PRIVACY POLICY

  1. Introduction
    1. Agensi Pekerjaan OTN Sdn Bhd (Company No.: 1378093-K) (“Open Talent Network“, “we“, “us” or “our“) respects the privacy of individuals with regard to personal data and is committed to protecting the privacy of its users, and strives to provide a safe, and secure user experience. Open Talent Network places great importance and priority on data security and data protection.
    2. Protecting personal rights is integral to Open Talent Network’s corporate culture and built into Open Talent Network’s services. Hence, Open Talent Network continuously works to improve data security measures to protect you and your privacy. This privacy policy is formulated in accordance with the Personal Data Protection Act 2010 (“PDPA“), which describes how your information is collected, used, processed and your choices with respect to your Personal Data (“this Policy“). This policy is regarding your privacy with respect to the use of the Open Talent Network Site Service. By continuing to access the Open Talent Network Site Service, communicating with us or voluntarily providing your personal data to us, you warrant that you are at least 18 years of age and expressly consent to our collection, storage, use and disclosure of your personal data as described in this Policy. Please refer to our Terms of Use which governs your use and access to our services when you access the Open Talent Network Site Service. You should read our Terms of Use, which may be updated occasionally, and understand the terms and conditions which you shall be bound to by continuing to access the Open Talent Network Site Service, providing your information or engaging in our services.
    3. The following discloses Open Talent Network’s information gathering and dissemination practices for the Open Talent Network Site Service (“Site“):
  2. Types of Information Collected
    1. In connection with your use of the Open Talent Network Site, we ask for and may collect information from and about you in different ways and at different points on the Open Talent Network Site Service. Some of the information that you submit may be personally identifiable information (that is, information that can be uniquely identified with you).
      1. In order to participate in the Open Talent Network Site Service, you must sign up for an account at the Site at https://www.opentalent.my.  When you access the Open Talent Network Site Service, Agensi Pekerjaan OTN Sdn Bhd collects certain personally identifiable information, including but not limited to your name, address (physical and email), general educational background (“Member Information“) where you provide us with this information.
      2. To begin using the Open Talent Network Site Service, you will be asked to register by creating a personal user account. Through the online registration form certain information, including but not limited to your full name, nationality, date of birth, correspondence address, email address, mobile number, education, academic records, working experience, internship role, internship type, desired location of internship and your resume (“Registration Information“) is collected. An asterisk indicates which information is mandatory in order to complete the registration process. Your Google Account, Microsoft Account or other public social media account may also be collected where you provide this.
      3. If you choose to submit information for a particular internship posting, you may be asked to complete a more extensive internship position description form (“Internship Description“) to provide additional information to fine-tune your qualifications and candidacy for that specific internship posting (“Candidacy Information“).
      4. Your Member Information, Registration Information and Candidacy Information are collectively referred to below as your “Employment Information“.
    2. You do not have to give us any personal information in order to perform internship searches or to read the content portions of our Site. However, we may collect the following general types of information about you when you visit our Site even if you choose to remain anonymous unless expressly stated otherwise: personal information, demographic information, behavioral information, and indirect information. Sometimes we collect combinations of all these types of information. In each case, it is indicated on the Site whether any personal or demographic data must be provided to use the requested service or not:
      1. Personal information is information that can be used to identify you, or any other individual to whom the information may relate, personally. We do not collect personal information unless you choose to provide it to us as stated above.
      2. Demographic information is information that is not unique to you in the sense that it refers to selected population characteristics, such as your postal code, age, preferences, gender, race or ethnicity, education, career history, interests, and favorites.
      3. We also collect behavioral information regarding how you use our Site and mobile applications, the areas of our Site that you visit, what services you access, and information about your computer hardware and software, including your IP address, geolocation, browser and operating system type, domain names, access times and referring Web site addresses. This information is necessary for analysing the use of resources, troubleshooting problems, preventing fraud, and improving our services.
      4. In addition, we may collect indirect information about you when you use certain third party services on the Site and the collection of such information is considered necessary for that purpose.
    3. We do not collect sensitive personal data or confidential information such as the password of your email account; password of your Open Talent Network account (as it is automatically encrypted and saved in the Open Talent Network database when you create an account or register with Open Talent Network and is not authorised for access by Open Talent Network unless required by law); physical and mental or other health conditions or medical records and history; Biometric information such as fingerprints, voice & facial patterns and DNA or any other sensitive information which is confidential or sensitive by its nature.
    4. Your Employment Information, personal information, demographic information, behavioral information, indirect information and any other information collected from your interaction and use of our Site are hereinafter referred to as your “Personal Data“. The provision of your Personal Data is voluntary. However, if you do not provide Open Talent Network with your personal data, Open Talent Network will not be able to process your Personal Data for the Purposes outlined below.
  3. Purpose of Processing Personal Data
    Open Talent Network may use and process your personal Data for business and activities which shall include, but not limited to the following:
    1. INTERNSHIP SEEKER
      Once you have activated your Open Talent Network Site personal user account, Open Talent Network submits your Registration Information to the Open Talent Network Site profiling engine to attempt to match your information with available internship postings. Upon a match of your Registration Information with an internship posting, Open Talent Network will notify you via email if you have elected to receive such notifications. Upon reviewing an internship posting, your Employment Information will be forwarded to that potential employer only if you click on the “Apply” button, thereby instructing Open Talent Network to forward the Employment Information to the potential employer.
    2. THE POTENTIAL EMPLOYER
      Open Talent Network has granted potential employers the ability to run searches through the Open Talent Network Site profiling engine to match their internship postings with internship seekers’ Registration Information. No personally identifiable information is released to these potential employers during these searches, and potential employers are not able to contact internship seekers through this portion of the Open Talent Network Site Service. Notwithstanding the foregoing, by agreeing to use our services, your Employment Information may be shared with a potential employer. In that event, the potential employer will have access to your Employment Information and has agreed to treat that information as confidential and to not disclose it to any third party without your prior written consent.
    3. THE EMPLOYER
      Once you have signed up for an account with Open Talent Network, the information you provided will be used to perform Open Talent Network’s obligations in respect of any contract entered into with you, to facilitate and/or provide you with any service you have requested as envisaged under the Site and to process your information to create your employer page with the Site for internship seekers to gain basic information about the employer. Open Talent Network may use the information to understand and analyse our performance as well as your needs and preferences to improve Open Talent Network’s services to you, to develop, enhance and provide products and services to meet your needs or to contact you for product or customer satisfaction surveys and market research; and for all other purposes ancillary to any of the purposes stated above.
    4. THIRD PARTIES
      Open Talent Network has contracted with a third party Application Service Provider (ASP) to implement and host the Open Talent Network Site Service. Information collected from you and potential employers will be stored on the ASP’s server and processed through its profiling engine. The ASP is not permitted to disclose your personally identifiable information to any third party without your consent.
  4. Users’ Consent to Open Talent Network to Use the Information
    1. By registering with Open Talent Network, by managing your profile, or opting in when presented with choices, you have explicitly consented for us to use your information, subject to local law, in the following ways, including but not limited to:
      1. allow you to create an account;
      2. create a profile for you based on information that you have provided to Open Talent Network;
      3. verify your account and maintain your account with us;
      4. contact you about Open Talent Network Site updates, informational and service-related communications, including important security updates;
      5. provide you additional communications, information, and promotions such as newsletters and career advice;
      6. inform you of other products or services available from Open Talent Network;
      7. enable you to provide feedback, to contact us and for us to respond to you;
      8. conduct surveys, questionnaires, promotions and contests, and to provide the results thereof such as success stories and contest winners;
      9. provide information about you and your potential interest in internship postings to employer customers;
      10. provide products and services to employer customers to complete the recruitment and hiring process, such as accessing the searchable resume database;
      11. provide products and services that enable users to network, post information on bulletin boards, view and compare profiles, and career background and experience;
      12. generate internal reports about the use of our site;
      13. prevent fraudulent or illegal activities, and to enforce our Terms of Use;
      14. conduct research, audit, risk assessment, including statistical research or data study;
      15. enable us to comply with obligations under laws or regulations or to assist in investigations by the authorities.
    2. Some of our products and services, such as our searchable resume database and networking, enable third parties to see your personal information and to contact you. Profile information may be used for networking with other community members or may be visible to employers who are using the Open Talent Network Site. In addition, portions of your searchable resume (but not your contact information) may be made public in your networking profile.
    3. Information you post in public areas of the Site or place in the searchable resume database will be accessed, used, and stored by others around the world, including those in countries that might not have legislation that guarantees adequate protection of personal information as defined by your country of residence. By providing your personal information for inclusion in our database, you acknowledge that you consent to your information being used as described here. While Open Talent Network takes measures to safeguard your information from unauthorised access or inappropriate use by third parties, Open Talent Network does not control these third parties and we are not responsible for their use of information you post or otherwise make available in public areas of the Open Talent Network Sites. Accordingly, you should ensure that you do not post sensitive information, including personality profiles, to the Site.
  5. Revocation Of Consent
    1. If you wish to revoke the consent that Open Talent Network has obtained from you for the purposes stipulated herein, please contact us at:

      Email:

      contact@opentalent.my

    2. If you revoke your consent for us to process your Personal Data, we may be unable to continue providing our services to you at the same or expected level of service. We will inform you of the likely consequences of such withdrawal of consent when we receive your notice of revocation of consent.
  6. Use and Disclosure of the Information We Collect
    1. We use the information we gather on the Open Talent Network Site, whether personal, demographic, collective or technical, for the purposes of operating and improving the Open Talent Network Site, fostering a positive user experience, and delivering the products and services that we offer.
    2. If you have provided consent for us to do so, we may also use the information we gather in order to send you emails or other communications regarding updates at the Site, to inform you of other products or services available from us or our affiliated companies, or to contact you about your opinion of current products and services or potential new products and services that may be offered.
    3. Open Talent Network cannot ensure that all of your private communications and other personal information will never be disclosed in ways not otherwise described in this Privacy Policy. Therefore, although we are committed to protecting your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private. As a user of the Open Talent Network Site, you understand and agree that you assume all responsibility and risk for your use of the Site, the internet generally, and the documents you post or access and for your conduct on and off the Site.
  7. Accessing, Limiting, Correcting and Updating Your Personal Data
    1. Subject to any exceptions under applicable laws of Malaysia, you may request for access to, request for a copy of, request correction of your Personal Data, request to limit the processing or use of your Personal Data and/or request deletion of your Personal Data for the above mentioned purposes and/or make any inquiries regarding your Personal Data by contacting us at contact@opentalent.my
    2. Subject to any laws of Malaysia, Open Talent Network reserves the right to impose a processing fee for access of your Personal Data in the amounts as permitted therein. In respect of your right to access and/or correct your Personal Data, Open Talent Network has the right to refuse your requests to access and/or make any corrections to and/or to delete your Personal Data for the reasons permitted under law, for example where the expense of accommodating your request is disproportionate to the risks to your or another person’s privacy.
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  2. Disclosure of Information to Others
    1. We disclose to third parties within your country and abroad your personal information, combined personal, demographic, behavioral or indirect information, as set forth below:
    2. We disclose your resume to employers who have posted internship opportunities that may be of interest to you on the Open Talent Network Site when you apply for those positions. We may share your information with third parties who help us in the delivery of our own products and services to you. We disclose information to companies and individuals we employ to perform functions on our behalf. Examples include but is not limited to hosting our web servers, analyzing data, providing marketing assistance, and providing customer service. These companies and individuals may be located in a country whose data protection legislation is different from your country, and they will have access to your personal information as necessary to perform their functions, but they may not share that information with any other third party or use that data for any other purpose. We will remain responsible for any information shared in this way.
    3. We disclose information to third parties if you consent to such disclosure. For example, if you make your resume searchable, then all parties with access to our searchable resume database (or copies thereof) will have access to your resume.
    4. We use data we have about you (such as the interests and preferences you have expressed) to determine whether you might be interested in the opportunities, products or services of a particular third-party. For example, if you indicate that you would like to receive information about the opportunities, products or services of third parties at the time you register for a Open Talent Network account, we supply your contact information to third parties such as employers, recruiters, data aggregators, marketers or others for the purpose of sending you email or otherwise communicating with you.
    5. We also share aggregated anonymous information about visitors to the Open Talent Network Site with Open Talent Network’s clients, partners, other Site visitors, and other third parties so that they can understand the kinds of visitors to the Sites and how those visitors use the Sites in order to serve advertisements to you on our Sites or other sites with which we have a business relationship. We may also aggregate on an anonymous basis data regarding qualifications, education, age, experience level or other information relevant to the internship search or competition among internship seekers for any such position. Such aggregated data does not identify users individually, and may be made available to employers or fellow internship seekers or community members. We disclose information to companies and individuals we employ to perform functions on our behalf. Examples include hosting our web servers, data, providing marketing assistance, and providing customer service. These companies and individuals will have access to your personal information as may necessary to perform their functions, but they may not share that information with any other third party.
    6. We disclose information if legally required to do so, if requested to do so by a governmental entity or if we believe in good faith that such action is necessary to:
      1. conform to legal requirements or comply with legal process;
      2. protect our rights or property or our affiliated companies;
      3. prevent a crime or protect national security; or
      4. protect the personal safety of users or the public.
    7. We may disclose and transfer information to a third party who acquires any or all of Open Talent Network’s business units, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets. In addition, in the event Open Talent Network becomes the subject of a bankruptcy proceeding, whether voluntary or involuntary, Open Talent Network or its liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of such information in a transaction approved by the court. You will be notified of sale of all or a substantial portion of our business to a third party via email or through a prominent notice posted on the Site.
  3. Use of Cookies
    1. We use “cookies” to help personalize and maximize your online experience and time online. A cookie is a text file that is placed on your hard drive by a Web page server. Cookies are uniquely assigned to your computer, and can only be read by a Web server in the domain that issued the cookie to you.
    2. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize the Site pages, or register for services, a cookie helps us to recall your specific information (such as user name, password and preferences). Because of our use of cookies, we can deliver faster and more accurate results and a more personalized site experience. When you return to the Open Talent Network Site, the information you previously provided can be retrieved, so you can easily use the features that you customized. We also use cookies to track click streams and for load balancing.
    3. You may have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline all cookies if you prefer. Alternatively, you may be able to modify your browser setting to notify you each time a cookie is tendered and permit you to accept or decline cookies on an individual basis. If you choose to decline cookies, however, that may hinder performance and negatively impact your experience on the Site.
  4. Third-party cookies and functions
    The Site may use third-party vendors to serve or track advertisements on the Site. Among other things, these third parties may use cookies, pixel tags and other technologies to enable such third parties to record which ads your browser has loaded and which pages you may have been viewing when the ads were delivered or accessed. The information collected through these functions is subject to the privacy policies of those third parties.
    1. Embedded URLs
      The Site and the ASP may use a tracking technique that employs embedded URLs to allow use of the Site without cookies. Embedded URLs allow limited information to follow you as you navigate the Site, but is not associated with personal information and is not used beyond the session.
    2. Embedded Pixels
      The Site and the ASP may use embedded pixel technologies on selected pages for the purposes of identifying unique user visits to the Site, as opposed to aggregate hits, and to identify the pages viewed. We may also use embedded pixel technologies to determine whether the recipient of an email has opened a particular message. The information provided by these technologies may be re-associated with personal information by the Site.
  5. Retention of Personal Data
    1. We will not retain your personal data longer than necessary for the fulfilment of the above mentioned purposes. However, relevant Personal Data may be retained subject to the conditions below
      1. as and when required under any applicable laws or legislation of Malaysia;
      2. where legal actions have arisen and are pending; and
      3. for commercial and/or operational purposes of Open Talent Network.
  6. Disclosure of Information
    1. Your Employment Information is released only when you choose to do so, and your information is only released to the potential employer who posted the internship to which you are responding. Once your Employment Information has been forwarded to a potential employer, all correspondences are directly between you and that potential employer. Employers have agreed to not disclose your Employment Information to third parties.
    2. As a user of the Site, you may restrict distribution of your Employment Information by indicating such restrictions in your account.
    3. As indicated above, you will be informed at each collection point what information is required and what information is optional. If the Site matches your Registration Information with a particular internship posting, you will be notified by email only if you have chosen to receive such notifications. You may opt out of receiving email notifications at any time.
  7. Right to Amendment
    1. We reserve the right to update and amend this Policy from time to time. Any amendments to this Policy will be posted on our Site.
    2. In accordance with Section 7(3) of the PDPA, this Policy is used in both English and Bahasa Melayu. In the event of any inconsistencies or discrepancies between the English version and the Bahasa Melayu version, the English version shall prevail