PrivacyPolicy

Kelnor IT Services and Consultancy (FZE) Privacy Notice Welcome to https://kelnorconsulting.com/ (the "Site"). This Privacy Notice ("Notice") describes how Kelnor IT Services and Consultancy (FZE) ("we", us, our, "Kelnor") may use, process, store and disclose personal data that we may collect about individuals, including if you register with us via our candidate registration process, apply for jobs through this Site and external job boards and from other sources. The types of personal data we collect are described in the section below ‘Your Personal Data and how we collect it’. We act as a controller and we are responsible for the personal data we process. This Notice informs you how we protect personal data and about your privacy rights. By accessing, browsing, or using the Site and/or by submitting personal data to us, you declare you have legal capacity and you are 21 years old or above. This Site is not intended for children and we do not knowingly collect personal data relating to children. It is important that you read this Notice together with any other Privacy Notice we may provide such as the Notice contained in our candidate registration form and on specific occasions when we are collecting or processing

personal data for new purposes so that you are aware of how and why we are processing your personal data. This Notice supplements other Privacy Notices you may receive from us and is not intended to override them.

Contact details

If you have any questions about how we use your personal data, contact SRTIP office or email us at info@kelnorconsulting.com.

Your personal data and how we collect it

We collect different types of personal data depending on our relationship with you and you may be in one or more of these categories:

• candidates searching for permanent employment with clients and hiring organisations;
• job applicants applying for employed roles working for Kelnor e.g. as recruitment consultant;
• internal employees carrying out work and operational activities connected to the performance of our business;
• business contacts at clients, hiring organisations and suppliers of goods and services.

Using this site

When you use this Site, we may ask for personal data including your name and contact information (email address, home address and phone number). Depending on the nature of your enquiry or activities on our Site, we may also ask for your job search criteria, employment experience, salary, and other background information and marketing preferences together with any login ID and password created by you.

Registering as a candidate for work finding services

We will collect personal data directly from you during in person interviews, video and online meetings and from other sources including your CV when you apply for a job through directly through our Site, via job sites, from social media such as LinkedIn, Facebook and Twitter and when you provide us with your details during a promotional, networking or training event. When you ask us to provide you with work finding services we will ask you to register as a candidate. During our candidate registration process we will collect personal data directly from you, your CV, from employment and educational referees and via online tests and assessments you may perform at our request. We may verify your professional qualifications with the relevant professional institute. We may disclose your personal data to our clients and hiring organisations inside and outside of the SRTIP, the UAE, Europe, UK and other locations for relevant job vacancies. Clients may request us to obtain additional personal data about you in relation to their job vacancies and role requirements. Your personal data will be securely stored in our online candidate database. To provide you with work finding services our recruitment consultants process your personal data to provide you with information regarding employment opportunities, roles you may find interesting, career-related information and to provide you with other requested information and/or services.

How we use your personal data

We collect, process, disclose and store your personal data we collect to administer your job application and during our candidate registration process, for the purposes of providing you with work finding services including permanent employment placements in finance, accounting, technology, administrative, legal, marketing, and project related work and other related roles, employment opportunities and career-related information through this Site and by email sent to you from our recruitment consultants. We process your personal data to evaluate your suitability for roles, conduct applicable background and verification checks and disclose your personal data to our clients and potential hiring organisations in relation to their job vacancies. We will process your personal data in accordance with the core provisions in Article 9(1) of Data Protection Law No.5 of 2020 (DP Law) and for our legitimate business purposes such as service announcements, communications relating to this Notice, internal administration, producing statistics, analysing how successful our marketing campaigns are, the number of visitors to our Site and complying with other contractual, legal and regulatory obligations and duties. If you provide us with personal data about third parties, you are the source of that information and we will assume that the third party has given you permission to do so and to Kelnor collecting, processing and transferring their personal data to the same extent as yours. Our success is dependent on efficiently matching candidates to clients’ vacancies. Our recruitment consultants are presented with a list of proposed candidates that are potentially suitable for a client’s vacancy but it does not lead to automated decision-making. Our recruitment consultants decide which candidates to shortlist for a specific client’s job, based on their expertise, knowledge of the job market, insight into the client’s business and requirements for the role, candidate discussions and other relevant criteria. Clients’ (through their hiring personnel) decide which candidates to select for interview (if any). Our clients’ hiring personnel make the final decision on which candidate to select for their job (if any) and ultimately to proceed to hire/engage/employ the candidate.

Applicants for employed roles

If you are a job applicant applying for a role as our direct permanent employee, we will collect personal data from you via your CV, during in person and video interviews, referees, professional and educational organisations, online assessments and other sources. We will process your personal data on the basis of legitimate interests for the purposes of administering the employment application, managing the internal hiring process and assessing your suitability for the role. We will store your personal data securely in our confidential online HR database. Your personal data cannot be viewed or accessed by anyone except for members of our HR and internal Talent Acquisition teams located in the UAE and other staff connected to the hiring process, such as interviewing and assessing your suitability for the role you have applied for and communicating with you. We take steps to ensure that your personal data is adequately protected and kept confidential. If we engage a third party to provide pre-employment screening services or testing, we will ensure that access is limited to the personal data that is compatible with those purposes and the service provider is contractually obliged to comply with applicable data privacy laws, confidentiality and provide adequate safeguards to keep your personal data secure until it is deleted or anonymised so that you can no longer be identified.If your employment application is unsuccessful, we will retain your personal data on our HR database for a period of 6 months for the purposes of evidencing that we have conducted the hiring process in a fair and transparent way. At the end of the retention period, your personal data will be automatically deleted.

The categories of personal data we may collect

Depending on the nature of your relationship with us, the types of personal data we may collect include:

• your identity (your full name, previous names, evidence of change of name); gender, date of birth, social media URL, whether you are a UAE resident, passport/work permit/visa sponsorship/Emirates ID and languages spoken;
• contact details including your name, personal email, home address and phone numbers so that we can contact you by email and text message;
• your job search criteria, preferences and expectations;
• details of your professional qualifications, skills, experience and training;
• current and desired remuneration/compensation and other benefits;
• educational history;
• employment history;
• contact details for employment and/or educational referees;
• employment and/or educational references;
• online skills tests and assessments;
• health/disability data and other information contained in your CV and/or that you choose to provide to us and it is relevant;
• your feedback and responses to surveys and questionnaires;
• technical data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Site and if you visit other websites employing our cookies.
• profile data including your username and password, your interests and preferences;
• usage data including information about how you use our Site and services; and
• marketing and communications data including your marketing and communication preferences.

We want to ensure we keep your personal data accurate and up to date and we may ask you to complete and sign our candidate registration form and/or provide us with an updated CV on a regular basis to help us to do this. The basis we process your personal data for these purposes is your consent. When we collect personal data from you directly, we will provide a link to this Notice at the point we collect the data.

Special categories of personal data If you provide details revealing or concerning (directly or indirectly) racial or ethnic origin, communal origin, political affiliations or opinions, religious or philosophical beliefs, criminal record, trade union membership and heath or sex life and including genetic data and biometric data where it is used for the purpose of uniquely identifying you, we will process this data only to the extent that it is necessary and relevant. Special categories of personal data will be processed in accordance with the restrictions imposed by law and will be retained for no longer than necessary before being deleted. If you choose to provide us with special categories of personal data (e.g. in your CV) and we do not need it, we will disregard this data.

Our clients, hiring organisations and suppliers

If you are a potential hiring organisation, a client or a supplier of goods and services, we will collect and process personal data about individuals in your organisation. We may enter the individual’s name, business email, business address and other business data, into our database as a designated business contact for the organisation, for the purposes of contacting the organisation in relation to our services and invoicing or the supplier if we are a recipient of the supplier’s goods and services. If the individual designated as a business contact is also a registered candidate, we may be processing additional personal data for work finding and other purposes that are described in this Notice. The source of business contact data may be the individual themselves, or their name and business details may be provided to us by a member of the organisation’s HR or procurement department, another hiring manager, an existing business contact or a candidate we have placed at the organisation. We may also obtain limited data from websites, social media, public and other sources.

Change of purpose

We will use your personal data only for the purposes for which we collected it (e.g. the provision of work finding services if you are a candidate or to consider you for employment if you are a job applicant) unless we reasonably consider that we need to use it for another purpose and that purpose is not incompatible with the original purpose for which we collected the data. If we need to use your personal data for an unrelated or new purpose, we will notify you including the legal basis which allows us to do so. We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by applicable law.

Disclosing your personal data to third parties

To the extent necessary or appropriate and without notifying you, we may disclose your personal data to external third parties (who are not members of Kelnor) located outside the SRTIP and / or in a location that does not have adequacy status, for legitimate and commercial purposes and the conduct and management of our business in the following circumstances:

• to companies and individuals we engage to perform business functions and services on our behalf. Examples of service providers include: providing payroll services to enable us to pay our employees; pre-employment screening and verification services; data storage facilities including inside and outside of the SRTIP, and the Cloud; hosting our Web servers; managing job posting applications via our third party job board aggregator; providers of data analysis services including the assistance of artificial intelligence for the purpose of efficient search and match of proposed candidates with client job vacancies; data security such anti virus scanning, detection and removal of malicious software; data analytics and producing statistics and for legal, accounting, audit and other professional services;
• to government agencies; law enforcement agencies; regulatory and supervisory authorities (such as the Commissioner of Data Protection);
• to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, we will let you know; and
• to IT consultants carrying out maintenance, testing and development work on our IT systems, service providers who we may appoint as data processors and to other service providers from time to time.

Where applicable, we will impose appropriate contractual security, confidentiality and other obligations on third party recipients and data processors, based on the nature of the personal data to be protected and the services they provide to us. We will only permit them to process your personal data in accordance with the law and our instructions. We do not allow third party processors to use your personal data for their own purposes, they will be required to hold your personal data securely and when our relationship ends, we will ensure your personal data is retained for the period we instruct, securely returned to us, destroyed or anonymised so that you can no longer be identified.

Keeping your personal data secure

We have put in place appropriate technical and organisational security measures to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access or other unlawful forms of processing. In addition, we limit access to personal data to those employees, contractors and third parties who have a business need to do so. We have put in place procedures in the event of a personal data breach and we will notify you and the Commissioner (and, as applicable, other relevant supervisory authorities) of a breach when we are legally required to do so.

How long we retain your personal data

Kelnor will retain your personal data for as long as necessary to fulfil the purposes that we collected it for. This means we will keep your personal data throughout the period of your relationship with us and whilst we are providing you with work-finding services administering a job application and keeping in contact with clients and hiring organisations.If you no longer wish to receive our services, you can request us to delete your personal data. When we have deleted your data, we may retain your name and personal email address on our suppression list for 7 years (or until you apply for job or ask us to provide work finding services) and then will we check with you before removing your personal data from our suppression list.We may continue to retain some of your personal data for applicable legal, compliance, accounting and tax purposes. Your name may be included in financial and transaction data (e.g. employee payslips, client invoices, receipts) for up to 7 years from when our relationship ends. The type of data we retain depends on the nature of our relationship with you and the services we have provided.If there is no retention period stated in law, we determine the appropriate retention period for personal data by considering the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of the data, the purposes for which we process it and whether we can achieve those purposes through other means, and applicable legal requirements.

Additional information, response times and fees

We want to ensure we keep your personal data accurate and up to date. In addition to your legal rights, you may ask us to update your personal data or request a copy of your personal data at any time, by contacting our SRTIP office. We may need to request specific information from you to help us confirm your identity before we can respond to your request. If you are making a request on behalf of someone else, then we will ask for information to satisfy us of your identity and for information to show you have authority to act on someone else’s behalf. This is a security measure to ensure that personal data is not accessed to disclosed to any person other than the individual who has the right to the data. We may also contact you to ask you for further information in relation to your request to help us locate personal data we hold and to speed up our response time. We respond to all legitimate requests within one month unless your request is complex or you have made a number of requests and in this case, we may extend the period by a further two months. We will notify you if we need to do this. You will not have to pay a fee to exercise any of these rights. However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

The legal basis for processing your personal data

We rely on one or more of the following lawful bases for processing personal data: (a) Your consent to the processing of personal data for specific purposes; (b) Processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into such contract; (c) Processing is necessary for compliance with applicable laws that we are subject to; (d) Processing is necessary for the purpose of our legitimate interests except where overridden by compelling legitimate interests of a data subject in a particular situation.

Purpose/Activity	Type of Personal Information	Lawful basis for processing Personal Information
To contact you when you submit your CV via our Site, a job board, or you make an employment application to us direct or via a job board, and to register you as a candidate for work finding services or as a job applicant for an employed position	Contact details CV referees	Your consent Fulfil a contract
To provide you with work finding services including: sending you details of available job opportunities and job alert emails in accordance with your job search preferences and criteria, providing career advice, asking you to complete online skills tests, providing your CV, skills test results and/or background/pre-employment screening (including to the extent necessary and relevant, special category data) disclosing your personal data to clients and hiring organisations in relation to their job vacancies / roles) and charging clients for placements we make.	Contact details Financial data Transaction data Marketing and Communications	Fulfil a contract Compliance with applicable laws Your consent
Transferring your personal data to our group companies	Contact details CV referees	Legitimate interests Your consent
Disclosing your personal data to government, law enforcement agencies, our appointed third party suppliers providing goods and services, including data analysis services and cloud based services	Contact details	Fulfil a contract Compliance with applicable laws Legitimate interests
To manage our relationship with you including:	Contact Profile/Survey	Fulfil a contract Your consent

Purpose/Activity	Type of Personal Information	Lawful basis for processing Personal Information
Notifying you about changes to our contracts and Privacy Notices Asking you to leave a review, provide feedback or complete a survey Administration and IT services connected with the conduct, management and administration of our business including representing you for roles	Marketing and Communications	Compliance with applicable laws Legitimate interests (e.g. keeping our records updated and to study how candidates and potential candidates and visitors to our Site, use of our services and Site, to develop and improve our services and to grow our business)
Keeping your personal data secure to prevent it from being lost, used, accessed, disclosed or altered in an authorised way	Identity Contact CV referees	Compliance with applicable laws
To investigate issues, disputes and complaints between us, and between us, you and our clients and to respond and seek to resolve them	Identity Contact Profile Usage data Marketing and Communications	Your consent Compliance with applicable laws Legitimate interests
To administer and protect our business and our Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data and cookies)	Identity Contact Technical data	Your consent Compliance with applicable laws Legitimate interests
For marketing and communications, make suggestions and recommendations to you about other relevant services that may be of interest to you (e.g. Newsletter, Salary Insights)	Identity Contact Technical data Usage data	Your consent Legitimate interests

Purpose/Activity	Type of Personal Information	Lawful basis for processing Personal Information
Guides, Online training, and inviting you to attend events	Profile data
To deliver relevant Site content and measure or understand the effectiveness of our advertising	Identity Contact Profile data Usage data Marketing and Communications Technical data	Your consent Legitimate interests (e.g. to study how customers use our products/services/Site, to develop them, to grow our business and to inform our marketing strategy)
To use providers of data analysis services, including the assistance of artificial intelligence for the efficient placement of candidates, data analytics to improve our Site, non-essential cookies, products/services, marketing, customer relationships and experiences	Technical data Usage data Profile data	Your consent Legitimate interests (e.g. to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
Retaining your personal data for as long as necessary for the purposes of providing you with work finding services and/or to manage the internal hiring process for employed roles and/or to contact clients and suppliers of goods and services	Identity Contact details CV referees	Fulfil a contract Compliance with applicable laws
To help us respond to queries, and requests from regulators, government and law enforcement agencies and the Courts	Identity Contact	Legitimate interests Compliance with applicable laws

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Site may become inaccessible or not function properly.

Analytics

We use web analytics services to gain insight into how our website is used so that we can measure and improve the performance content or functionality of our website, together this is analytics data. This data processing is based on your consent.
We also use privacy enhancing technologies to improve the protection of personal data and privacy by not allowing third party providers to draw conclusions about visitors to our website, improving the security of personal data and the control of data transfers. In the context of web analytics services, we rely on server-side tracking which means tracking is outsourced to our servers. This protects your privacy better, and at the same time, data related to our analytics data does not identify you, whilst still allowing us to perform the analysis we need. Through server-side tracking in connection with analytics, we improve the control over and security of related data (e.g. personal data such as IP addresses or identifiers).
We use server side tracking provided by a US based service provider, but all data processing takes place exclusively within Germany and the service provider does not store the analytics data processed by it. Through this service, server-side tracking with first-party cookies takes place and the anonymized analytics data are transmitted any possibility to identify visitors.
You can withdraw your consent to the use of non-essential Cookies at any time without affecting the lawfulness of the processing carried out before you withdraw your consent. Automated decision making, including profiling does not take place.

Links to other websites

Our Site may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements.

Customer feedback and complaints

If you would like to share your experience of working with us, whether it’s to tell us it our staff were great and found you work or if something isn’t quite right, we want to hear about it. You can provide feedback to your contact in your local Kelnor branch, or their manager.\We would ask you to provide us with the opportunity to discuss your concerns with you If you have any questions about how we use your personal data, contact us at:info@kelnorconsulting.com