Privacy Policy

1. ABOUT THIS NOTICE AND ITS SCOPE

1.1 EternityJob is an online employment marketplace and technology platform operated by Eternity Connect Sdn. Bhd. (Company No. 202601023199 (1685296-V)) ("Eternity Connect"). Agensi Pekerjaan Eternity Sdn. Bhd. (Company No. 202401030424 (1576273-D)) ("Eternity Recruitment") is a related company and licensed private employment agency in Malaysia which provides employer-facing recruitment and employment marketplace services through or in connection with EternityJob, including job advertising, Candidate search and matching and related recruitment services, and may also provide recruiter-led sourcing, screening, shortlisting, placement and other recruitment services. Eternity Connect and Eternity Recruitment are referred to collectively in this Notice as "Eternity", "we", "us" or "our" where the context permits. The "Platform" means www.eternityjob.com and any related website, mobile application, portal, database, software, system or online employment marketplace service operated by or for Eternity Connect from time to time. Eternity Recruitment may provide its employer-facing and other recruitment services through or in connection with the Platform and may separately provide recruitment services through www.eternity-recruitment.com.

1.2 This Privacy Policy / Personal Data Protection Notice ("Notice") is intended to constitute the written notice required under the Notice and Choice Principle in section 7 of the Personal Data Protection Act 2010 [Act 709] ("PDPA"), as amended from time to time. It explains how we collect, record, hold, store, organise, adapt, retrieve, use, disclose, transfer, analyse, combine, secure, retain, erase and otherwise process personal data in connection with the Platform, EternityJob services and the employer-facing and other recruitment and related services provided by Eternity Recruitment.

1.3 This Notice applies to everyone who uses the Platform as well as the followings: (a) candidates, job seekers and persons who create or maintain a candidate profile ("Candidates"); (b) persons whom we identify or source as potential Candidates, including from lawful external sources (“potential Candidates”); (c) employers, prospective employers, recruiters and their employees, representatives or authorised users ("Employer Users"); (d) visitors and users of the Platform, whether registered or unregistered; (e) referees, emergency contacts and other third parties whose personal data is provided to us; and (f) any other individual whose personal data we process in connection with our recruitment and related services.

1.4 For the purposes of the PDPA, Eternity Connect is generally the data controller in respect of Personal Data for which it determines the purposes and means of processing in connection with the technical operation, administration, security, development and use of the Platform. Eternity Recruitment is generally a separate data controller in respect of Personal Data which it processes in providing employer-facing recruitment and employment marketplace services through or in connection with the Platform, including job advertising, Candidate search and matching, Employer recruitment activities and applications, as well as its recruiter-led sourcing, screening, shortlisting, placement and other licensed private employment agency services. Depending on the particular activity, Eternity Connect and Eternity Recruitment may determine the purposes and means of processing separately or, for certain activities, jointly; or one entity may process Personal Data on behalf of the other where the circumstances and applicable law support that role. An Employer, another member of the Eternity Group or another organisation may also separately act as an independent data controller or as a data processor. Where an Employer receives Candidate information and uses it for its own recruitment, employment, compliance or business purposes, the Employer may have its own obligations under the PDPA and its own privacy notice.

1.5 This Notice should be read together with the applicable Candidate Terms of Use, Employer Terms of Use, cookie notice or settings, specific collection notices, consent statements and any other terms presented to you for a particular feature or service. If a more specific notice is provided for a particular processing activity, that specific notice will apply to that activity to the extent of any inconsistency.

1.6 For this Notice, the "Eternity Group" means Eternity Connect, Eternity Recruitment and their respective holding companies, subsidiaries, fellow subsidiaries, related corporations, associated companies, affiliates and other entities under common ownership or control from time to time, including any recruitment or employment platform operated by or for such entities.

2. WHAT WE MEAN BY PERSONAL DATA

2.1 "Personal Data" has the meaning given under the PDPA and generally means information in respect of commercial transactions that relates directly or indirectly to an individual who is identified or identifiable from that information or from that and other information in our possession or likely to come into our possession.

2.2 "Sensitive Personal Data" has the meaning given under the PDPA and includes personal data relating to health or physical or mental condition, political opinions, religious beliefs or other beliefs of a similar nature, the commission or alleged commission of an offence, biometric data, and any other category prescribed as sensitive personal data by law from time to time.

2.3 Where information has been irreversibly anonymised so that an individual can no longer reasonably be identified, we may use and retain that anonymised information for analytics, research, statistical, service-improvement and other lawful business purposes.

3. PERSONAL DATA WE MAY COLLECT AND PROCESS

3.1 The Personal Data we process depends on your relationship with us, the services you use and the information necessary for the relevant recruitment or Platform activity.

3.2 Candidates and potential Candidates

identity and profile information, including name, photograph, date of birth, age, gender, nationality, citizenship, identity or passport details where reasonably required, work eligibility and immigration or visa status;
contact information, including telephone number, email address, messaging-app details, mailing address and residential address;
CV, resume and professional information, including employment history, job titles, duties, experience, industries, skills, portfolio information, professional memberships, licences, certifications and other career information;
education and qualification information, including schools and institutions attended, qualifications, transcripts, academic results, training, language ability and certifications;
job and remuneration information, including current or previous remuneration where lawfully provided, expected salary, notice period, availability, preferred roles, industries, work arrangements and preferred locations;
application and recruitment information, including jobs viewed or applied for, questions and answers, cover letters, interview notes, screening or assessment results, recruiter notes, shortlisting information, matching information, offer and placement information, and application status such as shortlisted, interviewed, offered, hired or not selected;
reference and verification information, including referee details, references, identity or work-right verification, background checks, employment and qualification verification, where relevant and lawful;
communications and interaction data, including emails, messages, calls, support enquiries, recruiter communications, forms, feedback, surveys and notes of communications;
account and Platform information, including username, password or authentication information, profile settings, visibility settings, saved searches, saved jobs, applications and account preferences;
technical and usage information, including IP address, device identifiers, browser or device information, login records, date and time stamps, clickstream, pages viewed, searches, cookies, analytics identifiers and security logs;
location information, where you provide it or enable a location-based feature; and
any other information that you voluntarily provide or that we lawfully obtain and that is reasonably relevant to recruitment, matching, verification, legal, compliance, security or operational purposes.

3.3 Employer Users and other business contacts

name, designation, work contact details and other business contact information;
employer or organisation name, registered or business address, industry, company details and information reasonably required to verify the organisation or authorised user;
account credentials, authorised-user information, roles and permissions;
job advertisements, vacancy information, hiring requirements, candidate preferences and recruitment instructions;
communications, support requests, service history, feedback and records of dealings with us;
billing, invoice, transaction and payment-related information where relevant; and
Platform usage, device, login, security and analytics information.

3.4 Website visitors and unregistered users

3.4.1 If you visit or interact with the Platform without creating an account, we may still collect technical and usage data, cookie information, IP address, device and browser information and any contact details or Personal Data that you provide through enquiries, forms, subscriptions or communications.

3.5 Referees and other third parties

3.5.1 If you are named as a referee, emergency contact, representative, employee, director or other related person, we may process your name, contact details, relationship with the relevant Candidate or Employer and any information you provide to us in that capacity.

4. SOURCES OF PERSONAL DATA

4.1 We may obtain Personal Data from the following sources:

directly from you when you create an account, complete a profile or form, upload or send a CV, apply for a job, communicate with us, attend an interview or assessment, use the Platform or otherwise deal with us;
job boards, online recruitment portals, candidate databases, applicant-tracking systems and other recruitment sources to which we have lawful or authorised access;
professional networking platforms and services, including LinkedIn and similar services, subject to applicable law and the relevant platform terms;
publicly accessible professional profiles, company websites, professional directories, publications and other lawful public sources;
referrals, recruiters, recruitment partners, business partners, Employer Users, current or former employers, referees, educational institutions, professional bodies and verification providers;
members of the Eternity Group and Group recruitment platforms;
service providers that support recruitment, verification, communications, technology, analytics, fraud prevention, security, administration or other functions;
government departments, regulators, licensing authorities, law-enforcement bodies and other lawful sources where permitted or required by law; and
your device, browser and online activities when you use the Platform, including through cookies and similar technologies.

4.2 Where Eternity Recruitment or another member of the Eternity Group obtains your Personal Data from an external source, we may create or update a Candidate record in order to assess whether there may be a relevant recruitment opportunity and to contact you. We will provide this Notice as soon as practicable in accordance with the PDPA. Where consent is required before a particular further use, disclosure, searchable profile, Group sharing or other processing activity, we will seek the relevant affirmative consent before carrying out that activity.

4.3 If an Employer provides us with information about the outcome or progress of an application, we may record that information to administer the recruitment process, improve matching, maintain our recruitment records and provide our services.

5. WHY WE PROCESS PERSONAL DATA

5.1 Depending on the relevant entity, service and interaction, we may process Personal Data for one or more of the following purposes, where lawful and reasonably necessary:

Account and profile administration: to create, verify, maintain and manage Candidate and Employer Platform accounts, records, profiles, preferences, access rights and settings.
Recruitment and job matching: to help Candidates search for and apply for jobs through the Platform; to support job advertising, Candidate search, matching, recommendations and invitations provided as part of the employer-facing recruitment services of Eternity Recruitment; and, where applicable, to identify, source, assess, screen, shortlist, match and recommend Candidates for current or future job opportunities as part of recruiter-led services provided by Eternity Recruitment.
Candidate and Employer communications: to contact Candidates and Employer Users about applications, vacancies, interviews, assessments, offers, placements, account matters, service updates and other recruitment-related communications.
Profile visibility and employer access: to make authorised Candidate Profiles or portions of Candidate information searchable or viewable by verified Employer Users and, where applicable, authorised Eternity Group recruitment platforms.
Applications and placements: to facilitate job applications, interviews, screening, assessments, reference checks, verification, offers, onboarding, placement and related communications and administration.
Employer services: for Eternity Recruitment to provide employer-facing recruitment and employment marketplace services through or in connection with the Platform, including posting or managing job advertisements, providing Candidate-search, matching or other recruitment tools, managing Employer accounts and recruitment activity, verifying Employer Users and administering applicable fees, billing and transactions; and, where applicable, to provide recruiter-led sourcing, screening, shortlisting, placement or related services. Eternity Connect may process relevant Personal Data to operate, administer, secure, support and develop the technology through which those services are delivered.
Eternity Group services: to coordinate recruitment activities, share recruitment technology and infrastructure, identify opportunities across the Eternity Group, reduce duplicate records and provide integrated or cross-platform recruitment services.
AI, automation and analytics: to parse and organise CV information, support search and matching, generate recommendations, assist screening, improve relevance, detect anomalies, support recruiters and Employer Users, and operate or improve recruitment technology, subject to Section 10 below.
Service improvement and research: to conduct analytics, testing, research, quality assurance and product or service development, including developing and improving recruitment processes, algorithms and technology.
Security and integrity: to authenticate users, detect and prevent fraud, scraping, abuse, unauthorised access, security incidents and other prohibited or unlawful activities, and to protect our systems, users and business.
Customer support and relationship management: to respond to enquiries, provide support, manage complaints, conduct surveys, understand user needs and maintain our business relationships.
Marketing and career communications: to send job alerts, career-related content, events, newsletters or promotional communications where permitted by law and, where required, with consent.
Legal, regulatory and record-keeping obligations: to comply with the PDPA and other applicable legal, regulatory, licensing, tax, accounting, audit and corporate requirements, including, where applicable to Eternity Recruitment, the Private Employment Agencies Act 1981 [Act 246] and its licensing conditions, and to establish, exercise or defend legal rights.
Business administration and transactions: for internal governance, insurance, professional advice, corporate restructuring, investment, financing, merger, acquisition, sale or transfer of all or part of our business, subject to appropriate safeguards.

5.2 We will not process Personal Data for a new purpose that is incompatible with the purpose for which it was collected unless that processing is permitted by law and, where required, we have first provided further notice and obtained the necessary consent.

5.3 Depending on the circumstances, processing may be carried out with your consent or explicit consent, where necessary for the performance of a contract or steps requested by you before entering into a contract, to comply with a legal obligation, to protect vital interests, for the administration of justice, for functions conferred by law, or under another applicable provision or exception of the PDPA.

6. WHETHER PROVIDING PERSONAL DATA IS OBLIGATORY OR VOLUNTARY

6.1 Some Personal Data is obligatory if it is reasonably required to create or secure an account, verify identity or authority, submit or process an application, provide a requested recruitment service, comply with a legal requirement or complete another function that cannot reasonably be performed without the information. Required fields will generally be identified in the relevant form or user flow.

6.2 Other Personal Data is voluntary, including optional profile fields, preferences and other information that is not necessary for the relevant service. You may choose not to provide voluntary information.

6.3 If you do not provide Personal Data that is obligatory for a particular purpose, we may be unable to create or verify your account, process an application, provide some or all recruitment or Platform services, communicate with you, comply with legal requirements, or complete the relevant transaction or request.

7. CANDIDATE DATABASE, PROFILES AND VISIBILITY

7.1 Eternity Connect may maintain a Platform database containing Candidates who register for or use the Platform. Eternity Recruitment may access and process relevant Candidate information through the Platform in connection with the employer-facing recruitment services it provides and may separately maintain recruitment records or databases containing Candidates and potential Candidates lawfully sourced through the channels described in this Notice for its recruitment services. Where permitted by law, applicable settings and any required consent or authorisation, relevant Candidate information may be shared between Eternity Connect and Eternity Recruitment or other members of the Eternity Group for the purposes described in this Notice. We may extract, organise, standardise, classify, summarise, combine or update information from a CV, professional profile, application, communication or other lawful source in order to create or maintain a Candidate Profile or recruitment record.

7.2 Candidate information may be used by authorised Eternity Connect personnel for technical Platform administration, security, support, development and other Platform purposes and, where lawfully shared or separately collected, by authorised Eternity Recruitment personnel for employer-facing recruitment marketplace services, Candidate matching, Employer recruitment activity and recruiter-led recruitment services. A Candidate Profile will only be made searchable or otherwise available to Employer Users or through participating Eternity Group recruitment platforms in accordance with the Candidate's applicable profile settings, application activity, instructions, consent or other lawful basis.

7.3 Employer-facing Candidate information may include recruitment-relevant information such as job title, experience, skills, qualifications, industry, preferred role, preferred location, remuneration expectations, work eligibility and other information reasonably relevant to recruitment. We do not ordinarily make identity documents, NRIC or passport numbers, account passwords, bank information, full residential addresses, referee contact details or Sensitive Personal Data generally searchable by Employer Users.

7.4 Where a Candidate applies for a particular job, submits a profile to an Employer or otherwise requests that we facilitate a recruitment opportunity, we may disclose the relevant application, CV and related information to that Employer. Depending on the feature, an Employer may store or manage that information within its own recruitment systems.

7.5 Where the Platform provides profile visibility controls, Candidates may change the available settings through their account or request that we restrict or deactivate profile visibility, subject to technical limitations, active applications, legal obligations and statutory record-retention requirements.

8. EMPLOYER ACCESS TO CANDIDATE INFORMATION

8.1 Employer Users may be given access to Candidate information through the Platform only for legitimate recruitment, hiring, workforce-planning and related purposes as part of the employer-facing recruitment services provided by Eternity Recruitment through or in connection with the Platform, and in accordance with the relevant Candidate settings, application activity, instructions, consent or other lawful basis.

8.2 Our Employer Terms of Use may impose contractual requirements on Employer Users, including requirements to keep Candidate information confidential and secure, restrict access to authorised personnel, use Candidate information only for permitted recruitment purposes, and not scrape, sell, resell, publish, exploit or use Candidate information for unrelated marketing or other unauthorised purposes.

8.3 Once Candidate information is lawfully disclosed to an Employer and the Employer determines its own purposes and means of processing, the Employer may act as a separate data controller. The Employer's subsequent processing may be governed by its own privacy notice and legal obligations. We encourage Candidates to review the relevant Employer's privacy information where appropriate.

8.4 We may suspend, restrict or terminate Employer access where we reasonably suspect unauthorised access, scraping, misuse, unlawful disclosure or another breach of our terms or applicable law.

9. SHARING WITH THE ETERNITY GROUP AND OTHER RECIPIENTS

9.1 Sharing within the Eternity Group

9.1.1 To provide integrated recruitment services and broaden employment opportunities, we may disclose or make Personal Data available to members of the Eternity Group for purposes that are the same as, directly related to or compatible with the purposes described in this Notice. This may include making authorised Candidate Profiles available through websites, databases, portals, applications or other recruitment systems operated by or for members of the Eternity Group (collectively, "Group Recruitment Platforms").

9.1.2 Eternity Group sharing may be used to coordinate candidate management, identify suitable opportunities across different recruitment businesses, reduce duplicate records, support cross-industry or cross-border recruitment, operate shared technology, provide common support functions and improve Group recruitment services.

9.1.3 A member of the Eternity Group may act as a separate data controller or as a data processor depending on the function it performs. Where the relevant consent or authorisation covers Group recruitment sharing, we may make a Candidate Profile available through participating Group Recruitment Platforms without obtaining a fresh consent for every individual Group platform or Employer, subject to the Candidate's applicable profile settings, stated preferences, this Notice and applicable law.

9.2 Other classes of recipients

9.2.1 For the purposes described in this Notice, we may disclose Personal Data to the following classes of third parties where reasonably necessary and lawful:

current or prospective Employers and their authorised personnel;
members of the Eternity Group and operators of Group Recruitment Platforms;
recruiters, referral partners, recruitment partners and other persons involved in a relevant search, application or placement;
background-check, identity, work-right, qualification, employment, reference, assessment and compliance providers;
cloud hosting, database, applicant-tracking, CRM, communication, email, messaging, analytics, artificial-intelligence, cybersecurity, IT support, payment, backup and other service providers acting for or supporting us;
professional advisers, including lawyers, auditors, accountants, consultants and insurers;
banks, payment processors and financial service providers where relevant to a transaction;
government departments, regulators, licensing authorities, law-enforcement bodies, courts and other authorities where required or permitted by law; and
prospective purchasers, investors, financiers, merger partners, successors or other parties involved in a genuine corporate or business transaction, subject to appropriate safeguards.

9.2.2 Where a Candidate has authorised us to make the Candidate Profile available generally to suitable verified Employers for recruitment purposes, we may do so without seeking separate consent for each individual Employer, unless the Candidate has notified us of a more restrictive preference or applicable law requires otherwise.

10. ARTIFICIAL INTELLIGENCE, AUTOMATION, MATCHING AND MODEL IMPROVEMENT

10.1 We may use search tools, CV parsing, classification, recommendation systems, analytics, machine learning, artificial intelligence and other automated or semi-automated tools to assist in organising information, identifying potentially relevant Candidates or roles, improving search and matching, generating summaries or recommendations, supporting screening and helping our personnel and Employer Users use the Platform more efficiently.

10.2 These tools may consider recruitment-relevant information such as skills, experience, qualifications, career history, job preferences, location, work eligibility, remuneration preferences, Platform activity, application history and recruitment outcomes. Where voice, video, biometric or other Sensitive Personal Data is proposed to be used by an AI-enabled feature, we will apply the additional requirements applicable to that data and obtain explicit consent where required.

10.3 Automated outputs are intended to support recruitment activities and may be incomplete, probabilistic or inaccurate. Where an automated process could materially affect a Candidate's employment opportunity, we will implement appropriate safeguards and meaningful human involvement in accordance with applicable law and regulatory guidance. We do not intend AI-generated scores or recommendations to be treated as an infallible assessment of a Candidate.

10.4 We may use Personal Data and information derived from it to develop, test, validate, evaluate, fine-tune and improve our own recruitment technology, algorithms, matching systems, AI or machine-learning tools and related services, where that use is lawful, compatible with the purposes notified to you and subject to any consent requirements that apply.

10.5 For development and model-improvement activities, we will where reasonably practicable apply data minimisation and use anonymised, aggregated, masked, pseudonymised or otherwise de-identified information instead of directly identifying information. We do not intend to use Sensitive Personal Data for general-purpose model training unless the use is specifically necessary and lawful and any required explicit consent has been obtained.

10.6 We may engage third-party AI or technology providers to process information on our behalf. Where a provider proposes to use Personal Data for its own independent purposes or to train or improve its own general-purpose models, we will assess the proposed use, provide additional notice and obtain consent where required by the PDPA before permitting such use.

10.7 If a particular AI or automated feature involves materially different processing from that described in this Notice, we may provide a feature-specific notice or consent mechanism before the feature is used.

11. SENSITIVE PERSONAL DATA, REFERENCES AND VERIFICATION

11.1 You should avoid including Sensitive Personal Data in your CV, profile or application unless it is relevant and reasonably necessary for the recruitment process or specifically requested for a lawful purpose.

11.2 We will process Sensitive Personal Data only where permitted under the PDPA, including where the data subject has given explicit consent or another applicable statutory condition is satisfied.

11.3 We may contact referees, former employers, educational institutions, professional bodies, government or verification providers to verify information where relevant, lawful and appropriately authorised. Where you provide Personal Data about a referee or another individual, you should ensure that you are authorised to provide it to us and that any required consent has been obtained.

11.4 If an Employer requests a background, identity, work-right, qualification, criminal-record or other verification check, additional notices, declarations or consents may be provided where appropriate.

12. COOKIES, ANALYTICS AND THIRD-PARTY SERVICES

12.1 The Platform may use cookies, pixels, local storage, analytics tools and similar technologies to keep users signed in, remember preferences, maintain security, understand usage, measure performance, improve services and, where permitted, support advertising or marketing. Where required, we will provide appropriate cookie choices or seek consent for non-essential technologies.

12.2 If you use a third-party sign-in, verification, payment, assessment, communication or integration feature, the relevant third party may provide information to us or receive information from us as necessary to provide that feature. The third party may also process information under its own privacy terms.

12.3 The Platform may contain links to third-party websites, job boards, social-media services, Employer career sites or other platforms that we do not control. Their privacy practices are governed by their own policies, and you should review those policies before providing information to them.

13. MARKETING, JOB ALERTS AND RECRUITMENT COMMUNICATIONS

13.1 Communications concerning an active application, a role discussed with you, account administration, security, support or other requested recruitment services are service or recruitment communications and are distinct from general marketing.

13.2 We may send job alerts, career content, newsletters, invitations, surveys, events or promotional communications through email, telephone, SMS, messaging applications, push notifications or other channels where permitted by law and, where required, with your consent.

13.3 You may opt out of direct marketing at any time by using an available unsubscribe or preference function or by contacting us. Opting out of marketing will not necessarily stop communications that are necessary for an active application, account security, service delivery, legal compliance or another permitted purpose.

14. CROSS-BORDER TRANSFERS AND OVERSEAS ACCESS

14.1 Our recruitment activities and technology may involve transferring Personal Data to, storing it in, hosting it in, or making it accessible from locations outside Malaysia. This may occur where an Employer, a member of the Eternity Group, a service provider, cloud or backup system, AI or technology provider, support team, recruitment partner or Group Recruitment Platform is located or operated outside Malaysia.

14.2 Overseas recipients may be subject to laws that differ from Malaysian law. We will take reasonable steps appropriate to the nature of the Personal Data and the transfer to ensure that the information is protected in accordance with applicable legal requirements.

14.3 The countries in which our service providers, Employers, Eternity Group entities and other recipients operate may change from time to time.

15. RETENTION OF PERSONAL DATA

15.1 We retain Personal Data for no longer than reasonably necessary for the purpose for which it was collected or further processed, subject to any minimum retention period imposed by law, the need to establish or defend legal claims, regulatory or audit requirements, security needs and legitimate operational requirements permitted by law.

15.2 Where Personal Data is processed by Eternity Recruitment in its capacity as a licensed private employment agency, Eternity Recruitment is required under section 19 of the Private Employment Agencies Act 1981 to prepare, maintain and keep prescribed records, including records of job-seeker registration, employer registration, vacancies, placements and fees, for a period of not less than six (6) years from the date after the relevant record is made.

15.3 Candidate profile information held through the Platform, or other Candidate information that is not required to be retained by Eternity Recruitment as part of a statutory private-employment-agency record, may, as a general operational guideline, be retained for up to five (5) years after the Candidate's last meaningful interaction, application or profile update, unless the Candidate renews or continues the relationship, a longer period is reasonably necessary for an active Platform or recruitment purpose, or retention is required or permitted by law.

15.4 Contracts, invoices, accounting records, placement records, compliance records, consent records, complaint records and information relevant to actual or potential disputes may be retained for up to seven (7) years or such longer period as is required or permitted by applicable law or reasonably necessary for the relevant purpose.

15.5 When Personal Data is no longer required, we will take reasonable steps to delete, destroy, anonymise or remove it from active use, subject to lawful backup cycles, disaster-recovery systems, legal holds, archival obligations and technical limitations. Anonymised information may be retained without the same time limitation where it no longer identifies an individual.

16. SECURITY AND PERSONAL DATA BREACHES

16.1 We implement reasonable technical and organisational security measures appropriate to the nature of the Personal Data and the risks of processing. Measures may include role-based access controls, authentication, password controls, encryption where appropriate, logging and monitoring, backups, security testing, confidentiality obligations, staff training, vendor controls and incident-response procedures.

16.2 No method of storage or transmission is completely secure. You are responsible for keeping your account credentials confidential and should notify us promptly if you suspect unauthorised access to your account.

16.3 If a Personal Data breach occurs, we will investigate, contain and assess the incident and will notify the Personal Data Protection Commissioner and affected data subjects within the periods and circumstances required by the PDPA and applicable regulatory requirements.

17. YOUR RIGHTS, CHOICES AND MEANS TO LIMIT PROCESSING

17.1 Subject to the PDPA, applicable exceptions and verification of your identity or authority, you may have the following rights and choices in relation to your Personal Data:

Access: request access to Personal Data held by us and information about our processing, subject to the conditions, exceptions and fees permitted by law.
Correction: request correction of Personal Data that is inaccurate, incomplete, misleading or not up to date.
Withdrawal of consent: withdraw consent prospectively where processing is based on consent, subject to legal or contractual consequences and any processing that remains permitted or required by law.
Limit processing: request that we limit particular processing activities or profile visibility, including by changing available account settings or contacting us.
Prevent processing likely to cause damage or distress: make a written request in the circumstances provided under the PDPA.
Direct marketing: require us to cease or not begin processing Personal Data for direct-marketing purposes.
Data portability: request by electronic written notice that we transmit your Personal Data to another data controller of your choice, subject to technical feasibility, compatibility of data format and applicable legal requirements.
Profile choices: change available Candidate Profile visibility settings, deactivate a searchable profile, or request restriction of Employer or Group visibility, subject to active applications, lawful processing and statutory retention.
Account deletion or deactivation: where the Platform provides this functionality, request deletion or deactivation of your account. Certain Personal Data may nevertheless be retained where required or permitted by law, including statutory private-employment-agency records which Eternity Recruitment is required to retain.
Complaint: raise an enquiry or complaint with us concerning our handling of Personal Data and, where applicable, make a complaint to the Personal Data Protection Commissioner.

17.2 To exercise a right or choice, use any available Platform setting or contact us using the details in Section 21. We may require reasonable information to verify your identity, locate the relevant records or verify that you are authorised to act for another person.

17.3 Withdrawal of consent or restriction of processing operates prospectively and does not affect processing already lawfully carried out. Depending on the request, we may be unable to continue providing some or all recruitment or Platform services.

17.4 Where we are unable to fully comply with a request because of a legal obligation, statutory retention requirement, active legal claim, security requirement, another person's rights or another exception permitted by the PDPA, we may retain or continue processing the affected information to the extent permitted by law.

18. CONSENT, ACKNOWLEDGEMENT AND RECORDS OF CHOICE

18.1 This Notice is intended to inform you about our processing and does not by itself mean that every processing activity is based solely on consent. Where the PDPA requires consent or explicit consent for a particular activity, we will seek that consent through an appropriate affirmative mechanism.

18.2 Consent may be obtained electronically or in writing, including through an unchecked tick box linked to the relevant notice, an online form, a click-to-accept mechanism, a signed form, or a clear affirmative written reply by email, messaging application or other recorded communication.

18.3 We may retain evidence of a consent or choice, including the wording or version presented, date and time, method, relevant account or contact information and subsequent withdrawal or change.

18.4 Where a Candidate authorises Eternity Connect and/or Eternity Recruitment, as applicable, to make the Candidate Profile available generally to suitable verified Employers and/or participating Eternity Group recruitment platforms for recruitment purposes, that authorisation may cover subsequent disclosures within the notified scope without fresh consent for every individual Employer or participating Group platform, unless a more restrictive preference is selected or applicable law requires otherwise.

18.5 Where explicit consent is required for Sensitive Personal Data, or a materially different purpose requires additional consent, we may obtain a separate or additional consent notwithstanding any general account acceptance or earlier consent.

19. CHILDREN AND YOUNG USERS

19.1 Our recruitment services are principally intended for individuals who are legally able to seek employment and use the relevant service. If a person under eighteen (18) years of age uses a service for which parental or guardian consent is required by applicable law or the circumstances, the parent or legal guardian should provide the necessary consent or authority.

19.2 If we become aware that Personal Data of a minor has been provided without any consent or authority required by law, we may restrict the relevant account or processing and take reasonable steps appropriate to the circumstances.

20. CHANGES TO THIS NOTICE

20.1 We may update this Notice from time to time to reflect changes in law, regulatory guidance, technology, the Platform, Eternity Group arrangements, service providers or our processing practices. The current version will state its effective or last-updated date and will be made available on the Platform.

20.2 Where a change is made to this notice, including any change to processing, categories of Personal Data, classes of recipients, AI/model-training use, profile-sharing arrangements or other processing, we will provide notice on this platform and such change shall become valid and binding upon being published on the Platform.

21. CONTACT, DATA PROTECTION OFFICER AND COMPLAINTS

21.1 If you have questions about this Notice, wish to exercise a right or choice, withdraw consent, restrict profile visibility, make a complaint or contact us about our processing of Personal Data, you may contact:

Organisations: Technology platform operator / data controller for relevant technical Platform processing: Eternity Connect Sdn. Bhd. (Company No. 202601023199 (1685296-V)) Licensed private employment agency / data controller for employer-facing recruitment and related services, including services provided through or in connection with EternityJob: Agensi Pekerjaan Eternity Sdn. Bhd. (Company No. 202401030424 (1576273-D))
Address: A-06-01, A-06-02, A-06-03 & A-06-12, Tower A, Vertical Business Suite, Avenue 3, Bangsar South, No. 8, Jalan Kerinchi, 59200, Kuala Lumpur.
Email: privacy@eternityjob.com

21.2 We will consider privacy enquiries and complaints in accordance with applicable law. If you remain dissatisfied, you may have the right to raise the matter with the Personal Data Protection Commissioner of Malaysia.

22. LANGUAGE

22.1 This Notice is intended to be issued in both English and Bahasa Malaysia in accordance with section 7(3) of the PDPA. Both versions are intended to communicate the same substantive information. In the event of an inconsistency, the English version will prevail to the extent permitted by law.