Scope
We collect, store, use, process and disclose personal data to conduct our business, to meet our legal obligations and to provide and market our services. Your personal data is information or opinion/s about you that can be used to identify you directly or indirectly.
We must comply with the privacy law and data protection law when processing, collecting, storing, using or disclosing your personal data.

The purpose of our privacy policy is to explain, in general terms, what sort of personal data we collect, why we collect and store it and how we process, collect, store, use and disclose it.

Collection of your personal data
We may collect personal data from you in the course of providing services to our customer when you contact us or when we contact you.

We may collect personal data from you through hardcopy forms or through forms provided on our internet website pages. We may also collect personal data in face-to-face meetings and in interviews.
We may collect personal data from third parties, such as from referees and law enforcement agencies in the case of prospective employees with your authorization.

The personal data we may collect about you is dependent upon your relationship with us. The following are some examples of the types of personal data that we may collect from you:
(a) For the purpose of providing services to our customer:
Persons contacting us or contacted by us
personal details – including name, address, date of birth, passport numbers, e-mail addresses and telephone numbers.
(b) For the purpose of assessing prospective employees:
Prospective employees
application forms – name, addresses, telephone numbers;
resume details – which will usually include details such as an individual’s name, address, telephone numbers, academic qualifications, employment history, and referees;
reference checking; and
criminal record checks.
(c) For the purpose of marketing activities:
Representatives and employees of prospective customers
personal details – including name, address, e-mail addresses and telephone numbers.

We may also collect personal data about you from our customer where it is impractical for us to collect the information directly from you. In the course of providing services to our customer we may act on behalf of our customer in providing a service to you. Our customer provides us with information necessary to provide the service to you. The information provided to us by our customer may include personal data that our customer has collected from you with your consent.

The following are some examples of the types of personal data that we may collect about you from our customer:
(a) For the purpose of providing services to our customer:
Persons contacting us or contacted by us
personal details – including name, address, date of birth, passport numbers, e-mail addresses and telephone numbers.
Use and Disclosure of your personal data
Subject to the exceptions set out in the privacy law and data protection law (for example, the disclosure of personal data when allowed or required by law),
we do not disclose personal data collected in the course of providing services to our customer to third parties other than to our customer; and we do not disclose personal data collected for our use in marketing activities to third parties; and
we will only use and/or disclose your personal data for the purpose/s for which it is collected; or a related purpose, where you would reasonably expect that it be used and/or disclosed without your further consent.

We generally will only disclose personal data to third parties without your consent if that disclosure is necessary for the purpose/s for which that information was collected. Set out below are some examples of where it is necessary for us to disclose personal data to third parties:
(a) For the purpose of assessing prospective employees:
Prospective employees
Recruitment process – We require prospective employees to complete documentation and submit to pre-employment checks, including completing application forms, reference checking and criminal record checks which involves disclosure of personal data to various third parties.

We may send you marketing material in the course of our marketing activities. We will always provide you with a way to opt out of receiving marketing material from us.

Safeguarding your personal data
We store personal data in a range of paper-based and electronic forms only as long as necessary:
(a) Paper Security – Where personal data is stored in physical form, we may use a variety of mechanisms to protect the security and integrity of such information which might include:
locking personal data in cabinets and only giving access to those employees who have a need to use it; and
using other access control measures such as keyed access, security alarms and surveillance cameras to deter and detect unauthorised access.
(b) Computer and Network Security – Where personal data is stored in electronic form we adopt a number of security measures to protect information from unauthorised access to our computer systems which include:
access control for authorised users such as user names and passwords;
limiting access to shared network drives to authorised staff;
virus checking; and specialised IT support to deal with security risks.
We destroy personal data after we have used it for the purpose/s for which it was originally collected.

Accessing and correcting your personal data
You may request access to any personal data we hold about you by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you, the amount of which will be advised to you at the time of making your application.

There may be instances where we cannot grant you access to the personal data we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
If you believe that personal data we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will determine if the information requires amendment and if so we will amend it accordingly.

Making a privacy complaint
If you have a complaint about how we collect, hold, use, process or disclose your personal data or a privacy related matter such as refusal to provide access or correction, please let us know by contacting us (see the details below).
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you may contact your local privacy authority;

Contacting us
If you have any questions about this privacy policy, any concerns or a complaint regarding the treatment of your personal data or a possible breach of your privacy, you can contact us at:
DPO (Data Protection Officer) contacts:
dpo@mindpearl.com
+4969945189154

Telephone:
Australia: +61 7 3329 6900
Fiji: +679 334 6200
South Africa +27 21 440 6735
Spain: +27 21 440 6707
Malaysia: +60 35 562 6889
Switzerland: +41445867249
Germany +49 30 31198582

Postal address:
Australia: GPO Box 2754, Brisbane QLD 4001, Australia
Fiji: Mindpearl Limited, Private Mail Bag, Nasinu, Fiji Islands
South Africa: PO Box 50269, Waterfront, Cape Town, 8002, South Africa
Spain: C/Tarragona, 157 4^th 080014, Barcelona, Spain
Malaysia: Level 13A, Tower 9, UOA Business Park, No. 1, Jalan Pengaturcara U1/51A, Seksyen U1, Shah Alam,
Selangor Darul Ehsan 40150, Malaysia
Switzerland: Mühlebachstrasse 32, 8008 Zürich, Switzerland
Germany: Limbecker Platz 1, 45127 Essen, Germany