Privacy Policy

1. Overview

CMS Holoul DMCC ("CMS Holoul", "we", "our", or "us") is committed to protecting the privacy and security of personal information we collect in the course of our business operations. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our services, or interact with us in any capacity.

CMS Holoul is a UAE-registered company operating under the regulatory oversight of relevant UAE authorities. Our operations span the UAE, Egypt, Jordan, Lebanon, and India, and we are committed to complying with applicable data protection laws in each jurisdiction, including the UAE Federal Law No. 45 of 2021 on Personal Data Protection (PDPL).

2. Information We Collect

We collect information in the following ways:

Information You Provide Directly

• Contact & Identity: Name, email address, phone number, job title, and company name when you fill in contact or enquiry forms.
• Recruitment Data: CV/resume, work history, educational background, references, and application details submitted through our careers portal or email.
• Client Data: Business and contractual information provided during onboarding or the delivery of services.
• Communications: Messages, emails, and feedback you send to us directly.

Information Collected Automatically

• Usage Data: IP address, browser type, referring URL, pages visited, time and date of visit, and time spent on pages.
• Device Information: Device type, operating system, and browser version.
• Cookies & Tracking: We use cookies and similar technologies. See Section 8 for details.

Information from Third Parties

• Business partners and referral sources who share information about potential clients or employees.
• Publicly available sources, such as LinkedIn and company registries, for due diligence purposes.

3. How We Use Your Information

We use personal information for the following purposes:

• To provide, operate, and improve our business process outsourcing and collections services.
• To respond to enquiries, support requests, and communications.
• To process job applications and manage recruitment activities.
• To send service-related communications, updates, and newsletters (where consent has been given).
• To comply with legal and regulatory obligations in the UAE and other jurisdictions where we operate.
• To detect, prevent, and address fraud, security incidents, and misuse of our systems.
• To conduct business analytics, internal reporting, and service improvement initiatives.
• To fulfil contractual obligations with clients and business partners.

4. Sharing of Information

CMS Holoul does not sell, rent, or trade personal data. We may share information with:

• Affiliated Entities: Our subsidiaries and group companies operating in the regions where we deliver services.
• Service Providers: Trusted third-party vendors who assist in IT infrastructure, hosting, payment processing, or HR systems, bound by confidentiality agreements.
• Client Partners: Where necessary to fulfil a specific service contract, and only to the extent required by that contract.
• Regulatory & Legal Authorities: When required by law, court order, or governmental regulation in any jurisdiction where we operate.
• Professional Advisors: Legal, financial, or compliance advisors engaged by CMS Holoul, under strict confidentiality.

All third parties we share data with are contractually required to protect your information and are prohibited from using it for purposes other than those specified.

5. Data Retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by law:

• Client data: Retained for the duration of the contract plus 7 years for legal compliance.
• Recruitment data: Retained for 2 years from the date of application, unless extended consent is given.
• Website usage data: Retained for 12 months in aggregate, anonymised form.
• Marketing communications: Retained until you withdraw consent or unsubscribe.

6. Data Security

CMS Holoul is ISO 27001 and ISO 27002 certified and implements industry-standard security measures to protect personal data, including:

• Encryption of data in transit (TLS/SSL) and at rest.
• Access controls and multi-factor authentication for internal systems.
• Regular security audits, penetration testing, and vulnerability assessments.
• Staff training on data protection and information security policies.
• Incident response procedures in the event of a data breach.

While we take all reasonable precautions, no transmission over the internet is 100% secure. We encourage you to keep your communications with us secure and to contact us immediately if you suspect unauthorised access.

7. Your Rights

Subject to applicable law, you have the following rights with respect to your personal data:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete information.
• Deletion: Request erasure of your personal data, subject to legal retention requirements.
• Objection: Object to the processing of your personal data for direct marketing purposes.
• Portability: Receive your personal data in a structured, commonly used format.
• Withdrawal of Consent: Withdraw consent at any time where processing is based on consent.

To exercise any of these rights, please contact us at privacy@cmsholoul.com. We will respond within 30 days of your request.

8. Cookies

Our website uses cookies and similar tracking technologies to enhance your experience. The types of cookies we use include:

• Essential Cookies: Necessary for the website to function correctly. These cannot be disabled.
• Analytics Cookies: Help us understand how visitors interact with our website (e.g., Google Analytics).
• Marketing Cookies: Used to deliver relevant advertisements. These are only set with your consent.

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect website functionality.

9. Children's Privacy

Our website and services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that a child has provided us with personal data, we will take steps to delete such information promptly. If you believe a child has submitted personal data to us, please contact us immediately.

10. International Data Transfers

Given our presence across the UAE, Egypt, Jordan, Lebanon, and India, data may be transferred between our offices internationally. Where data is transferred outside the UAE, we ensure adequate safeguards are in place in compliance with UAE PDPL and equivalent regulations, including contractual clauses and data processing agreements with receiving entities.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in law, our practices, or the services we offer. We will post the revised policy on this page with an updated "Last Updated" date. We encourage you to review this policy periodically. Material changes will be communicated through our website or by direct notification where appropriate.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer: