Effective Date: July 1st, 2025

xptse LLC is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, share, and protect the personal information of contractors and candidates recruited for deployment to our clients in the Middle East, in compliance with the General Data Protection Regulation (GDPR) and the applicable data protection laws of the countries we operate in.

1. Who We Are

Legal Name: xptse LLC

We are a specialized recruitment partner focused on connecting highly skilled professionals with leading consulting and other firms across the Middle East. Our expertise lies in sourcing talent for complex and high-impact projects, ensuring our clients have access to the best minds in the industry.

We act as the data controller for your personal information.

2. How We Use Personal Data

You may interact with xptse LLC for a variety of reasons, including applying for contract roles, providing references, or engaging as a client or vendor. We do not sell your personal data.

Candidates and Contractors

We process your personal data to determine your suitability for specific roles, which may include interviews and skills assessments.

We may process your data to comply with legal obligations, such as verifying your eligibility to work in certain locations or screening against sanction lists.

If a client requires a background check, they act as the data controller for that information. We will notify you if this is required and direct you to the client’s privacy notice.

We may retain interview notes and information you provide during the process to assist in selection and compliance with legal requirements.

If you are successful, your data will be added to your placement file and processed for the duration of your assignment. If not, we may retain your data to evidence compliance with legal requirements or to inform you of future opportunities.

References

If you provide references, please ensure the referee has agreed to be contacted. We may reach out to them to verify your credentials and experience. Referee data is retained for the duration of the hiring process and, if successful, for the duration of the assignment or as required by law.

Clients and Vendors

We process limited personal data (name, business contact details) to manage our business relationship, including communication, invoicing, and contract performance. Data is retained for the contract duration or as required by law.

Website Visitors and General Inquiries

If you contact us via our website or other means, we may collect your name, contact details, and message content to respond to your inquiry. We may use cookies or similar technologies as described in our cookie notice.

3. Personal Data We Collect

Name and contact details (email, phone, address)

Curriculum Vitae (CV)

References from previous employers (if requested)

Other information you provide during the recruitment process

Any additional data required by clients for specific assignments (e.g., criminal records, only with your consent)

We may also collect information from social media or job boards if you interact with us through those channels.

4. Legal Basis for Processing

Legitimate Interests: Recruitment, placement, and business operations

Contractual Necessity: Steps prior to entering into a contract or contract performance

Legal Obligations: Compliance with laws and regulations

Consent: For any sensitive data or where required by law

5. Data Sharing and International Transfers

We may share your data with clients in Saudi Arabia, UAE, and Qatar (mainly consulting firms), and with our cloud service provider for secure storage.

Your data may be transferred from the EU to the Middle East. We use standard contractual clauses or equivalent safeguards to protect your data during international transfers.

When a client conducts a background check, they are responsible for that data as a separate controller. You will be informed if this is required.

We may share de-identified profiles with clients to gauge interest before sharing your full CV with your consent.

6. Data Retention

We retain your data for as long as necessary for recruitment and legal compliance. If there is no meaningful contact for two years, your data will be archived for up to three additional years before deletion, unless a longer period is required by law.

If you request deletion, we will honor your request unless retention is required by law or for legal claims.

7. Data Security

We implement access controls and other organizational measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction.

8. Your Rights

You have the right to:

Access your personal data

Rectify inaccurate or incomplete data

Request erasure (“right to be forgotten”)

Restrict or object to processing

Request data portability

Withdraw consent at any time (where applicable)

Lodge a complaint with a supervisory authority

We may request proof of identity before processing your request and will respond within one month, unless otherwise required by law.

9. Automated Decision-Making

We do not use automated tools or AI for decision-making in our recruitment process.

 

10. Contact Us

For privacy-related queries or to exercise your rights, contact:

Email: privacy@xptse.com

Note: This privacy policy may be updated periodically to reflect changes in our practices or legal requirements. Please review this page regularly.