Privacy Policy

1. Who We Are

Step AM Limited operates an online employment marketplace in Hong Kong. We are a licensed employment agency under Hong Kong law (Employment Agency Licence No. 79937).

When you apply for a job through our platform, we process your job application jointly with the employer to whom you are applying. For such processing, we and the employer are data controllers of your personal information.

2. Information We Collect

We collect different types of information about you depending on how you interact with us:

For Job Seekers (Candidates):

For Employers/Advertisers:

• Company name, business address, and billing information
• Contact details of administrators and users
• Payment and transaction information
• Job posting and recruitment activity data

3. Sensitive Information

We generally do not need to collect sensitive information about you. You should not disclose sensitive information that is not necessary or relevant.

However, there may be situations where we collect sensitive information, such as:

• When you voluntarily include it in your resume or job application
• When employers request specific information (e.g., vaccination status)
• When required for identity verification

We will only collect sensitive information with your explicit consent or where there is another legal basis permitting us to do so.

4. How We Use Your Information

5. Sharing Your Information

We may share your information with:

Employers

When you apply for a job, we share your application and relevant profile information with the employer. Employers may store your information in their own systems, over which we have no control.

Service Providers

Trusted partners who help us operate our platform (hosting, payment processing, analytics, customer support).

Legal & Regulatory Authorities

When required by Hong Kong law, court orders, or to protect our rights and safety.

Business Transfers

In connection with mergers, acquisitions, or business transfers.

6. International Transfers

Your personal data may be transferred to and processed in countries outside Hong Kong, including:

• Our servers may be located in other countries
• Service providers operating globally
• Employers located outside Hong Kong

We ensure that any international transfers comply with Hong Kong's Personal Data (Privacy) Ordinance (PDPO) and that appropriate safeguards are in place to protect your data.

7. Data Security

We implement comprehensive security measures including:

• Encryption of sensitive data in transit and at rest
• Access controls and authentication measures
• Regular security assessments and audits
• Employee training on data protection
• Incident response procedures

However, no method of transmission over the Internet is 100% secure. You should also protect your account credentials and notify us immediately of any unauthorized access.

8. Your Rights (Hong Kong PDPO)

Under Hong Kong's Personal Data (Privacy) Ordinance, you have the right to:

We will respond to your requests within 40 days as required by Hong Kong law. There may be restrictions on these rights in certain circumstances (e.g., legal obligations).

9. Direct Marketing

We may use your personal data for direct marketing purposes to send you:

• Job alerts and career opportunities
• Platform updates and new features
• Promotional offers and newsletters
• Career advice and resources

Your consent is required for direct marketing. You can:

• Opt-in during registration or in your account settings
• Opt-out at any time by clicking "unsubscribe" in emails
• Update preferences in your account settings
• Contact us to stop all marketing communications

10. Cookies & Tracking Technologies

We use cookies and similar technologies for:

• Essential Operations: User authentication, session management
• Preferences: Remembering your settings and preferences
• Analytics: Understanding how users interact with our platform
• Advertising: Showing relevant job advertisements
• Performance: Monitoring platform performance

You can control cookies through your browser settings. However, disabling some cookies may affect platform functionality.

Third-Party Tracking

We work with third-party analytics and advertising partners who may place cookies on your device. These partners are bound by contractual obligations to protect your data.

11. Data Retention

We retain your personal data for as long as necessary to:

• Fulfill the purposes outlined in this policy
• Comply with legal obligations (e.g., tax records: 7 years)
• Resolve disputes and enforce agreements
• Maintain business records as required by law

Typical retention periods:

• Active accounts: While account is active + 2 years after last activity
• Job applications: 2 years after application date
• Financial records: 7 years as required by Hong Kong law
• Marketing preferences: Until you opt-out or delete account

After retention periods expire, we securely delete or anonymize your data.

12. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately. We will take steps to delete such information.

13. Updates & Contact

Policy Updates

We may update this Privacy Policy periodically. We will notify you of significant changes by:

• Posting the updated policy on our website
• Sending email notifications for major changes
• Updating the "Last Updated" date

Your continued use of our services after updates constitutes acceptance of the revised policy.