1. Information We Collect

We collect personal information to provide our career counseling services and improve your experience. The types of information we may collect include:

1.1 Information You Provide Directly

• Personal Details: Name, email address, phone number, postal address, date of birth, and other contact information.
• Professional Information: Resume details, employment history, educational background, skills, certifications, and career goals.
• Payment Information: Billing details, credit card information, or other payment-related data for services rendered.
• Communication Data: Information provided during consultations, emails, feedback forms, surveys, or other interactions.
• Recordings: Audio or video recordings of career counseling sessions, phone calls, or virtual meetings, where explicitly disclosed and consented to (see Section 4 for details).

1.2 Information Collected Automatically

• Website Usage Data: IP address, browser type, operating system, device information, pages visited, time spent on our website, and referring URLs, collected via cookies and similar technologies (see Section 7).
• Analytics Data: Aggregated data on user behavior to improve our services, collected through tools like Google Analytics.

1.3 Information from Third Parties

• Third-Party Platforms: Information from job boards, social media platforms (e.g., LinkedIn), or other services when you link them to our platform or share data with us.
• Referrals: Information provided by third parties, such as employers or colleagues, with your consent.

2. How We Use Your Information

We use your personal information to provide, improve, and personalize our career counseling services. Specific purposes include:

• Service Delivery: Conducting career counseling sessions, providing job search assistance, resume reviews, interview coaching, and other professional services.
• Communication: Responding to inquiries, sending appointment reminders, and providing updates about our services.
• Recordings: Using recorded calls or meetings for quality assurance, training, compliance, or to document agreed-upon career plans, with your explicit consent.
• Billing and Payments: Processing payments for services and managing billing disputes.
• Website Improvement: Analyzing website usage to enhance user experience and functionality.
• Marketing: Sending promotional materials, newsletters, or event invitations, where permitted and with your consent (you may opt out at any time).
• Legal Compliance: Fulfilling legal obligations under UAE PDPL, GDPR (where applicable), or other regulations, such as tax reporting or responding to lawful requests.

3. Legal Basis for Processing

We process your personal data based on the following legal grounds, as applicable under UAE PDPL and GDPR:

• Consent: When you explicitly agree to data processing, such as for call recordings or marketing communications.
• Contractual Necessity: To fulfill our contract with you, such as providing career counseling services.
• Legitimate Interests: For purposes like improving our services, ensuring quality, or preventing fraud, where such interests do not override your rights.
• Legal Obligation: To comply with applicable UAE or EU laws, such as PDPL or GDPR.

GDPR applies only if we process personal data of EU/EEA residents, offer services to them, or monitor their behavior. If GDPR does not apply, we process data under PDPL or other UAE laws.

4. Recording of Calls and Meetings

As part of our career counseling services, we may record phone calls, virtual meetings, or in-person sessions to ensure quality, train our staff, and maintain accurate records of your career plans. Key details include:

• Consent: Recordings are made only with your explicit consent, requested at the start of the session or call. You may withdraw consent at any time.
• Purpose: Recordings are used for quality assurance, staff training, compliance with professional standards, and to document agreed-upon actions or recommendations.
• Storage and Security: Recordings are stored securely with restricted access and encrypted to protect your privacy.
• Retention: Recordings are retained for 1 year for quality assurance or as agreed with you, then securely deleted unless required for legal purposes.
• Access: You may request access to or deletion of recordings, subject to applicable laws (see Section 9).

If you do not consent to recordings, we will provide alternative methods to deliver our services, such as non-recorded sessions.

5. How We Share Your Information

We do not sell your personal information. We may share your data with third parties only in the following circumstances:

• Service Providers: With trusted third-party providers who assist us in delivering services (e.g., payment processors, cloud storage providers, or analytics tools), under strict confidentiality agreements compliant with PDPL and GDPR (if applicable).
• Professional Partners: With your consent, we may share relevant information (e.g., resumes) with employers, job boards, or training providers to support your career goals.
• Legal Requirements: When required by law, such as in response to a court order, subpoena, or regulatory request from UAE or EU authorities.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity, with safeguards compliant with PDPL and GDPR (if applicable).

6. Data Security

We implement robust technical and organizational measures to protect your personal information, including:

• Encryption of sensitive data during transmission and storage.
• Access controls to limit data access to authorized personnel only.
• Regular security assessments and updates to our systems.
• Secure storage of call and meeting recordings with restricted access.

These measures align with PDPL and GDPR requirements. Despite these efforts, no system is completely secure. In the unlikely event of a data breach, we will notify affected individuals and authorities as required by PDPL (within UAE-specified timelines) or GDPR (within 72 hours, if applicable).

7. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance your experience and analyze usage. For details on how we use cookies, please review our separate Cookie Policy. If you are in the EU/EEA, we obtain your consent for non-essential cookies as required by GDPR.

8. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this policy, including:

• Client Data: Retained for the duration of our engagement and up to 5 years after the last interaction, unless otherwise required by UAE or EU law.
• Recordings: Retained for 1 year for quality assurance or as agreed with you, then securely deleted.
• Website Data: Usage data is retained for 2 years for analytics purposes.

Data no longer needed is securely deleted or anonymized, in line with PDPL and GDPR (if applicable).

9. Your Rights

Under UAE PDPL, and GDPR (if applicable), you may have the following rights regarding your personal data:

To exercise these rights, contact us at privacy@mycareerpath.com. We will respond within the timeframes required by PDPL or GDPR (e.g., 30 days under GDPR, if applicable).

10. International Data Transfers

If you are located outside the UAE, or if we process EU/EEA data, your personal information may be transferred to or processed in countries with different data protection laws. For EU/EEA data, we use safeguards like Standard Contractual Clauses (SCCs) to comply with GDPR. For UAE data, we ensure compliance with PDPL cross-border transfer rules.

11. Third-Party Links

Our website may contain links to third-party sites (e.g., job boards or social media platforms). We are not responsible for their privacy practices. We encourage you to review their privacy policies before sharing personal information.

12. Children's Privacy

Our services are not directed to individuals under 16. We do not knowingly collect personal information from children. If we become aware of such data, we will take steps to delete it.

13. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. Updates will be posted on our website, and we will notify you of significant changes via email. The "Last Updated" date below indicates the effective date of the current policy.