Candidate Privacy Policy

Last updated April 1st 2022

INTRODUCTION

This privacy notice applies if you are applying for employment with Lalamove. “Lalamove”, “we”, “us” and “our” means the particular entity of the Group proposing to employ you on the date that you receive this document.

Where we use the term your “Application” in this Notice, we are referring to your application to work at Lalamove.

For the purpose of this Notice, “Group” means the entities listed in Appendix I (including their branches and representative offices) and their related subsidiaries and affiliates across the world.

We are committed to protecting and respecting your privacy. This Notice explains what personal information we gather and create about you, what we use that information for, and who we give that information to. It also sets out your rights in relation to your information and who you can contact for more information or queries. In this Notice, your information and other information provided by you are defined as “Personal Data”.

A. ABOUT THIS NOTICE

For the purposes of data protection law, we are a data controller / data user in respect of your Personal Data. We are responsible for ensuring that we use your Personal Data in compliance with the applicable data protection law in the jurisdiction where the relevant employing entity is located.

This Notice sets out the basis on which any Personal Data that you provide to us, that we create, or that we obtain about you from other sources, will be processed by us. Please take time to read and understand this Notice.

B. INFORMATION WE COLLECT ABOUT YOU

Subject to our entitlement to use your Personal Data for the reasons laid out under section “USE OF YOUR PERSONAL DATA” below, we will collect and process the following Personal Data about you: 

(a) Information you provide to us directly. You may give us information when you make your initial Application. This information may include: your name, age, date of birth, nationality, ID number, ID issuance authority, address, gender, marital status, personal email address and phone number, photograph, salary information or expected salary, resume and CV and any information referred to thereof, including your education information (eg school name and location, major, degree), working experience, title, professional qualifications, language skills, your reasons for applying to Lalamove, etc.. 

(b) Information we collect about you. This includes information that is collected in connection with your Application and is likely to include: 

  1. Personal Data that we collect through your communication and correspondence with us (including the content, date and time of your email correspondence); and 
  2. information obtained through any interviews and assessments with you. 

(c) Information we receive from other sources. We are also working closely with third parties and may receive information about you from them. Such information may typically include: Personal Data that we collect from screening, background and/or reference checks we may perform on you as part of the Application or recruitment process, which may include your address history, your credit history, your qualifications (both academic and professional), your previously held directorships (if any); criminal records and civil litigation information.

C. USE OF YOUR PERSONAL DATA / PERSONAL INFORMATION

To the extent necessary, we may collect, disclose and otherwise process your Personal Data in the following ways for the following purposes:

(a) to consider your Application (including, in some cases, verifying your qualifications and conducting reference check or background check with those third parties you name); 

(b) to meet our legal and regulatory obligations; 

(c) to maintain consistent practices and procedures with respect to the collection, use, disclosure, transfer and processing of Personal Data across all Group companies worldwide. These practices and procedures include the effective recording, management and administration of Personal Data; 

(d) to maintain consistent practices and procedures with respect to the recruitment of personnel across the Group, including the performance of human resources and other functions of the Group; 

(e) to facilitate equal opportunities monitoring; and 

(f) to maintain contact with you in the future and notify you of relevant job vacancies with a member of the Group that you might be interested in. Please note that if you do not want us to retain your information any longer, or want us to update it at any stage, please contact us in accordance with the “CONTACTING US” section. 

When we use your Personal Data, we make sure that the usage complies with applicable law and the law allows us and requires us to use Personal Data for a variety of reasons, such as: 

(a) you have freely provided us with your informed consent; 

(b) we need to use your Personal Data to take steps in preparation for entering into a contract with you, in particular to consider you for a position at Lalamove; 

(c) we need to use your Personal Data to comply with our legal and regulatory obligations; 

(d) we need to use your Personal Data to achieve our legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights, such as: 

  1. allowing us to effectively assess your skills, qualifications and/or the strength and merits of your Application and your suitability for the role applied for; 
  2. allowing us to effectively verify your information; 
  3. allowing us to effectively and efficiently administer and manage the operation of our business; 
  4. ensuring a consistent approach to the recruitment of Group personnel worldwide;
  5. maintaining compliance with internal policies and procedures; or 
  6. being able to contact you in relation to your Application and the recruitment process;

(e) your Personal Data is necessary for us to defend, prosecute or make a claim against you, us or a third party. 

Please note, if your Application is successful and you are subsequently offered and accept employment at Lalamove, the information we collect during the Application and recruitment process will become part of your employment record. 

D. SPECIAL CATEGORIES OF PERSONAL DATA

Certain types of Personal Data are subject to specific protection or restriction by law in certain territories, where such data is called “Special Categories of Personal Data” or other terms in similar nature. For example, criminal records may be deemed Special Categories of Personal Data under applicable law and we may use such data for your background check.

Subject to applicable law, Special Categories of Personal Data may include such data, the processing of which could create significant risks to the fundamental rights and freedoms.

We will only process your Special Categories of Personal Data if permitted by law and only if one of the following conditions is met:

  1. you have freely provided us with your explicit consent to the processing of the data;
  2. the processing is necessary for carrying out our obligations and specific rights in the field of employment law, social security or social protection law (including obligations in relation to health and safety and disability discrimination, the legality of personnel working in a particular jurisdiction, which will involve processing data in relation to nationality, work permits and visas, monitoring equality of treatment of racial or ethnic opportunity or treatment and vetting (where necessary));
  3. the processing is necessary to protect your health or safety in an emergency (or that of another person) where you are physically or legally incapable of giving consent;
  4. the data in question has been made public by you;
  5. the processing is necessary for the purpose of, or in connection with, any actual or prospective legal proceedings, for the purpose of obtaining legal advice or otherwise for the purposes of establishing, exercising or defending legal rights subject to applicable local legislation or where courts are acting in their judicial capacity;
  6. the processing is necessary for reasons of substantial public interest on the basis of local law which is proportionate to the aim pursued and which contains appropriate safeguarding measures; or
  7. the processing is otherwise permitted by law.

E. DISCLOSURE OF YOUR INFORMATION

(a) Disclosure within the Group

We may share your Personal Data with any member of our Group for the purpose of:

  1. management and administration of the Group business, including the maintenance of the centralised databases storing Personal Data;
  2. enabling the performance of the functions that each of the Group businesses may perform relating to regional or global HR decisions; or
  3. assessing compliance with applicable laws, rules and regulations, and internal policies and procedures across our business.

We will take steps to ensure that the Personal Data is accessed only by our employees that have a need to do so for the purposes described in this Notice and that they are subject to appropriate confidentiality and only use the data for purposes described in this Notice.

(b) Disclosure to other third parties

We may also share your Personal Data with selected third parties outside of our Group in the following scenarios:

  1. to the extent required by law, if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, establish, exercise or defend our legal rights or in order to enforce or apply our privacy policy and other agreements, or to protect the rights, or property of our Group. This includes exchanging information with other companies and organisations for the purposes of fraud or crime protection and risk reduction; and
  2. to third party agents and contractors, bound by obligations of confidentiality, in connection with the processing of your Personal Data for the purposes described in this Notice. This may include outsourced HR service providers and consultants, background check and reference check, IT and communications service providers, law firms, accountants and auditors.

F. WHERE WE STORE YOUR PERSONAL DATA / INTERNATIONAL TRANSFERS

Your Personal Data may be transferred among our Group entities and to the various entities that make up our international network and accessed by personnel authorised by us, and in limited circumstances to our third-party contacts, outside the jurisdiction where it is originally collected (Original Jurisdiction) as well as within it, for the purposes identified above.

Where we transfer your Personal Data outside the Original Jurisdiction, it will be protected in a manner that is consistent with how your Personal Data will be protected by us in the Original Jurisdiction. This can be done in a number of different ways, for instance:

(a) the destination to which we send your Personal Data is approved by the authority of the Original Jurisdiction as having an adequate level of protection;

(b) the recipient has signed a contract based on the standard form approved or recommended by the authority of the Original Jurisdiction, obliging them to protect your Personal Data; or

(c) other approaches approved or recommended by the authority of the Original Jurisdiction.

The Personal Data that we collect from you may also be processed by individuals operating outside of the Original Jurisdiction who work for us or for one of our suppliers.

In all cases, we will ensure that any transfer of your Personal Data is compliant with the applicable data protection law.

You can obtain more details about the protection given to your Personal Data when it is transferred outside the Original Jurisdiction by contacting us in accordance with the “CONTACTING US” section below.

G. SECURITY OF PERSONAL DATA

We have implemented generally accepted standards of technology and operational security, in order to protect your Personal Data against accidental, unauthorised or unlawful access, use, processing, alteration, disclosure, transfer, erasure, or loss. Although we use appropriate security measures once we have received your Personal Data, the transmission of data over the internet (including by email) is never completely secure. We endeavor to protect Personal Data, but we cannot guarantee the security of data transmitted to or by us. We will be responsible for any failure of our physical systems, technology or management error that may result in any unauthorised disclosure or compromise to your Personal Data. We will let you know in accordance with applicable law if a breach occurs that may have compromised the privacy or security of your Personal Data.

We will assess the Personal Data security impact regularly to comply with basic principles for Personal Data security and when new requirements are effective and legally binding and take appropriate actions to protect Personal Data.

All information you provide to us is stored on our secure servers or hosted by credible third-party service providers. Where we have assigned you (or where you have chosen) a password which enables you to access certain services within our IT systems, you are responsible for keeping this password confidential, which shall not be shared with anyone.

H. RETENTION PERIOD

It is our policy not to retain Personal Data longer than is necessary for the fulfilment of the purposes for which the data are or are to be used.

The retention period will be determined by the following criteria:

(a) the purpose for which we are using your Personal Data – we will need to keep the data for as long as is necessary for that purpose; and

(b) legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

In some instances, we may retain your information to consider you for other roles and future opportunities at Lalamove which may be of interest to you. If you do not want us to retain your information any longer, or want us to update it at any stage, please contact us in accordance with the “CONTACTING US” section.

I. YOUR RIGHTS

You have a number of legal rights in relation to the Personal Data that we hold about you. These rights vary among different jurisdictions, but usually include the following:

(a) the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;

(b) the right to withdraw your consent to our processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if there are other lawful grounds (other than consent) which we have relied on for doing so;

(c) the right to request that we rectify your Personal Data if it is inaccurate or incomplete;

(d) the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;

(e) the right to object to, and the right to request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to continue processing your Personal Data and / or to refuse that request; and

(f) the right to lodge a complaint with the competent data protection regulator if you think any of your rights have been infringed by us.

You can exercise your rights in accordance with applicable law at any time by contacting us using the details set out in the “CONTACTING US” section below. But please note that there may be circumstances where we are legally entitled to refuse your request (for example, where you request us to delete your Personal Data but we are legally obliged to retain the data).

Nothing in this Notice will impair or restrict any of your rights in relation to your Personal Data under applicable law.

J. CHANGES TO OUR PRIVACY POLICY

We reserve the right to update this Notice at any time, whereby we will make sure that the most recent version will be requested by contacting us as set out in this Notice.

K. CONTACTING US

If you would like further information on the collection, use, disclosure, transfer or processing of your Personal Data or the exercise of any of the rights listed in this Notice, please contact us at hr.dataprivacy@lalamove.com.

Appendix I

No Area Name of Entity
1 Hong Kong Easy Mobile Logistics Hong Kong Limited
2 Brasil LALAMOVE TECNOLOGIA (BRASIL) LTDA.
3 Indonésia PT LALAMOVE LOGISTIK INDONESIA
4 Malásia LALAMOVE MALAYSIA SDN. BHD.
5 México LALAMOVE TECNOLOGIA MEXICO SA DE CV
6 Filipinas LALAMOVE PHILIPPINES, INC.
7 Singapura EASYVAN (SG) PTE. LTD.
8 Tailândia LalaMove EasyVan Thailand Limited
9 Vietnã LALAMOVE VIETNAM LLC