Privacy Notice

1. OUR APPROACH TO PRIVACY

• 1.1  Future Perfect HK Ltd. and its affiliate entities-such as FP Philippines, Inc. (‘The Company’) is committed to ensuring the confidentiality, security and protection of personal data. This document gives details on how the Company uses and protects personal data for the purpose of obtaining the consent of data subjects, in pursuant with RA 10173 also known as the Data Privacy Act (DPA) of 2012, its Implementing Rules and Regulation (IRR), and other relevant laws of the Philippines.
• 1.2  The Company operates an employee and applicant testing platform that allows potential or current employees to take assessments through our website at https://applicant.buplas.com/ (the “Service”).
• 1.3  Before accessing or using our Service, please ensure that you have read and understood our collection, storage, use and disclosure of your personal information as described in this privacy policy.’’

2. IDENTITY OF THE DATA CONTROLLER

• 2.1  We provide you access to the Service on behalf of your employer or prospective employer (the “Employer”). As such, most of the personal information we collect about you when you use the Service is collected on behalf of the Employer. The Employer is therefore the data controller in respect of the personal information referred to in paragraph 3 below. 
• 2.2  We do, however, collect some personal information for our own purposes, such as where we collect certain personal information to monitor and improve our Service. Company is the data controller in respect of the personal information referred to in paragraph 4 below.

3. PERSONAL INFORMATION WE COLLECT ABOUT YOU ON BEHALF OF THE EMPLOYER

• The personal information we may collect (hereinafter “PII”)
•  3.1 We collect personal information on behalf of the Employer that you voluntarily submit directly to us when you use our Service. This can include information you provide to us when you fill in a form on our Service, respond to questions, take a test on our Service or upload any audio-visual file through the Service.
• 3.2  We will indicate to you if the provision of certain personal information is mandatory or optional. If you choose not to provide any personal information marked as mandatory, the Employer may not be able to process your application or perform some of its obligations to you.
• 3.3  The list below sets out the categories of personal information we collect about you on behalf of the Employer:
  • (a) Contact information, such as your name, mobile number and email address. 
  • (b) Account log-in details.
  • (c) Test responses and results. Your responses to test questions and the associated score, report or other performance evaluation.
  • (d) Any other personal information the Employer may request or you provide in connection with your application, such as information contained in any documents you upload to the Service or audio-visual recording if applicable.
• 3.4  The Employer may use this information to:
  • (a) open and maintain your candidate records (if you are an applicant) or update and maintain your employment records (if you are an existing employee of the Employer);
  • (b) communicate with you as part of the testing process;
  • (c) process your application or otherwise assess your suitability for a particular role;
• 3.5  The processing of the above personal information is necessary for:
  • (a) the performance of a contract and to take steps prior to entering into a contract; and
  • (b) the Employer’s legitimate interests, namely internal administrative, team management purposes as well as managing recruiting activities and/or human resources records.
• 3.6  The Employer might use the personal information we collect about you on its behalf for other purposes in connection with processing your application, internal administration, team management and/or maintaining human resources records. Please refer to any further privacy notices provided by the Employer for further information about how the Employer will use your personal information, including the personal information we collect through the Service on its behalf.

4. PERSONAL INFORMATION WE COLLECT ABOUT YOU FOR OUR OWN PURPOSES

• Personal information we may collect
• 4.1 We collect PII that you voluntarily submit directly to us when you fill in a form or respond to questions on our Service. We may use this information to communicate with you in connection with the testing process.
• 4.2 The processing of this personal information is necessary for:
  •  (a) the performance of a contract and to take steps prior to entering into a contract; and
  •  (b) our legitimate interests, namely administering the Service and communicating with users.
• We may use this information to:
  •  (a) monitor and improve our Service; and
  • (b) provide additional services to the Employer, such as monitoring and improving its application processes.

• Personal information we may collect automatically
• 4.3 We also automatically collect the following personal information indirectly about how you access and use the Service and information about the device you use to access the Service:
  • (a) Information about how you access and use the Service. For example, the website from which you came and the website to which you are going when you leave our website, how frequently you access the Service, the time you access our Service and how long you use it for, the approximate location that you access the Service from, whether you access the Service from multiple devices, and other actions you take on the Service.
  • (b) Information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to our Service. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to our Service through the device, your Internet service provider or mobile network, your IP address and your device’s telephone number (if it has one).
• 4.4  We may use the personal information we collect from you to monitor and improve our Service and business, and to help us to develop new products and services.
• 4.5  The processing of the personal information we collect from you automatically is necessary for our legitimate interests, namely: to tailor our Service to the user and to improve our Service generally; to monitor and resolve issues; to communicate with users; to contact users; and for the detection and prevention of fraud.
• 4.6  We may anonymize and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving our Service and developing new products and features. We may also share such anonymized information with others.
• The categories of recipients to which we may transfer your personal information
• 4.7 As required in accordance with how we use it, we may share your personal information with the following:
  • (a) The Employer. We may share your Contact Information with the Employer for the purpose of providing our services to the Employer.
  • (b) Service providers and advisors. We may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing mailing, email or chat services, web hosting, or providing analytic services. These third parties are listed on our subprocessor listing (updated from time to time) and available from us upon request.
  • (c) Law enforcement, regulators and other parties for legal reasons. We may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of Company, its users or others.
  • (d) With other companies and brands owned or controlled by Company, and other companies owned by or under the common ownership as Company, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this policy.

5. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

• 5.1  Security. We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers and all transfers of personal information are protected by TLS encryption technology. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.
• 5.2  Retention Periods. We will store the personal information we collect for our own purposes for no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests. The Employer may have its own policies regarding how long they store the information we collect on its behalf – please refer to any privacy policies provided by the Employer or contact the Employer directly using the contact details below to find out more.

6. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

• As a data subject you have the following rights under Data Privacy Act of 2012: Right to be informed, Right to object, Right to access, Right to rectify or correct erroneous data, Right to erase or block, Right to secure data portability, Right to indemnified for damages, Right to file a complaint.

7. LINKS TO THIRD PARTY SITES

• Our Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

8. OUR POLICY TOWARDS CHILDREN

• Our Service is not directed at persons under 18 and we do not knowingly collect personal information from children under 18. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.

9. CHANGES TO THIS POLICY

• We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the “last modified” date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

10. NOTICE TO YOU

• If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Service.

11.CONTACTING THE EMPLOYER

• If you have any questions, comments and requests regarding your personal information collected by us on behalf of the Employer as set out in paragraph 3, please contact the Employer directly.