Legal

This Job Applicant and Employee Data Protection Policy (“Data Protection Policy”) applies to all employees of and prospective employees or job applicants to Airship Global Private Limited (“Company”). The purpose of this Data Protection Policy is to explain how the Company collects, uses and discloses Personal Data of employees and prospective employees or job applicants which is subject to the Personal Data Protection Act 2012 (the “Act”), during the course of such person’s candidacy, job application process and to the extent applicable, employment with the Company.

In this Data Protection Policy, unless otherwise indicated or the context requires otherwise, reference to “you” or “your” refer to the employee or prospective employee or job applicant, and reference to “Airship”, “we”, “us” or “our” refer to the Company.

You hereby acknowledge and agree that Personal Data of yours or relating to you (including Personal Data provided by, or on behalf of, you or otherwise collected by the Company from third party or publicly available sources) may be collected, used and/or disclosed by the Company (and our affiliates, related corporations, service providers and agents) for the purposes as set out herein (and as may be updated from time to time).

It is important that you read and retain this Data Protection Policy, together with any other privacy notice or policy we may provide on specific occasions when we are collecting or processing Personal Data relating to you, so that you are aware of how and why we are using such Personal Data about what your rights may be.

1. What Personal Data do we collect?
   1. In this Data Protection Policy, “Personal Data” means any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
   2. During your employment with the Company or as part of the job application process, we will collect, use and/or disclose Personal Data of yours or relating to you.
   3. Examples of types of Personal Data we collect may include, but are not limited to:
      1. title, full name, date of birth, gender, citizenship, nationality, marital status, immigration status, residential address, telephone number(s), email address(es), online identifiers, Internet Protocol address;
      2. personal and family details including place of birth, race, ethnic origin, dependent information, language, family composition, emergency contacts, beneficiaries and next of kin;
      3. professional and work information and data with respect to the acceptance of the offer of employment, including proof of eligibility to work and details of any visa or work permit application, data with respect to career management and development, including date of hire, employee category, full/part-time status, qualifications;
      4. audio, video and other data related to use of building access control systems, including time and location of entry and exit, access to restricted zones and security camera footage data, and use of the company network systems;
      5. in respect of employees:
         1. your NRIC, passport or other unique identification number presented for identification purposes;
         2. bank account details, payroll records, and tax information;
         3. geolocation data about you during your employment with Airship, if, for example, you are operating a company-issued device, such as a company-issued mobile phone, as part of the fulfilment of your employment duties;
         4. health information regarding you and your family, including physical and mental health or condition, medical and health screening details, disabilities, meal preferences and food allergies and records of benefits entitlements and utilization;
         5. references, résumé(s) or curriculum vitae, language(s) spoken, background checks (including education, professional licenses, civil and criminal records, and regulatory matters) and membership of professional bodies, presence and absence (whether due to sickness or otherwise), accident reporting, occupational health information, work schedules, responsible duties, employee ID, time recording, vacation, all types of leave (including but not limited to maternity/paternity leave), training records, performance evaluations and documents relating to complaints, grievances, disciplinary actions, career progression and promotions, demotions, retirement and termination of employment or engagement and related data including notice periods, reasons for leaving and exit interviews;
         6. audio, video and other data related to access to and usage of office equipment and resources including but not limited to fixed and mobile phones, computer systems, email and the internet, office messaging systems (including Slack and GSuite), cost recovery systems, document management systems, contact management systems and online databases; and
         7. data related to travel for the purposes of the working relationship, including driver’s license details, special meal requests and travel preferences.
   4. For Airship employees, we may monitor use of your Airship email account, office messaging systems (including Slack and GSuite), Airship phone lines (including any mobile provided by Airship for your business use), the internet and any network usage while on Airship systems in accordance with Airship policies.
   5. We receive information about you directly from you, as well as from other sources including Airship systems, benefits and insurance providers, social security (or social insurance) agencies, past employers, recruitment agencies, compliance monitoring agencies, sources that supply employment verification services as well as public searches.
   6. For Airship employees, we collect additional Personal Data in the course of job-related activities throughout the period you work for us. This can be in the form of information you provide directly to us or information which we collect automatically about you, such as monitoring computer access and usage.
   7. Where you disclose Personal Data of other individuals to us (e.g. next-of-kin, dependents) to us, you warrant that you have obtained the prior consent of such individuals for us to collect, use, disclose and/or process such Personal Data for the relevant purpose for which you made the disclosure or as was notified to you at the relevant time and such other purposes as described in this Data Protection Policy.
   8. It is important that the Personal Data we hold about you is accurate and current. Please inform us at the earliest opportunity if Personal Data relating to you or that you provided to us changes during your relationship with us, so that our records can be updated. These include changes to the following (where applicable):
      1. name;
      2. contact details (home address, phone number(s), email address(es));
      3. marital status;
      4. dependents (e.g. for medical insurance purposes);
      5. emergency contacts and next of kin;
      6. bank details for payment of wages; or
      7. professional and educational qualifications.
2. How and why do we collect, use and disclose Personal Data?
   1. Personal Data collected from you may be used, disclosed and processed by us for any, some or all the following purposes:
      1. in respect of job applicants:
         1. to assess and evaluate your suitability for employment in any current or prospective position within Airship and our related corporations including Airship Group,Inc., Urban Airship UK Ltd, Airship France SAS, Airship Business France SAS, and Urban Airship Germany GmbH, and the terms and conditions of employment;
      2. in respect of employees:
         1. to make decisions related to your employment;
         2. to administer your pay and benefits, for example, making tax and other required deductions and making decisions about salary and compensation;
         3. to administer health insurance programs and manage or process any claims arising thereunder;
         4. to manage your holiday, sick leave and any other absences including family leave;
         5. to ship to you equipment or office accessories or use your address (with your name redacted out) in heat map exercises with regards to location of your residence in relation to a Company office location;
         6. to implement health and safety regulation or security measures, for example, ensuring the physical safety of our facilities, resources, employees, and other people from threats; preventing fraud and to secure our systems, data, resources, and facilities from unauthorized access or exploitation; monitoring compliance with our IT policies; ensuring network and information security, including preventing unauthorized access to our computer and electronic communications systems, and preventing malicious software distribution; and investigating theft and other illegal activities;
         7. to appraise and manage your performance and provide you with training;
         8. to deal with disciplinary matters and any grievance raised by or involving you;
         9. to ensure compliance with our rules and processes, for example:
            1. we monitor video camera records to ensure compliance with our policies regarding theft, health and safety and harassment; and
            2. we monitor use of our IT systems, including email, internet and intranet, Company mobile and landline phones, computers and tablets to ensure security of such systems, company data, customer data, and compliance with our security policies;
         10. to manage and plan our business, for example, conducting data analytics studies to review and better understand employee retention and attrition rates; and ascertaining and fulfilling education, training, and development requirements;
      3. to verify your identity and the accuracy of your personal details and other information provided;
      4. to enable us to contact you or communicate with you on any matters relating to your application or employment;
      5. to respond to any claims, actions or proceedings and/or to safeguard and enforce our legal rights and obligations (including but not limited to obtaining legal advice and dispute resolution);
      6. to conduct or assist to conduct investigations, including to prevent or investigate any wrongdoing, fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned;
      7. to meet or comply with any order or request of any court or governmental or regulatory authority or agency, and to assist in investigations and law enforcement by the relevant authorities and agencies;
      8. to meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations);
      9. to store or create backups of your Personal Data for contingency or business continuity purposes; and
      10. to generate internal reports and analyses, for example, annual, operational and management reports),

          (collectively, the “Purposes”).

   2. The Purposes may continue to apply even in situations where your employment with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
3. With whom might we share Personal Data?
   1. Personal Data relating to you may, in certain circumstances, be disclosed to third parties which include (and which may be updated from time to time):
      1. our related corporations, including:
         1. Airship Group, Inc.;
         2. Urban Airship UK Ltd.;
         3. Airship France SASand Airship Business France SAS; and
         4. Urban Airship Germany GmbH;
      2. any agent, contractor, vendor, or service provider of ours or our related corporations (and their respective service providers, subcontractors or related corporations), including:
         1. cloud and other data management and storage providers, to store the Personal Data you provide and for disaster recovery services, as well as destruction of information, including but not limited to AWS, Google, and Microsoft;
         2. IT issues ticketing service providers;
         3. IT service providers, for example, entities that assist with people operations, website design, hosting and maintenance, data and software storage, and network operations systems;
         4. invoice and payment tracking services providers;
         5. Human Resources information systems and payroll services providers, for example, Ultipro;
         6. recruitment vendors that assist with the application process including assessing job applicant qualifications and providing the platform through which applicant submit their applications;
         7. analytics service providers, including entities that analyze traffic to and on our website and assist with identifying and communicating with potential customers;
         8. security vendors, for example, entities that assist with security incident verification and response, service notifications, and fraud prevention;
         9. benefits and insurance providers, for example, health insurance providers;
         10. corporate credit card providers;
         11. emergency contact system providers;
         12. corporate services vendors to Airship;
         13. travel management providers; and
         14. office supplies and equipment providers;
      3. government or regulatory authorities or bodies, law enforcement agencies, and organisations to which we or our related corporations are under an obligation to make disclosure under the requirements of any applicable law, regulation or commercial arrangement;
      4. individuals and entities involved in any proposed or actual merger, acquisition, sale, corporate reorganization or financing (including any transfers made as part of an insolvency or bankruptcy proceeding), or similar transaction with us, including in the event of the sale of all or part of our assets or business;
      5. professional advisors and consultants, including tax, auditing, accounting and legal advisors; and
      6. your bank, mortgage company, lender, credit agency, other financial institutions, landlord, prospective employer, relocation company, visa or travel agency, but only with your consent.
   2. Your Personal Data may be transferred out of, processed and accessed outside of Singapore, including the European Economic Area (EEA), United Kingdom and United States of America. We will endeavour to ensure that transferred Personal Data is subject to a standard of protection comparable to that under the Personal Data Protection Act 2012. In accordance with applicable data protection and privacy laws and regulations, we will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside of Singapore. By providing us with Personal Data, you consent to such transfer and/or access. If you would like to know more about this, please contact us at privacy@airship.com.
4. How long might we retain Personal Data?
   1. We retain Personal Data as long as necessary for the purpose for which it was obtained. We may continue to retain the Personal Data for a longer period for operational business and legal purposes, including enforcement of our contractual and legal rights.
   2. What this means in practice will vary as between different types of Personal Data, and when we consider our approach, we take into account any ongoing need for Personal Data, as well as our legal obligations, for example in relation to tax, health and safety, employment rights and potential or actual disputes or investigations.
5. How will Personal Data be protected?
   1. We take the security of Personal Data very seriously and we have put in place internal controls and security measures to protect it. Access to your Personal Data is restricted to those employees, workers and agents who strictly need it. We also have cyber security measures in place as set out in our IT policy in the staff handbook or in our security policies. We take steps to ensure that third parties who have access to Personal Data only process it on our instructions and are subject to a duty of confidentiality. We have put in place appropriate procedures to deal with any suspected data security breach.
6. What are your rights in respect of Personal Data?
   1. Subject to the limitations and exceptions set out under applicable laws, you have the right to:
      1. access Personal Data we hold about you and obtain information about the ways in which such Personal Data has been or may have been used or disclosed by us within a year before the date of your request;
      2. withdraw your consent at any time where Personal Data is collected, used or disclosed with your consent (but please note that depending on the nature of the request and the circumstances, this may impact our ability to continue our relationship with you);
      3. request that we correct Personal Data we hold about you so that it is accurate; and
      4. exercise any other rights, with respect to Personal Data about you, available to you under applicable laws.
   2. You may exercise these rights by contacting us at privacy@airship.com.
7. Updates
   1. Except where expressly agreed as part of an employment contract between you and Airship, this Data Protection Policy will not form part of any potential employment contract.
   2. We may update this Data Protection Policy from time to time. Any such updated Data Protection Policy will be made available to you by posting it here.
   3. If you are an Airship employee, we will provide you with a new privacy notice when we make any substantial updates, and we will also notify you in other ways from time to time about the processing of your Personal Data. For Airship employees, any such updated notice will be made available to you by the Airship People Operations team via email to your Company email address and by posting it here.
8. Contacting Us
   1. If you have any questions about anything in this Data Protection Policy or would like to exercise any of your rights as outlined above, please contact the Airship Privacy team at: privacy@airship.com.