LMWN Group Recruitment Privacy Policy

Last Updated 20 October 2023
This Privacy Policy of LINE MAN (Thailand) Company Limited, LINE MAN Corporation Pte. Ltd, Wongnai Media Co., Ltd., LINE PAY Company Limited, and other subsidiaries, ("LMWN Group", "we", "us", or "our") is targeted towards applicants and potential recruits to the workforce of any of the companies in our LMWN Group with exception for our LINE MAN Drivers and Riders ("you", "your", or the "User"), and provides you with information on how we collect, use, and disclose your personal data in furtherance of our recruitment processes. We take the protection of your privacy seriously, and we want you to understand exactly how and why we use your information. Please read this Privacy Policy carefully as it describes how we collect, use, disclose, and/or transfer your personal data.

The Personal Data We Collect

We may collect the following types of personal data about you that are relevant to the Services:
  • Personal Identifierssuch as your full name, nickname, and images
  • Contact Informationsuch as your phone number, email address, physical address, LINE ID, and other applicable social media accounts
  • Profile Informationsuch as your language, education, work history and your skills and qualifications
  • Current Employment Informationsuch as evidence with regards to your employment history and remunerations (both monetary and non-monetary)
  • Official Documents Informationsuch as the personal data contained in your Thai ID card, passport, house registration, visa/work authorization, and signatures as necessary
  • Behavioral Informationsuch as your browsing history, orders and other behaviors collected through our cookies or other similar technologies when you visit our websites and other recruiting channels
  • Technical Identifierssuch as the technical identifiers we or a third party created for you, device ID, technical address, and carrier and operating system information as well as languages and timezones
  • Other Identifierssuch as those present in your resume, cover letter, tests answers or communications with recruiters
Note that, as a matter of practice, we do not generally collect your sensitive personal data, such as the data pertaining to your race, ethnic origin, political opinion, cult, religious or philosophical beliefs, sexual behavior, criminal record, health data, disability, trade union information, genetic data and biometric data. If you are required to send us documents or information containing sensitive personal data that is not required for the particular purpose you agree to redact such data before providing the document or information to us. For instance, when sending us a copy of your ID card you should cross out the sensitive information in the ID card, such as your blood type and religious beliefs, as applicable. In the event that we are intentionally collecting your sensitive personal data, we will only do so with your explicit consent and/or in strict compliance with the applicable laws.Additionally, in the event that you provide the personal data of other person to us, you are responsible for informing that person about our Services and the associated data processing via the relevant Privacy Policy prior to the submission of those persons' personal data to us, as well as obtaining their consents or relying on other applicable legal basis as exception to their consent for the disclosure of their data to us.Finally, please note that you are responsible for the accuracy of your own data and for notifying us of any changes in your personal data so that we can adjust your information to be as accurate, as up-to-date, and as complete as possible.

How We Collect Your Personal Data

Our sources of your personal data may include but is not limited to:
  • Information collected directly from you.These include, for example, the Personal Identifiers, Profile Information, Contact Information, Current Employment Information, Official Documents Information, and Other Identifiers that you have provided to us as part of our workforce recruitment processes
  • Information collected directly from your referees.These include, for example, your Personal Identifiers, Profile Information, Contact Information, and Current Employment Information shared to us via your referees
  • Information collected directly from recruiters we work with.These include, for example, your Personal Identifiers, Profile Information, Contact Information, Current Employment Information, and Other Identifiers shared to us via the recruiters we work with
  • Information collected automatically through your visits to our recruiting channels.These include, for example, the Behavioral Information and Technical Identifiers that we automatically create and/or collect through your use of our recruitment-related websites
  • Information collected from affiliates, group companies, and business partners.These include, for example, the Personal Identifiers, Contact Information, Current Employment Information, and Other Identifiers that we exchange with affiliates in the LMWN Group
  • Information collected from third-party.We sometimes receive your information from third-parties based on the prior permission you have given to such parties and/or us
  • Information collected from the public.We source our recruitment candidates from various public sources such as job posting websites. We also collect your information from public sources for purposes of background check and fraud prevention

How We Use Your Personal Data

In general, we use the personal data we collect about you for our recruitment purposes and pre-contractual offer processes. These include, for example:
  • Use of your Personal Identifier, Contact Information, Profile Information, Current Employment Information, and Other Identifiers to identify and contact promising candidates.
  • Use of your Personal Identifier, Contact Information, Profile Information, Current Employment Information, and Other Identifiers for evaluating your candidacy into our workforce.
  • Use of your Personal Identifier and Contact Information for arranging initial contact, further interviews, and for generally communicating with you.
  • Use of your Personal Identifier, Contact Information, Current Employment Information, and Other Identifiers for the pre-offer background verification process.
  • Use of your Personal Identifier, Contact Information, Current Employment Information, and Other Identifiers for drafting and sending you an offer letter (as relevant).
  • Use of your Personal Identifier, Contact Information, Current Employment Information, and Other Identifiers for our recruitment database in case other opportunities open up for unsuccessful candidates.
We may also use your personal data:
  • To verify your identity and prevent spam or other unauthorized or illegal activity
  • To better understand how users access and use our recruiting channels, both on an aggregated and individualized basis, in order to improve our recruiting channels, recruitment processes, and/or for other business research and analytical purposes
  • To optimize our ads on social media and the likes
  • To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities
  • As part of our auditing process
Additionally, in compliance with the applicable personal data protection law(s), we may also otherwise use your personal data as necessary
  • To meet our legal obligations, such as the responsibilities that we have to our regulators, tax officials, and law enforcements
  • For our legitimate interests or legitimate interests of any other person or legal person where such interests are not overridden by the fundamental rights that you have concerning your Personal Data
  • For preventing or suppressing a danger to a person's life, body or health
  • For the performance of a task we carried out in the public interest, or for the exercising of official authority vested in us
  • For the achievement of the purpose relating to the preparation of the historical documents or the archives for public interest, or for the purpose relating to research or statistics with appropriate security measures
  • For the establishment, compliance, exercise, or defense of legal claims
  • For the legitimate actions with appropriate safeguards by not-for-profit bodies
  • Where your personal data is information that you disclosed to the public with your explicit consent
Depending on the specific Services, the provision of your personal data may be necessary for compliance with a law or contract or may be necessary for the purpose of entering into the contract. For instance, the processing of certain identifiers may be needed for background verification before you enter into a contract with us. As such, if you do not provide the relevant personal data to us, we may not be able to proceed with your recruitment.

How We Share Your Personal Data

For the purposes as described under this Privacy Policy (including the purposes on how we use your personal data as described above), we may also disclose and/or transfer your personal data to the following types of parties:
  • Affiliates and Subsidiaries.For instance, we are closely linked as part of the LINE MAN Wongnai (LMWN) platform
  • Group Companies.LINE MAN (Thailand) Company Limited, LINE MAN Corporation Pte. Ltd, and LINE PAY Company Limited are also part of the LINE Group Companies
  • Data Processors.We may disclose your personal data to data processors and contractors or agents who perform functions on our behalf
  • Service Providers.We may disclose your personal data we collect to third party vendors and service providers such as our payment service providers. We may also disclose your personal data to our website, telephone, internet, cloud and physical storage services providers
  • Consultants.We may disclose your personal data to third party advisors such as our attorneys, auditors, business consultants, and other subject-matter consultants and experts
  • Business Partners.We may share the personal data with our third party business partners, including advertisers, recruiters, and researchers. For example, if you interact with content that mentions one of our recruiters, we may share that with them
  • Business Transfers.We may transfer the personal data we have collected to another company in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business
  • In Response to Legal Process.We may disclose your personal data in order to comply with the law, a judicial proceeding, court order, subpoena, or other legal process. For example, we may share your technical information and location data to comply with a police warrant
  • Regulators.We may disclose your personal data to regulators for legal compliance or per their reasonable request
  • To Protect Us and Others.We also may disclose your personal data if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service, or as evidence in litigation in which we are involved
  • Aggregate and De-Identified Information.We may also share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes
  • Per your request.We may also disclose your personal data to other third parties per your request

How We Share Your Personal Data Abroad

Our recruitment processes are generally conducted in Thailand. However, for the reasons identified above, we may also send or transfer your personal data to countries abroad, which may or may not have similar data protection standards to Thailand. For instance, we may transfer your personal data to cloud services overseas for data storage purposes and we may share your personal data to members of the LINE Group Companies abroad, where relevant.In all cases, we will put in place protection measures as necessary and appropriate for the data transfer in order to maintain and protect the security of your personal data.

On What Legal Basis Do We Collect, Use, and Share Your Personal Data

In general, we rely on our legitimate interests as part of our recruitment process. This includes the processing of your personal data for:
  • Identifying and contact promising candidates
  • Evaluating your candidacy into our workforce
  • Arranging initial contact and further interviews and for generally communicating with you
  • Pre-offer background verification process
  • Storage in our recruitment database in case other opportunities open up
  • Business research and analytical purposes to improve our recruitment
Additionally, we generally rely on our contractual obligation to process your personal data for drafting and sending you an offer letter once we determine that you would be a good fit to ultimately join our workforce.In some cases, our processing of your personal data may be required as part of our legal obligations under the law or for the establishment, compliance, exercise, or defense of legal claims, including the processing of your personal data to verify your identity and prevent spam or other unauthorized or illegal activity. (Note that we also consider such activities as part of our legitimate interests under the law even if they do not strictly arise to the levels of legal obligations for us to follow).Finally, we may rely on another lawful basis to process your data, depending on the specific occasion, including consent, the legal basis for which we have already listed above as well the preparation of historic documents or research for public interests, the protection of vital interests, for the legitimate actions of with appropriate safeguards by not-for-profit bodies, the processing of your personal data that is disclosed to the public with your explicit consent and as part of our public task. Note that for data transfers abroad, we may also rely on the basis for the transfer of your personal data abroad as being necessary for the compliance with a contract between us and other persons or juristic persons for your interests.

How Long Do We Keep Your Personal Data

We only keep your personal data to the extent necessary for the purposes explained in this Privacy Policy (and our internal Privacy Policy for Staffs in the event that you joined us) or as required by applicable laws. We will also retain your personal data if we reasonably believe there is a prospect of dispute/litigation to the extent permitted by applicable laws.For estimation purposes, the general expected retention period of all applicants is 3 years from application date. In the event that you join our LMWN Group, the general expected retention period of your personal data is 10 years from your contract termination as per the general prescription period under Thai law.

Minors, Incompetent, or Quasi-Incompetent Persons

Our recruitment opportunities are not directed to or designed for children under the age of majority under the applicable laws, and incompetent, or quasi-Incompetent persons and we do not knowingly collect, use, and/or disclose the personal data of such individuals without obtaining their legal guardian/custodian/curator’s consent.If we are aware that the personal data of children under the age of majority or of incompetent, or quasi-Incompetent persons under the applicable laws have been collected, used, and/or disclosed on the Services without appropriate consent, then we will take the appropriate steps to delete or anonymize this information unless there is legal ground for us to otherwise collect, use, and/or disclose of such information.

Cookies

We use cookies and similar tracking technologies on our recruitment channels.A cookie is a small text file that is stored on your computer, mobile, or other electronic device when visiting a website or application. This text file stores information that can be read by the website or application when visiting it again at a later date. Some of these cookies are necessary because otherwise the site or application will be unable to function properly. Other cookies are convenient for the visitor: for example, they remember your username in a secure way as well as your language preferences. The use of such cookies means that you do not need to fill out the same information each time you visit a website or application.
We use cookies:
  • To help us maintain your session when you visit our website or application
  • To enhance the security of our systems
  • To store your preferences and provide website or application customization for you
  • To help us understand how people use our website and application and to improve them
Most Internet browsers and iOS and Android devices allow you to control whether or not to accept cookies in the settings function. If, however, you deactivate cookies or limit the ability to set cookies on your electronic device, you may not be able to obtain the full benefit of the website or application or access all of its functions, which may limit your overall user experience.

Third Party Analytics

We may use automated devices and applications, including those offered by third parties to evaluate our recruitment processes and channels. We may also use other analytic means to evaluate our Services. We use these tools to help us improve our recruitment processes, performance and user experiences. The information collected may include unique device identifiers, device manufacturer and operating system, IP address, mac address, location, browser type, session start/stop time and user activity.

Third-Party Links

Our recruiting channels may contain links to third-party websites and/or applications. Any access to and use of such websites and/or applications is not governed by this Privacy Policy, but instead is governed by the privacy policies or notices of those third party websites and/or applications.

Your Rights

Subject to applicable laws, you may have the following rights with respect to your personal data:
  • The right to withdraw consent for the collection, use, or disclosure of your personal data that is based on your consent at any time. However, if you withdraw your consent, we may not be able to facilitate, communicate or provide some or all of our Services to you
  • The right to request access to or obtain a copy of your personal data that we hold about you as well as the right to request the disclosure of the acquisition of personal data obtained without your consent
  • The right to request us to provide your personal data in a commonly readable format or transmit that personal data in such a format to another organization
  • The right to request us to erase or destroy or anonymize your personal data in certain circumstances
  • The right to object to us or restrict us from collecting, using, or disclosing your personal data in certain circumstances
  • The right to request us to rectify your personal data to be accurate, up-to-date, complete, and not misleading
  • The right to lodge a complaint with the competent public authority if you believe that we have not complied with the law
You can exercise these rights by contacting us per the details below. Note that we may ask for additional information and/or documentation to verify your identity before proceeding with your request.

Pre-Regulation Notice (Thailand-Specific)

We are entitled to continue processing your personal data that have previously been collected by us before the effectiveness of the Personal Data Protection Act B.E. 2562 in accordance with the original purposes of processing. If you do not wish us to continue collecting and using your personal data, you may notify us to withdraw your consent at any time per the contact information below.

Personal Data Security

We have implemented appropriate technical and organizational measures, ranging from user access control to data encryption and anonymization, to prevent the unauthorized or unlawful loss, access to, use, alteration, correction or disclosure of your Personal Data. These measures and policies are regularly reviewed for updates when necessary.While we employ robust security measures, it is crucial to recognize that internet-based data transmission inherently involves risks beyond our control. We cannot ensure the complete security of your data during online transmission, and your usage of our recruiting channels acknowledges and assumes this risk.

Contact Us

If you want to exercise any of the rights as permitted by applicable laws as set out above or have any questions about the privacy aspects of our recruitment activities, please contact our Data Protection Officer at dpo@lmwn.com.For non-privacy related issues, you may reach us here.

Information about Your Data Controller

For Thailand: LINE MAN (Thailand) Company Limited 8 T-One Building, Floor 26 Soi Sukhumvit 40, Phra Khanong Subdistrict Khlong Toei District, Bangkok 10110 Wongnai Media Co., Ltd (Head Office) 8 T-One Building, Floor 26, 27 Soi Sukhumvit 40, Phra Khanong Subdistrict Khlong Toei District, Bangkok 10110 LINE PAY Company Limited (formerly known as Rabbit-LINE PAY Company Limited) 127 Gaysorn Tower Building, 18th Floor, Room A, B, Ratchadamri Road, Lumpini Subdistrict, Pathumwan District, Bangkok 10330 Living Mobile Company Limited 195 The R20 Space Building, 4th Floor, Soi Ratchadaphisek 20, Ratchadaphisek Road Samsen Nok Subdistrict, Huai Khwang District, Bangkok 10310 For Singapore: LINE MAN Corporation Pte. Ltd 10 Collyer Quay, #10-01, Ocean Financial Centre, Singapore 04315

Changes to this Privacy Policy

We may modify this Privacy Policy. The latest version of the Privacy Policy will always be posted on this site, and we encourage you to review the contents of the latest version of the Privacy Policy carefully.When we make any material changes to this Privacy Policy, we will notify you through reasonable means.
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