This Privacy Notice is part of the use of the LIGHTHOUSE Connections DMCC Web site at https://lighthouse-corp.com/.
Updated: November 2020
LIGHTHOUSE Connections DMCC’ Notice provides a framework of understanding about the processing of personal data collected by LIGHTHOUSE Connections DMCC, its subsidiaries, and affiliates listed here (as applicable, hereafter separately and/or jointly referred to as the “Data Controller”). The personal data collected by the Data Controller will be controlled and processed in accordance with the terms of this Privacy Notice.
This Privacy Notice applies to (1) our candidates for the position and the recipients of our professional services, (2) our associates, who are persons we place for or on assignment with one of our clients, or individuals to whom we provide relocation or career transition services, (3) users of websites and applications listed here (the “Pages”), and (4) representatives of our business partners, customers, and vendors. This Privacy Notice does not apply to our headquarters or to employees of the in-country staff, who are individuals employed by LIGHTHOUSE Connections DMCC and who work directly for LIGHTHOUSE Connections DMCC and not directly for a LIGHTHOUSE Connections DMCC client.
This Privacy Notice describes the types of personal data or personal information we collect, how we use the information, how we process and protect the information we collect, how long we store it, with whom we share it, to whom we transfer it, and the rights individuals may exercise regarding our use of their personal data. We also describe how to contact us about our privacy practices and to exercise your rights. In general, our privacy practices comply with local and international laws and regulations as applicable.
WHAT INFORMATION DO WE COLLECT?
We collect your personal information in a variety of ways, such as through our Pages and social networks; at our events and by phone and fax; through job applications and in-person recruitment, and our interaction with customers and suppliers. We may collect the following types of personal information (as permitted by local law):
- contact information (such as name, mailing address, email address, and phone number);
- user name and password when you register on our Sites;
- information you provide about friends or other people you want us to contact (the Data Controller assumes that such people have previously given their permission for such communication); and
- other information you provide to us, such as in surveys or through the “Contact Us” feature on our Pages.
In addition, if you are an associate or candidate for a position and apply for a job or create an account to apply for a job, we may collect the following personal information (as permitted by local law):
- employment and academic history;
- language and other job skills;
- ID card number or another government-issued identification number;
- date of birth;
- bank account information;
- nationality and authorization to work in the country;
- information provided by references; and
- the information included in your resume, information you provide about your professional interests, and other information regarding your qualifications for employment.
We may also collect the following personal data upon receiving your explicit consent (where required by applicable law):
- Disability and health-related information; and
- drug test results, criminal and other background checks.
In addition, we may collect information that you provide to us regarding other individuals, such as emergency contact information.
HOW DO WE USE THE INFORMATION WE COLLECT?
The Data Controller collects and uses the data collected for the following purposes (as permitted by local law):
- providing staffing solutions and connecting people to employment;
- create and manage online accounts;
- process payments;
- managing our relationships with business partners, customers, and suppliers;
- to the extent permitted by law and consistent with this Privacy Notice, send promotional materials, job alerts, and other communications;
- to the extent permitted by law, communicate and manage participation in special events, promotions, programs, offers, surveys, contests, and market research;
- respond to inquiries and complaints submitted by individuals;
- operate, evaluate, and optimize our business (including developing, improving, analyzing, and advancing our services; managing our communications; performing data analysis; and optimizing accounting, auditing, and other internal functions);
- protect against, attempt to identify and prevent fraud and other illegal activities, claims and other liabilities; and
- comply with and enforce applicable laws, relevant industry standards, contractual obligations, and our policies.
All processes will be carried out on sufficient legal grounds that can fall into several categories, including
- the consent or explicit consent of the owner of the information, when required by applicable law;
- ensuring that we comply with legal or contractual requirements, or with a requirement to enter into a contract (e.g., processing your personal data to ensure that your salary and taxes are paid properly); or
- that is essential and necessary for the legitimate interests of the Data Controller, as described in more detail below (for example, allowing access to a website to provide the services offered).
In addition to the activities listed above, if you are an associate or candidate for a position and apply for a position or create an account to apply for a position, as permitted by local law, we use the information described in this Privacy Notice for the following purposes:
- To provide you with job opportunities;
- To provide you with Human Resources services, including administration of benefit programs, payroll, results in management, and investigations or disciplinary actions;
- Provide you with additional services, such as training, career counseling, and transition services;
- Assessing your suitability as a candidate for a position and your qualifications as an associate for a position; and
- Analyzing data, such as (i) our candidate and job associate database; (ii) assessing individual performance and capabilities, including job skills qualifications; (iii) identifying skill shortages; (iv) using the information to match people to potential opportunities; and (v) analyzing data segmentation (trends in hiring practices).
- We may also use the information in a variety of ways, so we provide specific notice at or before the time of collection.
USE OF AUTOMATED METHODS FOR DATA COLLECTION
When you visit our Pages, we may collect certain information by automated means, such as cookies, web beacons, and web server logs. The information we collect in this way includes IP addresses, unique device identifiers, browser features, device features, operating system, language preferences, referring URLs, information about actions taken on our Pages, dates and times of visits to our Pages, and other usage statistics.
A “cookie” is a file that Web pages send to a visitor’s computer or other device connected to the Internet to uniquely identify the visitor’s browser or to store information or browser settings.
A “web beacon,” also known as an Internet tag, pixel tag, or invisible GIF file, links web pages to web servers and their cookies and is used to transmit information collected through cookies to a web server.
Using these automated collection methods, we may obtain “visitor data”, which is a record of the links and other content that a visitor clicks on when browsing a website.
Our Sites use these types of cookies:
a) Technical Cookies: Technical cookies are those used exclusively to “carry out the transmission of a communication on an electronic communications network, provided that this is strictly necessary for the information society service provider that has been expressly requested by the contracting party or the user to provide such service.
b) Profile Setting Cookies: Profile setting cookies are intended to create user profiles. They are used to send advertising messages in line with the preferences shown by the user while browsing. In view of the highly invasive nature of these cookies, with respect to the private sphere of users, local and European legislation requires users to be properly informed about their use in order to give their valid consent.
HOW DO WE COLLECT INFORMATION BY AUTOMATED MEANS?
Vendors of third-party applications, tools, widgets, and plug-ins on our Pages, such as shared social networking tools, may also use automated means to collect information about your interactions with these features. This information is collected directly by the feature providers and is subject to the policies or privacy notices of these providers. Subject to applicable law, LIGHTHOUSE Connections DMCC is not responsible for the information practices of these vendors.
HOW DO WE USE INFORMATION COLLECTED THROUGH AUTOMATED MEANS?
We use information collected through cookies, web beacons, pixels, web server logs, and other automated means for purposes such as
- To personalize the use of our Pages by our users;
- sending customized content tailored to the interests of our users and the way our users use our Pages; and
- manage our Pages and other aspects of our business.
We also use third-party analytical services on our Sites, such as Google Analytics and Adobe Omniture. The analytical service providers that manage these services use technologies such as cookies, web server logs, and web beacons to help us analyze your use of our Sites. The information collected through these means (including the IP address) may be disclosed to these analytical service providers and other relevant third parties who use the information, for example, to evaluate the use of the Pages.
ADVERTISING BASED ON PROFILES AND INTERESTS
On our Pages, we may collect information about your online activities to provide you with advertising regarding products and services customized to your individual interests. We may also obtain information for these purposes from third party websites to which our advertisements have access.
You may see LIGHTHOUSE Connections DMCC advertisements on other websites because we contract with third-party advertising networks. Through such ad networks, we may target our messages to users through demographic, interest-based, behavioral, and contextual means. Through the ad networks, we can track your online activities over time by gathering information through automated means, including through the use of third-party cookies, web server logs, pixels, and web beacons. The networks use this information to show you advertising that may be tailored to your particular interests and previous activity. The information collected by our advertising networks on our behalf includes data about your visits to the websites that provide services to LIGHTHOUSE Connections DMCC, such as the pages or advertisements you view and the actions you take on those websites. This data collection takes place both on our Sites and on the sites of third parties that participate in these advertising networks. This process also helps us track the effectiveness of our marketing efforts. For additional information on how to opt-out of interest-based advertising, please visit aboutads.info/choices/. Where required by applicable law, we will obtain your consent before using your information for interest-based advertising.
Our Pages are not designed to respond to “no-tracking” signals from browsers.
Information collected through third-party plug-ins and widgets on the Pages (such as information regarding your use of a shared social networking tool) is collected directly by the plug-ins and widget providers. This information is subject to the privacy policies of the plug-in and widget vendors, and LIGHTHOUSE Connections DMCC is not responsible for the information practices of these vendors.
Google Analytics: tools.google.com/dlpage/gaoptout
Adobe Analytics: adobe.com/privacy/analytics.html#1
The Data Controller may process personal data for legitimate business purposes, which include some of the following:
- when the process allows us to improve, modify, personalize or otherwise optimize our services/our communications for the benefit of our customers, candidates, and partners;
- to identify and prevent fraud;
- to improve the security of our network and information systems;
- to better understand how people interact with our websites;
- for direct marketing purposes;
- to send you postal communications that we believe will be of interest to you; and
- to determine the effectiveness of advertising and promotional campaigns.
Whenever we process data for these purposes, we will ensure that we consider and take into account your rights. You have the right to object to such processing, and may do so by contacting us as described below. Please note that if you exercise your right to object, this may affect our ability to carry out and provide the services to you.
HOW DO WE PROCESS AND PROTECT PERSONAL INFORMATION?
We process the personal information we collect, as well as that collected by automated means, for the purposes specified above and for a specified period of time, which complies with our internal retention policy, to ensure that personal data is not kept longer than necessary.
We maintain administrative, technical, and physical safeguards designed to protect the personal data you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. To ensure sufficient security and confidentiality of personal data, we apply the following security measures where appropriate:
- Encryption of data in transit;
- Strong user authentication controls;
- Strengthened network infrastructure; and
- Network monitoring solutions.
HOW LONG DO WE STORE THE DATA WE COLLECT?
We store the personal data we collect in our systems in such a way that we can identify the data subjects for no longer than is necessary for a view of the purposes for which the data was collected, or for as long as the data is processed.
The need to retain the personal data collected, in order to provide the specified services to the user;
The legal interest of the Data Controller, as specified in the above purposes; and
The existence of specific legal obligations to perform the related processing and storage necessary for the specified periods.
WHAT INFORMATION DO WE SHARE?
We do not disclose the personal information we collect about you, except as set forth in this Privacy Notice or in separate notices provided in connection with particular activities. We may share personal information with providers who perform services on our behalf based on our instructions. We do not authorize these providers to use or disclose the information except as necessary to provide the services on our behalf, or to comply with legal requirements. In addition, we may share your personal data (i) with our subsidiaries and affiliates; (ii) if you are a job applicant, with clients who may have job opportunities available or interest in placing our job applicants; and (iii) with third parties with whom we work, such as consultants and subcontractors in the job placement industry, to get you a job.
In addition, we may disclose your personal information (i) if required by law or legal process; (ii) to law enforcement or various government officials in connection with a lawful request for disclosure; and (iii) when we believe that disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent activity or illegal activity. We also reserve the right to transfer your personal information in our possession in the event of a sale or transfer of all or a portion of our business or assets (including in the event of a restructuring, dissolution, or liquidation).
We may transfer the personal information we collect about you to countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country where you originally provided personal data. When we transfer your information to other countries, we will protect the data as specified in this Privacy Notice and such transfers will comply with applicable law.
YOUR RIGHTS AS A DATA SUBJECT
When authorized by applicable law, the owner of the information may exercise certain specific rights, such as
Right of access: The holder of the information can access his personal data to verify that his personal data are processed according to the law.
Right to data portability: The information owner may demand the portability of the data, which means that the information owner may receive the personal data it originally provided in a structured and commonly used format, or may demand that the data be transferred to another data controller.
Right to limit processing: The data subject may demand that the Data Controller restrict the processing of the data subject.
Right to suppression: The information owner may demand that the Data Controller suppress his information and no longer process such data.
Right of rectification: The holder of the information may demand the correction of any incorrect or incomplete data held, in order to protect the accuracy of such information and to adapt it to the data processing.
Right of objection: The holder of the information who provides personal information to the Data Controller may, at any time, object to the processing of the data for various reasons, without having to justify his decision.
Right not to be subject to automated individualized decisions: The information holder may demand not to be subject to a decision based solely on automated processing, including profiling if such a profile has a legal effect on the information holder or significantly affects him/her.
Right to File a Complaint with the Supervisory Authority: Each information holder has the right to file a complaint with the appropriate supervisory authority.
UPDATES TO OUR PRIVACY NOTICE
This Privacy Notice (including any supplements) may be updated periodically to reflect changes in our privacy practices and updates as required by law. We will notify you of any significant changes by posting a prominent announcement on our Pages, indicating at the top, when the most recent update was made.
HOW TO CONTACT US?
If you have any questions or comments regarding this Privacy Notice, or if you would like to exercise any of your rights, please contact
LIGHTHOUSE Connections DMCC
Dubai : United Arab Emirates