Privacy Policy for Hong Kong (Revised for Compliance)
WHO IS THE DATA CONTROLLER?
KeeSell Group Companies BV (registered and headquartered in Hong Kong) is the data controller responsible for processing your Personal Data on KEESELL.COM. For inquiries, contact our Data Protection Officer at keesell.com@gmail.com.
WHAT PERSONAL DATA DO WE PROCESS?
Application Data:
Collected via job applications, contact forms, or subscriptions (e.g., name, email, CV).
Used for recruitment, interviews, talent pool management, and future job offers.
Legal Basis: Consent (Art. 6(1)(a) GDPR for EU applicants) and legitimate interests under Hong Kong’s Personal Data Privacy Ordinance (PDPO).
Third-Party Candidate Data:
Sourced from public platforms (e.g., LinkedIn) or referrals.
Processed for recruitment purposes under legitimate interests (Art. 6(1)(f) GDPR for EU applicants).
Website Access Data:
Includes IP address, browser type, and device details for security and analytics.
Legal Basis: Legitimate interests (PDPO and GDPR).
HOW IS YOUR PERSONAL DATA SHARED?
Third-Party Service Providers:
Greenhouse Software, Inc. (USA) processes recruitment data. Transfers comply with Hong Kong PDPO via standard contractual clauses (SCCs).
KeeSell Group Affiliates:
Shared with global affiliates under strict confidentiality for recruitment or fraud prevention.
Legal Compliance:
Disclosed to authorities as required by Hong Kong law (e.g., fraud investigations).
Business Transfers:
Data may transfer to new owners during mergers/acquisitions to ensure service continuity.
Retention Periods:
Job Applications: Stored for 12 months (talent pool). Consent renewed via email.
General Data: Retained only as needed for services or legal obligations (e.g., employment laws).
HOW CAN YOU MANAGE YOUR DATA?
Access/Correction:
Registered users can edit or delete data via account settings.
LinkedIn-connected accounts: Update via LinkedIn’s settings.
Deletion Requests:
Contact keesell.com@gmail.com to erase data (subject to legal retention requirements).
EU Data Subjects:
Under GDPR, request access, rectification, or object to processing.
COOKIES & ANALYTICS
Google Analytics:
Anonymized IP tracking via cookies. Opt-out via Google’s tool.
LinkedIn Plugin:
Pre-fill applications with LinkedIn data. Manage preferences via LinkedIn settings.
COMPLIANCE & SAFEGUARDS
Adheres to Hong Kong PDPO and GDPR (for EU users).
Transfers outside Hong Kong use SCCs or Privacy Shield-certified partners.
Full Policy: KEESELL.COM/PRIVACY
Effective Date: 15-03-2025
