Effective Date: 04/06/2025
Last Updated: 04/06/2025
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1. INTRODUCTION
Harrison Finch (“we,” “us,” or “our”) is a brand under EXPENSIVE LLC FZ, a company registered in the Meydan Free Zone, Dubai, United Arab Emirates. This Privacy Policy explains how we collect, process, use, store, share, and protect your personal data when you interact with us or use our services globally, in compliance with applicable data protection laws including but not limited to the General Data Protection Regulation (GDPR), UAE Federal Decree-Law No. 45 of 2021 (PDPL), the UK Data Protection Act 2018, and the California Consumer Privacy Act (CCPA), as amended.
We are committed to safeguarding personal data and maintaining the trust of our clients, candidates, employees, and partners. By using our website or services, you agree to the terms of this Privacy Policy.
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2. DEFINITIONS
Personal Data: Any information that relates to an identified or identifiable individual.
Processing: Any operation performed on personal data such as collection, storage, use, sharing, etc.
Data Subject: A natural person whose personal data is being processed.
Controller: The entity that determines the purposes and means of processing personal data.
Processor: A third party that processes personal data on behalf of the controller.
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3. WHAT DATA WE COLLECT
We may collect the following types of personal data:
• Candidate Data: CVs, employment history, educational background, certifications, skills, reference checks, compensation expectations, background screening data, and any other information voluntarily provided by the candidate, excluding sensitive personal data unless explicitly required and consented to.
• Client Data: Company information, contact details, job descriptions, hiring objectives, and feedback.
• Usage Data: IP addresses, device identifiers, browser types, access logs, cookies (via Google Analytics), tracking pixels (e.g. Meta Pixel), and session recordings (via tools such as Hotjar).
• Communication Data: Emails, messages, calls, and recordings from interviews or meetings.
• Platform Data: Interaction data on our ATS, Notion, NiftyPM, or other collaboration tools.
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4. LEGAL BASES FOR PROCESSING
We process personal data based on:
• Consent
• Contractual Obligation
• Legitimate Interests
• Legal Obligation
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5. HOW WE USE PERSONAL DATA
• Match candidates with suitable job roles in Risk & Compliance
• Conduct background checks and due diligence
• Facilitate communication between candidates and clients
• Monitor usage and behavior on our digital platforms
• Improve user experience and site functionality
• Send marketing communications (newsletters, updates, offers), with clear opt-out options
• Ensure legal and operational compliance
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6. DATA SHARING AND DISCLOSURE
We may share your personal data with:
• Internal teams (recruitment, operations, legal)
• Clients (only when relevant to a specific hiring process)
• Service providers (Google Workspace, Notion, ATS, NiftyPM, analytics & email tools), under strict data protection terms
• Legal advisors, regulators, or auditors where legally required
We do not sell your data.
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7. INTERNATIONAL TRANSFERS
Data may be transferred and stored in the USA or other jurisdictions where our cloud systems and processors operate. We use:
• Standard Contractual Clauses (SCCs)
• Encrypted data storage
• Role-based access control and 2FA
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8. DATA RETENTION
• Candidates: up to 5 years after last engagement (unless withdrawn earlier)
• Clients: up to 7 years for compliance purposes
• Communications: 2 years unless required longer
• Marketing Data: until user unsubscribes or withdraws consent
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9. DATA SECURITY MEASURES
We apply:
• Encrypted cloud storage (e.g., Google Workspace, NiftyPM)
• Access logging and 2FA
• Staff training in data protection
• Regular audits and security reviews
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10. RIGHTS OF DATA SUBJECTS
Depending on jurisdiction, users may:
• Access their data
• Request correction or deletion
• Object to processing
• Withdraw consent
• Request data portability
Requests: privacy@harrisonfinch.com
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11. COOKIES AND TRACKING TOOLS
We use cookies and analytics tools including Google Analytics, Meta Pixel, and Hotjar-type behavior tracking systems. These help us improve the user experience, analyze visitor behavior, and optimize our content. You may disable cookies in your browser at any time.
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12. MARKETING COMMUNICATION
By subscribing or opting in, you agree to receive email communications, newsletters, and marketing updates. You can unsubscribe at any time using the link in any marketing email or by contacting us.
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13. AUTOMATED PROCESSING & PROFILING
We use ATS systems that rank or segment candidates based on job match. No final decisions are made solely based on automation.
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14. DATA BREACH RESPONSE
In the event of a breach:
• You’ll be notified within 72 hours (where legally required)
• We will inform authorities and initiate a full investigation
• Affected users will be advised on mitigation steps
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15. LIABILITY & DISCLAIMERS
While we use industry-standard protection, EXPENSIVE LLC FZ and Harrison Finch are not liable for:
• False data provided by users
• Breaches on third-party platforms beyond our control
• Indirect losses related to data exposure
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16. POLICY UPDATES
We may update this Privacy Policy periodically. The latest version will always be published on our site with the date of last revision.
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17. CONTACT
For questions or requests about your personal data:
Email: privacy@harrisonfinch.com
Mailing Address: EXPENSIVE LLC FZ
Meydan Grandstand, 6th Floor
Meydan Road, Nad Al Sheba
Dubai, U.A.E.