for Marketing and Profiling).

You can withdraw consent, or object to processing for Marketing by selecting the appropriate link included at the bottom of every marketing e-mail message received.

Aside from the above means, you can also exercise your rights described above by sending a written request to SGWI at the following address: privacy@safeguardworld.com

In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through the Website is unlawful.

9. Amendments

This Privacy Policy entered into force on May 18, 2018. SGWI reserves the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. SGWI will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Website. SGWI therefore invites you to regularly visit this Privacy Policy in order to acquaint yourself with the latest, updated version of the Privacy Policy, so that you may remain constantly informed on how SGWI collects and uses Personal Data.