Privacy Policy

Last updated on October 31, 2022

People Intelligence Singapore Pte. Ltd. respects the privacy of users and visitors to its website. This Privacy Policy describes how People Intelligence Singapore Pte. Ltd. (“Omni HR”, “Omni” “we”, “our” or “us”) collects, stores, uses and discloses data. It also describes your rights with respect to your data.

Please read this Privacy Policy carefully and make sure that you fully understand it. You are not legally required to provide us with any of your personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our services providers, please simply do not visit or interact with our Sites, nor use our Services. You may also choose not to provide us with “optional” personal data (i.e. “not required” fields on forms), but please keep in mind that without it we may not be able to provide you with the full range of our Services or with the best user experience when using our Services. By using our Sites or Services, you are expressly consenting to our collection, processing, storing, disclosing, using and handling of your data as set forth in this Policy now, and as amended by us from time to time.

When we use the term “personal data” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual. We will not process any special (or sensitive) categories of Personal Data or Personal Data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in our Terms of Services (“Terms”).

Who do we collect data from?

  • Business User / HR Managers: Personal data that we collect, process and manage on behalf of our business customers / HR Managers (“Business Customer”), submitted to our cloud-based employee management system (hereinafter referred to as the “Platform”). We also collect personal data of the internal focal persons of such Business Users / HR Managers, who directly engage with Omni concerning the Omni account of such Business User / HR Manager, such as Admins or billing contacts. We may also collect and process personal data of personnel / employees of such Business Users / HR Managers, provided to us by such Business Users / HR Managers for availing our Services.
  • Employees: Personal data of the Employee where the Employee is directly interacting with the Sites or using the Services for himself / herself.
  • Visitors / Users of our Sites / Services: Data relating to visitors / users of our websites (including https://omnihr.co/), participants at our events, and any other prospective customer, user or partner (collectively, “Prospects”) who visits or otherwise interacts with our websites, digital ads and content, emails, integrations or communications under our control (“Sites”, and collectively with the Platform – the “Services”).

What data do we collect?

We may collect the following categories of personal data:

From Business Customers

From Employees

  • Name, email, phone number, position, workplace, profile picture, login credentials, contractual, billing details, payment details, educational qualification, employment history, and any other information submitted by you or otherwise available to us when you sign up or log in to the Platform, when creating your individual profile (“User Profile”), or by updating your account. Such information may also include special categories of personal data (such as information about your health and finance) and information relating to criminal convictions and offences (only if we have your consent and subject to local laws).
  • We collect this information directly from you, or from other sources and third parties such as your employer / HR Manager, organizers of events or promotions that both you and us were involved in, and through the use of tools and channels commonly used for connecting between companies and individual professionals in order to explore potential business and employment opportunities, such as LinkedIn, ZoomInfo, etc.

From all Users / Visitors of our Sites / Services (apart from the aforesaid)

  • Connectivity, technical and usage data, such as IP addresses and approximate general locations derived from such IP addresses, device and application data (like type, operating system, mobile device or app ID, browser version, location and language settings used), activity logs, the relevant cookies and pixels installed or utilized on your device, and the recorded activity (sessions, clicks, use of features, logged activities and other interactions) in connection with our Services. We collect and generate this information automatically, including through the use of analytics tools (including cookies and pixels) – which collect data such as: how often one visits or uses the Sites, which pages they visit and when, which website, ad or email message brought them there, and how they interact with and use the Sites and its various features.
  • Personal data contained in any forms and inquiries that you may submit to us, including support requests, interactions through social media channels and instant messaging apps, registrations to events that we host, organize or sponsor, and participation in our online and offline communities and activities; surveys, feedback and testimonials received; expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement; and sensory information including phone call and video conference recordings (e.g., with our customer experience or product consultants), as well as written correspondences, screen recordings, screenshots, documentation and related information that may be automatically recorded, tracked, transcribed and analysed, for purposes including analytics, quality control and improvements, training, and record-keeping purposes.

We collect this information you provide to us when you request or purchase products, services, or information from us, register with us (including when you link your profile on a third-party site or platform with your registration account), participate in forums or other activities on our sites, respond to guest surveys, call us, or otherwise interact with us using one or more devices. You may provide information in a variety of ways, including by typing or using voice commands.

From time to time, we may receive Personal Data about you from third party sources like databases and social media but only where we have checked that these third parties either have your consent to or are otherwise legally permitted or required to disclose your personal information to us. The types of information we obtain from such third parties include your name, e-mail address, postal address, location, designation, and telephone number.

Use of Cookies and other technologies to collect information

Our Sites and Services (including some of our Services Providers) utilize “cookies”, anonymous identifiers, pixels, container tags analytics signals, web beacons, log files, and other technologies in order for us to provide and monitor our Services and Sites, to ensure that they perform properly, to analyze our performance and marketing activities, and to personalize your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall personal data, such as an IP address, as indicated by a Prospect or User. You may also use the “Cookie settings” feature available in our Services depending on your location and activity on our Services, as applicable. We may also use Google Analytics to help us understand how you use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application. However, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or to block or remove cookies altogether.

How do we use your data & what legal bases do we rely on?

We use personal data for the following purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):

How we use your data

Legal basis

For providing you with Services

Administering your account (including when you subscribe and sign-up to any of our Services), evaluating and assessing the needs of your business to suggest suitable Services and respond to service requests, questions or concerns, enabling your transactions with other users when you use our Services, to prevent or respond to any misuse of our Services or Applications or any violations of our Terms and any applicable laws, for collecting subscription fees.

We process your Personal Data for these purposes based on our legitimate interests or a third party’s legitimate interest to ensure we provide our Services in an effective, safe and efficient manner.  Where we process your Personal Data for administering your account, or to the extent necessary to collect subscription fees, we do so for the purposes of our contract with you.

For recruitment

When you apply for an open position by either populating / filling the application form, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf, we will use such data to evaluate you for any open positions.

Where we use your Personal Data for recruitment purposes, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions.  We will not process any special (or sensitive) categories of Personal Data or Personal Data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

For hosting and managing events, programs, and any other promotions

It is necessary for us to use your Personal Data in this way to perform our obligations in accordance with any contract that we may have with you where you have signed up to attend an event, program, etc., or it is in our legitimate interest or a third party’s legitimate interest to use Personal Data in such a way to ensure that the event / program is operated in a secure, efficient and effective way or it is in our legitimate interest to use your personal data to enable us to administer our promotion fairly and effectively and to ensure that we comply with self-regulatory codes governing the operation of promotions. We may specifically ask your permission to use your photos, quotes, comments, testimonials, reviews, or other content that you make available or publish at the event or program. Where this is the case, our processing of such Personal Data will be based on consent (or,  if we enter into a contract with you for this purpose,  on the performance of the terms of the said contract).

For participation in public forums, Community platform, Forms, etc.

When you visit or register for our publicly accessible community forums and blogs or submit any forms on our Site, your testimonials / comments / reviews which may contain your Personal Data, may be read, collected, and used by others who access them. Where we use your content as aforesaid, it is in our legitimate interest to use any Personal Data that you provide to us to ensure that we provide the relevant Services in an effective way. Prior to posting the testimonial, we will obtain your consent to post your name along with the testimonial. If you do not consent we are only allowed to use the testimonial in a fully anonymized way. If you want to revoke your consent and your testimonial to be removed, please contact us.

For providing you newsletters, updates, etc. upon your subscription and for sending advertising and marketing communications

If you have requested content from us, i.e. a newsletter, it is in our legitimate interest to use your Personal Data in such a way to ensure that we process your request in an effective way. It is in our legitimate interest to use your Personal Data for advertising and marketing purposes (except where we are required by applicable law to obtain your consent).

For personalised / targeted advertising and marketing, including through the use of cookies and other similar technologies

Where we use your personal data to display online personal advertisement to you, we rely on the consent that you have provided in respect of the collection of such data, or, subject to local law, it is otherwise in our legitimate interests to promote our Website and our Services to you. Please see “Use of Cookies and other technologies to collect information” section to learn more.

For performing analytics in order to assess your business needs, to suggest you suitable services, to respond to customer service requests, or for product improvement services

It is also in our legitimate interests to process Personal Data in order to perform analytics, train our algorithms, improve, enhance, develop, support and operate the Services and its availability, compile reports and record insights into usage patterns, develop new products and services using machine learning technologies and to better serve you and be able to provide customized content and features to you.

For administration, business transition and legal compliance

Where we use your Personal Data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your Personal Data to comply with any legal obligations imposed upon us, such as a court or government order.

For security

It is in our legitimate interests to process your Personal Data so that we can keep our Platform and premises secure and provide a safe environment for our personnel and visitors.

We use the information about you we receive from third parties to maintain and improve customer support experience, improve the accuracy of the records we hold about you and for our sales and marketing purposes.

When processing your Personal Data received by third parties for these purposes, we will rely on the consent that you have given such third party to share data with us. Otherwise, subject to local law, our processing activities will rely on our legitimate interests to improve our customer service and ensure our marketing databases are accurate.

Where is your data stored and when is it retained?

Data Location: We and our authorized Service Providers (defined below) maintain, store and process personal data in Singapore and other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by applicable law.

Omni headquarters are in Singapore. While privacy laws vary between jurisdictions, Omni, its affiliates and Service Providers are each committed to protect personal data in accordance with this Privacy Policy, customary and reasonable industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. These steps may include implementing standard contractual clauses where recognized by law, obtaining your consent, or other lawful means of transferring personal information.

Data Retention: We may retain your personal data for as long as it is reasonably needed in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy and at our reasonable discretion. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of such data, the potential risk of harm from unauthorized use or disclosure of such data, the purposes for which we process it, and the applicable legal requirements. If you have any questions about our data retention policy, or wish to inquire about your personal data in our possession or request the deletion of any personal data that you have submitted to us, please contact us at support@omnihr.co

When and with whom do we share your data?

When processing your Personal Data, we may need to share it with other third parties (including other entities within our Group of Companies), as set out below. Data with third parties are shared only as reasonably necessary to provide the Service(s) and subject to confidentiality obligations. This list is non-exhaustive and there may be circumstances where we need to share Personal Data with other third parties:

  • With third party service providers providing us with services, such as research and analytics, anti-spamming and anti-phishing services, marketing and data enrichment or for them to reach out to you on our behalf.
  • With third parties assisting us in providing the Services, and assisting us with marketing, advertising our product/service offerings, or providing, maintaining and improving the features and functionality of the Services.
  • With payment processors who process your credit card and other payment information.
  • If you register to any event that we host, organize or sponsor, with your permission we may share your registration details with others, including the hosts, organizers, speakers, services providers and sponsors of that event.
  • With third-party social media networks, advertising networks and websites.
  • If you submit a public review or feedback, note that we may (at our discretion) store and present your review publicly, on our Sites and Services.
  • In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations.
  • We may share your personal data with others if we believe in good faith that this will help protect the rights, property or safety of Omni, any of our Users, or any members of the general public.
  • With affiliates of Omni and companies that we will acquire in the future when they are made part of our group – this may be for customer support, marketing, technical operations, account management or organizational purposes and to provide, enhance and improve the Services. In addition, should Omni or any of its subsidiaries undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your personal data may be shared with the parties involved in such an event.
  • With auditors, lawyers, accountants and other professional advisers who advise and assist us in relation to the lawful and effective management of our organization and in relation to any disputes we may become involved in

Communications

We engage in Services and promotional communications, through email, phone, SMS and notifications.

Services Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. You can control your communications and notifications settings from your User Profile settings, or otherwise in accordance with the instructions that may be included in the communications sent to you. However, please note that you will not be able to opt-out of receiving certain Services communications which are integral to your use (like password resets or billing notices).

Promotional Communications: We may also notify you about new features, additional offerings, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or email), through the Services, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify Omni at any time by sending an email to us, changing your communications preferences in your User Profile settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change email preferences” instructions contained in the promotional communications you receive.

Behavioural advertising and Re-marketing: We may display personalised content, including from third party content publishers, and personalise ads, based on the information we have about you. We may also work with third parties such as network advertisers to serve ads on our Website and on third-party websites or other media, including targeted ads. These third parties may use cookies, JavaScript, and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

How do we keep your data secure?

The security, integrity, and confidentiality of your information are extremely important to us. Omni takes all appropriate technical and administrative security measures to protect your personal data from loss and misuse. Your data is stored in a secure operating environment, which is not publicly accessible. Your personal data is encrypted when transferred using Secure Socket Layer (SSL) technology. This means that communication between your computer and our servers uses a recognized encryption method, provided your browser supports SSL. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable.

We have appropriate internal policies regarding standard operating procedures in handling your personal information and/or data. Only employees who need access to such information to perform a specific job, as provided in this Policy, are granted access to personal data. In addition, we are committed to taking strict action to enforce the privacy responsibilities of our employees.

In the event that the security of information and/or personal data is breached as a result of a security failure, We will immediately, and not later than any period specified under any applicable law, notify the Users whose personal information security is breached.

Where we have given you a username, password and/or security information which enables you to access particular features of the Service, you are responsible for keeping these access credentials confidential. You must not share these details with anyone, or store them in a way that may allow a third party to access them.

Your rights

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. In accordance with applicable law and subject to the terms of this policy, your controls and choices may include:

  • Right to obtain information about the clarity of identity, the basis of legal interests, the purpose of the request and use of personal data, and about our accountability;
  • Correcting, updating, and deleting your account with us;
  • Choosing or changing your choices for subscriptions, newsletters, and alerts;
  • Right to withdraw consent granted for personal data;
  • Right to data portability;
  • Choosing whether to receive from us offers and promotions for our products and services, or products and services that we think may be of interest to you;
  • Controlling targeted advertising from many ad networks and partners; data exchanges; and marketing analytics and digital advertising and marketing service providers;
  • Choosing whether we share your personal information with other companies so they can send you offers and promotions about their products and services;
  • Requesting removal of your personal information from our Sites or Services;
  • Requesting access to the personal information we hold about you and that we amend or delete it.

If you wish to exercise your privacy rights under applicable law (including the EU or UK GDPR or the California Consumer Privacy Act (CCPA)) – such as (each to the extent applicable to you under the laws which apply to you) the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with Omni, or to restrict or object to such personal data’s processing (including the right to direct us not to sell your personal data to third parties now or in the future), or to obtain a copy or port such personal data, or the right to equal Services and prices (e.g. freedom from discrimination) – please contact us by email. If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EEA or the UK, as applicable.

Please note that when you ask us to exercise any of your rights under this Privacy Policy or applicable law, we may instruct you on how to fulfill your request independently through your User Profile settings; refer you to your Admin; or require additional information and documents, including certain personal data and credentials in order to process your request in a proper manner (e.g. in order to authenticate and validate your identity so that we know which data in our systems relates to you, and where necessary, to better understand the nature and scope of your request). Such additional information will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request, and of how each request was handled), in accordance with this Privacy Policy.

We may redact from the data which we make available to you, any personal or confidential data related to others.

Data controller/processor

Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “Services provider”), who processes such data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

Omni is the “data controller” of its Prospects’, Users’ and Business Customers’ personal data, as detailed in Sections above. Accordingly, we assume the responsibilities of a data controller (solely to the extent applicable under law), as set forth in this Privacy Policy.

Omni is the “data processor” of personal data contained in Business Customer Data, as submitted by our Business Customers and their Users. We process such data on behalf of our Business Customer (who is the “data controller” of such data) and in accordance with its reasonable instructions, subject to our Terms, (to the extent applicable) and other commercial agreements with such Customer.

Our Business Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on the Business Customer’s behalf or at their request, as well as all individuals whose personal data may be included in Business Customer Data processed through the Services, have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, use or other processing of data through our Services are fully met by the Business Customer. Our Business Customers are also responsible for handling data subject rights requests under applicable law, by their Users and other individuals whose data they process through the Services.

If you would like to make any requests or queries regarding personal data we process as a data processor on our customer’s behalf, including accessing, correcting or deleting your data, please contact the Business Customer’s Admin directly.

Additional notices

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. When we make material changes to this Privacy Policy, we will give notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Services or by sending an email. Your continued use of the Services after the changes have been implemented will constitute your acceptance of the changes.

California Requirements: This Privacy Policy describes the categories of personal information we may collect and the sources of such information, and our retention and deletion practices. We also included information about how we may process your information, which includes “business purposes” under the California Consumer Privacy Act (CCPA). We do not sell your personal information for the intentions and purposes of CCPA. We may disclose personal data to third parties or allow them to collect personal data from our Services as described hereinabove, if those third parties are authorized Services Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or if you integrate the Services of third parties with our Services, or direct us to disclose your personal data to third parties, or as otherwise described hereinabove.

If you have any questions or would like to exercise your rights under the CCPA, you can contact us by email.

Third Party Websites and Services: Our Services includes links to third party websites and services, and integrations with Third Party Services (as defined in the Terms). Such websites, services and Third Party Services, and any information you process, submit, transmit or otherwise use with or to such websites, services and Third Party Services, are governed by such third party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such websites, services and Third-Party Services. We have no liability or responsibility for the content, activities of such Third Party websites or services.

Age Limitations: To the extent prohibited by applicable law, Omni does not allow use of our Service and Website by anyone younger than 16 years old, or such other age prescribed by applicable law. We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16, or such other age prescribed by applicable law, is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email.

Questions, concerns or complaints: If you have any comments or questions regarding our privacy policy or practices, or if you have any concerns regarding your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by Omni, please contact Omni’s support at support@omnihr.co.

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