Last Revised: June 17, 2025
IDEAL-CAREERBRIDGE HOLDINGS (HK) LIMITED (hereinafter referred to as “Smart Deer” or “we”) operates the website www.smartdeer.work (hereinafter referred to as “Site”) and provides services through this site to help businesses of all sizes conduct first-class human resource management operations in a compliant and efficient manner.
SmartDeer has developed a global privacy protection program that ensures the same high standards of privacy protection for you regardless of your location. This Employee Privacy Policy, together with Smart Deer’s Global Privacy Policy, explains the types of information we process, how we use it, and your rights. When we refer to SmartDeer, if applicable, we mean the SmartDeer entity with whom you have a contract.
This Privacy Policy is designed to inform SmartDeer employees how we collect, use, and disclose information related to you.
I.Sources of Personal Information
We obtain your personal information through the following means:
a.Personal information collected by government, law enforcement, regulatory, and other authoritative bodies;
b.Personal information collected by third-party organizations (such as pension management institutions, healthcare providers, etc.);
c.Personal information you voluntarily submit during the recruitment process and throughout your employment;
d.Personal information provided by clients;
e.Personal information collected through the SmartDeer system and applications;
f.Personal information collected during payment processes;
g.Personal information collected during the handling, processing, or maintenance of employee visas, work permits, residence permits, and other immigration-related matters.
II.Information We Process
SmartDeer collects and processes relevant information primarily to manage your employment relationship. This includes information provided during the pre-contractual phase, throughout the term of the agreement, and after its conclusion, as permitted or required by applicable laws. The specific types of information include:
a.Identifying details, such as your complete name, mailing address, electronic mail address, contact phone number, birthdate, national identification number, gender, marital status, citizenship, country of employment, photocopy of identification card, tax-related information, etc.
b.Compliance-related documentation, such as work experience records, educational qualifications, employment permits, visa details, etc.
c.Employment-specific information, including job title, employment status and classification, terms of employment, employment contract details, salary information, benefits entitlements, leave records, expense reimbursements, equity plan participation, and other pertinent work-related information.
d.Data related to the use of SmartDeer systems, such as technical connection data (IP address, device location, system logs, etc.).
e.Talent management-related information, such as detailed information from job applications, résumés/curricula vitae, information obtained during interviews, prior work experience, educational background, professional qualifications, language skills, other relevant experience and skills, training courses attended, etc.
f.Financial data, such as payment card number, expiration date, security code, billing address, transaction records, and payment information between your accounts and ours.
g.Personal information that may involve political opinions, religious beliefs, or philosophical beliefs.
h.Data related to public functions, political offices, activities, and trade union duties, including personal information related to the payment of trade union service fees or membership dues to associations, political entities, or trade union organizations.
i.Health-related data, such as illness or injury status, sick leave records, medical certificates or documents proving the necessity of absence, disability status, physical limitations, accident records, exposure to risk factors, and physical and mental health conditions relevant to performing specific tasks.
j.Personal information related to criminal records and ongoing criminal proceedings.
The above categories of information include the relevant data about you that SmartDeer has collected and processed over the past 12 months. These categories of personal information may contain “sensitive personal information” or “special categories of personal data” as defined under applicable data protection laws. SmartDeer will only use or disclose such personal information for the purpose of providing services to you, as permitted under applicable data protection laws, and will not use it for any other purposes. The types of personal information we collect may vary by country. You may view the information collected about you by SmartDeer through your SmartDeer system account.
III.Purposes and Legal Basis for Processing Personal Information
The processing of your personal information will strictly comply with all applicable data protection laws and regulations and will be carried out for the following purposes and legal bases, as permitted under data protection laws.
| Purpose | Legal Basis |
| Fulfilling the employment contract with you, including completing the recruitment process, executing the contract, providing benefits and compensation, assessing performance, and managing travel-related matters arising from job responsibilities. | Necessary for the performance of the contract |
| Complying with various legal and regulatory obligations, such as labor law contract management, tax compliance, social security and insurance regulations, employment health and safety requirements, trade union obligations, financial obligations, and other current or future legal requirements. | Legal obligation |
| Supporting your training and development to enhance skills, accumulate knowledge, and promote career growth, enabling you to perform your job duties efficiently and creating opportunities for career advancement. | Legitimate interest |
| Providing technical support, user access management, data security, and business continuity services to ensure the functionality, security, and stability of company systems. | Legitimate interest |
| Defending SmartDeer’s rights in legal, administrative, arbitration, or mediation proceedings, including participating in litigation or arbitration to protect contractual or intellectual property rights. | Legitimate interest |
| Fulfilling insurance obligations related to employer responsibilities, such as handling workplace injuries, occupational diseases, or damages caused to third parties. | Legitimate interest |
| Ensuring equal opportunities in the workplace to avoid discrimination and foster a diverse and inclusive working environment. | Legitimate interest |
| Fulfilling specific obligations or purposes stipulated in associations, organizations, or collective agreements, such as providing trade union assistance. | Legitimate interest |
| Managing corporate activities related to asset transfers, business restructuring, mergers, acquisitions, spin-offs, or other corporate transformations to ensure a smooth transition of operations. | Legitimate interest |
| Facilitating internal communication by publishing your name, surname, email, phone number, and photo on the SmartDeer intranet. | With your consent |
| Meeting compliance requirements by sharing relevant documents with clients upon your consent. | With your consent |
| Promoting equal employment rights and benefits by processing data related to political views, religious or philosophical beliefs to arrange for religious holidays or catering services. | To fulfill obligations or rights in the employment field |
| Managing sick leave, disabilities, accidents, and fitness assessments to ensure employee welfare and meet legal requirements. | To fulfill obligations in employment, social security, and related fields |
| Processing personal data related to criminal records or procedures to fulfill legal obligations or specific job requirements. | To fulfill legal obligations or specific job requirements |
| Processing sensitive personal data to establish, exercise, or defend legal rights. | When necessary to defend legal rights |
If we need to process your personal information to fulfill our contractual obligations with you, the provision of such information is mandatory. Failure to provide it may render the employment contract invalid.
If you provide personal information of a third party, you should declare that you have obtained the third party’s consent (where applicable) and ensure that you have disclosed the relevant matters in these terms to them.
IV.Your Rights
Under applicable privacy regulations, you may have some or all of the following rights:
a.Access to Personal Information: You can obtain a copy of your personal information and related data processing information.
b.Data Portability: You can obtain a portable copy of your personal information or transfer it to a third party.
c.Rectification of Personal Information: You can correct inaccurate or incomplete personal information.
d.Erasure of Personal Information: You can request deletion when personal information is no longer needed for the purposes for which it was collected.
e.Objection to Processing: You can object to the processing of your personal information.
f.Withdrawal of Consent: You can withdraw your previously given consent.
g.Restriction of Sensitive Information Use: You can limit the use or disclosure of sensitive information.
h.Non-discrimination: You have the right not to be discriminated against for exercising your privacy rights.
i.Opt-out of Targeted Advertising: You can choose not to allow personal data to be collected or processed for targeted advertising, sales, or profiling.
j.Right to Appeal: In certain jurisdictions, if we refuse your request, we will inform you of the reason and provide an appeal explanation. If we fail to respond to your privacy request, you have the right to appeal within a reasonable time.
k.Data Anonymization: You can request anonymization of your data.
l.Access to Shared Entities: You can request information about the public and private entities with whom we share your personal information.
m.Complaint to Regulatory Authorities: If you believe that SmartDeer has infringed upon the rights recognized by applicable data protection regulations, you may lodge a complaint with the relevant data protection authorities.
Note that we do not provide an opt-out option for the sale of personal information, as we do not sell personal information (and have not done so in the past 12 months) and will not sell information of individuals under the age of 16.
You may exercise the above rights or inquire about how SmartDeer handles your personal information by sending an email to support@smartdeer.work. We will review and respond to your request.
V.Subjects Who Can Access Your Personal Information
To achieve necessary purposes such as employment management, payroll processing, and regulatory compliance, SmartDeer will provide your personal information to the following entities in accordance with applicable laws:
a.Affiliated Companies: SmartDeer’s associated enterprises and parent company.
b.Government Agencies: Public institutions such as tax authorities, labor regulatory departments, and immigration management departments.
c.Professional Service Agencies: Including consultants, advisors, and law firms.
d.External Auditing Agencies: Third-party institutions responsible for auditing.
e.Labor Unions: Relevant union organizations.
f.Business Partners: Third parties and their professional advisors involved in corporate mergers, spin-offs, or other business reorganizations and transfers.
g.Service Clients: The specific clients to whom you provide services in the course of your duties.
h.Third-Party Service Providers: Entities that perform services on behalf of SmartDeer, such as recruitment solution providers, payroll payment service providers, benefits program operators, insurance companies, medical service institutions, software suppliers, identity verification providers, and customer support agencies.
i.By Your Authorization: Situations where you have explicitly given consent to share your information.
j.Anonymized Data Sharing: Providing anonymized, aggregated, or de-identified data to academic institutions for research purposes or disclosing such information to the public, while ensuring your privacy.
VI.Cross-Border Transmission of Personal Information
To provide services and manage employment contracts, SmartDeer may share your personal information internally or externally on a global scale, including with partners. No matter where your personal information is transmitted, stored, or processed, we will take reasonable measures to safeguard its privacy. These measures may include implementing legally recognized standard contractual clauses, obtaining your consent, or transferring personal information through other lawful means.
If you have any questions about international data transfer and protective measures, please contact us at support@smartdeer.work.
VII.Data Retention Period
SmartDeer will only retain your personal information for the shortest period necessary to fulfill the purposes for which it was collected, in compliance with applicable legal requirements. This retention period ensures that we can fulfill legal obligations, resolve disputes, and enforce relevant agreements. We will not keep your data longer than necessary to achieve the processing purposes.
When determining the appropriate retention period, we will take into account the quantity, nature, and sensitivity of the personal information, as well as the purposes for which we process it and whether we can achieve those purposes through other means. After the retention period expires, your personal information will be deleted, anonymized, or aggregated.
VIII.Changes to This Privacy Policy
This Privacy Policy will be effective as of the “Last Revised” date at the top of this Privacy Policy and will remain in force unless any changes to its provisions are made in the future, which will become effective immediately after being posted on this page.
We reserve the right to update or amend this Privacy Policy at any time. We recommend that you check this Privacy Policy regularly to stay informed of the latest content. If you have any questions or concerns regarding privacy when using our services, please contact us at support@smartdeer.work.、
IX.Appendix
The definitions of the terms used in this Privacy Policy are as follows:
a.Account: Refers to the account used to access and use the system in accordance with the applicable terms.
b.User: Refers to any individual authorized to access an account.
c.Customer: Refers to a user who uses the system to request services and makes payments related to the services received through the system.
d.Business: Refers to any type of legal entity that creates an account on the system and manages it through an administrator.
e.Administrator: Refers to a user who applies for an account on behalf of a business, accesses the services, manages the account, and otherwise acts on behalf of the business.
f.Content: Refers to all content on or made available through the system or services, including any documents, images, photos, videos, data, audio, or text, as well as any modifications or derivative works of the above.
g.User Content: Refers to all information content provided by users through the system or services.
发表回复