Our purpose is to help people live more fulfilling and productive working lives and help organisations succeed. We believe it’s important that you understand how your information is collected, used, protected and how you can manage it when you engage with us. Our Privacy Policy explains all of this in detail below.
By registering and creating an account with us, using our products and services, visiting our Platforms or simply engaging with us over the phone, via email, in person or by any other means, the terms contained in this Privacy Policy will apply to you.
Capitalised terms in this Privacy Policy are defined in section 17, unless otherwise stated.
Papaya is a digital job marketplace and talent-matching platform operated by:
INDEX AI PTE. LTD.
160 ROBINSON ROAD, #14-04, SINGAPORE BUSINESS FEDERATION CENTER, SINGAPORE 068914
Email: info@mypapaya.ai
We provide digital services that help Candidates find job opportunities and help Employers identify, evaluate, and hire suitable talent. Our ecosystem includes:
Papaya Candidate Platform
Papaya Employer Platform
Papaya AI (resume parsing, job matching, scoring)
Talent Search (for Employers)
People Search (public or semi-public profiles, depending on user settings)
Partner Integrations (ATS, HRIS, and recruitment partners)
We may operate in additional countries in the future. When we do, this Privacy Policy will apply to your use of our Services unless otherwise specified.
Papaya is the primary data controller for Personal Information you provide or that we collect through the Papaya Services.
When you apply for a job, interact with an Employer, or choose to share your Profile with an Employer:
We process your Personal Information as a data controller.
The Employer also becomes an independent data controller of any Personal Information you provide.
Papaya is not responsible for how Employers or third-party partners use your information once shared.
If you interact with Papaya through a third-party service, such as an ATS provider, job distribution network, or recruitment agency:
Papaya and the third-party provider may each act as controllers and processors for different aspects of your Personal Information.
Papaya will not control how those third parties handle your information after sharing.
We collect different types of information about you depending on how you interact with us and use the Papaya Services. For example:
To sign up as a Registered User on our Platforms (whether you are a Candidate or an Employer), you will need to provide basic information such as your name and email address.
If you are a Candidate, and you choose to create a Profile and/or apply for a job, depending on the Employer, we may collect additional Personal Information about you on behalf of the Employer.
The main types of information (including Personal Information) we may collect include, but are not limited to, the following.
Description
General Data
For all Registered Users:
Your name, email address, Google Login identifier and any password you choose to set within our Platforms.
For Candidates setting up a Profile, you may elect to disclose the following information:
Your country of residence, preferred work locations, résumé(s), licences and certifications, profile photo, and any other Personal Information included in your résumé or Profile. This information may be processed using Papaya AI to extract structured data and improve job matching.
For Candidates applying for a job:
Depending on the Employer, we may collect additional Personal Information from you on behalf of the Employer, including any information contained within your résumé, cover letter, responses to application questions or role requirements. We may also collect information from our partners (including ATS providers) relating to your application status with the Employer (such as shortlisted, interview, hired, rejected or equivalent terms).
Contact Data
Your email address, mobile number, other contact numbers, home address, contact address and, where applicable, company details.
For Registered Users using Google Login:
Your Google-associated name and email address.
If you are an Employer:
Company name, business address, billing address, and the name, email address and phone number of your primary account holder and any authorised additional users.
Other contact information a Candidate may include in their résumé(s) uploaded to our Platforms or shared through Papaya AI.
Any other contact information a User may share with us in the course of using our Platforms.
Background Data
For Candidates setting up a Profile, you may elect to disclose a personal summary, career history, profile photo, educational background, certifications, language skills, other skills, salary expectations, preferred job classifications and locations, right-to-work information, preferred work types, availability, and any other background information contained in your résumé(s) uploaded to our Platforms. We may process this information through Papaya AI to enhance matching accuracy.
Usage and Device Data
Information relating to your access and visits to the Platform, usage patterns, device identifiers, Cookies, pages visited, search and click activity, personalised content preferences, IP address, browser type, operating system, referrer page, timestamps and clickstream data captured in log files. This information is automatically collected through Cookies or similar technologies placed on your browser or device (see Section 11 for details on how we manage Usage and Device Data).
Third Party Data (including Personal Information of a Related Person)
Name, email address, mobile number, other contact numbers, workplace, position and relationship with the Registered User. You must ensure that you have obtained consent from any relevant third party before disclosing their Personal Information to us.
Location Data
Your home address, contact address and, depending on your device settings, your device’s approximate or precise location while using the Platform. Device location is stored only on your device and only where you have given permission for the application to identify your location.
We may collect your Usage and Device Data, Contact Data and/or Location Data if you engage with us as an Unregistered User. For example, if you access job listings, browse our Platforms, or contact us by phone, email or online form without creating an account.
For Users who are under the minimum age required under applicable privacy laws, you represent and warrant that your parent or legal guardian has been informed of and agreed to this Privacy Policy. Where required by law, you are responsible for obtaining valid parental or guardian consent (“Parental Consent”) before providing us with your Personal Information.
We may request evidence of Parental Consent and reserve the right to delete any Personal Information collected from you if we cannot verify that you have obtained the necessary consent. We will not be responsible or liable where you fail to obtain Parental Consent.
We may also collect other Personal Information that you provide to us as part of your engagement with the Platform, including but not limited to information submitted in surveys, promotions, feedback forms, assessments, or communications with our support team.
In most cases, we do not need to collect your Sensitive Information when you engage with us. You should not disclose any Sensitive Information to us unless it is necessary or directly relevant. Candidates should be particularly careful during the job application process and when creating or updating a Profile, especially when selecting the “Public” visibility setting (see section 13 below for further information on Profile visibility settings).
However, there may be circumstances where we do collect and handle your Sensitive Information. For example, a Candidate may choose to provide an Employer with specific health information (such as vaccination status information) or other Sensitive Information as part of a job application. In such cases, this information will be collected by us on behalf of the Employer.
We will only collect Sensitive Information where:
a. you consent to our collection and processing of the Sensitive Information by voluntarily including such information within your résumé, Profile, cover letters, responses to application questions, or other documents submitted to an Employer as part of a job application process;
b. you voluntarily include such information within your Profile or any information you upload to our Platforms, including any materials processed through Papaya AI;
c. you have provided your explicit consent to a third-party verification or assessment provider (where relevant) to share such Sensitive Information with us; or
d. we are permitted or required to collect such information under applicable laws.
If you select the “Public” visibility setting for your Profile, any Personal Information (including Sensitive Information) that you include in your Profile may become widely accessible to the public through People Search or through third-party platforms and websites that index or receive Profile data. This may include General Data and Background Data that you have added to your Profile. We strongly recommend that you carefully review all information in your Profile and remove any Sensitive Information that you do not wish to be publicly accessible before selecting the “Public” visibility setting, as such information may remain visible or cached on external platforms even after your visibility settings change or your Profile is deleted.
Third-party platforms and websites operate independently of Papaya and may retain, cache, or republish publicly available content according to their own schedules and policies. You are solely responsible for ensuring that your Profile does not contain Sensitive Information that you do not wish to be publicly accessible.
We collect your Personal Information in several different ways depending on how you engage with us and our Platforms.
We collect your Personal Information directly from you when you interact with us, including (but not limited to) when you:
– register and create an account using your Google login;
– create or update your Profile;
– upload résumés, documents, or other information (including documents processed through Papaya AI for parsing or enhancement);
– apply for a job through our Platforms;
– communicate with us by phone, email, chat, or through other channels; or
– access or use our Platforms, products, or services.
We may receive or collect your Personal Information from another entity within the Papaya Group (as defined in section 17), in accordance with the privacy policies of those entities and applicable data protection laws.
We may also collect your Personal Information indirectly through third parties, including:
Google Login
When you register or sign in using your Google account, you give Google permission to share certain information with us, such as your name and email address. If you already have a Papaya account registered with the same email address, we may link your existing account to your Google login.
Please note that updating your email address in your Papaya account settings will not unlink your Google login. You may unlink Papaya from your Google account through your Google Account’s “Security” or “Apps with access to your account” settings. If you unlink your Google account, we will continue to retain any Personal Information originally shared with us at registration.
Service Providers and Partners
We may collect your Personal Information through third parties we work with, including recruitment software providers, background verification partners, analytics providers, and other Service Providers or Partners involved in facilitating our services.
Employers / Advertisers
If you are a Candidate, we may collect additional Personal Information from Employers (such as updates to your application status) if this information is captured within our Platforms during a job application process.
Government, regulatory, or enforcement authorities
Where required or permitted by law, we may receive Personal Information about you from government agencies, law enforcement bodies, regulatory authorities, or similar organisations. This may include information from agencies responsible for immigration, border security, or identity verification.
We collect Usage and Device Data through Cookies and similar technologies when you use our Platforms or interact with Papaya content on third-party sites. This includes information about your device, browsing behaviour, interactions with pages or advertisements, and other technical data.
For more information on Cookies and how we manage Usage and Device Data, please refer to section 11 of this Privacy Policy.
We collect and Process Personal Information from you where we have a legal basis to do so and where such Processing is necessary for the purposes set out below.
To provide you with our products and services
We use your Personal Information (including information processed through tools incorporating artificial intelligence and machine learning, such as Papaya AI) to operate and deliver our products and services. This includes, but is not limited to:
– assisting and enabling Candidates in searching for roles and submitting job applications;
– assisting Employers in identifying and recruiting suitable Candidates;
– parsing résumés, cover letters, and related documents through Papaya AI to generate structured information;
– making your Profile searchable and viewable to Employers through Talent Search and, where selected by you, publicly viewable through People Search;
– enabling you to receive job recommendations and application insights;
– enabling Employers and Partners to contact relevant Candidates;
– verifying your identity and account credentials; and
– managing your account, transactions, and interactions with our Platforms.
General Data
Contact Data
Background Data
Usage and Device Data
Third Party Data
Location Data
Legitimate Interest
Contractual Necessity
Notification and/or Consent (where required under applicable Privacy Laws)
To customise and improve our products and services
We use your Personal Information—including through Papaya AI and other automated systems—to personalise, enhance, and improve your experience across our Platforms. This may include:
– tailoring job recommendations for Candidates;
– generating suitability assessments comparing a Candidate’s résumé to job requirements;
– suggesting screening questions or assessment items for Employers;
– providing Employers with indicators or signals (such as Candidate responsiveness or likelihood of engagement);
– optimising search ranking and relevance within Talent Search and People Search;
– improving the accuracy of résumé parsing, categorisation, and skill extraction through machine learning.
Your résumé and Profile information may be processed by automated systems to analyse your suitability relative to job opportunities. Insights generated may be visible to both Candidates and Employers.
General Data
Contact Data
Background Data
Usage and Device Data
Location Data
Legitimate Interest
Notification and/or Consent (where required by applicable Privacy Laws)
To communicate with you and provide support
We may contact you to provide information about your account, technical updates, product usage, actions on your applications, and other support-related matters.
When communicating with you via phone, we may record calls for training, verification, and quality assurance purposes. We may also send verification messages (such as emails or SMS) to keep your account secure.
General Data
Contact Data
Usage and Device Data
Location Data
Legal Obligation
Legitimate Interest
Notification and/or Consent (where required by applicable Privacy Laws)
To market and promote our products and services
We may use your Personal Information to send you marketing communications about Papaya’s products, features, job-related content, newsletters, events, surveys, promotional campaigns, and other information that may be of interest to you.
We may communicate with you through email, SMS, push notifications, online messages, telephone, instant messaging platforms, or via social media.
See section 13 for how you can manage your communication preferences.
General Data
Contact Data
Background Data
Usage and Device Data
Location Data
Legitimate Interest
Notification and/or Consent (where required by applicable Privacy Laws)
Usage and Device Data for personalised advertising
We monitor and analyse your Usage and Device Data to personalise, manage, and target display advertisements visible to you across our Platforms or third-party sites.
See section 11 for more information regarding Cookies and targeted advertising.
General Data
Contact Data
Usage and Device Data
Location Data
Legitimate Interest
Notification and/or Consent (where required by applicable Privacy Laws)
To conduct market surveys, trials, and customer research
We may use your information to conduct research, usability studies, analytics, beta testing, surveys, and other initiatives to understand how Users interact with our Platforms and to improve our products.
General Data
Contact Data
Usage and Device Data
Legitimate Interest
Notification and/or Consent (where required by applicable Privacy Laws)
To send you information about products and services offered by Papaya, Employers, and Partners
We may send you information about opportunities, products, events, or services offered by Papaya, our Partners, or Employers that may be relevant to you.
General Data
Contact Data
Background Data
Legitimate Interest
Notification and/or Consent (where required by applicable Privacy Laws)
For research and development
We use your Personal Information to gain insights into User behaviour and improve or develop new products and services across the Papaya Group. This includes analytics, testing, AI model improvement, and internal research initiatives.
General Data
Contact Data
Background Data
Usage and Device Data
Location Data
Legitimate Interest
Notification and/or Consent (where required by applicable Privacy Laws)
To manage and administer our products and services, verify identity, and ensure security
We use your Personal Information to:
– verify your identity;
– monitor and protect our Platforms from misuse;
– detect, prevent, and respond to fraud, abuse, security incidents, or malicious behaviour;
– maintain the safety and integrity of our systems and operations.
General Data
Contact Data
Background Data
Usage and Device Data
Legitimate Interest
Legal Obligation
Notification and/or Consent (where required by applicable Privacy Laws)
To protect the rights and interests of the Papaya Group
We may use your information to protect the rights, property, assets, personnel, or interests of the Papaya Group, our Users, Employers, or Partners.
General Data
Contact Data
Background Data
Usage and Device Data
Third Party Data
Legitimate Interest
Legal Obligation
Notification and/or Consent (where required by applicable Privacy Laws)
We may Process your Personal Information to comply with our legal and regulatory obligations. This includes responding to law enforcement requests, data protection authorities, or statutory requirements, and facilitating your rights under applicable Privacy Laws.
General Data
Contact Data
Background Data
Third Party Data
Usage and Device Data
Legal Obligation
Notification and/or Consent (where required by applicable Privacy Laws)
It is important for us to Process your Personal Information in order to provide our products and services to you. If you do not want your information to be Processed for the purposes set out in this Privacy Policy, you may need to cease using our Platforms, products or services or engaging with us.
You can choose not to share your Personal Information with us. However, if you choose not to provide us with the necessary Personal Information, we may not be able to provide you with some or all of our products or services.
We also require your Personal Information to meet our legal obligations. Where the legal basis for the Processing of your Personal Information is to comply with our legal obligations, a failure by you to provide us with certain Personal Information may cause us and/or you to be in breach of these legal obligations.
We may share your Personal Information in several different ways.
We may share your Personal Information with any entity or business within the Papaya Group for the purposes set out in this Privacy Policy.
For example, if you are a Candidate and an Employer requires identity verification, document checks, or other assessments, we may share your Contact Data or other relevant information with our verification partners to facilitate those processes.
If you are a Candidate, you agree that we may share your Personal Information with Employers when you apply for a job advertisement on our Platforms.
By applying for a job, you agree that we may share the information contained in your Profile and your application materials with the relevant Employer and that your information may be stored in:
our Employer portal on behalf of the Employer;
the Employer’s own recruitment system or careers page; or
the Employer’s selected recruitment software or ATS provider.
We do not take responsibility for, and cannot ensure the security of, your Personal Information stored by Employers outside of our Platforms.
Any questions relating to a job advertisement, your application, or its status should be directed to the relevant Employer.
Depending on your Profile visibility settings, we may also share your Profile with Employers through our Talent Search product, which allows Employers to view a Candidate’s Profile (including any Personal Information within that Profile) when searching for suitable Candidates. Please refer to section 13 for more information on Profile visibility settings and how your information may be accessible to Employers.
To apply for some job advertisements, portions of your Profile will automatically be shared with the Employer. When this occurs, regardless of your selected visibility setting (Public, Standard, Limited or Hidden as described in section 13), your job application and relevant Profile information (including General Data, Contact Data, Background Data, Third Party Data and Location Data) will be shared with the Employer.
Some Employers may require you to answer specific questions as part of your application. By providing responses, you acknowledge that we will share your answers with that Employer and may use your answers to update your Profile and enable Employers to view this information when using Talent Search.
We will notify you when any part of your Profile will be included in your application. We will also specify which parts of your Profile will be provided to the Employer.
Please note that if you choose to share your Profile, résumé, or any application information with Employers, those Employers may intentionally or unintentionally share that information with other parties (including where a recruitment agency shares your information with its client). The use, disclosure, or storage of your information by Employers in their own systems is beyond our control and we cannot accept responsibility for their conduct or data security practices. Employers are required to comply with all applicable laws, including obligations relating to the use and disclosure of Personal Information under the PDPA and other relevant laws.
Candidates should contact Employers directly to request access to, or deletion of, any Personal Information provided as part of a job application or made available to Employers through Talent Search.
We may share your Personal Information with third parties, including Service Providers, contractors, and Partners, for purposes such as:
assisting us in delivering our products and services;
enabling you to access products or services provided by those third parties;
conducting surveys, trials, testing, and customer research; or
any other purpose outlined in Section 6 of this Privacy Policy.
We may share your Personal Information with government authorities, law enforcement agencies, regulatory bodies or authorised officers who have the legal authority to request such disclosure. This includes compliance with court orders, statutory obligations, or other legal processes.
In the event of a merger, acquisition, divestment, restructuring or similar transaction, we may share your Personal Information with the transferee, successor entity, or any prospective purchaser (including their advisers), where such sharing is necessary for evaluating or completing the transaction.
If you are a Candidate and select the “Public” visibility setting for your Profile, you agree that your Profile and Personal Information may be shared with and accessible by:
all Platform Users (both Registered and Unregistered Users); and
individuals using Third Party Platforms and Websites, including search engines and public indexing services.
The specific information available to each category of viewer is described in section 13.
When enabling access to certain Papaya products or services, we may provide links to Third Party Platforms and Websites that are not owned or controlled by us. This may result in the sharing of your Personal Information with those platforms. We are not responsible for the privacy practices of such platforms.
Where you select the “Public” visibility setting for your Profile, disclosure to Third Party Platforms and Websites may occur through indexing, scraping, caching, processing, aggregation, or republication by search engines, AI-powered services, content aggregators, automated crawlers, or similar technologies. We do not control how those platforms collect, retain, or use your Personal Information, and we cannot guarantee deletion of your information from such external sites, including removed or cached copies.
Such platforms may store or process data in jurisdictions with different, or less protective, privacy laws than those applicable to Papaya.
Users are strongly encouraged to review the privacy policies of Third Party Platforms and Websites before engaging with them.
We may share your Personal Information outside of your Home Location under the following circumstances:
a. Papaya Group hosting and operations
We may share your Personal Information with INDEX AI PTE. LTD. and other Papaya Group entities responsible for hosting and operating the Platforms. Your Personal Information may be stored on secure servers located in Singapore, the United States of America, the European Union, or other jurisdictions where our cloud infrastructure providers operate.
b. Service Providers, Partners, and third parties
We may share your Personal Information with Service Providers, Partners, or other third parties who provide services to us from overseas locations, including but not limited to Singapore, Australia, New Zealand, the United States of America, the Netherlands, Germany, France, Ireland, India, and other jurisdictions where our vendors or technology partners operate.
c. Papaya Group entities
We may share your Personal Information with any entity or business within the Papaya Group for the purposes described in this Privacy Policy.
d. Employers located outside your Home Location
Where you apply for a job with an Employer located outside your Home Location, your Personal Information may be accessible to that Employer through your job application and/or via access to your Profile through Talent Search. Employers may view your Personal Information when searching for Candidates in your Home Location or in the preferred work locations listed in your Profile. Please refer to section 13 for more information on visibility settings.
e. Public visibility settings
If you select the “Public” visibility setting for your Profile, certain Personal Information may become accessible worldwide through our Platforms and through Third Party Platforms and Websites. This includes jurisdictions that may not have privacy laws equivalent to those in your Home Location.
f. Legal or regulatory obligations
We may share your Personal Information overseas where necessary to comply with applicable legal, regulatory, law enforcement, or governmental requirements.
We take reasonable steps to safeguard our systems and protect your Personal Information from misuse, interference, loss, unauthorised access, modification, or disclosure. Personal Information that we hold is stored on secure servers and protected in controlled environments.
We follow accepted industry standards to protect your Personal Information. However, no method of electronic transmission or storage can be guaranteed to be completely secure.
Third parties with whom we share your Personal Information (including Employers) are required to comply with relevant legal obligations regarding the use and disclosure of Personal Information. Where you provide information directly to a third party (for example, by applying through an Employer’s careers platform), the collection and use of your information are governed by that third party’s privacy policy and not ours.
You also play an important role in keeping your Personal Information secure. You must maintain the confidentiality of any passwords and account details used on the Platforms. Please notify us immediately if you become aware of any unauthorised use of, or security breach relating to, your account.
Our servers automatically collect your Internet Protocol (IP) address to assist with diagnosing technical issues, maintaining the security of our Platforms, and monitoring usage patterns, including approximate geographical location.
We use Cookies and similar technologies to provide Users with an improved browsing and Platform experience. These technologies collect information such as preferences, click activity, saved search criteria, and login details (when you opt into features such as “Auto Login”).
We may use this information to:
customise and improve your Platform experience;
remember your preferences and recent searches;
improve website performance and test new features;
analyse behaviour and make business decisions;
assist with payment processing;
generate aggregated reports for our business Partners and advertisers;
tailor display advertisements across our Platforms and third party websites.
This information may be shared with Papaya Group entities, Service Providers, and Partners to assist in delivering improved products and services.
We may also use device identifiers and similar technologies to recognise you across different devices and services, and we may share device identifiers with Service Providers and Partners for advertising, analytics, and security purposes.
Some of our Partners may place their own Cookies on pages you visit on our Platforms. These collect non-personal information for purposes such as targeting display advertisements and conducting market research.
You may limit the use of your information for targeted advertising by adjusting your browser or device settings to block Cookies. However, disabling Cookies may restrict access to certain areas or functionalities of the Platforms.
When you use our mobile applications (“Our Apps”), we may use third party software development kits (SDKs) and analytics tools to collect information about app installs, usage, and user engagement.
This information helps us tailor and measure display advertisements promoting Our Apps across third-party sites and apps.
You may opt out of certain tracking features by adjusting your device privacy settings:
iOS 14.5+: Settings > Privacy > Tracking
Older iOS devices: Limit Ad Tracking
Android devices: Opt out of interest-based ads
To better understand our Users, we use third party measurement and analytics providers. Cookies may be used to collect information such as:
number of page views;
number of unique visitors;
average time spent on the Platforms;
common entry and exit points.
For Unregistered Users, this data is aggregated before being shared with us.
For Registered Users, data may be connected across sessions and devices to improve accuracy.
This aggregated and anonymised information may be shared with media organisations or research companies for industry analysis and comparison.
We retain your Personal Information for as long as necessary to fulfil the purposes for which it was collected, as described in this Privacy Policy, or as required by applicable laws.
If you submitted a job application through our Platforms and your Personal Information was transferred to an Employer, you will need to contact that Employer directly to request deletion of your information from their systems.
We may retain certain Personal Information even after you request deletion where retention is reasonably necessary for purposes including:
compliance with legal and regulatory obligations;
resolving disputes or enforcing agreements;
preventing fraud or misuse;
maintaining backups or system recovery capabilities;
internal software testing in secure, closed environments.
Where Personal Information is retained in testing environments, it is stored securely and used strictly for internal development and quality assurance. Where retained in backup systems, it is held only for the limited purpose of restoring data in the event of system failure.
We will take reasonable steps to delete or anonymise Personal Information that is no longer required for these purposes, where required under applicable Privacy Laws.
You can make certain requests in relation to Personal Information that we hold about you. Some of these requests only apply in certain circumstances, as set out in more detail below.
Access: You have the right to ascertain whether we hold Personal Information about you and to request access to such Personal Information. For Candidates, you may access much of your information at any time by logging in to your account and accessing the “Settings” section and your Profile page. For Employers, you may access your information at any time by logging in to your account and accessing the “Account Details” section. Alternatively, any User can contact us to request access to their Personal Information.
Correction/Rectification: You have the right to correct any Personal Information held about you that is inaccurate or incomplete. If you are a Candidate (excluding those who only subscribe to Job Alerts and do not have a Profile), you can change or update your Profile at any time by logging in to your account and accessing the “Profile” section or adjusting your settings within the “Settings” section. For Employers, you may correct your information by accessing the “Account Details” section of your account. Any User may also contact us directly to request correction or updating of their Personal Information.
Deletion:
a. For Candidates, you can request that we delete Personal Information held by us within your account by logging in and accessing the “Settings” section or by electing to delete Personal Information accessible on your Profile page. Alternatively, any User can contact us to request that we limit the Processing of, or delete, their Personal Information or to withdraw their consent to our Processing of their Personal Information (where consent is the applicable legal basis).
b. Please note that if you have selected the “Public” visibility setting for your Profile and you make a deletion request in accordance with item (a) above, we will promptly remove your Profile information (which includes your Personal Information) from our Platforms. However, if your Profile information has been accessed, indexed, cached or republished by Third Party Platforms and Websites (as a result of your Public visibility setting), versions of your Profile information may continue to be displayed by those platforms for a period of time after your deletion request is processed by us. We cannot guarantee the complete removal or deletion of your Personal Information from such Third Party Platforms and Websites, as they operate independently of Papaya and manage their own update and deletion processes. You may wish to contact those platforms directly regarding deletion of your Personal Information.
When you contact us directly and make a request under this section, we may ask you to provide information to verify your identity before we proceed. Depending on the circumstances and applicable Privacy Laws, we may not be able to fulfil a particular request. Where this is the case, we will explain our reasons to you where we are permitted to do so.
You can also contact us to request access to any additional Personal Information rights that may be available to you under applicable Privacy Laws. We will respond to your request as soon as reasonably practicable and in accordance with those laws.
You are responsible for providing accurate, complete and up-to-date information to us about yourself and any other person whose Personal Information you provide to us, and for updating this information when it becomes inaccurate or outdated. For Candidates, we reserve the right to disable and/or delete your Profile or certain information within your Profile (including any stored resume or cover letter) at our sole discretion. We may take such steps, for example, where information is found or believed to be untrue, misleading or being stored for improper purposes.
You may opt out of certain communications from us, as set out in more detail below.
For job application updates and notifications on new job opportunities, you can update your preferences within the “Settings” area of the Platforms (not available to Employers).
For receiving marketing and promotional messages from us, you can click “unsubscribe” in the footer of any marketing or promotional email, which will link you to a preference or settings page where you can update your notification preferences, or you may reply “STOP” to an SMS that you receive from us (where applicable).
Please note that clicking “unsubscribe” in the footer of an email will only unsubscribe you from the particular type of marketing or promotional message you have received (for example, job market insights or career advice). To opt out of all marketing or promotional messages from us, you may need to update your notification preferences within your account settings or our preference centre (where available). Opting out of emails will not automatically opt you out of receiving SMS, and vice versa.
You can also contact us using the details in section 15 if you need assistance managing your communication preferences.
We will comply with any unsubscribe or opt-out request as soon as reasonably practicable, and in accordance with applicable Privacy Laws.
Visibility Settings
Upon registration, Candidates are asked to create a personal Profile by providing certain Personal Information and selecting one of the visibility settings – “Public”, “Standard”, “Limited” or “Hidden” – as described below. Candidates without Profiles will also be required to create a Profile when they first apply for a job on our Platforms.
A Profile may include uploaded resume(s), employment and educational history, contact details, profile photo, salary expectations, preferred job classifications, licences, certificates, skills, languages, a personal summary, locations, your approachability signal generated by our systems (Approachability Signal), right to work, preferred work types, your availability for your next role, and any other information that you may provide in your resume(s) or otherwise upload to our Platforms. Some of this information may be identified as verified data by Papaya or our third-party verification providers with your consent.
In the “About your next role” section of your Profile page:
A. You can turn your Approachability Signal on or off; and
B. You can select preferred locations for your next job. If you apply for a job advertisement where the job location is not listed in your preferred locations, that location may automatically be added to your list of preferred locations.
Talent Search visibility
Employers can use our Talent Search functionality to search for Candidate Profiles and contact relevant Candidates. These Employers may be located outside of your Home Location. However, a Candidate will only be visible to Employers when they are searching for Candidates in locations listed by that Candidate as a preferred location (including their Home Location) and any location that the Candidate has included in a resume stored on their Profile page.
Employers may use Talent Search to search for and contact potential Candidates, and Candidates can decide how much of their Profile they wish to share with Employers by selecting one of the visibility settings described below. Notwithstanding the visibility setting you choose, when you apply to a job advertisement through the Platforms, both your job application and relevant parts of your Profile will be shared with the Employer. Candidates can amend their Profile prior to applying (see section 8(b) of this Privacy Policy).
If you select a “Public” or “Standard” visibility setting for your Profile, then:
your Profile can be seen by Employers using Talent Search;
we may parse information from your resume to populate your Profile, and a preview of your resume may be visible to Employers using Talent Search;
if an Employer chooses to download your Profile, your full Profile including contact details and your uploaded resume will be provided to that Employer;
an Employer may contact you either via the details contained within your resume or via a Talent Search Connection Method; and
information that you have verified through our verification providers (for example, verified identity, career history, education, licences and certifications) may be visible to Employers.
Limited
If you select a “Limited” visibility setting for your Profile, then:
your Profile can be seen by Employers using Talent Search, but Employers cannot view or download your resume or direct contact details;
an Employer cannot view your contact details contained within your resume but may contact you via our Talent Search Connection Method; and
some verified information (for example, verified identity, career history, education, licences and certifications) may be visible to Employers.
Hidden
If you select a “Hidden” visibility setting for your Profile, then:
your Profile is completely hidden from Employers using Talent Search; and
an Employer cannot contact you via Talent Search.
*Note: Profiles set to “Public” visibility will appear to Employers using Talent Search with the same access level as “Standard” profiles, but may also be visible more broadly as explained below.
Profiles with “Public” visibility
If you select a “Public” visibility setting for your Profile, then in addition to being searchable and viewable to Employers via Talent Search, your Profile may be:
searchable and viewable to all Users of our Platforms through our People Search feature; and
publicly accessible off our Platforms via multiple online channels including Third Party Platforms and Websites.
People Search
We may make your Profile and Personal Information searchable and viewable to different audiences with varying levels of access:
Unregistered Users can only view basic Profile information.
Registered Users can view expanded Profile information, including certain verified information, subject to their account type and our settings.
By selecting the “Public” visibility setting, you acknowledge and agree that:
your Personal Information may be publicly accessible worldwide through multiple channels, including (but not limited to) Third Party Platforms and Websites;
while we implement controls to limit access to certain information based on audience type, your Profile information may ultimately be accessible to anyone;
we cannot control who accesses your publicly available information or how they use it;
Third Party Platforms and Websites operate independently of Papaya and may index, scrape, cache, process, aggregate and redistribute your publicly accessible information according to their own policies, even after you change your visibility settings or delete your Profile (including in cached or republished versions); and
you bear sole responsibility for determining what information to include in your Profile.
Managing your visibility settings
Candidates can modify their Profile visibility settings at any time by signing in to their account and accessing the “Profile visibility” section under the Profile page.
To delete your Profile, you will need to delete your entire account with us, as described in this section 13.
We may modify this Privacy Policy from time to time. You should review this Privacy Policy periodically so that you remain informed of any changes. In some circumstances, depending on the nature of the changes and applicable Privacy Laws, we will notify you of changes before they take effect.
By continuing to use our Platforms, products or services after any changes take effect, you agree to the modified Privacy Policy.
If you have any questions or complaints regarding this Privacy Policy, or if you wish to contact us regarding our use or handling of your Personal Information, you can contact us via the channels below. You may also contact us to request a copy of this Privacy Policy in hard copy or in another accessible format.
Any privacy complaint received by us will be referred for prompt investigation, and we will respond to you as soon as reasonably practicable. If you remain unsatisfied with the resolution of your complaint, you may be entitled to seek further recourse from your local data protection regulator.
Papaya (INDEX AI PTE. LTD.)
Registered office address:
160 Robinson Road
#14-04, Singapore Business Federation Center
Singapore 068914
Email: [insert privacy contact email, e.g. privacy@papaya.ai]
Phone: [insert contact number, if applicable]
If and when Papaya appoints local representatives or data protection officers in other jurisdictions (such as the EEA or UK), details of those representatives will be published on our Platforms and/or updated in this section.
This Privacy Policy may be translated into one or more local languages in the territories where we operate. In the event of any inconsistency or conflict between the English language version of this Privacy Policy and any translated version, the English language version shall prevail. The translated version shall be deemed automatically amended to conform to and be consistent with the English language version.
In this Privacy Policy, unless the context otherwise requires, the following terms have the meanings set out below:
Advertiser / Employer
An individual or entity (including employers and recruiters) that creates an account on Papaya’s employer-facing products and services (“Papaya Employer”) to post job advertisements on our Platforms or to use other advertiser-specific products and services to source potential Candidates for job vacancies. Advertiser/Employer accounts are separate from Candidate accounts and are subject to the terms that apply to advertiser-side use of our Platforms.
Advertising Locations
Has the meaning given to it in section 11 of this Privacy Policy.
Approachability Signal
Has the meaning given to it in section 6(a) of this Privacy Policy and refers to an indicator generated by our systems about the likelihood that a Candidate may be approachable regarding certain job opportunities.
Candidate
An individual (excluding Employers) who uses our Platforms and/or accesses our services (whether by registered account or not), including creating and maintaining a Profile, whether for job seeking, future opportunities, networking or other career-related purposes.
Cookies
Cookies, tags, applets, scripts and other similar technologies.
EEA
The European Economic Area.
GDPR
The European General Data Protection Regulation, Regulation (EU) 2016/679.
Home Location
Your primary place of residence (if you are a Candidate, your primary place of residence as selected in your Profile).
Job Alerts
Email or in-app notifications of job advertisements that a Candidate will receive based on saved searches, preferences or similar settings on our Platforms.
Linked Accounts
Third party logins (such as Google account logins) that you choose to link to your Papaya account.
Our Apps
Has the meaning given to it in section 11(c) of this Privacy Policy and refers to our mobile applications.
Parental Consent
Has the meaning given to it in section 3(c) of this Privacy Policy.
Partners
Third parties who work with us to provide us or our Users with services, for example marketing partners, recruitment software providers, verification providers, analytics providers or strategic business partners that provide ancillary services.
People Search
A search feature accessible via our Platforms that enables Profiles with a “Public” visibility setting to be searchable and viewable by any User (including individuals accessing our Platforms via external channels), subject to the access controls we implement.
Personal Information / Personal Data
Information (including Sensitive Information) that identifies an individual or could reasonably identify an individual, including facts and opinions, whether they are true or not. In certain jurisdictions, this is referred to as “personal data”. References to Personal Information in this Privacy Policy include a reference to Personal Data, where applicable.
Platform(s)
Our online websites, mobile websites, applications, products, services, features and software operated by or on behalf of Papaya Group.
Privacy Laws
The applicable privacy and data protection laws (including any applicable spam or electronic communications laws) as may be in force from time to time in a particular jurisdiction that regulate the collection, use, disclosure, storage of, and granting of access rights to, Personal Information.
Process, Processing or Processed
The collection, use, disclosure, transfer, retention or other handling of Personal Information.
Profile
A personal profile created on our Platforms by a Candidate, which contains Personal Information of that Candidate, as further described in section 13 of this Privacy Policy.
Registered User
A User who has registered an account with us via our Platforms (or by other permitted means to obtain access to our products and/or services) and is signed in to that account when using our Platforms. In certain contexts (such as visibility), Registered Users who are signed out of their account when using our Platforms, products or services will be treated as Unregistered Users.
Related Person
A person who is related to a Registered User, such as a referee, emergency contact, or other contact whose Personal Information is provided to us by the Registered User.
Related Platforms
Has the meaning given to it in section 5(d) of this Privacy Policy and includes platforms operated by Papaya Group entities that share infrastructure or services.
Papaya, we, us, our
INDEX AI PTE. LTD. and, where the context requires, other entities within the Papaya Group.
Papaya Group
INDEX AI PTE. LTD. and each of its related bodies corporate or affiliated entities, as defined under applicable corporate law.
Sensitive Information
Certain categories of Personal Information defined as sensitive or special category data under applicable Privacy Laws, which may include information or opinion about an individual’s racial or ethnic origin, political opinions, religious beliefs, trade union membership, sexual orientation, criminal record (including proceedings for offences and related outcomes), health and genetic information, biometric information, or government-issued identifiers, provided such information otherwise meets the definition of Personal Information.
Service Providers
Third parties that help us to provide our products and services to you. Examples include analytics providers, cloud hosting providers, storage providers, IT service providers, marketing and advertising service providers, market research providers, accounting, audit, legal and compliance service providers, event management providers, electronic payment service providers and other vendors.
Talent Search
Our talent database product available through Papaya’s employer tools that allows Employers to search, refine and connect with Candidates who maintain a Profile and have set their Profile visibility settings to enable their Profile to be searchable by Employers.
Talent Search Connection Method
A method by which an Employer using Talent Search can contact a Candidate, for example by sending a Candidate a job opportunity or a customised message about a role through our Platforms.
Terms and Conditions
Any terms of use, terms and conditions or other agreed terms (as may be amended from time to time) that you agree to when procuring our products and services or using our Platforms.
Third Party Platforms and Websites
Websites, platforms, mobile applications, tools or services not operated by Papaya, including but not limited to public search engines, AI-powered services, automated crawlers, content indexing and aggregation tools, and other online services that may access, index, scrape, cache, process, aggregate or republish content from our Platforms.
UK
The United Kingdom.
Unregistered User
A user who:
a. uses or visits our Platforms but does not have a Registered User account;
b. holds a Registered User account but is not signed in at the time they access our products or services; or
c. engages with us via other channels external to our Platforms (for example, by phone or in person, by direct job application, as an investor, by participating in any events, programmes or promotions, or by using Third Party Platforms and Websites).
Usage and Device Data
Has the meaning given to it in section 3(a) of this Privacy Policy and generally includes information about how you access and use our Platforms, such as device identifiers, IP address, browser type, operating system, pages visited and clickstream data.
Users, you, your
Candidates, Employers, Registered Users, Unregistered Users and all other individuals who otherwise engage with us and/or use our products, services or information, whether on or off our Platforms, unless the context indicates that only a particular type of User is being referred to.
Young User
Any User who is under the minimum age provided for under applicable Privacy Laws in their jurisdiction (for example, under 13 years old in Singapore, or as otherwise defined by local law).
If you are a citizen or habitual resident of any of the jurisdictions described in this section, the following jurisdiction-specific terms will supplement, and should be read together with, this Privacy Policy. In the event of a conflict between the jurisdiction-specific terms that are relevant to your jurisdiction and the rest of this Privacy Policy, the jurisdiction-specific terms will prevail.
If you are based in the EEA or the UK, then in addition to what is set out in this Privacy Policy, the following applies to you in accordance with the GDPR or the UK GDPR (as applicable).
You may contact us using any of the methods set out in section 15 to request that we:
provide you with a copy of the Personal Information we hold about you in a portable and machine-readable form; or
share your Personal Information with a nominated third party, where this is technically feasible.
Where required by law, Papaya may appoint a representative in the EEA or UK to act as our point of contact for data protection matters. Details of any such representative will be published on our Platforms or otherwise notified to you.
If you are based in Hong Kong, then in addition to what is set out in this Privacy Policy, we intend to use the name and contact details of Registered Users for the purpose of direct marketing in relation to the following products and services, and your consent (which may include an indication of no objection) is required for us to do so:
our products and services, including information about new features, job opportunities and career-related content, newsletters, surveys, and event information;
products and services offered by other entities within the Papaya Group; and
products and services offered by Employers and Partners that may be relevant to you.
Please refer to section 13 for your options to unsubscribe from direct marketing.
If you are based in Thailand, then in addition to what is set out in this Privacy Policy, the following applies to you in accordance with the Personal Data Protection Act B.E. 2562 (2019) and any related regulations or guidance (“Thai PDPA”).
Retention Period
We will retain your Personal Information for as long as necessary to fulfil the purposes set out in this Privacy Policy or as otherwise required by applicable law.
Data Subject Rights
Subject to the limitations and conditions of the Thai PDPA, you are entitled to the following rights in respect of your Personal Information:
Right to access – to request access to or a copy of your Personal Information, as well as information on how your Personal Information was obtained without your consent (if applicable).
Right to data portability – to obtain your Personal Information in a format which is readable or usable with automatic tools, and to request that we transmit such data to another data controller where technically feasible.
Right to object – to object to the Processing of your Personal Information, particularly where it is Processed for direct marketing.
Right of erasure – to request that your Personal Information be deleted, destroyed or anonymised.
Right to suspension – to request that the Processing of your Personal Information be suspended.
Right to rectification – to request that your Personal Information be updated, completed or corrected.
Right to withdraw consent – where Processing is based on consent, to withdraw your consent at any time, without affecting the lawfulness of Processing carried out before withdrawal.
Right to lodge a complaint – to lodge a complaint with the relevant supervisory authority if you believe we have not complied with the Thai PDPA.
We encourage you to contact us first so that we can attempt to resolve any concerns directly.
If you are based in the Philippines, then in addition to what is set out in this Privacy Policy, the following applies to you in accordance with the Data Privacy Act of 2012 (“DPA”) and its implementing rules and regulations.
Subject to the limitations and conditions of the DPA, you are entitled to the following rights in respect of your Personal Information:
Right to be informed – to be informed that your Personal Information is being, or has been, processed, including the existence of automated decision-making and profiling. This Privacy Policy is one way in which we do so.
Right to object – to object to the Processing of your Personal Information, including for direct marketing, automated processing or profiling, in certain circumstances.
Right to access – to reasonable access, upon demand, to your Personal Information, including the source of your data, how it has been processed, and to whom it has been disclosed.
Right to rectification – to dispute inaccuracies or errors in your Personal Information and have us correct it immediately, unless your request is vexatious or unreasonable.
Right to erasure or blocking – to suspend, withdraw or request the blocking, removal, or destruction of your Personal Information from our systems in certain circumstances.
Right to damages – to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of Personal Information, taking into account any violation of your rights and freedoms.
Right to data portability – to obtain a copy of your Personal Information in an electronic or structured format that is commonly used and allows for further use.
Right to lodge a complaint – to lodge a complaint with the National Privacy Commission. We encourage you to contact us first so that we can attempt to resolve your concerns.
If you are based in New Zealand, some of the third parties to whom we may disclose your Personal Information (as described in section 8) may be “overseas persons” for the purposes of the Privacy Act 2020 (for example, companies incorporated outside New Zealand).
You authorise us to make those disclosures and acknowledge that those recipients may not be subject to privacy laws that provide comparable safeguards to those under the Privacy Act 2020.
If you are based in Malaysia, then in addition to what is set out in this Privacy Policy, the following applies to you in accordance with the Personal Data Protection Act 2010 (“Malaysia PDPA”).
Parental Consent
Where you agree to this Privacy Policy to allow a minor to access and use our Platforms, products or services, you hereby consent to the Processing of the minor’s Personal Information in accordance with this Privacy Policy and personally accept and agree to be bound by its terms. You agree to take responsibility for the actions of such minor and for ensuring that the minor complies with this Privacy Policy.
Right to limit Processing
You may request to limit the Processing of your Personal Information by contacting us using the details in section 15. However, limiting the Processing of your Personal Information may affect our ability to provide certain products or services to you.
If you are based in Singapore, all references to Privacy Laws in this Privacy Policy should be construed as including the Personal Data Protection Act 2012 (“PDPA 2012”) and related subsidiary legislation, regulations, guidelines and directions.
Deemed consent and statutory exceptions
References to consent in this Privacy Policy include deemed consent under PDPA 2012, for example, where you voluntarily provide Personal Information to us for a particular purpose, or where consent may be deemed under PDPA 2012 when you use our Platforms or services. Subject to PDPA 2012, we may also rely on statutory exceptions to the requirement for consent where appropriate, including:
Business improvement exception – where the use of Personal Information (including sharing within the Papaya Group) is for the purpose of improving, enhancing or developing new goods/services or business processes, understanding customer behaviour and preferences, or identifying and personalising goods/services that may be suitable for customers.
Public agency exception – where Personal Information is obtained from, or disclosed by, a Singapore public agency and our collection, use or disclosure is consistent with the purpose of that disclosure.
Research exception – where Personal Information is used or disclosed for research (including market research), subject to the conditions under PDPA 2012, including that there is a clear public benefit, the research results will not be used to make decisions about you, and any published results will not identify you.
Collection, use and/or disclosure of NRIC numbers (or equivalents)
We will only collect, use and/or disclose Singapore National Registration Identity Card (“NRIC”) numbers, or equivalent identifiers such as passport numbers or work permit numbers, where permitted or required under law, or where necessary to accurately establish or verify your identity to a high degree of fidelity. Where appropriate, we will consider alternatives to full NRIC numbers (for example, partial NRIC) while still meeting our business and legal requirements.
Right to withdraw consent
Where the legal basis for Processing your Personal Information is consent, you may withdraw your consent at any time, subject to the conditions and limitations under PDPA 2012. Withdrawal of consent will not affect the lawfulness of Processing based on consent before its withdrawal, and may affect our ability to provide you with certain services.
Transfer of Personal Information outside Singapore
Further to section 9, where your Personal Information is transferred out of Singapore, we will take reasonable steps to ensure that the recipient provides a standard of protection to your Personal Information that is at least comparable to the protection under PDPA 2012 (for example, through data transfer agreements or other appropriate safeguards).
By registering and creating an account with us, using our products and services, visiting our Platforms or otherwise engaging with us, you acknowledge and agree that your Personal Information may be transferred within or outside Singapore to third parties, including those described in sections 8 and 9, for the purposes set out in this Privacy Policy. We will implement reasonable security arrangements to protect your Personal Information, including administrative, physical and technical measures such as access controls, encryption (where appropriate), data minimisation and secure transmission practices.