Positka FSI Pte Ltd and its subsidiaries and affiliates (collectively, "Positka," "we," "us," or "our") respect your privacy and are committed to protecting your personal data. This Privacy Policy explains what personal data we collect, how we use, share, and safeguard it, and the choices and rights you have, in connection with our websites, platforms, and services (the "Sites").
We process personal data in accordance with all applicable data protection and privacy laws in the jurisdictions in which we operate. Where different legal requirements apply to you, we apply protections designed to meet a high global standard. This policy is intended to operate globally and is not specific to any single country.
This policy applies to visitors, clients, candidates, event participants, and other individuals who interact with Positka. By using our Sites, you acknowledge the practices described in this policy.
For most personal data collected through our Sites (for example, recruitment, marketing, and website analytics data), Positka acts as the data controller and determines the purposes and means of processing.
Where Positka processes personal data on behalf of a client as part of delivering our analytics or advisory services, we act as a processor, handling data only on that client's documented instructions and under the terms of our agreement with them. In such cases, the client's own privacy notice governs how that data is used, and you should direct requests to that client.
If you are unsure which role applies to your data, please contact us using the details in the "How to Contact Us" section below.
We collect personal data in the ordinary course of our business activities with associates, clients, and partners, including in connection with client services. We also collect personal data when you:
The data collected varies by activity and may include your name, mailing address, email address, phone or fax number, and background information relevant to a job application.
We also automatically collect certain technical information about the devices you use to access our Sites, such as IP address, device identifiers, browser type, and browsing behaviour, gathered through cookies, web beacons, pixels, and similar technologies (collectively, "Cookies and Tracking Technologies"). This data may be linked to a unique identifier and, where applicable, to other personal data you have provided.
We do not seek to collect sensitive or special-category personal data (such as health, biometric, racial or ethnic, religious, or similar information) unless it is necessary and permitted by law. Where we do process such data, we will do so only with your explicit consent or where otherwise required or permitted by applicable law, and we will apply enhanced safeguards.
Positka may also receive personal data about you from third parties, such as data brokers, aggregators, or publicly available sources including social media platforms, during our business activities. We may combine this with data we already hold, or use it independently, for purposes such as benchmarking and analytics (for example, analysing recruiting trends across an industry).
Where we obtain personal data that was not collected directly from you, we will, where required by applicable law, inform you of the source of the data, the categories of data concerned, and the purposes for which we use it. We take reasonable steps to confirm that the third party has provided transparent information about its collection, use, and disclosure of that data, and has a lawful basis to share it with us.
We use the data we collect to:
We rely on one or more of the following legal bases to process your data: your consent; the necessity of processing to perform a contract with you or take steps at your request before entering a contract; our legitimate business interests (such as improving our services, operating analytics, or ensuring security), balanced against your rights and interests; and compliance with a legal obligation.
By way of example, we rely on contractual necessity to process recruitment applications, legitimate interests to operate site analytics and security, and consent for marketing communications and non-essential cookies. Where we rely on consent, you may withdraw it at any time as described in Section 5, without affecting the lawfulness of processing carried out before withdrawal.
We may combine and analyse personal data to evaluate and offer content and services most relevant to you and may retain personal data on file to contact you in future, subject to the retention limits described in Section 9.
Please be aware that any information you choose to disclose publicly on our Sites (for example, in a forum) may be collected and used by others. Positka is not responsible for the actions or policies of third parties in connection with information you disclose publicly.
Where we rely on your consent to process personal data or to set non-essential Cookies and Tracking Technologies, we obtain that consent in a manner that is freely given, specific, informed, and unambiguous, through a clear affirmative action. In practice, this means:
If you do not provide consent where it is required, we may be unable to provide certain services or communications that depend on that consent.
Positka and its service providers may use first- and third-party Cookies and Tracking Technologies, including web beacons, to operate our Sites and services and to collect analytics on how they are used, including whether communications we send are opened or clicked.
Cookies that are strictly necessary to operate our Sites are always active. For all other categories — such as analytics, performance, functional, and advertising cookies — we obtain your consent through a cookie banner or preference centre before those technologies are set on your device. You can review and change your cookie choices at any time through our cookie preference settings, and you can also control cookies through your browser settings.
Where a recognised browser-based privacy or opt-out signal is legally required to be honoured, we will treat it as a valid request to opt out of the applicable processing.
We use a few third-party tools to operate our Sites, understand how they are used, and manage our marketing and communications. These tools may set cookies or process personal data on our behalf, subject to the consent controls described above.
Our website uses Zoho Analytics, a web analytics service provided by Zoho Corporation, to help us analyse how our Sites are used. Information generated, such as time, place, and frequency of visits and your IP address, is transmitted to and stored by Zoho. Zoho applies privacy-enhancing measures including IP anonymisation, encryption of data in transit, and retention limited to what is necessary to provide the service. More information is available in Zoho's cookie and privacy policies.
Our website uses Google Analytics, a web analytics service provided by Google, to understand how visitors use our Sites. Google Analytics uses cookies that transmit information such as time, place, and frequency of visits, including your IP address, to Google. We apply IP anonymisation so that your IP address is shortened before being processed where this feature is available. We also use Google Tag Manager, a tag management system that helps us deploy and manage tracking and analytics tags across our Sites without changing the data those tags collect. You can opt out of Google Analytics using the browser add-on provided by Google.
We use UTM parameters — tags appended to URLs in our marketing campaigns — to understand which channels and campaigns drive traffic and engagement to our Sites. UTM data is reviewed at an aggregated level within our analytics tools.
Our Sites may allow you to sign in or associate a social network account, including but not limited to LinkedIn, X (formerly Twitter), Facebook, and YouTube. If you connect a social account, you give us permission to access the information available in your public profile, which may include your email address, name, profile picture, and location, depending on that platform's settings. We do not store your social network login credentials. Your use of a social network remains governed by that platform's own privacy policy.
Positka may use artificial intelligence (AI) and machine learning tools, including in the delivery of our analytics and advisory services to clients, and in certain internal processes such as candidate screening and content personalisation.
Where AI is used to support a decision that may significantly affect you, a human reviews the outcome before any final decision is made. You may request human review, express your point of view, or contest the decision in accordance with the "Your Data Protection Rights" section below. We do not use AI to make solely automated decisions that produce legal or similarly significant effects about you without appropriate safeguards. Where we engage third-party AI providers, we take reasonable steps to ensure they process personal data in a manner consistent with this Privacy Policy and applicable law.
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements. When determining retention periods, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes of processing, and whether those purposes can be achieved by other means.
Where we retain data for longer than the original purpose requires (for example, for analysis or historical record-keeping), we will do so only where supported by a lawful basis, and we will anonymise or aggregate the data where practicable so that it can no longer be associated with you. When personal data is no longer required, we securely delete or anonymise it.
We may share personal data with: our subsidiaries and affiliates; service providers and processors who perform services on our behalf (such as hosting, analytics, and communications) under contractual confidentiality and data-protection obligations; professional advisers; and regulators, law-enforcement bodies, or other authorities where required by law or to protect our rights. We may also share data in connection with a corporate transaction such as a merger, acquisition, or asset sale. We do not sell your personal data.
Because we operate globally, your personal data may be transferred to, stored in, and processed in countries other than the one in which it was collected, including countries whose data protection laws may differ from those in your jurisdiction. Where we transfer personal data across borders, we implement appropriate safeguards required by applicable law — such as standard contractual clauses or equivalent mechanisms — to ensure your data remains protected. You may contact us for more information about these safeguards.
We maintain appropriate technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure, loss, or destruction. These measures include access controls, encryption of data in transit, monitoring, and staff confidentiality obligations. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
We maintain procedures to detect, investigate, and respond to personal data breaches. Where a breach is likely to result in a risk to your rights, freedoms, or interests, we will notify the relevant supervisory authority and affected individuals without undue delay, in the manner and within the timeframes required by applicable law, and we will take steps to mitigate any potential harm.
Subject to applicable law and any exceptions it provides, you may have the following rights in relation to your personal data:
To exercise any of these rights, please contact us using the details below. We will respond to your request within the timeframe required by applicable law and, where none is specified, without undue delay and generally within one month. We may need to verify your identity before acting on your request. There is normally no charge, although we may charge a reasonable fee or decline to act where a request is manifestly unfounded, excessive, or repetitive, as permitted by law.
Our Sites and services are not directed to children, and we do not knowingly collect personal data from children below the age of consent applicable in their jurisdiction. Where the processing of a child's data requires parental or guardian consent under applicable law, we will seek such consent, and we do not knowingly conduct behavioural tracking or targeted advertising directed at children. If you believe we have collected data from a child without appropriate consent, please contact us and we will take steps to delete it.
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the "Last updated" date and, where appropriate, provide additional notice or seek your consent as required by law. We encourage you to review this policy periodically.
If you have questions, concerns, or requests regarding this Privacy Policy or our handling of your personal data, or if you wish to exercise your rights, please contact our Data Protection / Information Security team using the contact details published on our website. If you are not satisfied with our response, you may have the right to contact the data protection authority in your jurisdiction.
Looking for general information or have a specific question? Fill the form below or drop
us a line at susan@positka.com.
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