We are committed to protecting the privacy, confidentiality and security of the personal information we hold by complying with the requirements of Hong Kong's Personal Data (Privacy) Ordinance. We are equally committed to ensuring that all our employees and agents uphold these obligations.

This privacy notice explains what information we gather about you, what we use that information for, the lawful basis on which that information is used and who we give that information to. It also sets out your rights in relation to your information and who you can contact for more information or queries.

What this privacy notice covers and who it applies to

We recognise the importance of your personal information and are committed to protecting your privacy and handling your personal information in an open, transparent and secure manner.

This privacy notice sets out how we will collect, handle, store, share and protect information about you when you:

(a) engage with us in relation to employment or experience opportunities at JASG, including when you apply for a role with JASG or participate in any assessment programme relating to such a role;

(b) engage with us in relation to course application or course registration via Jardine Aviation Academy;

(b) visit and use our website;

(c) otherwise contact us, whether as part of media or investor communications, as part of our community and stakeholder outreach activities or otherwise.

This privacy notice applies to personal information collected on or through this website by JASG and its affiliates("we", or "us", or "our"). When we refer to "our Website" or "this Website" in this privacy notice we mean the specific webpages of Jasg.websflow.io or erecruit.jasg.com that link to this notice. In this privacy notice, we may refer to information about you as your "personal information". We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as "processing" such personal information.

We will refer to the activities mentioned in items (a)-(b) above collectively as the "Activities".

What personal information we collect

We typically collect or obtain your personal information because you give it to us (for example, when you engage with us in relation to the Activities or filling in a form on our Website), or because other people give that information to us (for example, recruiters or third party service providers that we use to help operate our business and run our Website), or because it is disclosed on publicly available sources such as business and employment oriented social networking services and job boards.

We also usually collect or obtain personal information from you because we observe or infer that information about you from the way you interact with us or others. For example, in order to improve your experience when you use this Website and ensure that it is functioning effectively, we (or our service providers) generally use cookies (small text files stored in a user's browser) and web beacons which may collect personal information.

The personal information that we collect or obtain typically includes: your name; age; date of birth; gender; picture; identification documents; immigration status; birth certificate; e-mail address (including your business, personal, and/or university e-mail addresses); home address; telephone number; other contact details; country of residence; family circumstances (for example, your marital status when you enter it in in a form on our Website, or it appears in any documentation you provide to us such as your marriage certificate); employment and education details (for example, your resume, scores on any assessments, evaluation records, interview recordings, remuneration details, the organisation you work for, your job title and/or the name of the university you attended, visa or work permit details); financial and tax-related information (for example, your income, assets and tax residency where such information appears in any documentation you provide to us); lifestyle and social circumstances (for example, where we would like to invite you to an event that may be of interest to you); postings on any blogs, forums, wikis and any other social media applications and services that we provide; IP address; browser and device type; language; access times and duration; details of how you like to use our Website; details of how you like to interact with us and other similar information.

In some cases, the personal information we collect may also include so called 'sensitive' or 'special categories' of personal information, such as details about your health (like any disabilities that you may have and any accommodations we may need to make for you in the workplace); sexual orientation (for example, if you provide us with details relating to your partner or spouse); ethnicity, race and religious beliefs (for example, for the purpose of equal opportunities monitoring in JASG); and any criminal convictions you may have (for example, for the purpose of conducting background checks on you). Usually this is because you volunteer this information to us.

The types of personal information and special categories of personal information that we collect will also generally vary depending on the activities for which you engage with us, how you use our Website, and the information you provide to us. In some rare circumstances, we also gather other special categories of personal information about you because you volunteer that information to us or we are required to gather that information because of legal or regulatory requirements imposed on us. If we are so required to gather sensitive personal information from you, we will indicate to you that the provision of this information is mandatory, and the consequences if we cannot collect this information.

In some cases, we will also collect personal information about you indirectly from third parties such as: (i) recruitment agencies that you use to apply to JASG or publicly available sources such as business and employment oriented social networking services (such as LinkedIn, Facebook and YouTube) and jobs boards (such as jobsDB). (ii) background check providers;  and (iii) third party service providers that help us operate our business and run our Website (such as Webflow).

How we use personal information about you

Use of personal information for the Activities

We will use your personal information in connection with the Activities. In particular, we will use your personal information to:

• undertake recruitment activities, such as determining the suitability of your qualifications, checking for any existing or potential conflicts of interest or any other restrictions which may otherwise restrict or prevent employment with JASG;
• assist us in obtaining services from or managing external service providers (e.g. recruitment agencies);

• manage our HR records and update our employee database;
• where relevant, manage and make available personal information within the JASG;
• otherwise correspond and manage our relationship with you.

Use of personal information for other activities that form part of the operation of our business

We generally also use your personal information for the purposes or, in connection with, other activities that form part of the operation of our business. In general, these activities are:

• satisfaction of applicable legal or regulatory requirements;
• responding to requests from, and other communications with, competent public or judicial authorities;
• financial accounting, invoicing and risk analysis purposes;

• prudent operational management (including credit and risk management, insurance, audit, training and similar administrative purposes);
• prudent IT management (including management of our IT resources, infrastructure and business continuity);
• business development purposes;
• obtaining services from our professional advisors, such as lawyers, accountants and consultants;
• considering, and entering into, any transaction involving part or all of the business or assets of the JASG

• protecting our rights and those of our customers and clients;
• meeting our corporate and social responsibilities; and
• to otherwise correspond with you, whether as part of media or investor communications (including sending you email alerts), as part of our community and stakeholder outreach activities or otherwise.

Use of personal information collected via our Website

We generally use personal information collected via this Website:

• to manage and improve any services provided via our Website;
• to manage and improve our Website (including drawing up statistics on the usage of our Website);

• to tailor content of our Website to provide you with a more personalised experience and draw your attention to information about products and services that may be of interest to you;
• to manage and respond to any request you submit through our Website; and
• to help us learn more about you, the products and services that you receive, and other products and services that you might be interested in receiving.

The legal grounds we use for processing personal information

We generally use your personal information for the purposes outlined above because: (a) it is necessary for our legitimate interest and does not unduly affect your interests or fundamental rights and freedoms (see below); (b) it is necessary for legal and/or regulatory obligations or requests that we are subject to, such as keeping records for tax purposes or providing information to a public body or law enforcement agency; (c) it is necessary to perform contractual obligations that we owe to you or to take pre-contractual steps at your request; (d) it is necessary for the performance of a tasks carried out in the public interest, such as assisting with diversity in the workplace; or (e) in some cases, we have obtained your prior consent.

Examples of the 'legitimate interests' referred to above are:

• to benefit from cost-effective services (e.g. we may opt to use certain IT platforms offered by service providers);
• to determine whether a candidate or potential candidate's skills and experience are suitable for a role within JASG, and determine whether or not to make an offer of employment with JASG;
• at the appropriate stage in the recruitment process (i.e. as part of making an offer of employment to you), to verify the accuracy of information (including remuneration details) you have provided to us as part of your application, including through background screening and recruitment agencies;
• to prevent fraud or criminal activity, misuses of our website as well as the security of our IT systems, architecture and networks and security of JASG premises; and
• to meet our corporate and social responsibility objectives.

To the extent that we process any sensitive personal information relating to you for any of the purposes outlined above, we will do so because either: (1) you have given us your explicit consent to process that information; (2) the processing is necessary for reasons of substantial public interest on the basis of applicable law (for example where we are required by law or regulatory requirements to process that information in order to ensure that we meet our anti-money laundering obligations); (3) the processing is necessary to carry out our obligations under employment, social security or social protection law; (4) the processing is necessary for the establishment, exercise or defence of legal claims; or (5) you have made the information manifestly public.

Where we are legally required to obtain your explicit consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you.

Who we disclose your personal information to

In connection with one or more of the purposes outlined in the "How we use personal information about you" section above, we generally disclose details about you to: other members of the Jardine Matheson Group; professional advisors and third parties that provide services to us (such as IT systems providers, hosting providers, payroll providers, IT support providers, consultants (including lawyers and accountants), public relationship advisers and competent authorities (including any national and/or international regulatory or enforcement body or courts or other form of tribunal). Where we disclose detail about you to other members of the Jardine Matheson Group they will either act as another controller under this notice or will only process personal information on behalf and upon request of the controller.

Please note that some of the recipients of your personal information referenced above will be based in countries other than your country of residence whose laws may or may not provide the same level of data protection as your country. These countries typically include Hong Kong, Singapore and the UK. Your personal information may also be disclosed to other jurisdictions where Jardine Mtheson Group have business operations, such as the People's Republic of China and other countries in South East Asia including Vietnam, Thailand, Malaysia, and Indonesia. In such cases, we will ensure that there are adequate safeguards in place to protect your personal information that comply with our legal obligations.  

Further details of the transfers of your personal information outside of your country of residence and the adequate safeguards used by the Jardine Matheson Group in respect of such transfers (including copies of relevant agreements) are available from us by contacting privacy@jardines.com. You can also use this e-mail address to request further information about the entities that comprise the Jardine Matheson Group and the countries in which they operate.

How long we keep your personal information

We will hold your personal information on our systems for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. In general, although there may be some limited exceptions:

(a) information relating to unsuccessful candidates is kept for up to twelve months after the date on which the post applied for is filled;

(b) information relating to potential candidates for roles within JASG is kept for up to twelve months from the date of our last communication with such candidates;

(c) information relating to successful candidates is dealt with by our employee privacy notice that will be provided to you upon joining JASG;

(d) cookies relating to our website (subject to your preferences) will be kept for up to twelve months, after which it may be archived for a further seven years before it is permanently removed from our systems; or

(e) information about your correspondence with us, including through online forms or email correspondence, is kept for seven years, after which it will be archived for a further seven years before it is permanently removed from our systems.

Protection of your personal information

We use a range of physical, electronic and managerial measures to ensure that we keep your personal information secure, accurate and up to date. These measures include:

• education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal information;
• administrative and technical controls to restrict access to personal information on a 'need to know' basis;

• technological security measures, including fire walls, encryption and anti-virus software; and
• physical security measures, such as staff security passes to access our premises.

Although we use appropriate security measures once we have received your personal information, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavour to protect personal information, but we cannot guarantee the security of data transmitted to us or by us.

Your rights and how to contact us

You have various rights in relation to your personal information. In particular, you have a right to:

• object to the processing or your personal information;
• request a copy of personal information we hold about you;
• ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete;

• ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information; and
• withdraw consent to our processing of your personal information (to the extent such processing is based on consent).

To exercise any of your rights, or if you have any other questions about our use of your personal information, please e-mail us at jasl@jasg.com. You may also use these contact details if you wish to make a complaint to us relating to your privacy.

If you are unhappy with the way we handled your personal information or any privacy query or request you have raised with us, you also have a right to complain to a data protection regulator in the place where you live or work, or in the place where you think an issue in relation to your personal information has arisen. A list of national data protection regulators in the European Union can be found here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

Changes to this privacy notice

This notice was last updated on 31st October 2022.

It may be subject to amendments. Any future changes or additions to the processing of personal information as described in this notice affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.