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Henoto Worldwide

Candidate Privacy Notice

Henoto Middle East Events LLC

Last updated: 05/11/2026

1. Introduction

This Candidate Privacy Notice (the "Notice") describes how Henoto Middle East Events LLC ("Henoto MEE", "we", "us", "our") processes the personal data of candidates who apply for a position with us, whether through direct submission, our website, third-party job platforms, recruitment agencies, or referrals.

This Notice is provided in compliance with:

  • UAE Federal Decree-Law No. 45/2021 on the Protection of Personal Data (the "PDPL") and its Implementing Regulations, where applicable;
  • For candidates residing in the European Economic Area (EEA), Regulation (EU) 2016/679 (the "GDPR") and applicable national data protection laws;
  • For candidates residing in the United Kingdom, the UK GDPR and the Data Protection Act 2018.

This Notice is specific to the recruitment and selection activities of Henoto MEE. Other entities of the Henoto Group may have separate privacy notices governing their own recruitment activities.

2. Data Controller

The Data Controller is:

Henoto Middle East Events LLC
One Space Thuraya Business Center
Magnum Opus Tower, Office 1613
Barsha Heights, Dubai, United Arab Emirates
General contact: dubaioffice@henoto.com
Privacy contact: privacy.hmee@henoto.com

3. Categories of Personal Data We Process

In the context of your application, we may collect and process the following categories of personal data:

  • Identification data: full name, date of birth, nationality, gender (where voluntarily disclosed), photograph (if included in your CV);
  • Contact details: postal address, email, telephone number;
  • Professional data: CV / resume content, education, qualifications, certifications, work history, professional references, language skills, technical skills, portfolio (where relevant);
  • Application data: cover letter, motivation, salary expectations, notice period, availability;
  • Identity documents: copy of passport, residence permit, Emirates ID, driving licence (where relevant for the position or required for visa / work-permit processing);
  • Pre-employment screening data: results of education verification, professional reference checks and - where lawful and necessary for the position - background-check results;
  • Communications: correspondence exchanged during the recruitment process, interview notes, assessment outcomes.

We do not actively request special categories of personal data (such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health data, sexual orientation, or biometric or genetic data). Where such data are required for visa, immigration or other legal purposes, they will be collected on a specific and separate legal basis.

4. Sources of Personal Data

We collect your personal data:

  • directly from you, when you submit your application or during any phase of the recruitment process;
  • from third parties, such as recruitment agencies, professional referees you have nominated, background-check providers acting on our behalf, or publicly available sources (e.g. LinkedIn) for verification purposes.

5. Purposes and Legal Bases of Processing

We process your personal data for the following purposes and on the following legal bases:

Purpose Legal basis under GDPR Legal basis under UAE PDPL
(a) Assessing your application and conducting the selection process Art. 6(1)(b) - measures at the request of the data subject prior to entering into a contract Art. 4(2) - necessary for entering into a contract
(b) Pre-employment screening (education verification, reference checks, background checks) Art. 6(1)(f) - legitimate interest in verifying the suitability of candidates Art. 4(7) - legitimate interest of the Controller
(c) Compliance with legal and regulatory obligations (immigration, labour, tax, anti-money-laundering) Art. 6(1)(c) - legal obligation Art. 4(4) - compliance with legal obligation
(d) Inclusion of your CV in our talent pool for future opportunities (up to 12 months) Art. 6(1)(a) - your consent Art. 4(1) - consent
(e) Establishment, exercise or defence of legal claims Art. 6(1)(f) - legitimate interest Art. 4(7) - legitimate interest

You may withdraw your consent for purpose (d) at any time by writing to privacy.hmee@henoto.com, without affecting the lawfulness of any processing carried out before withdrawal.

6. Recipients of Personal Data

Your personal data may be accessed or shared with the following categories of recipients:

  • Internal recipients: HR personnel, hiring managers, and authorized staff of Henoto MEE involved in the recruitment process;
  • Other Henoto Group entities: where the position has an international or cross-border scope, or where coordination with other Group entities (including Henoto S.p.A. in Italy, and Group offices in the USA, Mexico, China, Vietnam, Poland and other countries) is operationally necessary;
  • External processors: IT and cloud service providers, recruitment platforms, background-check providers, all acting under a data-processing agreement and bound by appropriate confidentiality and security obligations;
  • Public authorities: UAE Ministry of Human Resources and Emiratisation (MOHRE), General Directorate of Residency and Foreigners Affairs (GDRFA), tax and labour authorities, and other competent authorities, where required by law;
  • Professional advisors: legal counsel, auditors, and similar professionals, where strictly necessary.

7. International Transfers of Personal Data

Your personal data are primarily processed in the United Arab Emirates. Where we transfer your personal data outside the EEA or the UAE - for example to other Henoto Group entities or to processors located in third countries - we implement adequate safeguards in accordance with applicable law, including:

  • Standard Contractual Clauses approved by the European Commission, when data of candidates resident in the EEA are transferred to a third country not benefitting from an adequacy decision;
  • The safeguards prescribed under Articles 22 and 23 of the UAE PDPL for transfers originating from the UAE.

You may request a copy of the relevant safeguards by contacting privacy.hmee@henoto.com.

8. Retention Periods

We retain your personal data only for as long as necessary for the purposes set out in this Notice:

  • If you are selected: your application data will be merged into your employment file and retained in accordance with applicable employment-record retention rules (typically for the duration of employment plus the period required by labour, tax and social-security laws).
  • If you are not selected: your personal data will be deleted within six (6) months from the conclusion of the relevant recruitment process, unless you have provided your consent to be included in our talent pool.
  • Talent pool (with your consent): up to twelve (12) months from the date of your application, after which your data will be deleted unless you renew your consent.
  • Where retention is required for the establishment, exercise or defence of legal claims: data may be retained until expiry of the applicable statute of limitations.

9. Your Rights

Subject to the conditions and limitations set out in applicable law, you have the following rights:

  • Right of access (GDPR Art. 15 / PDPL Art. 13): to obtain confirmation of whether we process your personal data and to receive a copy thereof;
  • Right to rectification (GDPR Art. 16 / PDPL Art. 14): to have inaccurate or incomplete data corrected;
  • Right to erasure (GDPR Art. 17 / PDPL Art. 15): to request deletion of your personal data, subject to applicable exceptions;
  • Right to restriction of processing (GDPR Art. 18 / PDPL Art. 16);
  • Right to data portability (GDPR Art. 20 / PDPL Art. 18): to receive your data in a structured, commonly used and machine-readable format;
  • Right to object (GDPR Art. 21 / PDPL Art. 17): to object to processing based on legitimate interest;
  • Right to withdraw consent, where consent is the legal basis for processing, at any time and without affecting the lawfulness of processing prior to withdrawal.

The exercise of certain rights under the UAE PDPL may be subject to the entry into force of the relevant Implementing Regulations.

10. How to Exercise Your Rights

To exercise any of the rights listed above, please contact us at: privacy.hmee@henoto.com

We will respond to your request without undue delay and, in any event, within thirty (30) days of receipt, in accordance with applicable law. We may ask you to provide reasonable proof of identity to ensure that we disclose personal data only to the data subject.

11. Right to Lodge a Complaint

You have the right to lodge a complaint with the competent supervisory authority. In particular:

  • United Arab Emirates: UAE Data Office (https://www.uaedataoffice.gov.ae);
  • Italy: Garante per la protezione dei dati personali (https://www.garanteprivacy.it);
  • Other EEA countries: the data protection supervisory authority of your country of residence, place of work, or place of the alleged infringement.

12. Automated Decision-Making

We do not make decisions concerning candidates based solely on automated processing, including profiling, that produce legal effects or similarly significantly affect them. Where AI-assisted tools are used to support pre-screening activities (e.g. CV parsing or preliminary filtering), final selection decisions are always taken by human reviewers.

13. Updates to This Notice

We may update this Candidate Privacy Notice from time to time to reflect changes in our practices or in applicable legal requirements. The updated version will be published on our website together with the date of the latest revision. We invite you to consult this Notice periodically.

Henoto Middle East Events LLC
Document version: 1.0 - 05/11/2026