Privacy Statement:

This privacy statement is effective as of January, 2020. Please note that this privacy statement will be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws.
This page and its sub-pages tell you everything you need to know about how CPR Vision Management Pte Ltd and/or its affiliates, subsidiaries and newly acquired companies ("CPR Vision"; "we") protect the personal data we process and control relating to you ("your personal data"; "your data") and which rights you have in relation to the processing of your personal data.


1. How does CPR Vision Management Pte Ltd protect your personal data?

CPR Vision attaches great importance to your right to privacy and the protection of your personal data. We want you to feel secure that when you deal with us and that your personal data is in good hands.
CPR Vision protects your personal data in accordance with applicable laws and our data privacy policies. In addition, we maintain the appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage thereto.

Which categories of personal data do we collect and how do we process such personal data?
We collect personal data of our employees, potential employees, clients, suppliers, business contacts, shareholders and website users. If the data we collect are not listed in this privacy statement, we will give individuals (when required by law) appropriate notice of which other data will be collected and how they will be used.
Below is also a chart describing the categories of personal data we collect:

Personal details, contact details and identifiers.

In addition to the personal details listed above, CPR Vision may collect additional personal details for recruitment/employment purposes, such as national identification number, social security number, insurance information, marital/civil partnership status, domestic partners, dependents, emergency contact information, and military history.

Education information and professional or employment-related information.

CPR Vision may collect information about your education and professional or employment-related information, such as your employment history.

Sensitive data for recruitment purposes.

CPR Vision may collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status), trade union membership information, religion, race or ethnicity, minority flag, and information on criminal convictions and offences. CPR Vision collects this information for specific purposes, such as health/medical information in order to accommodate a disability or illness (subject to legal limits on the timing of collection of such information and other applicable limitations) and to provide benefits; background checks and diversity-related personal information (such as race or ethnicity) in order to comply with legal obligations and internal policies relating to diversity and anti-discrimination.

Documentation required under immigration laws.

CPR Vision may collect data on citizenship, passport data, and details of residency or work permit (a physical copy and/or an electronic copy).

Financial information for payroll/benefits purposes

Your banking and other relevant financial details we need for payroll/benefits purposes.

Talent management information.

Information necessary to complete a background check, details on performance decisions and outcomes, performance feedback and warnings, e-learning/training programs, performance and development reviews (including information you provide when asking for/providing feedback, creating priorities, updating your input in relevant tools), driver’s license and car ownership information, and information used to populate biographies.

Requested recruitment information

Information requested to provide during the recruitment process, to the extent allowed by applicable law.

Recruitment information you submit

Information that you submit in résumés / CVs, letters, writing samples, or other written materials (including photographs).

Information generated by us during recruitment

Information generated by interviewers and recruiters related to you, based on their interactions with you or basic Internet searches where allowed under applicable law.

Recruitment information received from third parties

Information related to you provided by third-party placement firms, recruiters, or job-search websites, where applicable.

Audiovisual materials

Photograph, and images/audio/footage captured/recorded on CCTV or other video systems when visiting our office or captured in the course of recruitment events or video recruitment interviews or during any other virtual and live events (including recordings during virtual workshops or similar events).


Recommendations related information provided on your behalf by others.


Documentation and related information required under immigration laws.

Employment history and background checks

Information about your prior employment, education, and where applicable and allowed by applicable law, credit history, criminal records or other information revealed during background screenings.

Diversity related information

Information about race / ethnicity / religion / disability / gender and self-identified LGBT status, for purposes of government reporting where required by law, as well as to understand the diversity characteristics of the CPR Vision workforce, subject to legal limits.

Assessment information

Information generated by your participation in psychological, technical or behavioural assessments. You will receive more information about the nature of such assessments before your participation in any of them.

Except for certain information that is required by law or by CPR Vision policies (including management of an employment relationship with CPR Vision), your decision to provide any personal data to us is voluntary. You will therefore not be subject to adverse consequences if you do not wish to provide us with your personal data. However, please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this privacy statement, and you may not be able to use certain tools and systems which require the use of such personal data.

If you provide us with personal data of another person (for instance, a potential employee/referral), you are responsible for ensuring that such person is made aware of the information contained in this privacy statement and that the person has given you his/her consent for sharing the information with CPR Vision.

The above-mentioned categories of personal data have been obtained either directly from you (for example, when you provide information to sign up for a newsletter or register to comment on a forum website) or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites and social media, suppliers and vendors.

For which purposes and on which legal basis do we use your personal data?
CPR Vision uses your personal data only where required for specific purposes. Please view the table below for (i) a list of the purposes for which we use your personal data and (ii) an overview of the legal basis for each such purpose.


Legal basis

Managing our contractual and/or employment relationship with you.

Necessary for the performance of a contract to which you are a party.


Justified on the basis of our legitimate interests for ensuring that we recruit the appropriate employees.

Facilitating communication with you (including in case of emergencies, and to provide you with requested information).

Justified on the basis of our legitimate interests for ensuring proper communication and emergency handling within the organization.

Complying with legal requirements.

Necessary for the compliance with a legal obligation to which we are subject.

Improving the security and functioning of our website, networks and information.

Justified on the basis of our legitimate interests for ensuring that you receive an excellent user experience and our networks and information are secure.

Specific Recruitment/Employment Purposes

Legal basis

Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available.

Justified on the basis of CPR Vision’s legitimate interests of ensuring that it recruits the appropriate employees.

Manage your application.

Justified on the basis of CPR Vision’s legitimate interests of ensuring that it recruits the appropriate employees.

Facilitate communication with you.

Justified on the basis of CPR Vision’s legitimate interests of ensuring proper communication within the organization and with you.

Perform administrative functions (e.g. reimburse you for interview-related expenses).

Justified on the basis of CPR Vision’s legitimate interests of ensuring that it recruits the appropriate employees.

Perform data analytics, including analysis of our applicant pool in order to better understand who is applying to positions at CPR Vision and how to attract and keep top talent.

Justified on the basis of CPR Vision’s legitimate interests of ensuring that it continually improves its recruitment processes.

In some cases, record your online interview for review by additional recruiters and hiring managers.

Justified on the basis of CPR Vision’s legitimate interests of ensuring that it recruits the appropriate employees.

Administration of employee benefits

Justified on the basis of CPR Vision’s legitimate interests of ensuring that our employees receive the applicable benefits.

Perform any legally required reporting and respond to legal process.

Compliance with a legal obligation.

Where the above table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interests are not overridden by your interests, rights or freedoms, given (i) the transparency we provide on the processing activity,
(ii) our privacy by design approach,
(iii) our regular privacy reviews and
(iv) the rights you have in relation to the processing activity.
We will process your personal data for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws.
To the extent you are asked to click on/check "I accept", "I agree" or similar buttons/checkboxes/functionalities in relation to a privacy statement, doing so will be considered as providing your consent to process your personal data, only in the countries where such consent is required by mandatory law. In all other countries, such action will be considered as a mere acknowledgement and the legal basis of the processing of your personal data will not be your consent but any other applicable legal basis.
We will not use your personal data for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.

Will we share your personal data with third parties?
We may transfer personal data to our service providers, professional advisors, public and governmental authorities or third parties in connection with a (potential) corporate or commercial transaction. Such third parties may be located in other countries. Before we do so, we shall take the necessary steps to ensure that your personal data will be given adequate protection as required by relevant data privacy laws and CPR Vision’s internal policies. CPR Vision may also transfer your personal data to any of its global affiliates/partners in furtherance of any visits to our CPR Vision locations.
We may also share your information in connection with a substantial corporate transaction, such as, a merger, consolidation, asset sale, initial public offering.

What about sensitive data?
We do not generally seek to collect sensitive data (also known as special categories) through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.

The term "sensitive data" refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).

What about data security?
We maintain organizational, physical and technical security arrangements for all the personal data we hold. We have protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the processing we undertake.

What are the sources we get your personal information from?
If we do not obtain your personal information directly from you, we may obtain it from the following sources: publicly available sources (registers or the internet), CPR Vision employees, contractors, (prospective) members of board of directors, shareholders, CPR Vision’s affiliates, subsidiaries and newly acquired businesses, employers of our contractors, public authorities, public websites and social media, previous employers, educational institutions, suppliers and vendors (including third party data providers).

How long will your personal data be retained by us?
We will retain your personal data only for as long as is necessary. We maintain specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the following retention criteria:

  • We retain your data as long as we have an ongoing relationship with you (in particular, if you have an account with us).
  • We will only keep the data while your account is active or for as long as needed to provide services to you.
  • We retain your data for as long as needed in order to comply with our global legal and contractual obligations.


2. How do we use personal data when you visit CPR Vision’s website?

What personal data do we capture?
CPR Vision collects personal data at its websites in two ways: (1) directly (for example, when you provide personal data to sign up for a newsletter or register to comment on a forum website); and (2) indirectly (for example, through our website's technology).
We may collect and process the following personal data:

  • Personal data that you provide by filling in forms on our website. This includes registering to use the website, subscribing to services, newsletters and alerts, registering for a conference or requesting a white paper or further information. Pages that collect this type of personal data may provide further information as to why your personal data are needed and how it will be used. It is completely up to you whether you want to provide it.
  • If you contact us, we may keep a record of that correspondence.
  • We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
  • Any postings, comments or other content that you upload or post to an CPR Vision website.
  • Our website collects personal data about your computer, including (where available) your IP address, operating system and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics.
  • Details of your visits to our website, the pages you view and resources you access or download, including but not limited to, traffic data, location data, weblogs and other communication data.

Do we include (links to) websites and programs of third parties?
Our websites may include:

  • Links to and from the sites of our partner networks, advertisers and affiliates.
  • Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal data collected through such programs for their own purposes.

We do not accept any responsibility or liability for such third parties’ sites or programs. Please check such third parties’ terms of use and privacy statements before using and providing any information to such third parties’ sites and programs.


3. How do we use cookies (and other tracking technologies)?

In addition to the information set out above, this section describes how we use cookies and other tracking technologies.
We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and, eventually, to determine how we can tailor our website to make it a more positive and relevant user experience.
Please see our Cookies policy for more details.


4. How do we use personal data when you visit our offices?

In addition to the information set out above, this section describes how we use personal data when you visit CPR Vision offices.
If you have any questions on data privacy or you want to let us know about website/marketing permissions, please contact us.


5. Contact us

Please click here if you have a general question about how CPR Vision protects your personal data.