RECRUITING TALENT - BUILDING TEAMS
Data protection
SEOMNIA – FZCO | As of: June 2026
1. Data Controller
The data controller within the meaning of the General Data Protection Regulation (GDPR) and the data protection law of the United Arab Emirates (Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, "PDPL") is:
SEOMNIA – FZCO [IFZA Business Park, DDP Building A1 – 3641379065, Free Zone, Dubai, United Arab Emirates] Email: office@seomnia.com Website: www.seomnia.com
2. Scope and Applicable Law
This privacy policy applies to the processing of personal data of:
visitors to our website,
candidates within the context of our recruitment services,
contact persons at business clients and prospects (B2B).
For individuals in the European Economic Area (EEA) and Switzerland, processing is governed by the GDPR and the Swiss revFADP respectively. For individuals residing in the United Arab Emirates and the wider GCC region, we additionally observe the requirements of the UAE PDPL (see Section 13). Where both legal frameworks apply, we apply whichever standard of protection is stricter.
3. Categories of Personal Data and Purposes of Processing
3.1 Visiting Our Website
When you access our website, our hosting provider automatically collects certain information (server log files), including IP address, date and time of access, browser type and version, operating system, and the page accessed.
Purpose: Provision of the website, ensuring stability and security.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in the secure operation of the website).
Retention period: Log files are generally deleted after a maximum of 30 days.
Our website is operated via Wix.com Ltd. An adequacy decision by the EU Commission is in place. Further information: https://de.wix.com/about/privacy
3.2 Contacting Us
If you contact us by email, contact form, or LinkedIn, we process the data you provide (name, contact details, content of your inquiry) to handle your request.
Legal basis: Art. 6(1)(b) GDPR (pre-contractual measures) or Art. 6(1)(f) GDPR (legitimate interest in responding to inquiries).
Retention period: Deletion once the inquiry has been fully processed and no statutory retention obligations apply.
3.3 Candidates (Recruitment Services)
As a recruitment agency, we process data of candidates who apply to us, whom we actively approach (active sourcing, e.g. via LinkedIn), or who are referred to us by third parties. In particular, we process:
basic personal data (name, date of birth, contact details),
application documents (CV, references, qualifications, certificates),
information on professional background, salary expectations, availability, mobility,
interview notes and assessments from the placement process,
publicly available professional profile data (e.g. LinkedIn, Xing).
Purposes: Conducting the placement process, matching against open positions of our clients, sharing your profile with potential employers (exclusively following prior coordination with you), communication throughout the application process.
Legal bases:
Art. 6(1)(b) GDPR – performance of pre-contractual measures and the placement relationship at your request;
Art. 6(1)(a) GDPR – your consent, in particular for inclusion in our talent pool beyond the specific placement process and for sharing your profile with a specific client;
Art. 6(1)(f) GDPR – legitimate interest in the initial approach of suitable candidates based on publicly available professional profile data (active sourcing). You may object to this processing at any time.
We only process special categories of personal data (e.g. health data, such as a disability status) where you proactively disclose such information to us, and exclusively on the basis of your explicit consent (Art. 9(2)(a) GDPR). We ask that you only share such data with us where it is relevant to the placement process.
Disclosure to clients: Your profile is shared with specific, named potential employers only following prior consultation with you and with your consent. An anonymized presentation (without identifying details) may be provided for an initial suitability assessment.
Retention period: If a placement process ends unsuccessfully, we retain your data for seven months after conclusion of the process to defend against potential claims under equal treatment law (e.g. AGG in Germany, GlBG in Austria). With your consent, we additionally include you in our talent pool for 24 months; we will request an extension before this period expires. You may withdraw your consent at any time with effect for the future.
3.4 Business Clients and B2B Initial Outreach
We process business contact data of contact persons at companies (name, role, business email address, business phone number, company details) in order to offer our recruitment services and to establish, conduct, and maintain business relationships.
This data is sourced from publicly available sources (company websites, commercial registers, professional networks such as LinkedIn) as well as from B2B databases (see Section 5).
Legal basis: Art. 6(1)(f) GDPR – legitimate interest in direct marketing toward business clients (cf. Recital 47 GDPR) and in maintaining business relationships; for existing contracts, Art. 6(1)(b) GDPR.
Competition law: Initial outreach by email is conducted in compliance with applicable unfair competition law requirements (in particular Section 7 UWG [German/Austrian Act Against Unfair Competition] in Germany and Austria). Every email includes a simple opt-out option; objections are implemented without delay and maintained on an internal suppression list.
Retention period: In the event of an objection, your data will be blocked for marketing purposes. Contractual and invoicing data is subject to statutory retention periods.
Right to object: You may object at any time, without giving reasons, to the processing of your data for direct marketing purposes (Art. 21(2) GDPR) – by emailing office@seomnia.com or via the unsubscribe link included in every message.
4. Recipients and Processors
To provide our services, we engage the following categories of service providers, with whom data processing agreements pursuant to Art. 28 GDPR are in place where required:
Wix.com Ltd., website hosting Google Cloud EMEA Ltd. / Google LLC (Google Workspace), email, documents, calendar Manatal Co., Ltd., applicant tracking system (ATS) Apollo.io (ZenLeads Inc.), B2B contact database, email distribution Dripify Ltd., LinkedIn campaign management LinkedIn Ireland Unlimited Company, professional network, communication
Further recipients may include: potential employers (see Section 4.3), tax and legal advisors, banks and payment service providers, as well as authorities, where legally required.
US service providers certified under the EU-U.S. Data Privacy Framework are considered to provide an adequate level of protection in this respect; otherwise, we enter into EU Standard Contractual Clauses (Art. 46(2)(c) GDPR).
5. Data Transfers to Third Countries
As SEOMNIA – FZCO is based in the United Arab Emirates, your data is processed in a third country within the meaning of the GDPR for which no adequacy decision by the EU Commission exists. We ensure an adequate level of protection through:
processing in systems with a data location in the EU/EEA, where available;
EU Standard Contractual Clauses with the service providers we engage;
technical and organizational measures (see Section 9);
where necessary, transfers on the basis of Art. 49(1)(b) GDPR (necessity for the performance of a contract that exists with you or is being entered into – in particular the placement relationship).
Upon request, we will provide you with information on the relevant safeguards in place.
6. Cookies and Tracking
Our website uses technically necessary cookies required for the operation of the site (legal basis: Art. 6(1)(f) GDPR or Section 165(3) TKG 2021 / Section 25(2) TDDDG [German/Austrian telecommunications and digital services laws]). Non-essential cookies (e.g. for statistics or marketing purposes) are only used with your consent via our cookie banner (Art. 6(1)(a) GDPR). You may withdraw your consent at any time via the cookie settings.
As part of our email communications, we use tracking that indicates to us whether emails have been opened and links clicked (technically implemented via a dedicated subdomain). The legal basis is our legitimate interest in measuring the effectiveness of our business communications (Art. 6(1)(f) GDPR); you may object to this at any time.
7. Retention Period (Summary)
Unless stated otherwise above, we retain personal data only for as long as necessary for the stated purposes or for as long as statutory retention obligations apply (e.g. tax and commercial law retention periods of up to 7 or 10 years). The data is subsequently deleted or anonymized.
8. Data Security
We implement appropriate technical and organizational measures to protect your data, in particular transport encryption (TLS), access restrictions based on the need-to-know principle, two-factor authentication for our systems, and contractual confidentiality and data security obligations imposed on all service providers.
9. Your Rights Under the GDPR
You have the following rights with respect to your personal data:
right of access (Art. 15 GDPR),
right to rectification (Art. 16 GDPR),
right to erasure (Art. 17 GDPR),
right to restriction of processing (Art. 18 GDPR),
right to data portability (Art. 20 GDPR),
right to object to processing based on Art. 6(1)(f) GDPR (Art. 21 GDPR), at any time and without giving reasons in the case of direct marketing,
right to withdraw consent given, with effect for the future (Art. 7(3) GDPR).
To exercise your rights, an informal message to office@seomnia.com or to our EU representative (Section 2) is sufficient.
Right to lodge a complaint: You have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU member state of your habitual residence or place of work.
10. No Automated Decision-Making
No automated decision-making, including profiling within the meaning of Art. 22 GDPR, takes place. Placement decisions are always made by humans.
11. Obligation to Provide Data
You are under no statutory or contractual obligation to provide your data. However, without the information required for the placement process, we are unable to consider you for placement procedures.
12. Supplementary Information for Individuals in the United Arab Emirates (UAE PDPL)
For data subjects residing in the United Arab Emirates, Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("PDPL") additionally applies. Under this law, you are in particular entitled to:
the right to be informed about the processing of your data and to receive a copy thereof,
the right to rectification and erasure,
the right to restriction of processing and to object, including objection to direct marketing,
the right to data portability,
the right not to be subject to a decision based solely on automated processing,
the right to lodge a complaint with the competent authority (UAE Data Office).
We process personal data under the PDPL only on the basis of your consent or a legally permitted exception (in particular for the performance of a contract or to safeguard legitimate interests, where permissible). Transfers of personal data from the UAE to third countries are made only under the conditions set out in Articles 22 and 23 of the PDPL (adequate level of protection or appropriate contractual safeguards). Requests under the PDPL should be directed to: office@seomnia.com
13. Changes to This Privacy Policy
We will update this privacy policy as the legal situation or our processing activities change. The version published on this website at any given time shall apply.