DATA PROTECTION & PRIVACY STATEMENT
Data Protection at Lidl Asia Pte. Limited
(Version 3.2 last updated 25.06.2021)
Personal Data Privacy Statement
We, Lidl Asia Pte. Limited (“Lidl”) are pleased that you are interested in data protection on our website. When you visit our website, we want you to feel comfortable and secure and regard our implementation of data protection as a customer-oriented quality feature.
This Personal Data Privacy Statement (“Privacy Statement”) informs you about Lidl’s data protection practices and the type and scope of processing (“processing” includes the collection, use, disclosure and transfer) of your personal data conducted by us. Personal data is information that can be assigned directly or indirectly to your person. The Personal Data (Privacy) Ordinance (“PDPO”) in Hong Kong and the Personal Data Protection Act (“PDPA”) in Singapore serve as the legal basis for data protection.
Please read this Privacy Statement carefully to understand our policies and practices regarding your personal data. By using our website, you consent to this Privacy Statement. If you do not agree with the practices described in this Privacy Statement, you should not use this website or provide us with your personal data. This Privacy Statement may change from time to time (see ‘Changes to Our Privacy Statement’) and your continued use of our website is deemed to be acceptance of those changes.
This Privacy Statement applies when your personal data is collected by us, such as when you contact us, enter into contractual negotiations, conclude contractual agreements with us or otherwise send information to us at your own accord. This Privacy Statement also applies to personal data in our possession or under our control, including personal data in the possession of our affiliates within the Schwarz group (“Affiliates”) and organisations which we have engaged to process personal data on our behalf (“Data Processors”).
Personal data that you provide us with is treated confidentially. We use your data solely for the Purposes (as defined below). In order to do so, we may use and transfer data that you have provided to us within our business or to our Affiliates or Data Processors for those Purposes.
We will not retain your personal data for longer than is necessary to fulfil the purpose for which you have provided your personal data to us or to satisfy such other legal or statutory requirements which we need to comply with.
To the extent that you choose to provide personal data in connection with our social media platforms outside of our website (for example, through our LinkedIn page), any information you provide to us on those platforms is also subject to this Privacy Statement. Further, you may also be subject to the policies of those social media platforms (see ‘Links to other websites’).
You may write to our data protection officer using the contact details provided in section 12.1 below to enquire about this Privacy Statement and our data protection practices.
1. Collection of personal data
Individuals, from whom we collect personal data include the officers, employees, representatives and/or agents belonging to us, our business partners and/or contractors.
In general, we collect your personal data directly from you. We may obtain your personal data in a number of ways, such as information provided to us in forms filled out by individuals, face to face meetings, telephone conversations, email messages and other correspondence, including when you report a problem or request further services. We also collect personal data provided by third parties.
Generally, we do not collect your personal data unless it is provided to us voluntarily by you and only after (i) you have been notified of the purposes for which the data is collected, and (ii) you have provided consent to the collection and usage of your personal data for those purposes. We may also collect your personal data without your consent if there is an applicable consent exception under applicable data protection laws.
We may also obtain other personal data that you choose to provide to us in connection with your use of our website as well as records and copies of your correspondence and other data comparable with the types of data specified in section 2.
2. Types of personal data we may process
The types of personal data we process may include:
- your name*;
- your contact information such as your telephone number, email address and mailing address*;
- personal data required to assess your suitability as an employee, contractor or business partner*;
- personal data required to perform contractual obligations between us*;
- personal data collected automatically when visiting our website as specified below in section 7; and
- other personal data you voluntarily provide to us.
Please note that it is mandatory for you to provide us with your personal data marked with asterisks. In the event that you do not provide such personal data, we may not be able to communicate with you, respond to your queries, evaluate your suitability as an employee, contractor or business partner or do business with you in the ordinary course of business.
3. Use of personal data and purpose of processing
We process your personal data when it is necessary for our business purposes (as specified below) or to meet the purposes for which you have submitted the information to us.
Your personal data may be used for one or more of the following purposes ("Purposes"):
- communicating with you;
- verifying your identity;
- performing contractual obligations between us;
- assessing your suitability as an employee, contractor or business partner;
- handling and responding to your inquiries, suggestions or complaints;
- conducting analysis to help us better understand our business partners, personnel and contractors and to improve our operations, services and products;
- facilitating website access and compiling aggregate statistics on website usage;
- the purposes as described in section 7 below;
- meeting legal, regulatory or compliance requirements, dealing with enquiries from law enforcement or regulatory bodies or for the purpose of obtaining legal advice; and
- any other purposes directly related to any of the above purposes.
We will not process your personal data (including provide your personal data to third parties) for direct marketing or other unrelated purposes without your consent.
4. Disclosure of personal data
Where we are required by applicable data protection laws to do so, we will obtain your express and voluntary consent to disclose your personal data to other parties, except when an applicable consent exception under applicable data protection laws applies.
We also disclose your personal data to our Data Processors, which are third parties engaged by us to assist us with our business activities. Any such third parties whom we engage will be bound contractually to keep all information confidential and will only process your personal data on behalf of us upon our instructions.
We may disclose your personal data to our Affiliates or Data Processors (i) for the Purposes as stated above; (ii) in order to meet the purpose for which you have submitted the information or for which the information has been automatically collected; or (iii) to provide you with information at a later date which may be of relevance and interest to you based on the nature and purpose of your voluntary requests.
5. Transfer of data outside of your jurisdiction
We may transfer your data to our Data Processor or other Affiliates within the Schwarz Group. These process your data on our behalf and are each carefully selected and contractually obliged.
In this regard, the data processing may involve some of the data to be transmitted servers located outside of Singapore and/or Hong Kong belonging to our Data Processors other Affiliates.
Where we transfer your personal data outside of your jurisdiction, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA in Singapore or the PDPO in Hong Kong (as the case may be).
Alternatively, we may rely on another legal basis under applicable laws for transferring your personal data outside of Singapore and/or Hong Kong, for example:
i. such transfer is necessary for the performance of a contract between you and Lidl and if the transfer is not proceeded with, you would suffer significant financial loss;
ii. there is a data transfer agreement between Lidl and the recipient which requires the recipient to provide a standard of protection for the personal data that is at least comparable under the PDPA in Singapore or the PDPO in Hong Kong (as the case may be) and specifies the countries and territories to which the data may be transferred under the agreement;
iii. there are binding corporate rules within the Schwarz Group (for intra-group transfer only) which specifies the recipients and the recipient countries and territories; and
iv. relying on the data protection laws of the recipient jurisdiction if there is in force in that recipient jurisdiction any law which is substantially similar to or serves the same purposes as the PDPA in Singapore or the PDPO in Hong Kong (as the case may be).
6. Retention of personal data
Unless there is a specific legal requirement for us to keep the personal data, we will take all reasonable steps to erase your personal data that is no longer required for the purposes (including any directly related purpose) for which the personal data was originally collected.
Where there are legal requirements for retention, we would not store personal data for longer than the statutory retention requirements call for.
7. Data collected automatically when visiting our website
When you visit our website, various information is exchanged between your device and our server. This can also be personal data. The information collected in this way is, among other things, used to optimize our website or to display advertising in the browser of your device.
Purposes of data processing / legal bases:
When you visit our career website, your device's browser will automatically and without any action on your part send the following data to our career website’s server:
- the IP address of the requesting internet-enabled device,
- the date and time of access,
- the name and URL of the retrieved file,
- the website/ application from which the access was made (referrer URL),
- the browser you are using and, if applicable, the operating system of your internet-enabled computer and
- the name of your access provider
This data is temporarily saved in a so-called log file for the following purposes:
- to ensure a smooth connection,
- to ensure seamless use of our website/ application,
- to evaluate system security and stability.
If you have consented to the so-called geolocation in your browser or in the operating system or other settings of your device, we will use this function to offer you individual services (e.g. the location of the closest job offer) based on your current location. We process your location data exclusively for this purpose.
The legal basis for processing the above data is your consent.
Storage period / criteria for determining the storage period:
The data is stored for a period of seven days and then automatically deleted. If you stop using our career website, the geolocation data will be deleted.
8. Embedded and third-party content
9. On our recruiting portal (creation of a candidate profile)
Thanks for your interest in a career with Lidl. In the following sections we will inform you about which data we process when you visit the recruiting portal.
9.1 What data do we process in the candidate profile?
9.2 Purposes and legal basis – Why do we process your personal data?
9.3 Data retention – How long do we store your personal data?
9.4 Are you obliged to provide the data?
9.5 Your rights as a data subject in relation to this section 9
9.6 Contact person for questions about the recruiting portal
9.7 Responsible entity for the Recruiting Portal
10. Your rights as a data subject in relation to this Privacy Statement (except section 9)
This section applies to all data processing under this Privacy Statement, save for section 9 of this Privacy Statement. For more information on your rights as a data subject in relation to any data carried out pursuant to section 9, please refer to sub-section 9.5.
11. Changes to our Privacy Statement
The Privacy Statement posted here on our website is the latest version, so that you will always know what information we gather, how we might use that information and whether we disclose it to anyone. However, we reserve the right to change this Privacy Statement without prior notification to you or your prior consent. You may determine if any such revision has taken place by referring to the date on which this Privacy Statement was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.