Privacy Policy

1. Who we are

This website is operated by Sustera People and Purpose Consultancy F.Z.C (“Sustera”, “we”, “us”), a recruitment consultancy for luxury hospitality and food & beverage, holding Business License No. 41519 and operating from Dubai, United Arab Emirates. Sustera is the data controller for the personal information described in this policy.

Contact for all privacy matters: info@susteraconsultancy.com.

2. Who this policy covers

This policy applies to three groups of people: candidates and professionals who share their profile with us; employers and their representatives who enquire about or use our services; and visitors to this website. Where a section applies to only one group, we say so.

3. Information we collect

Candidates and professionals. When you send us your CV or apply for a role through us, we collect the information you provide and the information we need to assess and present you: name and contact details; CV, work history, education, qualifications and languages; nationality and current right to work or visa status, where relevant to a role; current location and willingness to relocate; salary expectations; LinkedIn profile and other professional profiles you share; references, with your agreement; a photograph if your CV includes one; and our own notes from conversations, interviews and assessments. We do not ask for health, religious, political or other sensitive information. If your CV contains such information, we do not use it.

Employers and their representatives. Name, role, employer, business contact details, details of the roles you brief us on, and our correspondence with you.

Website visitors. Information you submit through our forms; technical data such as your IP address, device, browser and pages viewed, collected through analytics only if you accept analytics cookies (see section 11); and the cookie preference you choose.

4. Where the information comes from

Most information comes directly from you, by email, through our forms, in conversation or in interviews. We may also receive information from an employer who briefs us on a role, from a referee you have named, or from someone who refers you to us. We may approach you using information you have made public on a professional network such as LinkedIn; if we do, we tell you who we are and why we are contacting you at the first contact.

5. Why we use your information and on what basis

We use personal information for the following purposes:

• Providing recruitment services: reviewing profiles, matching candidates to roles, presenting candidates to employers, coordinating interviews and offers, and supporting both sides through to the start date.
• Providing career support services: interview coaching, CV optimisation and LinkedIn positioning for professionals who engage us for these services.
• Keeping you in our network: holding your profile so that we can contact you when a suitable role arises.
• Responding to enquiries from employers and professionals.
• Running and improving this website, including analytics where you have consented.
• Meeting legal and contractual obligations, including record keeping, tax, and the terms of our agreements with employers.

Our legal bases are: your consent, which you can withdraw at any time; the performance of a contract or the steps you ask us to take before entering one; our legitimate interests in running a recruitment consultancy, balanced against your rights; and compliance with legal obligations. We process personal information in accordance with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data. Where the law of your country gives you additional rights, including the EU and UK General Data Protection Regulations and Türkiye’s Law No. 6698 on the Protection of Personal Data, we honour those rights.

6. How we share candidate profiles with employers

This is the heart of our service, so we state it plainly:

• We present your profile to an employer only after you have agreed to that specific opportunity. We do not circulate CVs, post profiles, or send your details to employers speculatively.
• Before you agree, we tell you who the employer is, what the role is, and what we intend to share.
• What we share is limited to what the employer needs to assess you for that role: typically your CV, our summary of your experience and suitability, and your availability and expectations. We do not share interview notes about other roles or other employers.
• We do not contact your current employer or your references without your permission.
• Once shared, the employer holds your information under its own privacy obligations. We require employers in our agreements to treat candidate information confidentially and to use it only for the role concerned.

We never sell personal information, and we never share it with third parties for their own marketing.

7. Other recipients

We use a small number of service providers who process information on our behalf and under our instructions: website hosting (Hostinger), form delivery (Formspree), email and document services (Microsoft 365), analytics (Google Analytics 4, only with your consent), messaging with employers (WhatsApp), and our secure candidate database and file storage (Supabase and Amazon Web Services). Each provider is bound by a contract that restricts its use of the information to the service it provides to us.

We may also disclose information where the law requires it, to professional advisers under confidentiality, or in connection with a sale or restructuring of our business, in which case this policy continues to apply.

8. International transfers

We operate from the United Arab Emirates and work with employers and professionals in the GCC, Europe and Türkiye. Your information may therefore be transferred to and processed in those countries, and by our service providers in the European Union, the United Kingdom and the United States. Where a transfer leaves the country in which the information was collected, we rely on the safeguards permitted by applicable law, including contractual protections with the recipient and, for employers, the consent you give to the specific presentation.

9. How long we keep information

• Candidate profiles: for as long as you wish to remain in our network. You can ask us to delete your profile at any time, and we do so promptly.
• Placed candidates: for the duration of the placement and the guarantee period, and afterwards for five years for contractual and tax records.
• Employer records: for the duration of our relationship and afterwards for five years for contractual and tax records.
• Enquiries that do not lead to an engagement: twenty-four months.
• Analytics data: fourteen months, the retention period set in our Google Analytics configuration.

When you ask us to delete your information, we may keep a minimal record of your request so that we do not contact you again.

10. Your rights

Depending on the law that applies to you, you have the right to: ask what information we hold about you and receive a copy; correct inaccurate or incomplete information; ask us to delete your information; withdraw a consent you have given, including the consent to share your profile with a specific employer, without affecting what was done before withdrawal; object to or restrict certain processing; and receive your information in a portable format.

To exercise any of these rights, email info@susteraconsultancy.com. We respond within one month and may ask you to confirm your identity first. If you are not satisfied with our response, you may complain to the supervisory authority in your country, including the UAE Data Office.

11. Cookies and analytics

We use optional analytics cookies to understand how visitors use our website and to improve it. We use Google Analytics 4 for this purpose. Analytics is activated only after you choose “Accept analytics” in our cookie banner; until then, no analytics cookies are set. We do not use advertising cookies, and our advertising-related consent settings remain disabled.

When analytics is enabled, Google Analytics may collect pages viewed, interactions, referral source, device and browser information, and approximate location. We store your cookie preference locally in your browser so that we remember your choice. You can change it at any time through “Cookie settings” on every page; if you withdraw consent, analytics stops and our consent mechanism attempts to remove the Google Analytics cookies set by our website. Google’s own practices are described in its Privacy Policy.

12. Security

We protect personal information with access controls, encryption in transit, restricted access to our candidate database, and confidentiality obligations on everyone who works with us. No method of transmission or storage is completely secure, so we cannot guarantee absolute security, but we review our measures regularly. If a breach affects your information in a way that creates a risk to you, we notify you and the relevant authority as the law requires.

13. Children

Our services are for working professionals and employers. We do not knowingly collect information from anyone under 18.

14. Changes to this policy

We update this policy when our practices or the law change. The date and version at the top show the current edition. Material changes are announced on this page; where the law requires it, we also notify you directly.

15. Contact

Sustera People and Purpose Consultancy F.Z.C · Business License No. 41519 · Dubai, United Arab Emirates
info@susteraconsultancy.com