Privacy Policy

Section 01Introduction

SiRuiX Partners Pte. Ltd. (“SiRuiX”, “we”, “us”, “our”) is a licensed employment agency incorporated in Singapore. UEN 202624921Z. Employment Agency Licence No. 26S3568.

We provide executive search and career advisory services. In doing so we necessarily handle personal data — of candidates, of client contacts, of referees, and of visitors to this website.

This Privacy Policy explains what we collect, why, who we share it with, how long we keep it, and what rights you have. It applies to our website at www.siruix.com (the “Site”), to our services, and to all personal data we hold, however it reaches us. It is directed at individuals in Singapore and in the other markets in which we operate.

We handle personal data in accordance with the Personal Data Protection Act 2012 of Singapore (the “PDPA”), the Employment Agencies Act 1958 and its licence conditions, and, where applicable, the data protection laws of other jurisdictions in which we operate.

Section 02Data Protection Officer

We have appointed a Data Protection Officer responsible for ensuring our compliance with the PDPA.

Please direct all questions, access requests, correction requests, consent withdrawals and complaints relating to personal data to the DPO.

Section 03Whose Personal Data We Handle

Section 04Personal Data We Collect

From candidates and career advisory clients

Name, contact details and preferred contact method; curriculum vitae and career history; current and past employers, roles and responsibilities; education, qualifications and professional memberships; languages; current and expected remuneration; notice period and availability; work authorisation and right-to-work status; nationality or residency status where required for a role or a work pass application; professional references; interview notes and our own assessment of suitability; and any other information you choose to provide to us.

Where a specific role or a client’s onboarding process requires it, and only with your consent at the relevant time, we may also collect identification documents, educational or employment verification records, and background screening results.

From client contacts

Name, job title, business contact details, and records of our correspondence and dealings with you.

From referees

Name, job title, organisation, business contact details, and the content of the reference you provide.

From website visitors and email enquiries

The Site is an informational website. It does not host an application form, and we do not collect personal data through the Site itself.

Where we advertise a role on the Site, we invite interested individuals to write to us at talent@siruix.com. If you do so, we collect the contents of your message and any attachments you send, including your curriculum vitae. Sending us your CV in this way is treated as your consent for us to consider you for the role concerned, to contact you about it, and to consider you for other opportunities that may suit you, as described in section 6.

If you send us your CV without responding to a specific role, we will consider you for opportunities we think may suit you. If you would prefer us not to keep your details, tell us and we will delete them, other than any record we are required to retain by law or under our employment agency licence conditions.

We do not use the Site to collect personal data from you directly, and we operate no analytics or visitor tracking of any kind. Our hosting provider maintains standard technical logs. See section 10.

What we do not collect

We do not seek information on your race, religion, marital status, family responsibilities, disability or age except where a genuine and lawful job requirement exists, or where an individual volunteers it. Our practice is aligned with the Tripartite Guidelines on Fair Employment Practices, and we do not accept discriminatory job requirements from clients.

Section 05How We Collect Personal Data

• Directly from you — by email, telephone, video or in-person meetings, or through a data collection form we send you
• By email to talent@siruix.com, where you write to us in response to a role advertised on the Site or send us your CV unprompted
• From professional networking platforms and other publicly available sources, in the course of identifying and researching potential candidates
• From referrals by mutual contacts, clients or other candidates
• From referees you have nominated
• From our clients, where they refer a candidate to us

Where we obtain your data from a source other than you directly, we will tell you at first contact where it came from and why we are approaching you.

Section 06Why We Use Personal Data, and On What Basis

We use personal data for the following purposes.

For candidates and career advisory clients

• To assess your suitability for a role and to present you to a client
• To carry out our engagement with you, including interviews, assessment, references and offer support
• To provide career advisory services
• To keep you informed of opportunities that may be relevant to you
• To maintain a talent pool for future mandates
• To comply with our obligations under the Employment Agencies Act and licence conditions

For client contacts

• To deliver our services under the engagement
• To communicate about mandates, proposals, invoices and related matters
• To inform you about our services where you have consented or where the exception for business contact information applies

For all

• To maintain accurate business records
• To comply with legal, regulatory and tax obligations
• To establish, exercise or defend legal claims

The basis on which we rely

The basis for each use will be one of the following, as applicable:

• Your consent, given expressly, for example by completing our candidate data form
• Deemed consent, where you voluntarily provide data for an evident purpose — for instance, sending us your CV in response to a role
• Deemed consent by contractual necessity, where disclosure is reasonably necessary to conclude or perform a contract with you
• Publicly available data — for example, a professional profile that is generally accessible to the public, which we may review when identifying and researching potential candidates
• Legal or regulatory requirement

Business contact information — your name, title and business contact details, provided in a business rather than personal capacity — falls outside the consent requirements of the PDPA.

Section 07Who We Disclose Personal Data To

We disclose personal data only where necessary, and only to:

• Our clients, where we present you as a candidate. We tell you which client before we do so, and we do not submit your details to any client without your agreement.
• Referees you have nominated, for the purpose of obtaining a reference.
• Service providers acting on our behalf — our IT and cloud service providers, and, where engaged, background screening or assessment providers. These providers act on our instructions and are bound to protect your data.
• Professional advisers — our legal, accounting and insurance advisers, where necessary for a specific matter, such as advice on a dispute or a claim. This is not routine.
• Regulators and authorities, where required by law, including the Ministry of Manpower in connection with our employment agency licence.
• Another search or advisory firm, where we work jointly with them on a mandate. We will tell you before this happens, and we do not share your details with another firm without your agreement.

Section 08Transfers Outside Singapore

We operate from Singapore and work with clients, candidates and search partners in other markets. Where a role, a client or a search partner is located outside Singapore, your personal data may be transferred to a recipient in that country.

Before any such transfer, we take steps to satisfy ourselves that the recipient is bound by legally enforceable obligations to protect your data to a standard comparable to that required under the PDPA. Depending on the recipient, this may be achieved through data protection clauses in our client, partner and supplier agreements, or through the recipient’s own binding rules or applicable local law.

Our cloud service providers may also store or process data on servers located outside Singapore. The same requirement applies to them.

Section 09How Long We Keep Personal Data

We keep personal data only for as long as it serves the purpose for which it was collected, or for as long as we are required to keep it by law.

Some retention periods are fixed by law and we cannot shorten them. As a licensed employment agency we are required to retain certain records under the Employment Agencies Act 1958 and our licence conditions, and to retain accounting records for tax purposes.

Our detailed retention periods are set out in our internal retention and disposal schedule. In summary:

Where more than one period applies to the same record, the longer period governs. At the end of the retention period we delete the data or render it anonymous.

Section 10Cookies and Website Analytics

The Site is a static informational website. We do not use analytics services, tracking pixels, advertising cookies or any other technology that profiles visitors. We do not build a picture of who visits the site or what they look at.

As with any website, our hosting provider keeps standard technical logs recording information such as IP addresses and times of access. These are generated automatically, are retained for security and troubleshooting purposes only, and are not used to identify or profile individual visitors.

You can delete or block cookies through your browser settings at any time. Doing so will not affect your access to any part of this Site.

Section 11Your Rights

Access

You may ask us for the personal data we hold about you and how it has been used or disclosed in the past year. We will need to verify your identity before we respond. We will then respond as soon as reasonably possible. If we cannot respond within 30 days, we will tell you within that period when we will.

Certain data is excluded from the right of access under the PDPA. In particular, opinion data kept solely for an evaluative purpose — such as our assessment of a candidate’s suitability for a role, or our shortlist rationale — is exempt, and further exceptions are set out in the Act. We will provide the factual data we hold about you and explain what has been withheld and why. We may charge a reasonable fee for responding to an access request. Where we do, we will give you a written estimate of the fee before we proceed.

Correction

You may ask us to correct personal data that is inaccurate or incomplete, and we will respond as soon as practicable. If we cannot respond within 30 days, we will tell you within that period when we will. Where we make a correction, we will send the corrected data to any organisation we disclosed it to in the preceding year, unless that organisation does not need it. Where we are satisfied on reasonable grounds that a correction should not be made, we will not make it, but we will annotate our records with the correction you sought.

Withdrawal of consent

You may withdraw your consent to our use or disclosure of your personal data at any time, on reasonable notice, by writing to dpo@siruix.com. We will tell you the likely consequences — in most cases, withdrawal means we can no longer represent you for current or future opportunities. Withdrawal does not require us to delete records that we are required to keep by law, including under our employment agency licence conditions, or that we need in order to establish, exercise or defend a legal claim.

Marketing

You may ask us to stop sending you marketing communications at any time. Where you have provided a Singapore telephone number, you may also register it with the national Do Not Call Registry.

Section 12Accuracy and Security

We take reasonable steps to ensure that the personal data we hold is accurate and complete, particularly where it will be used to make a decision affecting you or will be disclosed to a client. Please tell us if your details change.

We protect personal data through access controls, encryption in transit and at rest, restricted access on a need-to-know basis, secure disposal at the end of the retention period, and a documented breach response procedure. No system is entirely secure, but we review these measures regularly. Where a data breach is assessed as notifiable under the PDPA, we will notify the Personal Data Protection Commission and affected individuals in accordance with the Act.

Section 13Third-Party Websites

The Site may link to third-party sites and platforms. We are not responsible for their content or their privacy practices. Please read their own privacy policies before providing them with personal data.

Section 14Minors

Our services are directed at working professionals and are not intended for individuals under 18. We do not knowingly collect personal data from minors. If you believe we hold data relating to a minor, please contact our DPO and we will delete it.

Section 15Complaints

If you have a concern about how we have handled your personal data, please contact our Data Protection Officer at dpo@siruix.com in the first instance. We will acknowledge your complaint and aim to resolve it promptly.

If you remain dissatisfied, you may refer the matter to the Personal Data Protection Commission of Singapore at www.pdpc.gov.sg.

Section 16Changes to This Policy

We may update this Privacy Policy from time to time. The current version and its effective date are shown at the top of this page. Where changes are material, we will take reasonable steps to notify you.

Section 17Governing Law

This Privacy Policy is governed by the laws of Singapore.

This Privacy Policy describes our practices in handling personal data. It does not form part of, and does not create, any contract between you and SiRuiX.