PRIVACY POLICY

Principle

Thank you for visiting our website and for your interest in our company and services. We take the protection of your personal data seriously. This notice explains how we collect, use, disclose and protect personal data in line with the applicable laws of the United Arab Emirates (including the UAE Federal Data Protection Law (PDPL)) and, where relevant, other applicable laws. A detailed version can be provided on request.

1. Name and address of the controller

Controller
POLYTALENT HR CONSULTANCY LLC
Dubai Branch Building -1-141, Office No. 1-141-434, Mankhool
Dubai – United Arab Emirates
Email: privacy@polytalent.de

1.1 Contact for data protection / Data Protection Officer

If you have questions about this notice or would like to exercise your rights, please contact:
Data Protection Officer (DPO): Mr. Eyüp Aramaz
Email: privacy@polytalent.de

2. General information on data processing

Our website automatically collects certain technical information each time it is accessed (e.g., browser type and version, operating system, referrer URL, sub-pages visited, date/time of access, IP address, ISP, and similar information). This data is stored in server log files.

We do not draw conclusions about individual users from this information. We use this data to correctly deliver website content, improve the site, ensure IT security and stability, and provide information to competent authorities if a cyberattack occurs. Log data is analyzed statistically and to improve security. Log data is stored separately from other personal data.

2.1 Scope of processing

We collect and use personal data only to provide a functional website and our services. We process personal data with your consent or when another lawful basis applies (see 2.2).

2.2 Lawful bases (PDPL)

Depending on the context, we process personal data on one or more of the following grounds permitted under UAE PDPL:

Consent (you have given clear consent).
Contract (processing is necessary to enter into or perform a contract with you).
Legal obligation (compliance with applicable laws).
Legitimate interests (our or a third party’s legitimate interests that do not override your rights and freedoms, e.g., website security, fraud prevention, service improvement).
Vital/public interest or judicial proceedings, where applicable.

2.3 Data deletion and retention

We delete or anonymize personal data when the purpose no longer applies. Data may be retained if required by applicable law or to establish, exercise or defend legal claims. When statutory retention periods expire, data is deleted unless further storage is lawfully required.

3. Provision of the website and log files

3.1 Description and scope

When you access our website, our systems collect: browser type/version, operating system, ISP, IP address, date/time, referrer URL, pages visited. Some of this can be personal data (e.g., IP address). Log data is not combined with other data.

3.2 Lawful basis

Our lawful basis is legitimate interests (ensuring website operation, security and performance).

3.3 Purpose

To deliver the website to your device, maintain security and troubleshoot performance issues. No marketing analysis is performed on raw log files.

3.4 Storage period

Session data is deleted after the session ends. Log files are kept for up to 7 days, then deleted or anonymized unless longer retention is necessary for security or legal reasons.

3.5 Objection

Collecting log data is essential for operating the site; therefore there is no general opt-out.

4. Use of cookies

We use cookies and similar technologies (e.g., local storage, pixels) to make our website user-friendly and to analyze usage.

You can configure your browser to block cookies or to alert you when cookies are being set. Disabling cookies may affect website functionality.

4.1 Description and scope

We use:

Strictly necessary cookies (e.g., load balancing, consent storage).
Functional/analytics cookies (e.g., to remember preferences; to understand how the site is used: pages visited, features used, frequency, search terms).

Analytics data is pseudonymized where possible and not combined with other personal data.

When you first visit the site, we display a consent banner. Non-essential cookies are used only with your consent.

4.2 Lawful basis

Necessary cookies: legitimate interests (site operation).
Analytics/marketing cookies: consent via our cookie banner.

4.3 Purpose

To enable core functions, improve the site, and understand what content is useful.

4.4 Storage/objection

Cookie lifetimes vary by purpose and provider. You can withdraw consent at any time via the cookie settings on the site or your browser controls.

5. Newsletter

5.1 Description and scope

You may subscribe to our newsletter by providing at least your email address (optionally name). We also store your IP address and timestamp at registration for security/audit purposes. No data is shared with third parties for their own marketing.

5.2 Lawful basis

Consent (you can withdraw at any time).

5.3 Purpose

To send you the requested newsletter.

5.4 Retention

Stored until you unsubscribe.

5.5 Withdrawal

Use the unsubscribe link in any newsletter or email privacy@polytalent.de.

6. Contact form and email

6.1 Description and scope

If you contact us (form or email), we process the data you provide (e.g., first/last name, email, phone, message). We also log IP address and timestamp for security. Data is not shared with third parties unless required for your request or by law.

6.2 Lawful basis

Consent (for the form), contract (pre-contractual/contractual correspondence), and/or legitimate interests (responding to inquiries, ensuring security).

6.3 Purpose

To process and respond to your request and prevent abuse of our systems.

6.4 Retention

We retain correspondence as long as needed to handle your request and in accordance with legal retention requirements.

6.5 Objection/withdrawal

You can withdraw consent or object to processing at any time by emailing privacy@polytalent.de. If you do, we may be unable to continue the conversation.

7. Your rights

Subject to conditions under UAE PDPL and other applicable laws, you may have the following rights:

Access to your personal data.
Rectification of inaccurate data.
Erasure of personal data (where legally permissible).
Restriction or objection to processing (including direct marketing).
Data portability (to receive your data in a machine-readable format and transmit it to another controller).
Withdrawal of consent (does not affect prior processing).
Complaint to the competent supervisory authority (e.g., the UAE Data Office).

To exercise your rights, contact privacy@polytalent.de. We will respond within a reasonable period in line with applicable law.

8. Applicant data

8.1 Description and scope

If you apply via our site, we process: name, email, phone, job applied for, how you heard about the job, your message, networks (if provided), and attachments (CV, cover letter, certificates). We also log IP address, date/time for security.

We use this data only for recruitment and do not share it with third parties unless required to process your application (e.g., with prospective employers) or by law.

8.2 Lawful basis

Contract / pre-contractual steps, and/or consent where required (e.g., keeping your profile for future roles).

8.3 Purpose

To evaluate and process your application, communicate with you, and analyze sourcing channels.

8.4 Retention

Typically retained for the duration of the recruitment process and, unless you consent to a longer period, deleted within 6 months after closure. Security logs related to submissions are deleted after 7 days.

8.5 Withdrawal

You can withdraw your application or consent at any time. We will then stop processing and delete the data unless retention is legally required.

9. Google Analytics (with IP anonymization)

We use Google Analytics (Google LLC, USA) to analyze website use. We use IP anonymization where available so that your IP is shortened before storage. Google sets cookies to help analyze site use. Information generated by cookies (including truncated IP) may be transferred to and stored on Google servers (including in the USA). Google processes this information on our behalf to evaluate website usage and provide reports.

Lawful basis: Consent (via cookie banner).
Opt-out: You can withdraw consent in our cookie settings or install the browser add-on: https://tools.google.com/dlpage/gaoptout

Further information: Google Privacy Policy and Analytics Terms.

International transfers: Where data is transferred outside the UAE, we implement appropriate safeguards (e.g., contractual protections) consistent with PDPL.

10. Smashleads™ (lead generation)

We use smashleads forms to capture leads. Processing details: https://smashleads.de/data-processing.html

Lawful basis: Consent (form submission) and legitimate interests (managing and responding to inquiries).

11. Google Ads (Conversion Tracking)

We use Google Ads conversion tracking (Google LLC, USA). When you click our ad and reach our site, Google may place a conversion cookie to measure performance. Data may be transferred to the USA.

Lawful basis: Consent (marketing cookies).
Opt-out: Manage via our cookie banner or Google Ads settings: https://www.google.com/settings/ads

12. Google reCAPTCHA

We use Google reCAPTCHA (Google LLC, USA) to protect forms against abuse. reCAPTCHA analyzes interactions (e.g., IP address, device/browser data).

Lawful basis: Legitimate interests (website security and fraud prevention).
Privacy information: https://policies.google.com/privacy

13. Cookie consent (Borlabs Cookie)

We use Borlabs Cookie (Borlabs – Benjamin A. Bornschein, Hamburg, Germany) to record your cookie choices. A consent cookie stores your selections. Data is retained until you delete the Borlabs cookie or we no longer need to keep consent records. Details: https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/

You can adjust your preferences anytime via our Cookie Settings.

14. Meta (Facebook) Pixel

We use the Meta (Facebook) Pixel to measure conversions and optimize ads (Meta Platforms, Inc., USA and/or Meta Platforms Ireland). Data may be linked to your Meta account and used for ad personalization per Meta’s policies.

Lawful basis: Consent (marketing cookies).
Opt-out / info: https://www.facebook.com/about/privacy/ and EU choices: http://www.youronlinechoices.com

15. Heyflow

We use Heyflow (Heyflow GmbH, Hamburg, Germany) to build interactive forms/flows. Heyflow may set cookies and process data such as IP address, timestamps, pages visited, browser/device information, and the data you submit in forms.

Lawful basis: Consent (where applicable) and/or legitimate interests (efficient handling of inquiries).
Privacy: https://heyflow.app/de/datenschutz

16. International data transfers

We may transfer personal data to countries outside the UAE (e.g., to service providers in the EU or USA). Where we do so, we implement appropriate safeguards in accordance with PDPL (such as contractual protections) and require recipients to protect your data appropriately. You can contact us for more details.

17. Security

We implement technical and organizational measures appropriate to the risk to protect personal data against unauthorized access, alteration, disclosure or destruction.

18. Updates to this policy

We may update this notice from time to time to reflect legal, technical or business changes. The updated version will be published on this page and is effective upon posting.

Contact
For any privacy requests or questions, please email privacy@polytalent.de or write to:
POLYTALENT HR CONSULTANCY LLC
Dubai Branch Building -1-141, Office No. 1-141-434, Mankhool, Dubai – UAE