Virtuos Holdings Pte. Ltd. and all of its subsidiaries (collectively, “we” or “us”) are committed to protecting your personal data. It is a core principle of our business and also our corporate social responsibility to protect and properly manage personal information obtained from third parties. This Privacy Policy describes what information we may collect and how we use, transfer or process it. We encourage you to read this Privacy Policy carefully when using our website and/or providing your personal data in any other way. If you do not want us to obtain, process or share your information in the ways set forth in this Privacy Policy, you may not be able to use our website and/or providing your personal data for any purposes. By using our website and/or providing us your personal data, you are accepting the practices described in this Privacy Policy.

This Privacy Policy is effective as of and was last modified on 01 March 2023.

If you have any questions, comments or concerns in regard to this Privacy Policy, please contact our Privacy Office at  [email protected].

I. YOUR PERSONAL DATA; HOW WE COLLECT AND USE YOUR PERSONAL DATA

1. Definition

Personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification numberlocation data, an online identifier or to one or more factors specific to the physicalphysiologicalgeneticmentaleconomiccultural or social identity of that natural person.

2. How we collect your personal data

a) Use of Cookies

We use cookies, advertising IDs and/or similar analytical technologies on this website (collectively referred to as “Cookies”) to make the interaction between you and the website faster and easier by letting you navigate between pages efficiently, storing your preferences, and generally improving your experience of a website. On mobile, we use your mobile device advertising ID. Advertising IDs are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple’s ID for advertising, which are uniquely associated with your mobile device. Cookies may also be set by third parties, including by Google Analytics and/or social networking sites.

By accessing and using out website, you are deemed to consent to receive Cookies, unless you disable or delete Cookies or set your browser to alert you when Cookies are being sent to your computer. Please also note that the use of information obtained by third party providers through cookies placed by them is also subject to their own privacy policies.

b) Contact information (via Contact Us webpage)

By sending your personal data through our Contact Us webpage, you consent to the collection, storage, processing, use and disclosure of your data by us for the purposes of providing subsequent services, direct marketing, and to communicate with you for one or more of such purpose(s).

c) CVs and applications from jobseekers and candidates (via Careers webpage)

  • You hereby represent and warranty that all information you provide is true, accurate, complete, latest update, and relates to you and not to any other person.
  • By applying to our job opportunities and sending us your CV through our Careers webpage, you consent to the collection, storage, processing, use and disclosure of your data by us as described in this Privacy Policy. This will include your name, address, e-mail address, phone numbers, educational background, picture, work experience and information from your CV and application.
  • As we use Avature’s services to assist with our recruitment processes, Avature’s privacy policy (https://www.avature.net/website-privacy-policy/) rather than this Privacy Policy, shall apply to the processing of your personal data.
  • We may retain your application and personal data submitted for the timeframe permitted under appliable laws, so that your candidacy may be considered for other suitable positions within this timeframe.
  • We may also retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your legitimate interests or the legitimate interests of another natural person or entity.

d) Any other way different from collecting information via website

By providing us your personal data via any method other than our website, i.e. through phone calls, name cards, visiting our office, etc.; you consent to the collection, storage, processing, use and disclosure of your data by us as described in this Privacy Policy.

To avoid any misunderstanding, any personal data which is shared and covered under a non-disclosure agreement shall be protected by such non-disclosure agreement.

3. How we use your personal data

a) We use personal data within the scope of the purposes of use specified, except where allowed by applicable laws and regulations. Your personal data will not be further processed in a manner that is incompatible with these purposes unless we notify you otherwise. Personal data submitted via the website and/or otherwise provided to us could potentially be shared across our studios globally and this would only be done for the above-mentioned purposes.

b) We will not use personal data beyond the necessary scope for the attainment of the stated purposes of use.

c) We shall not provide personal data and personal identification data to a third party without prior consent from the individual, except where allowed by applicable laws and regulations.

II. HOW WE PROTECT YOUR PERSONAL DATA

  1. Respect for Individual Rights and Freedoms

We respect your individual rights and freedoms under the EU General Data Protection Regulation 2016/679 (the “GDPR”) and other applicable data protection laws, including:

  • the right to access;
  • the right to rectification/correction of errors;
  • the right to erasure;
  • the right to restrict processing;
  • the right to object to processing;
  • the right to data portability;
  • the right to complain to a supervisory authority; and
  • the right to withdraw consent.
  1. Personal Data Protection Management System

We shall comply with all applicable laws of the territories where it operates, including GDPR. We shall ensure that personal data shall be processed in a lawfully, fairly and transparent manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage. In order to ensure the security of personal data, we implement security measures necessary for prevention of leakage, loss or damage of personal data, including, as appropriate, the measures referred to GDPR. Should the handling of any personal data be outsourced to a third party, an agreement with that third party requiring the protection of personal data will be created. We also provide instructions and supervision to the third party regarding the correct handling of personal data.

Internally, our managers collectively oversee the protection and management of personal data, and employees receive periodic training and guidance on best procedures when handling personal data.

We take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personal data from unauthorized access and disclosure. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal data, searches, or other communications will always remain secure. You should also take care with how you handle and disclose your personal data and should avoid sending personal data through insecure email/link.

III. RETENTION PERIODS

We will hold your personal data on our systems for as long as is necessary for the relevant purpose, or as otherwise described in this Privacy Policy.

IV. CHILDREN’S PRIVACY

We do not knowingly collect any personally identifiable information from children below the age without requiring parental consent.

V. CONTINUOUS IMPROVEMENTS

We seek to continuously review and improve our Privacy Policy to adapt to changes in business, legal, cybersecurity or technological environments. When we post changes to this Privacy Policy, we will revise the “last modified” date at the top of this Privacy Policy. We recommend that you check our website from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.

Last Updated: 09 March 2023