OUR COMMITMENT TO PRIVACY

Privacy Policy

Updated January 2023

01. Intro / Basic info

Horizons Global Technology Pte. Ltd. (“Provider”, “we”, us”, “our”) is a technology company; we build a workforce management platform that allows our customers to hire the best talents in minutes, without worrying about compliance, payroll or HR administration.

This Privacy Policy explains what information we collect, how we use it and what rights you have in relation to it, when you visit our website www.joinhorizons.com (“Website”) and when you use our solutions (“Solutions”), through our platform.

This Privacy Policy applies to our Website and our platform, available through our Website. By using the Website and our Solutions, you agree to the collection, use and other processing of your information in accordance with this Privacy Policy.

02. Collection

Personal data refers to any information relating to you, that could be used – on its own or in combination with other information – to personally identify you, for example your name of email address.

We may collect or receive the following types of personal data when you visit our Website or use our Solutions:

Personal data automatically collected:

Device Data	Information about your computer phone, tablet, or other device you use to access our Website, Internet service provider, mobile carrier
Technical & usage	IP address, login and logout data, browser time and settings
Location Data	Device location, time zone, depending on our device settings

Personal data you may have to disclose to us:

Employment	Job title, hire date, performance history, sick time, package
Identity	Name, marital status, date of birth, photo, national ID or passport
Contact	Device location, time zone, depending on our device settings
Online profile	Username, photo, password, and other background information you have uploaded on the platform when using our Solutions
Contractual	Details about the Solutions we provide you with
Financial	Bank account details, transaction information
Special categories of data	“Sensitive Data”: information revealing racial or ethnic origin, religion, political or philosophical beliefs, health condition, disabilities, or sexual orientation, etc. We only collect such Sensitive Data where required by law, for example to enter into an employment relationship or to proceed with visa application.

All personal data you provide to us must be true, complete, and accurate; you must notify us of any change to such information during our relationship, otherwise it may prevent us for providing the Solutions and we may have to remove your access to our Solutions.

We may also collect and receive personal data about you from third parties: as you employer, ex-employer, insurance providers, for the purposes described in this Privacy Policy.

03. Purpose

We use personal data that we collect about you for the following reasons:

Fulfill our contractual obligations:
- Operate the Website, manage our relationship with you and provide the Solutions
- Enable your use of and access to our Website and Solutions

Operate and improve our Website and Solutions:
- Improve, personalize our Website and Solutions
- Develop and test new products and features

Business operation:
- Manage and process payment transactions
- Manage and enforce contracts with you and other third parties

Marketing purposes:
- Communicate about our products and services
- Send you surveys and obtain your feedback

Risk mitigation:
- Identify and report fraud, money laundering and other crime
- Investigate and respond to complaints and feedbacks

When required by applicable laws:
- For tax calculation, or accounting and legal requirements
- For onboarding and global mobility cases

04. Sharing

We may process your personal data if you have given us specific consent to use your personal information for a specific purpose. We may also share your personal data with the third parties listed above, without further notice to you, unless otherwise required by law.

Vendors and services providers:

That assist us to perform our business and deliver our Solutions, and with whom we have executed an agreement ensuring confidentiality of data and limiting how they may use your data. Such vendors and services providers include:

Web hosting companies and customer management services

Banks and financial institutions

Business partners and other affiliates:

With whom we offer joint services. Such partners include:

Insurance carriers, brokers, and other third-party partners

Current and future entities that controls or is controlled by us.

Government agencies and tax authorities:

As required to provide the Solutions, they include:

Immigration offices, ministry of manpower, regulatory agencies

Other official or governmental bodies

Audit of other necessary action:

In the event we are involved in a merger, acquisition, bankruptcy, transfer to another provider, we may disclose, sell, or share part of our assets including your personal data in the due diligence process.

Public authorities:

When required by law to respond to legal process, if we believe that such action is necessary to (i) comply with law, or (ii) to protect the security and integrity of our Solutions.

05. Security

We aim to protect your personal data, especially from loss, misuse, unauthorized access, alteration, destruction, or disclosure to unauthorized third parties. Thus, we have implemented the following organizational, physical, and technical measures:

Access:

We strictly control online and internal access to your personal data to ensure that they remain protected against any alteration: passwords, access control list, measures authorizing or restricting the granting and use of access to personal data, authentication procedures are in place, efficiently implemented and regularly tested. Users’ access is granted on the principle of ‘strict need to know’, for all arriving staff according to their seniority and duties; such access and cancelled for all departing staff. In addition, all our staff and vendors (when any) are subject to a duty or confidentiality and non-disclosure.

Encryption:

When accessing to our Website to use our Solutions, access to your account is secured by several protection mechanisms: encryption of your personal data whatever their state (at rest, in transit, in process), use of TLS/SSL protocol for data transmission, encryption of all transmission via our server using the HTTPS protocol.

Policy Toward Children:

We do not knowingly collect or solicit personal data from children under 13, without verifiable consent from their parent or legal guardian. If you become aware of any personal data, we may have collected from children under age 13, please contact us (see the ‘Contact’ section at the end of this Privacy Notice).

External Link:

Our Website may contain links to other websites that are not operated by us. Note that we have no control over and assume no liability for the privacy policy of such third-party websites.

However, despite our efforts and safeguards to secure your personal data, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Therefore, you should only access our Website within a secure environment, and decide with special care what data you share to us with our Website or by e-mail.

06. Storage Duration

We retain your information for as long as necessary to fulfill the contractual or statutory obligations for which they were collected, and especially for the following reasons:

When a longer retention period is required or permitted by law

To comply with our legal obligations

To respond to a request or complaint

To enforce our agreements

When we have no ongoing legal reason or business need to retain your information, we will either delete or anonymize such information. In some cases, you may also request us to delete your data.

07. Changes

This Privacy Policy is effective as of the last updated version specified on the top of this Policy. We reserve the right to revise or update this Privacy Policy from time to time without notifying you, unless otherwise required by laws. We encourage you to check this Privacy Policy periodically. By continuing to use our Solutions, you consent to abide and be bound by the revised Privacy Policy and practices described in it.

08. GDPR Framework

Regardless of whether you are a citizen or resident of a country of the European Union (“EU”) or the European Economic Area (“EEA”), we process your personal data, when applicable, in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Data Protection Act 2018.

09. California Residents

If you are resident of California, the California Civil Code Section 1798.83 enables you to enquire about categories of personal data (if any) we may have disclosed to third parties for direct marketing purpose, and the contact details of all such third parties with which we have shared personal information in the preceding 12 months. To make such request, please contact us (see the ‘Contact’ section at the end of this Privacy Notice).

10. Rights

When it comes to your personal data, you have the following individual rights:

Right to be informed about how we process your personal data

Right to access to your personal data and obtain copy of them

Right to request erasure of your personal data, as far as possible

Right to restrict the processing of your personal data

Right to object to the processing of your personal data if you think it would impact on your individual rights and fundamental freedom

Right to request rectification of your personal data if they are incorrect or obsolete

Right to withdraw your consent to process your personal data, at any time, for the cases where we rely on your consent for processing; we will not continue to process such personal data based on this consent. Note that withdrawing your consent may impact our ability to fulfill our obligations and your access to our Website and Solutions