This document outlines the privacy practices of VArrow Technologies, emphasizing our commitment to safeguarding personal information.

VArow Technologies takes its role in the IT sector seriously, with a focus on delivering comprehensive solutions ranging from IT infrastructure deployment, project-specific expertise, IT professional outsourcing, to consultative services. Our mission is centered on providing exceptional IT services and solutions.

In compliance with the General Data Protection Regulation 2016/679 (“GDPR”), our responsibilities include acting as either a “data processor” or “data controller” based on the nature of our engagement and the purpose for which personal data is processed.

By entrusting us with your personal information, you are agreeing to the terms set forth in this policy, consenting to our processing of your information as detailed herein. Should you find any aspect of this policy unacceptable, we ask that you refrain from providing us with your personal information. Please be aware that withholding your personal information or withdrawing consent may limit our ability to deliver services to you effectively.

Moreover, VArrow Technologies is known for its expertise in advising companies on the recruitment and selection of specialists and executives. Our services extend to support in recruitment processes, development and implementation of assessment procedures, career development, compensation consulting, and strategic HR advisory.

This Privacy Policy is applicable to VArrow Technologies, including its consulting services.

Our role often involves facilitating the placement of personnel with employers, for which we receive a commission.

This section explains how we, VArrow Technologies, approach the handling of personal information, adhering to local data protection laws and, where applicable, the definitions and principles outlined in the General Data Protection Regulation (GDPR). Personal information, in this context, refers to data about an identifiable living individual, obtained directly or indirectly, including opinions and intentions regarding the individual, irrespective of the form in which it is recorded.

Our collection of personal information is primarily aimed at supporting your engagement with us, whether it be through recruitment processes, training programs, or the facilitation and implementation of IT solutions.

The categories of personal information we typically process include:

• Contact details: Name, addresses (residential and mailing), telephone numbers, and email addresses.
• Payment information: Details of credit/debit cards such as the type of card, card number, security code, and expiration date.
• Passport information for identity verification purposes.
• Loyalty program or frequent flyer details, when relevant.
• Health and dietary specifics, if applicable, to ensure your wellbeing in our engagements.

Additionally, should you reach out to us for other reasons, such as participating in a competition or providing feedback, we may collect relevant personal information for those specific interactions. Our business operations necessitate the collection of further details, including financial data for transaction processing, security footage for safety purposes, and any other information you choose to share with us.

This structured approach to data collection enables VArrow Technologies to conduct its business activities efficiently while ensuring the privacy and security of personal information entrusted to us.

Scope and Definition of Personal Information

“Personal information” is defined according to local data protection laws and, where applicable, the definition of personal data under the GDPR. This typically includes information that can identify a living individual directly or in conjunction with other available data. This may encompass expressions of opinion and intentions towards an individual, regardless of the format in which it is stored.

The personal information we gather is primarily required to facilitate recruitment, training, or the implementation of IT solutions by VArrow Technologies. This encompasses:

• Contact details including name, address, phone number, and email.
• Payment and financial information for processing transactions.
• Passport and travel-related information.
• Loyalty or frequent flyer program details.
• Health and dietary information as necessary.
• Additional information for other contact reasons, like competitions or feedback.

This information supports VArrow Technologies and its related activities, including security measures and other essential business operations.

Collection Methods

VArow Technologies is committed to collecting personal information in accordance with local data protection legislation. Collection usually occurs directly from the information you provide throughout your interaction with us, unless collecting directly from you proves impractical or unreasonable.

Collection can happen through various interactions:

• Direct communications in person, or via phone, letter, email.
• Website visits.
• Social media engagements.
• CV submissions for job applications.

Furthermore, we may collect your information when you:

• Apply for a job.
• Register for recruitment or positions.
• Subscribe to our marketing materials (e.g., newsletters).
• Request brochures or information.
• Engage with our services on social media.
• Interact with us as a business partner or supplier.

Anonymous or pseudonymous submissions are possible, except for sensitive information, which we may collect via surveys or feedback with your consent.

On occasion, we may need to collect information about you from third parties, such as CV banks or recruitment websites. It’s important to inform us if your information was provided without your consent or if you provided someone else’s information without their consent.

Accuracy and Maintenance of Information

VArow Technologies endeavors to keep your personal information accurate, complete, and up-to-date. You play a vital role in this by notifying us of any changes or inaccuracies in your information. While we strive to maintain the integrity of the information we hold, we cannot be held liable for any issues arising from incorrect or incomplete information provided by you or on your behalf.

Basis for Processing

VArow Technologies will process your personal information only under the following conditions:

• When you have explicitly consented to the processing, which you can withdraw at any time.
• When processing is necessary to deliver the services you have requested.
• When we need to comply with legal obligations.
• When processing serves our legitimate interests or those of a third party, provided your interests and fundamental rights do not override those interests.

Purpose of Collection

The primary reason we collect your personal information is to facilitate recruitment services, assist with employment opportunities (whether with one of our clients or for a specific project as a freelancer), or support business partnerships. The specific purpose may vary (e.g., for training, outsourcing services, IT consulting, or recruitment activities), and will be clearly disclosed within this Notice.

Upon submitting your CV, we often serve as an intermediary for the concerned recruiter (e.g., an IT company), processing your information to fulfill the services you’ve sought from us. This includes using your details for both our internal purposes, as outlined in this Notice, and for the recruitment service provider we represent.

Consequently, your information may be shared with clients (hiring managers), training agencies, certification bodies, or other service providers involved in fulfilling the services you’ve applied for.

If you have any concerns about your personal information being transferred to any recruitment agency, hiring company, or service provider, or if you need further details, please see the “Feedback / Complaints / Contact” section below.

Uses of Personal Information

We collect personal information for various purposes, including:

• Providing chosen services and tools (e.g., saving job preferences to your profile or pre-populating forms).
• Identification and prevention of fraud.
• Regulatory reporting and compliance.
• Development and improvement of our services and those of our affiliates.
• Servicing our relationship with you, such as creating and maintaining a customer profile to enhance service delivery.
• Market research, customer satisfaction surveys, and feedback to improve our relationship and services.
• Business and service analysis and research.
• Internal accounting, administration, and legal obligations.
• Compliance with legal, customs, and immigration requirements related to outsourcing or recruitment services.

We may also use your personal information for direct marketing related to our services and products, and potentially those of third parties, if you find them of interest, unless you’ve opted out. This includes mail, electronic communications, and phone calls, adhering to opt-in preferences for electronic marketing.

Opting Out of Communications

Should you decide to stop receiving marketing material, participating in surveys, or receiving other communications from us, please refer to the “Feedback / Complaints / Contact” section. You can opt-out of electronic marketing communications by using the unsubscribe option provided in the messages you receive.

For details on your rights to restrict the use of your information for online behavioral advertising, please see the “Your Rights” section of this Notice.

Commitment to Non-Disclosure

VArow Technologies is committed to protecting your privacy. We do not sell, rent, or trade your personal information. Any disclosure of personal information to third parties is strictly controlled and conducted in accordance with local data protection laws. “Disclosure,” as used in this notice, encompasses transferring, sharing (verbally or in writing), sending, or making your personal information available or accessible to another party.

Third-Party Disclosure

Your personal information may be shared with the following categories of third parties:

• Our Service Providers: This includes contractors, suppliers, and any third parties who assist us in delivering our services and products, such as IT solution providers, marketing material distributors, event organizers, research agencies, and external business advisors like lawyers and accountants.
• Our Affiliates: Information may be shared within our related entities and brands for operational purposes.
• Travel and Event Partners: This includes hotels, car rental companies, and other service providers related to events or travel.
• Legal Transfers: We may disclose your information to any party where we transfer or novate our rights or obligations.
• Employer Disclosures: If you are part of a corporate, business, or government entity we serve, your personal information may be disclosed for event or work-related purposes.
• Emergency Contacts: In cases where you cannot be reached, we may disclose information to individuals who can verify their relationship with you, provided it’s in your interest and they pass our security checks.
• Legal and Regulatory Compliance: We may disclose information as required by law, to customs and immigration authorities, to government agencies, regulatory bodies, law enforcement, and enforcement agencies to fulfill legal obligations, protect against fraud, or investigate suspected illegal activities.

Conditional Disclosure

Apart from these conditions, we will not disclose your personal information without your explicit consent, except in situations where disclosure is deemed necessary to reduce or prevent a threat to life, health, or safety, or to comply with legal obligations.

Third-Party Websites

Our websites may offer features operated by third parties, such as social networking and geo-location tools. These features, managed by third-party entities, may use or share personal information according to their privacy policies. We encourage you to review these policies if you engage with these features.

Ensuring Your Privacy

VArow Technologies takes your privacy seriously and adheres to stringent practices for the protection and lawful handling of your personal information. Our policies are designed to respect your rights and ensure transparency in how your data is used and shared.

Disclosure Practices

VArow Technologies is committed to the principle that we do not sell, lease, or trade your personal information. We disclose your personal information to third parties only as described in this policy, in compliance with local data protection laws. “Disclosure” encompasses the transfer, sharing, sending, or otherwise making available your personal information to another party.

Your personal information may be shared with:

• Our contractors, service providers, and suppliers, including those involved in IT solutions, marketing material distribution, event organization, market research, communications, logistics, and legal or financial advisory services.
• Our affiliates and related brands.
• Service providers like hotels, car rental companies, and other related service providers.
• Parties to whom we may transfer our rights or duties.
• Your employer, in the context of corporate or government client services or events.
• Verified individuals acting on your behalf, under certain conditions.
• Authorities, as required by law, for compliance and protective purposes.

We ensure that any disclosure is in accordance with your rights and the legal protections afforded to your information.

International Transfers

Your personal information may be transferred internationally in the following contexts:

(a) Overseas Entities: As part of VArrow Technologies’ global operations, your information may be shared with our related entities in other countries for service facilitation and administrative, advisory, and technical tasks.

(b) Overseas IT Service Providers: To deliver our services, it may be necessary to share your information with overseas IT service providers based on the nature of the services you seek. These providers may be located in various countries, depending on where the services are rendered or the providers are headquartered.

(c) Third-Party Service Providers: We may also share your information with third-party service providers overseas for services including storage and processing.

We ensure that any international transfer of your personal information is carried out with necessary safeguards and in compliance with local data protection laws, including the GDPR. This may involve contractual measures to protect your data or transferring data to jurisdictions recognized as providing an adequate level of legal protection for personal information.

Should you require details on the safeguards or wish to make inquiries about the specific locations where your information may be processed, please refer to the “Feedback / Complaints / Contact” section.

Liability and Redress

While we take steps to protect your information, including ensuring appropriate safeguards are in place for international transfers, there may be instances where information is transferred to countries without equivalent data protection laws. In such cases, and to the extent allowed by your local data protection laws, VArrow Technologies may not be held liable for the practices of these overseas recipients regarding your personal information.

VArow Technologies is dedicated to the protection and security of personal information. We are committed to implementing and upholding rigorous technical and organizational measures to safeguard personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. We have established a variety of physical, electronic, and managerial procedures to secure the personal information we possess from loss, misuse, and from unauthorized access, alteration, disclosure, or interference.

We continuously assess our security protocols and technologies to ensure the utmost protection of your personal information, treating it with the same level of care as we do our own confidential data. However, it is important to note that while we strive for the highest level of security, we cannot be held accountable for the actions or security measures of third parties regarding information they may collect or process through their platforms, services, or in any other manner.

Upon determining that personal information is no longer needed for our business objectives, or as mandated by law, VArrow Technologies will either destroy or anonymize the information, thus preventing it from being associated with any individual.

Commitment to Security

VArow Technologies is dedicated to the security and protection of personal information. We implement and maintain robust technical and organizational measures to ensure a level of security appropriate for safeguarding the personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. Our security measures include physical, electronic, and managerial procedures to guard against misuse, as well as unauthorized access, modification, or interference. We continually assess and update our security protocols to align with industry standards and protect personal information as diligently as we protect our own confidential data. However, we do not assume responsibility for the security measures of third parties handling information through their services or websites.

Retention and Disposal

Personal information that is no longer needed for business purposes or by law will be either destroyed or anonymized.

Your Rights

You have the right to:

• Update, modify, delete, or obtain a copy of the personal information we hold about you.
• Restrict, withdraw consent, or object to our use of your personal information.
• Request a copy of your personal information processed based on consent or as necessary for contract performance in a structured format.

To exercise these rights, please contact us via the email provided in section 13. Upon request, we will acknowledge receipt and inform you of the timeline to receive your information pack, typically within a month or as permitted for complex requests.

While we strive to honor all valid requests regarding your personal data, we may deny access in certain situations as allowed by applicable laws, including for reasons related to national security or corporate confidentiality. Denials will be accompanied by explanations, unless providing such reasons is deemed unreasonable. All denials and the rationale behind them will be recorded as per local data protection legislation.

Restrictions and Consequences

Requests to limit the use of your personal information may impact our ability to deliver services. Accuracy of information is crucial; you are responsible for ensuring that your data is up-to-date, and we will assume correctness unless notified otherwise.

Opting out of marketing communications is possible at any time via the unsubscribe link in emails or by contacting us as outlined in section 13.

Identity Verification and Administrative Fees

We may require proof of identity to process your requests securely and prevent unauthorized data disclosure. For repetitive or excessive requests, an administrative fee may be applied.

Use of Social Media Features

VArow Technologies’ websites and mobile applications incorporate social media features and widgets (e.g., “Like” and “Share” buttons/widgets) provided by third-party companies like Facebook. These features may be hosted directly on our site/app or by the third parties. They are designed to collect information such as which pages you visit on our site/app, your IP address, and may set cookies to ensure proper functionality.

Interaction with Social Media Platforms

If you are logged into a social media account, the respective third party may link your activities on our website or app with your account on their platform. This includes recording interactions with social media features. Additionally, these companies may share with us information according to their policies, such as your name, profile picture, gender, friend lists, and any other information you’ve chosen to make public, to facilitate targeted marketing through their platforms. Conversely, we may share information with them to enhance your user experience and present you with relevant marketing on their platforms.

Privacy and Control

Your engagement with social media features on our platforms is subject to the privacy policies of the respective third-party providers. We encourage you to review their privacy policies to understand how they collect, use, and share your personal information. Furthermore, you have the ability to manage the sharing of your information and opt-out of targeted marketing by adjusting your privacy settings on the respective social media platforms.

For detailed information about the privacy practices of these third-party companies and to better understand how your personal information is handled, please refer directly to their privacy policies.

When you visit our website, use our mobile applications, or open communications from us, our servers log information about your device and network, including your IP address. An IP address is a unique number assigned to your computer when you connect to the internet.

We use IP addresses to manage our systems, investigate security issues, and gather anonymized data about usage of our website and/or mobile apps. We may also link your IP address with personal information we have about you for various purposes, such as customizing our marketing and advertising efforts to your interests, assuming you’ve agreed to receive electronic marketing materials from us.

Analytics Services

At VArrow Technologies, we engage third-party web analytics services on our websites and mobile apps, as detailed in our Cookies Policy. These analytics services are managed by external providers who employ technologies like cookies and web beacons to assist in analyzing how visitors interact with our digital platforms.

Cookies and Tracking Technologies

Cookies are small data files stored on your device that help websites remember your preferences and some details of your visits. Web beacons are tiny graphics embedded in emails and web pages to track your actions around the web and when you open emails we send. These technologies are instrumental in enhancing and personalizing your experience with our services, as well as in collecting aggregated usage and performance data.

For comprehensive details about how we use cookies and other tracking technologies, including how you can manage your preferences and opt-out options, please visit our Cookies Policy available on our website.

Our websites may feature links to external sites not operated by us, over which VArrow Technologies has no control. We cannot take responsibility for the privacy practices or content found on these third-party websites. We strongly encourage you to review the privacy policies of any third-party sites you visit, as their approaches to privacy and data protection may vary from ours.

This section serves to remind users to stay informed about their privacy across the web, especially when navigating away from VArrow Technologies’ digital environment.

Subject Access Requests

If you need to update us on changes or corrections to your personal information, obtain a copy of the information we have on you, request the deletion of your information, or wish to restrict further processing of your data, please follow the link below to reach out to us:

Link: Contact Us

We commit to addressing these requests within one month of their receipt.

Inquiries, Comments, or Complaints

For any questions, feedback, or complaints regarding this Privacy Policy or our treatment of your personal information, please reach out to your consultant or our Data Protection Officer via the contact details provided below. We aim to respond as swiftly and helpfully as possible.

Email: info@varrow.tech

Post: VArrow Technologies, Building B115 second floor- Smart Village, Cairo-Alexandria road

Your input and concerns are invaluable to us, and we are dedicated to ensuring your personal information is handled with the utmost care and respect.

VArow Technologies may revise this Privacy Policy periodically. Whenever we modify it, we will make the updated version available on our website. Additionally, we will prominently highlight any significant changes on our site and note the date of the most recent update at the end of the Privacy Policy. It’s important for you to review our website occasionally to stay informed about any adjustments. Depending on the nature of the update, we might also ask for your consent to the new terms.

This Privacy Policy was last updated on March 10th, 2024.