PRIVACY POLICY

Protecting your confidentiality and data with elite-level security standards.

Last Updated: December 2025

1. Introduction

Welcome to Elite & Co ("we," "our," "us"), a premium executive recruitment agency with operations in the United Arab Emirates (UAE). As the data controller under UAE's Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), we determine the purposes and means of processing your personal data. We are committed to protecting your privacy and ensuring the highest level of confidentiality for your personal information in compliance with the PDPL and other applicable laws.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our executive staffing services through our website and related platforms. It applies to data subjects in the UAE and reflects our practices as a global agency handling sensitive professional data.

Confidentiality Commitment: At Elite & Co, we operate under strict confidentiality agreements. Your personal and professional information is treated with the highest level of discretion, mirroring the elite standards we apply to all our services, in full alignment with PDPL principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality.

2. Information We Collect

2.1 Candidate Information

When you apply for positions or register as a candidate with Elite & Co, we may collect (with a valid lawful basis under PDPL Article 5):

2.2 Client Information

When engaging our staffing services, we may collect (with a valid lawful basis under PDPL Article 5):

2.3 Automated Information Collection

We automatically collect certain information when you visit our website (lawful basis: necessary for our legitimate operations under PDPL):

3. How We Use Your Information

Purpose Lawful Basis (PDPL Art. 5) Description
Talent Placement Contract / Consent To match candidates with appropriate positions and present qualified candidates to clients
Service Provision Contract To deliver our staffing services and manage our relationship with clients
Verification Legal Obligation / Consent (for sensitive data) To verify qualifications, experience, and background information
Communication Contract / Consent To communicate regarding opportunities, interviews, and placements
Legal Compliance Legal Obligation To comply with legal obligations and industry regulations, including PDPL
Security Legal Obligation To maintain the security and integrity of our systems

Special Note on Sensitive Data: We only collect sensitive personal data (e.g., background or health information under PDPL) with your explicit consent and only when necessary for specific placements.

4. Data Sharing and Disclosure

We maintain strict control over your personal information as the data controller. Disclosure only occurs under limited circumstances, in compliance with PDPL Articles 13-15:

4.1 With Your Consent

We share candidate information with potential employers only after obtaining explicit consent from the candidate for each specific opportunity.

4.2 Service Providers (Processors)

We engage trusted third-party processors bound by PDPL-compliant contracts for:

4.3 Legal Requirements

We may disclose information when required by law, such as:

5. Data Security

As required by PDPL Article 7, we implement appropriate technical and organizational measures to protect your information:

Confidentiality Training: All Elite & Co staff undergo comprehensive confidentiality training and sign binding non-disclosure agreements to ensure your information remains protected. In case of a data breach, we will notify the UAE Data Office immediately upon awareness (per PDPL Article 21) and affected data subjects if the breach poses a high risk to privacy.

6. Your Rights

Under PDPL Article 13, as a data subject, you have the following rights, which we honor promptly (typically within one month):

Right Description
Access Request confirmation of processing and access to your personal information
Correction Request correction of inaccurate or incomplete information
Deletion Request deletion of your personal information ("right to be forgotten")
Restriction Request restriction of processing (e.g., during verification)
Portability Request transfer of your data to another organization in a structured format
Objection Object to processing (including profiling)
Withdraw Consent Withdraw consent at any time (where processing is consent-based), without affecting prior lawfulness

To exercise these rights or lodge a complaint, contact our Data Protection Officer. You may also complain to the UAE Data Office if unsatisfied with our response.

7. Data Retention

Per PDPL Article 6 (storage limitation), we retain personal information only as long as necessary for the purposes outlined, or as required/permitted by law:

8. International Data Transfers

As a global staffing agency, we may transfer your personal information outside the UAE (PDPL Article 23). Transfers occur only with appropriate safeguards, including:

9. Contact Information

For privacy-related inquiries, rights exercises, or complaints, please contact our Data Protection Officer (appointed per PDPL Article 10 for high-risk processing):

Data Protection Officer

Elite & Co

Office 1501, The Gate Building, DIFC, Dubai, UAE

Email: dpo@elite-co.com

Phone: +971 4 123 4567

UAE Data Office: For regulatory complaints, visit u.ae or contact via their portal.

10. Policy Updates

We may update this Privacy Policy to reflect changes in our practices or legal requirements, including PDPL executive regulations. Material changes will be notified via website posting and email (where we have your consent). We encourage regular review.

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