Client Privacy Policy

 

Effective Date: 01/04/2023

1. Purpose of This Document

This Privacy Policy explains how The Free Spirits FZCO (“we”, “us”, “our”) collects, uses, stores, and protects your personal data when you visit www.worldwidenanny-uk.com or engage with our recruitment services in the UAE.

As the data controller, The Free Spirits FZCO is responsible for ensuring your personal data is handled in accordance with applicable data protection regulations in the United Arab Emirates, including the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL).

This notice informs you of how and why your personal data will be used during our recruitment process and how long it will be retained. Please read this notice carefully and check back periodically for updates.

2. Data Protection Principles

We are committed to ensuring that your personal data is:

  • Processed fairly, lawfully, and transparently
  • Collected for specified, explicit, and legitimate purposes
  • Adequate, relevant, and limited to what is necessary
  • Accurate and kept up to date
  • Retained only as long as necessary for the intended purposes
  • Processed securely to protect against unauthorized access, loss, or damage

3. Types of Personal Information We Collect

In connection with your nanny or domestic staff search, we may collect and store the following categories of personal information:

  • Full name, title, address, contact numbers, and email address
  • Details of your domestic staffing requirements
  • Information about your family, nationality, children, and household preferences
  • Languages spoken at home
  • Invoices or receipts issued by us to you
  • This information is necessary to assist you in finding candidates who meet your specific requirements.

4. How We Collect Your Personal Data

We collect your personal information directly from you when you:

  • Contact us via phone, email, website forms, or in person
  • Interact with our consultants or submit a job description
  • We may also receive limited information from candidates who name you as a potential employer or referee.

5. Purpose and Use of Your Information

We process your personal data to:

  • Understand your recruitment needs
  • Identify and propose suitable candidates
  • Facilitate interviews and candidate introductions
  • Maintain accounting records and comply with legal obligations
  • We rely on our legitimate interests to carry out these recruitment-related activities.

6. Invoices and Accounting

We collect your billing information and issue invoices as part of our legal and financial obligations. This includes retaining data necessary to comply with UAE accounting laws and for potential audit purposes.

7. Data Sharing

We may share your information with relevant third parties including:

  • Potential candidates to facilitate interview arrangements
  • Third-party service providers who assist with recruitment services
  • Regulatory bodies (where legally required, e.g., for audit or compliance)

We do not allow third-party service providers to use your data for their own purposes. They are only permitted to process your data under our strict instructions and with confidentiality agreements in place.

8. Data Security

We take data security seriously and implement appropriate technical and organisational measures to protect your personal information against unauthorized access, loss, misuse, or alteration. Access is limited strictly to staff and third parties who need the data for service-related purposes.

In the event of a data breach, we will notify you and any applicable authority in accordance with UAE law.

9. Data Retention

We retain your personal information for up to 24 months after the conclusion of your search, unless a longer retention period is required or permitted by law.

If we wish to retain your data for a longer period, we will request your explicit consent.

10. Your Rights Under UAE Law

Subject to applicable data protection laws, you have the right to:

  • Request access to your personal data
  • Request correction of any incorrect or incomplete data
  • Request deletion of your data (where processing is no longer necessary)
  • Object to the processing of your data
  • Request restriction of processing
  • Request data portability (where applicable)
  • To exercise any of these rights, please contact:

Sonia Mateos

contact@worldwidenanny-uk.com

Subject Line: “Data Access Request”

11. Right to Withdraw Consent

You have the right to withdraw your consent for the processing of your personal information at any time. To do so, please

email: contact@worldwidenanny-uk.com

Subject Line: “Withdrawal of Consent”

Once your request is received, we will stop processing your data (unless otherwise legally required) and securely delete it in line with our retention policy.

12. Contact Us

If you have any questions about this Privacy Policy or how we handle your data, please contact:

The Free Spirits FZCO

contact@worldwidenanny-uk.com

www.worldwidenanny-uk.com

Registered Office Address:

Dubai Digital Park, Building A1

Dubai Silicon Oasis

Dubai, United Arab Emirates

WHAT IS THE PURPOSE OF THIS DOCUMENT?

The privacy policy explains what personal information we collect when you visit the www.worldwidenanny-uk.com website, and how we use your data.
Worldwide Nanny’s Limited is a “Data controller”. Therefore, we are responsible for the way we hold and use personal data about you, as you are applying for positions that we advertise on behalf of our clients. It makes you aware of how and why your personal data will be used during the recruitment process and how long it will be retained for.

We are required to notify you of this information, under the new General Data Protection Regulation (EU) 2016/679) (GDPR) which replaces the Data Protection Regulation (Directive 95/46/EC). Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.

DATA PROTECTION PRINCIPLES

Personal data shall be:

  • processed fairly and lawfully
  • obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes.
  • adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.
  • accurate and, where necessary, kept up to date.
  • processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
  • processed in accordance with the rights of data subjects under this Act.
  • Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
  • not be transferred to a country or territory outside the European Economic Area unless that country or territory
  • ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

THE KIND OF INFORMATION WE HOLD ABOUT YOU

In connection with your Nanny search, for domestic staff recruitment purposes, we will collect, store and use the following categories of personal information about you:

• The information you have provided to us on the phone, by email or filling our online form including but not limited to, name, title, address, home and personal telephone number and personal email address
• Description of the services you require and you provided to us
• Information about your family, your nationality children and interests you provided to us;
• Languages spoken at home
• Invoices and / or receipts issued by us to you.

The information provided by you are necessary for us to assist you with your search and match candidates with your requirements.

HOW IS YOUR PERSONAL INFORMATION COLLECTED?

What information is being collected?

We collect your personal data (such as name and contact details, language spoken at home) when we receive it directly from you such as where you contact us proactively (by phone, email, in person) or where you connect with our consultants on business networking sites or through our consultant’s business development activities more generally. We may seek more information about you from analysing online and offline media and we may be supplied with information about you by Candidates (for example when you are named as a referee).

How do we collect your information?

From you, from the job description you provide us with, email and phone

Why do we collect your information?

Legitimate interest, to understand your recruitment requirements, arrange interviews and find a suitable candidate for you

HOW WE WILL USE AND SHARE INFORMATION ABOUT YOU

To enable Worldwide Nanny to contact you and arrange interviews, to enable candidates to attend interview with you and to find you a suitable candidate matched to your requirement

Invoices
How do we collect your information?

From us to you

Why do we collect your information?

Legitimate interest, for us to meet our HMRC obligations

How do we use and share your information?

To enable us to comply with any accounting requirements including audits by HMRC and any other statutory bodies

AUTOMATED DECISION-MAKING

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

DATA SHARING

Why might you share my personal information with third parties?

We will share your information to potential candidates for the purpose of securing you a Nanny/Governess/Maternity Nurse or any other Domestic staff as set out on the registration form.

We will only share your personal information with the following third parties for the purposes of processing your search:

  • Assist you with your candidate search;

  • Enable us to match candidates that may be suitable and are able to provide the services required

  • Arrange interviews with candidates who may be suitable for a position with you;

  • Meet our own obligations to HMRC and other regulatory bodies.

We do not allow our third-party service providers to use your personal data for their own purposes.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

DATA RETENTION

How long will you use my information for?
We will retain your personal information for a period of 24 months after we have communicated to you our decision about whether to appoint you. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.
If we wish to retain your personal information on file we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your rights in connection with personal information
Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected..
    Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
    Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Sonia Mateos via contact@worldwidenanny-uk.com with subject line “GDPR Requests” in writing.

RIGHT TO WITHDRAW CONSENT

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected..
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.

want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Sonia Mateos via contact@worldwidenanny-uk.com with subject line “GDPR Requests” in writing.

When you contact Worldwide Nanny to help you with your nanny or domestic staff , you provided consent on the date of registration with us to process your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact Sonia Mateos via contact@worldwidenanny-uk.com with subject line “GDPR Requests”. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information and, subject to our retention policy, we will dispose of your personal data securely.