Privacy policy for the Nippon Hasha, Inc. employer branding and recruitment

Date of publication: 07-06-2024

We at Nippon Hasha, Inc. manage our employer branding and recruitment process through our career site (the “Career Site”), and by using a related applicant tracking system.

In this privacy policy, we explain how we process your personal data if:

1. You visit our Career Site (you being a “Visitor”)

2. You connect with us via our Career Site, to create a profile with us and receive information about current or future vacancies with us (you being a “Connecting Candidate”)

3. You apply for a position with us, via our Career Site or a third party service (you being an ”Applying Candidate”)

4. We collect information about you from other parties, sites and services, since we believe your profile is of interest for our current or future vacancies (you being a “Sourced Candidate”)

5. We receive information about you from our employees or partners, since they believe your profile is of interest for our current or future vacancies (you being a “Referred Candidate”)

6. We receive information about you from a Candidate, who lists you as their reference (you being a “Reference”).

This privacy policy also describes what rights you have when we process your personal data, and how you can exercise these rights.

When we use the term “Candidate” in this privacy policy, we are referring to each of Connecting Candidates; Applying Candidates; Sourced Candidates; and Referred Candidates, unless it’s stated otherwise.

About processing of personal data

Personal data is all information that can be directly or indirectly linked to a living, physical person. Examples of personal data are: name, e-mail address, telephone number and IP address. Processing of personal data is any automated use of personal data - such as collecting, creating, analyzing, sharing, and deleting personal data.

There are laws and regulations on how companies may process personal data, so-called data protection laws. Different data protection laws apply to different types of use of personal data, and in different parts of the world. An example of a data protection law that is relevant for our use of your personal data, as described in this privacy policy, is the EU Data Protection Regulation (2016/679, “GDPR”).

Most obligations under the GDPR apply to the so-called data controller. A data controller is the entity that decides for which purposes personal data will be processed, and how the processing will be executed. The data controller can use a so-called data processor. A data processor is an entity that is only allowed to process personal data as instructed by the data controller, and may not use the personal data for its own purposes.

We are the data controller when we process your personal data as described in this Privacy policy.

1. For what purposes do we process your personal data?

I understand that Company collects and processes my personal information for legitimate employment-related purposes, including:

1. Verification of my employment history, job titles, duties, length of service, performance, conduct, reason for leaving, and rehire eligibility.

2. Validation of education, professional licenses, certifications, and job-related credentials.

3. Conduct of professional, employment, and character reference checks.

4. Assessment of my suitability, integrity, qualifications, and fitness for the position applied for.

5. Protection of the Company, its employees, guests, assets, confidential information, funds, inventory, and business operations.

6. Compliance with legal, regulatory, audit, security, and internal control requirements.

The Company shall process my personal information only for declared, specific, and legitimate purposes, and only to the extent necessary for the hiring process. This follows the Data Privacy Act requirement that processing must observe transparency, legitimate purpose, and proportionality.

2. Personal Information That May Be Processed

I authorize the Company and/or its authorized representative or background check service provider to collect, verify, use, and process the following information, as applicable to the position:

The Company shall not intentionally collect information that is excessive, irrelevant, or unrelated to the role.

3. Authorization to Conduct Reference and Background Checks

I authorize the Company, its Human Resources representatives, hiring managers, authorized officers, and/or accredited third-party service providers to:

1. Contact my current and previous employers, supervisors, HR representatives, schools, licensing bodies, professional contacts, and declared references.

2. Request confirmation or feedback regarding my employment, performance, behavior, attendance, separation reason, disciplinary record, and eligibility for rehire.

3. Verify the truthfulness, accuracy, and completeness of the information I submitted.

4. Document the results of the background and reference checks for hiring evaluation and employment records.

5. Share relevant background check results only with authorized Company decision-makers who have a legitimate need to know.

I understand that the Company may decide not to proceed with my application if I refuse to provide necessary information or consent for checks that are relevant to the position.

4. Consent to Contact Current Employer

I authorize the Company to contact my current and/or previous employers as part of the background check.

A. Current Employer

Full name, email address, mobile no.:

1. Immediate superior

2. Immediate subordinate, if applicable

3. HR Head

4. Colleague from other departments

B.Reason for restriction, if any.

C. Previous Employer (most recent):

Full name, email address, mobile no.:

1. Immediate superior

2. Immediate subordinate, if applicable

3. HR Head

4. Colleague from other departments

5. Third-Party Background Check Provider

I understand that the Company may engage an accredited third-party background check provider for verification services. The provider shall process my personal information only for the authorized purpose and subject to confidentiality, security, and data protection obligations.

The Company remains responsible for ensuring that personal information is processed lawfully, fairly, securely, and only for the declared purpose.

6. Data Privacy Notice

I understand that:

1. My personal information will be processed by the Company for recruitment, hiring, background verification, risk assessment, and employment decision-making.

2. My personal information may be shared with authorized Company representatives, hiring decision-makers, legal/compliance officers, auditors, and accredited third-party service providers, only when necessary.

3. My information shall be stored securely and protected against unauthorized access, loss, misuse, alteration, disclosure, or destruction.

4. My information shall not be sold or used for unrelated commercial purposes.

5. The Company shall retain my information only for as long as necessary for recruitment, hiring evaluation, legal compliance, audit, dispute resolution, or legitimate business purposes.

7. Retention Period

For unsuccessful applicants, background check records shall be retained for up to twelve (12) months from the completion of the hiring process, unless a longer period is required for legal, audit, dispute, or compliance purposes.

For hired employees, relevant background check records may form part of the employee’s 201 file and shall be retained in accordance with the Company’s employee records retention policy and applicable law.

8. My Rights as a Data Subject

I understand that, under the Data Privacy Act, I have rights as a data subject, including the right to be informed, right to access, right to object, right to rectification, right to erasure or blocking, right to damages, right to data portability, and right to file a complaint with the National Privacy Commission.

For data privacy concerns, I may contact:

Ms. Kristine Refuerzo

kristine.refuerzo@nipponhasha.com

63 917 106 1419

Nippon Hasha, Inc.

U-7006, 7/F Four E-Com Center

Mall of Asia Complex, Pasay City 1300

Philippines

9. Certification and Consent

I certify that the information I provided to the Company is true, complete, and accurate to the best of my knowledge.

I understand that any false statement, omission, misrepresentation, falsified document, or material inconsistency discovered during the background check may result in withdrawal of my application, withdrawal of job offer, non-hiring, or if already employed, disciplinary action subject to due process.

By acknowledging below, I freely give my informed consent to the collection, verification, use, processing, storage, and limited disclosure of my personal information for the purposes stated in this form.

I understand that this consent is specific to employment application, hiring evaluation, and job-related background verification.

10.Reference Check Authorization

I authorize the persons, companies, schools, professional bodies, licensing agencies, and institutions contacted by the Company Name or its authorized representative to provide truthful and relevant information regarding my employment, education, qualifications, work performance, conduct, attendance, reason for leaving, and eligibility for rehire.

This authorization is given for employment evaluation purposes only.

11. What rights do you have, and how can you exercise them?

In this section, you will find information about the rights you have when we process your personal data. As described below, some of the rights only come into play when we process your personal data under a particular legal basis.

If you want to exercise any of the rights listed here, we suggest that you:

• Visit the Data & Privacy page on our Career Site, where we offer features to let you exercise your rights;

• Log in to your account with us, where you can use the settings in the account to exercise your rights; or

• Contact us directly at reyca.silva@nipponhasha.com.

Right to be informed

You have the right to be informed about how we process your personal data. You also have the right to be informed if we plan to process your personal data for any purpose other than that for which it was originally collected.

We provide you with such information through this privacy policy, through updates on our Career Site (see also Section 11 below), and by answering any questions you may have for us.

Right to access your personal data.

You have the right to know if we process personal data about you, and to receive a copy of the data we process about you. In connection with receiving the copy of your data, you will also receive information about how we process your personal data.

Right to access and to request a transfer of your personal data to another recipient (“data portability”).

You can request a copy of the personal data relating to you that we process for the performance of a contract with you, or based on your consent, in a structured, commonly used, machine-readable format. This will allow you to use this data somewhere else, for example to transfer it to another recipient. If technically feasible, you also have the right to request that we transfer your data directly to another recipient.

Right to have your personal data deleted (“right to be forgotten”).

In some cases, you have the right to have us delete personal data about you. This is for example the case if it’s no longer necessary for us to process the data for the purpose for which we collected it; if you withdraw your consent; if you have objected to the processing and there are no legitimate, overriding justifications for the processing. (For the separate right to object, see below.)

Right to object against our processing of your personal data.

You have the right to object to processing of your personal data which is based on our legitimate interest, by referencing your personal circumstances.

Right to restrict processing.

If you believe that the personal data we process about you is inaccurate, that our processing is unlawful, or that we don’t need the information for a specific purpose, you have the right to request that we restrict the processing of such personal data. If you object to our processing, as described just above, you can also request us to restrict processing of that personal data while we make our assessment of your request.

When our processing of your personal data is restricted, we will (with the exception of storage) only process the data with your consent or for the establishment, exercise or defence of legal claims, to protect the rights of another natural or legal person, or for reasons relating to an important public interest.

Right to rectification.

You have the right to request that we rectify inaccurate information, and that we complete information about you that you consider incomplete.

Right to withdraw your consent.

When we process your personal data based on your consent, you have the right to withdraw that consent at any time. If you do so, we will stop processing your data for the purposes you’ve withdrawn your consent for. However, it doesn’t affect the lawfulness of processing that was based on your consent before it was withdrawn.

Right to raise a complaint.

If you have complaints about our processing of your personal data, you can raise a complaint with the data protection authority in Philippines. You can find their contact details here.

You can also lodge a complaint with your national data protection authority, which you can find listed here if you are based in the EU. If you are based in the UK, you can lodge a complaint with the Information Commissioner’s Office, here.

12. Updates to this Privacy policy

We update this privacy policy when necessary - for example, because we start processing your personal data in a new way, because we want to make the information even clearer to you, or if it’s necessary to do so in order to comply with applicable data protection laws.

We encourage you to regularly check this page for any changes. You can always check the top of this page to see when this privacy policy was last updated.