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Haalufa USA, Inc, Inc. and its subsidiaries respects your privacy and we acknowledge that you have certain rights related to any personal information we collect from you and we have certain obligations in respect of the same. Haalufa USA, Inc supports the various international and local privacy laws, and has procedures in place to meet the requirements of those laws. This Privacy Statement supports our privacy principles and informs you about our practices for gathering, storing, and using the personal information of individuals who use our websites, apply for or use our employment or outsourcing services, and those who are representatives of our customers (including prospective customers), service providers, and suppliers. We encourage you to review this information so that you may understand how we collect, use, and share your personal information.  So, when we mention “Haalufa USA, Inc”, “Haalufa USA, Inc”, “we”, “us” or “our” in this privacy statement, we are referring to the relevant DEPARTMENT OR DIVISION responsible for processing your personal information. If we change anything important about this statement (the information we collect, how we use it, or why we use it) we will highlight those changes in the Change History section at the end of this Privacy Statement and provide a prominent link to it for a reasonable length of time following the change and prior to the change taking effect. If you have questions, please contact our Data Protection Officer at: E-mail: inquiries@haalufausa.com  Post:    Haalufa USA, Inc, Inc. in the U.S. can be contacted at 10 Whippoorwill Drive, Saylorsburg, Pennsylvania 18353 (USA)

1.         Information We Collect

  • Haalufa USA, Inc collects, stores, and uses personal data to provide our recruiting, employment, outsourcing, and consulting services. We collect personal data about individuals who use our websites, apply for employment or engagement with us, or placement by us through our recruitment services, employees, and those who are representatives of our customers (including prospective customers). Haalufa USA, Inc does not knowingly direct its services or obtain, sell, or share information from children under age 16.
  • Most of this data is provided by you directly when you contact us, submit an application, attend an in-person recruiting event, through phone conversations, contact us about our services, or during your outsourcing or employment relationship.
  • We also collect data about individuals who are employed or engaged by our customers in connection with our provision of outsourcing and consulting services to those customers.  This is generally obtained through our interactions with customers, suppliers, and service providers.
  • When you interact with a Haalufa USA, Inc website or application, we collect data related to how you interact with that service by, for example, our use of cookies placed on your device.
  • We have set out further details below on the types of personal data we collect (and have collected in the prior 12 months), store, and use and the reasons we use your personal data.

2.         Why We Use Your Information – We will use your personal data where:

  • you have given your consent to the relevant processing activity for the purposes of which we have informed you. Where this is the case, you always have the right to withdraw that consent;
  • it is necessary for the performance of and compliance with your employment contract  or other applicable engagement contract with us or in order to take steps prior to entering into that contract or another contract with you;
  • we need to process your information in order to comply with a legal or regulatory obligation (for example, complying with duties under employment, social security, social protection, and tax legislation for example, complying with our obligations under equality legislation or in relation to statutory sickness or maternity rights);
  • exceptionally it is necessary for vital interests relating to you or another person (for example, avoiding serious risk of harm to you or others); or
  • it is necessary for our legitimate interests (or those of a third party) provided that our legitimate interests are not overridden by your interests or rights which require protection of your data.
  1. We will use special categories of personal data where:
  • you have provided your explicit consent. Where this is the case, you always have the right to withdraw that consent;
  • we need to do so to carry out our legal obligations (e.g. in the context of employment, social security and social protection law, or for a collective agreement) for example, complying with our obligations under equality legislation or in relation to statutory sickness or maternity rights;
  • it is necessary for the establishment, exercise, or defense of legal claims;
  • it is necessary for the purposes of preventative or occupational medicine, for the assessment of your working capacity, medical diagnosis, or provision of health care (for example, in relation to Occupational Health referrals and reports);
  • where it is needed for reasons of substantial public interest, such as for equal opportunities monitoring;
  • exceptionally, where it is necessary for vital interests relating to you or another person (for example, avoiding serious risk of harm to you or others) and where you are not capable of giving consent; or
  • where you have already made the relevant personal information public.
  • We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

4.         Legitimate InterestsAs mentioned above, we can, sometimes, use your personal information where this is necessary for our legitimate interests (or those of a third party). This includes where use of your personal information is necessary to:

  • ensure effective administration and management of your employment or engagement, benefits, management of the business, and business continuity;
  • ensure our assets are protected, kept confidential, and not used for inappropriate or unlawful purposes;
  • prevent, detect, or investigate unauthorized use of our systems and ensure we comply with law and our policies;
  • ensure we can contact you or your family in the case of an emergency;
  • check you are legally entitled to work, manage performance, discipline, and promotion processes;
  • manage training and development requirements;
  • maintain product development and enhancement, along with effective marketing through analytics and profiling for business intelligence;
  • deal with disputes and accidents and take legal or other professional advice;
  • comply with another country’s laws and regulations;
  • prevent fraud and financial crime; and
  • ensure network and information security.
  • If you would like further information on our legitimate interests as applied to your personal information, please contact the Data Protection Officer.

5.         Failure to provide information where required

  • Where we are requesting information from you in order to employ or engage you, or in order to place or job-match you, if you do not provide the information that we have identified as required we may be unable to properly assist with your request for employment, placement, or job-matching to be performed by Haalufa USA, Inc.

6.         Retaining Your Information

  • We will retain your personal information for as long as is necessary in connection with our agreement with you, to provide you with the services requested, for legitimate business reasons or for other necessary purposes such as compliance with a law, regulation, or other legal authority, or as is otherwise permitted to be maintained for other legal purposes, such as audit, security, fraud prevention, or preserving and defending Haalufa USA, Inc’s legal rights.  Additionally, job applicants and individuals whose assignment has ended will be maintained in Haalufa USA, Inc’s talent pool to be potentially contacted about other employment opportunities. European talent pools will retain your applicant data for no longer than three years. Individuals located outside of Europe will be retained in alignment with local legal requirements, but in all cases no longer than ten years. Where applicable, Haalufa USA, Inc will remove your information from the talent pool upon verified request.
  1. Where your information may be shared
  • Haalufa USA, Inc holds its employees, agents, and suppliers accountable for maintaining the trust that you place in us with your personal information.
  • For individuals, Haalufa USA, Inc shares the data that is necessary to perform its staffing and outsourcing services with other Haalufa USA, Inc entities, customers, suppliers, or with service providers that may be engaged to assist in managing the processes required to provide these services.
  • Any engagement of a customer, supplier, or service provider will be governed by appropriate contractual requirements prohibiting the use of your information for any purposes beyond those specifically directed by Haalufa USA, Inc, and requiring that they ensure sufficient administrative and technical security mechanisms are in place to prevent your information from being improperly used, disclosed, or accessed.
  1. Your Rights and Choices:
  • We respect your right to access and control your information. The amount of personal information you are required to supply when requesting our services is consistent with Haalufa USA, Inc’s interests in providing our services to you. Haalufa USA, Inc complies with applicable data protection laws and regulations. We process personal data about you for the purposes set out in this Privacy Statement, including to provide recruitment, placement, employment or outsourcing services, operate our business, comply with our legal and contract obligations, and fulfill other legitimate interests of Haalufa USA, Inc. In most countries in which Haalufa USA, Inc has an employment contract with you, the processing of contact, payroll, and benefit information is a contractual or statutory obligation, and failure to provide information to allow processing may restrict your ability to be employed by Haalufa USA, Inc. You may have certain rights in relation to your personal data. The availability of these rights and the ways in which you can use them are set out below in more detail.

9.         How We Transfer Information We Collect Internationally

  • International Transfers of Information We Collect: We collect information globally and may transfer, process, and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the services. Whenever we transfer your information, we take steps to protect it.
  • International Transfers Within Haalufa USA, Inc:To facilitate our global operations, we transfer information globally and allow access to that information from countries in which the Haalufa USA, Inc owned or operated companies have operations for the purposes described in this privacy statement. These countries may not have equivalent privacy and data protection laws to the laws of many of the countries where our customers and users are based. When we disclose information about you within and among Haalufa USA,, Inc, we make use of the EU-U.S. Data Privacy Framework to receive personal data transfers from the European Union/European Economic Area to the U.S. (see “EU-U.S. Data Privacy Framework Notice” section below), and the standard contractual data protection clauses, which have been approved by the European Commission, to safeguard the transfer of information we collect from the European Economic Area, the United Kingdom (the “UK”), and Switzerland.
  • International Transfers to Third Parties: Some of the third parties described in this privacy statement, where services are provided under a contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we disclose information of data subjects in the European Economic Area, the UK, or Switzerland, we make use of the European Commission-approved standard contractual data protection clauses, or other appropriate legal mechanisms to safeguard the transfer. You agree with this Privacy Statement and adhere to its languages, and by checking the box next to the content during the application submission. Please do not submit your information if you disagree with this privacy statement.
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