Privacy Policy

1. Introduction

Welcome to GTW-Global (“GTW-Global,” “we,” “our,” or “us”).

GTW-Global operates a digital platform that hosts and displays listings and provides training. We are committed to protecting your privacy and handling your personal information responsibly, transparently, and securely.

This Privacy Policy explains how we collect, use, disclose, store, transfer, and protect your personal information when you use our website, applications, products, services, and related platforms (collectively, the “Platform”).

By using the Platform, you acknowledge that you have read and understood this Privacy Policy.

2. Scope

This Privacy Policy applies to users located in:

• India
• European Union member states
• United Kingdom
• Australia
• Philippines
• Gulf Cooperation Council (GCC) countries

Where local privacy laws provide greater protections than this Privacy Policy, those local laws will prevail to the extent required.

3. Information We Collect

Depending on how you interact with the Platform, we collect:

A. Personal Information

• Full name
• Email address
• Mobile number
• Complete Postal Address, which shall include City, State/Province/County, and Country
• Date of birth (where required)
• Profile photograph
• Skills
• Certifications

B. Account Information

• Username
• Security questions

C. Professional Information

• Employment History, comprising job title, company name, company location, and start and end dates of engagement, including whether the role is current.
• Career Preferences, comprising migration or sponsorship availability, notice period, preferred work environment, and preferred destination countries.
• Job postings
• Talent profiles

D. Usage Information

We automatically collect:

• IP address
• Browser type
• Device identifiers
• Operating system
• Time zone
• Language preferences
• Device type
• Referring pages
• Pages visited
• Session duration
• Clickstream information

E. Cookies and Similar Technologies

Cookies and similar technologies used on the Platform are addressed in our separate Cookie Policy.

F. Communications

We collect information contained in:

• Messages
• Customer support requests
• Survey responses
• Event registrations
• Webinar participation
• Community discussions
• Feedback
• Forms submitted through the Platform

4. How We Collect Information

We collect information through the following routes.

From the supply partner that lists you. Where you are listed on the Platform by a supply partner, we receive profile, employment, and career preference information from that supply partner for the purpose of creating and displaying your listing on the Platform. We do not collect personal information about you from publicly accessible sources.

Directly from you. We collect information you provide to us directly, including when you register for training via the Platform, when you contact us, and when you submit forms or communications through the Platform.

Automatically through your use of the Platform. We automatically collect usage information as described in Clause 3D, including information generated through your participation in and progress through training delivered via the Platform. Cookies and similar technologies are addressed in our separate Cookie Policy.

From business and partner contacts. We collect the business contact information of individuals associated with our supply partners and customer partners, such as name, work email address, and phone number, in connection with our commercial relationship with their organisation.

5. Legal Bases for Processing

Where applicable, we process personal information on the following bases. The basis we rely on depends on the purpose of the processing and on the law applicable to you.

Purpose Group (Clause 6)	Basis Relied On
Account creation, authentication and access	Performance of a contract; consent
Operating the marketplace: hosting, displaying, enabling selection	Performance of a contract; consent
Delivering training	Consent; performance of a contract
Support, communications and service notifications	Performance of a contract; legitimate interests where recognised
Security, fraud prevention and legal compliance	Compliance with legal obligations; legitimate interests where recognised
Platform analytics and improvement	Performance of a contract; legitimate interests where recognised
Personalisation	Performance of a contract; legitimate interests where recognised
Ancillary functions: networking, recruitment and talent discovery, matching	Performance of a contract; legitimate interests where recognised
Marketing, where permitted	Consent; legitimate interests where recognised

6. How We Use Your Information

A. Account creation, authentication and access

• Create and manage accounts
• Authenticate users

B. Operating the marketplace

• Host and display listings on the Platform
• Enable browsing of listings and selection by customer partners

C. Delivering training

• Deliver training via the Platform
• Monitor and record training progress

D. Support, communications and service notifications

• Provide customer support
• Communicate updates
• Send service notifications

E. Security, fraud prevention and legal compliance

• Prevent fraud
• Detect abuse
• Maintain security
• Comply with legal obligations

F. Platform analytics and improvement

• Analyse Platform performance and improve Platform functionality
• Conduct research and analytics

G. Personalisation

• Personalise user experience

H. Ancillary functions

We may also use personal information in connection with the following functions:

• Enabling networking opportunities
• Facilitating recruitment and talent discovery
• Matching professionals with opportunities

I. Marketing

• Deliver marketing communications where legally permitted

J. Payments

Process payments: Process payments made by customer partners for programs and courses, and issue payouts to supply partners. We do not collect or store payment card or bank account details. Payments are processed through our third-party payment processor, and cardholder data does not enter our systems.

7. Artificial Intelligence and Automated Processing

Use of automated systems. We use artificial intelligence, machine learning and automated systems for spam detection, fraud prevention, customer support automation, analytics, and monitoring and recording your progress through training delivered via the Platform.

We may also use such systems in connection with talent recommendations, opportunity matching, content recommendations, and search optimisation.

Automated decision-making. Assessments completed as part of training are scored automatically. A failing result under the applicable pass criteria will prevent you from proceeding to subsequent stages of onboarding or training. Because a listing is displayed only once onboarding, including training, is complete, this automated scoring can accordingly affect whether your listing is displayed on the Platform. Verification of identity and supporting documents is conducted through manual review and is not a solely automated decision.

Safeguards. Where a decision is made about you by solely automated means and produces legal or similarly significant effects, you may request human intervention, express your point of view, and contest the decision. Requests may be made using the contact details in Clause 19.

8. Sharing of Personal Information

We disclose personal information as set out below.

A. Platform operation and display

We disclose Listing Information to authenticated customer partners who are under contract with us, so that they may browse listings and select a caregiver according to their requirements. “Listing Information” means the profile information about a caregiver made available to customer partners through the Platform, and does not include personal information we hold about you but do not display. Access to the Platform is restricted to authenticated users; no listing is published publicly.

We also disclose your onboarding, verification, and listing status to the supply partner that listed you, and to our cloud hosting providers.

B. Service providers

We disclose personal information to service providers who perform services on our behalf, including providers of cloud hosting and infrastructure services, providers of video communication and transcription services, providers of automated document processing services, and providers of payment processing services.

C. Ancillary functions

We may disclose personal information to recruitment partners, employers, educational institutions and professional organisations in connection with the ancillary functions described in Clause 6H.

D. Marketing

We may disclose personal information to marketing vendors, where permitted by applicable law.

E. Legal, regulatory and professional

We disclose personal information to government authorities where legally required, and to our professional advisers, auditors and insurance providers.

F. Payments

We use a third-party payment processor to process payments made through the Platform and to issue payouts to supply partners. We do not disclose payment card or bank account details to our payment processor or any other party, as we do not collect or hold this information.

We do not sell or share personal information for monetary or other valuable consideration.

9. International Data Transfers

GTW-Global’s Portal is hosted in Singapore. Personal information collected from individuals located in other territories, including the European Economic Area, the United Kingdom, India, Australia, the Philippines and the Gulf Cooperation Council states, is transferred to and processed in Singapore.

Where required by applicable law, we implement appropriate safeguards for these transfers, including Standard Contractual Clauses and, for transfers from the United Kingdom, the UK International Data Transfer Addendum. You may request a copy of the safeguards applicable to your information by contacting us using the details in Clause 19.

10. Data Retention

We retain personal information only for as long as necessary to:

• Provide our services
• Fulfil contractual obligations
• Meet legal requirements
• Resolve disputes
• Enforce agreements
• Maintain security
• Improve our Platform

We retain personal information for as long as it is reasonably necessary for the purposes described in this Privacy Policy, including to provide the Platform and deliver training, to maintain your listing for as long as you remain onboarded and your supply partner relationship remains active, to meet our legal and regulatory obligations, to resolve disputes, to enforce our agreements, and to maintain the security of the Platform.

Where you withdraw consent to your listing, we will delete the related personal information within 30 days of withdrawal.

Where you exercise a right of erasure under Clause 11, the relevant personal information is soft-deleted and permanently purged within 30 days, subject to any information we are required or permitted to retain for the purposes described above.

Access logs and records maintained for security and audit purposes are retained for seven years, after which they are archived in accordance with our internal data governance practices.

Where a supply partner relationship ends, or a caregiver’s listing is removed from the Platform, we retain the information necessary for the purposes described above for the applicable retention period. The listing itself will no longer be displayed.

11. Your Privacy Rights

Depending on where you are located, you may have the following rights in relation to your personal information.

Access. You may request confirmation of whether we hold personal information about you and access to that information, together with information about the categories of personal information we hold, the sources from which it was obtained, the purposes for which it is used, and the categories of recipients to whom it is disclosed.

Correction. You may correct or update certain information yourself through your account settings on the Platform. Where information cannot be corrected in that way, you may request that we correct or complete personal information that is inaccurate or incomplete.

Erasure. You may request that we delete personal information we hold about you. We may be unable to delete information we are required to retain for the purposes described in Clause 10, including to meet legal requirements, resolve disputes, enforce agreements and maintain security.

Withdrawal of consent. Where we process your personal information on the basis of your consent, you may withdraw that consent at any time. Withdrawal does not affect processing carried out before withdrawal. Where your listing information was provided to us by a supply partner, withdrawing consent given to us may not affect the supply partner’s own processing or its transmission of that information, and you may need to contact the supply partner directly.

Human review of automated decisions. Where a decision is made about you by solely automated means and produces legal or similarly significant effects, you may request human intervention, express your point of view, and contest the decision, as set out in Clause 7.

Complaints. You may lodge a complaint with the supervisory or data protection authority in your jurisdiction.

Exercising your rights. To exercise any of these rights, contact us using the details in Clause 19. We may request additional information to verify your identity before responding, and we may be unable to respond if we cannot verify you. You may authorise an agent to make a request on your behalf, provided the agent produces signed written authority or a power of attorney.

Certain information may be exempt from these requests under applicable law, and we may decline requests that are unfounded, excessive, or that would adversely affect the rights of others. Some of the rights set out above are not available in all jurisdictions.

12. Children’s Privacy

Our Services are not intended for children under the age of 18, and we do not knowingly collect Personal Data from anyone under 18 years old. If you are under 18, please do not attempt to use our Services or send any Personal Data about yourself to us.

In the event we learn that we have collected Personal Data from a child under 18, we will promptly delete that information from our records. If you believe that a child under 18 may have provided us with their information, please contact us using the information in the Contact section below so that we can take appropriate action.

13. Security

We implement administrative, technical and organisational measures designed to protect personal information against unauthorised access, disclosure, alteration and destruction. These measures are calibrated to the sensitivity of the information concerned.

We restrict access to personal information to personnel who require it in order to operate the Platform and provide our services, and we require our service providers to implement appropriate security measures in respect of information we disclose to them.

Where you hold credentials for access to the Platform, you are responsible for keeping those credentials confidential and for notifying us promptly of any unauthorised use of your account. No internet transmission or storage system can be guaranteed to be completely secure.

14. Third-Party Services

The Platform may contain links to third-party websites, products or services. GTW-Global is not responsible for the privacy practices of those third parties. Once you navigate away from the Platform, this Privacy Policy ceases to apply and the privacy policy of the third-party site or service will govern; you should review those policies independently.

This Clause does not apply to the recipients described in Clause 8, to whom we disclose personal information and in respect of which this Privacy Policy continues to apply.

15. Cookies

We use cookies and similar technologies on the Platform. The categories of cookies we use, their purposes and their duration are set out in our separate Cookie Policy.

You may manage your cookie preferences through your browser settings or through any consent tool made available on the Platform.

16. Marketing Communications

Where permitted by applicable law, we may send you newsletters, product updates, event invitations, information about professional opportunities, and other marketing communications.

You may unsubscribe from marketing communications at any time using the unsubscribe link included in those communications or by contacting us using the details in Clause 19.

Service, administrative, security and training-related communications are not marketing communications. We will continue to send you those communications regardless of your marketing preferences, for as long as you use the Platform.

17. Data Breach Response

In the event of a personal data breach affecting your personal information, we will inform you as soon as practicable and within any timelines required under applicable law. Where required, we will also notify the relevant regulatory authorities.

18. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The date at the top of this Privacy Policy indicates when it was last revised.

Where we make a material change to this Privacy Policy, we will notify you in advance of the change taking effect, through the Platform or by email. Non-material changes and clarifications take effect immediately on publication.

19. Contact Us

For privacy-related questions or requests, please contact:

• Email: [yourdomain]
• Registered Office: [Address]

Where required by law, GTW-Global may designate local representatives or Data Protection Officers for specific jurisdictions.

20. Jurisdiction-Specific Notices

Additional privacy notices may apply to users located in certain jurisdictions, including but not limited to:

• European Union (GDPR)
• United Kingdom
• India
• Australia
• Philippines
• United Arab Emirates
• Saudi Arabia
• Qatar
• Bahrain
• Oman
• Kuwait

Where local law requires additional disclosures or rights, those notices supplement this Privacy Policy.

21. Governing Law

This Privacy Policy shall be governed by and interpreted in accordance with the laws of Singapore, and the courts of Singapore shall have jurisdiction in respect of any dispute arising out of or in connection with it, except where mandatory local privacy laws provide otherwise.

Nothing in this Privacy Policy limits any rights granted to you under applicable data protection laws, including your right to lodge a complaint with the supervisory or data protection authority in your jurisdiction.