Spring Near East - Privacy Policy

Spring Near East FZCO · Last updated: 15 October 2026

Spring Near East FZCO ("we", "us", "our") respects your privacy. This Privacy Policy explains what personal data we collect, why we collect it, how we use, share and protect it, how long we keep it and what rights you have. Please read it together with our Cookie Policy and Terms & Conditions.

1. Who We Are

Spring Near East FZCO is a company registered in Dubai, United Arab Emirates, under trade licence number 3862, with its registered office at Premises No. 4EB 733-SD40, Seventh Floor, Building 4 East B, Dubai Airport Freezone, Dubai, United Arab Emirates. We operate offices in Istanbul, London, Barcelona, Cairo and Dubai.

Spring Near East FZCO is the data controller for personal data processed under this policy. Where one of our group companies or offices determines how your data is processed, that entity is also a controller, and this policy applies to it as well.

2. Scope

This policy applies to personal data we process:

through our Website, www.springne.com, including our contact and career forms;
through offline channels, such as meetings, events, phone calls, email and visits to our premises;
by our affiliates, subsidiaries, group entities and offices;
in relation to social media features and pages we operate.

It covers the personal data of the following groups ("you"): Website visitors; customers and prospective customers; suppliers, manufacturers, vendors and service providers; partners, contractors and consultants; job applicants, trainees and referred candidates; employees; board members and other stakeholders; and visitors to our offices.

Employees may receive a separate internal privacy notice with further detail. If you follow a link to a third-party website, this policy no longer applies (see Section 19).

3. Applicable Laws

We process personal data in accordance with the data protection laws that apply to our activities, including:

the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data;
the UK General Data Protection Regulation and the Data Protection Act 2018;
the EU General Data Protection Regulation (EU) 2016/679 and the Spanish Organic Law 3/2018;
the Turkish Law on the Protection of Personal Data No. 6698 (KVKK);
the Egyptian Personal Data Protection Law No. 151 of 2020.

The laws that apply to you depend on where you are located and which of our entities processes your data. Your use of the Website and our processing of your personal data are governed by this policy and the applicable data protection laws of the relevant jurisdiction.

4. Our Data Protection Principles

We are committed to processing personal data:

lawfully, fairly and transparently, on the basis of your consent or another legal basis permitted by law;
for specified and lawful purposes only, and not in a way that is incompatible with those purposes;
on a data minimisation basis: personal data must be adequate, relevant and limited to what is necessary for the purposes for which it is processed;
accurately, keeping it up to date where necessary;
for no longer than necessary (see Section 13);
securely, protecting it against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures.

5. Personal Data We Collect

The personal data we collect depends on your relationship with us.

Group	Categories of Personal Data
Website visitors	Device and browser information, pages visited, approximate location derived from the browser, cookie and consent choices, security data such as bot-detection signals (see our Cookie Policy)
People who contact us	Name, company, job title, email address, phone number, country, the content of your enquiry and our correspondence
Customers and prospective customers	Name, job title, business contact details, company details, contract and transaction history, communications, payment and invoicing details, tax information, due diligence and know-your-customer (KYC) information
Suppliers, manufacturers, vendors, service providers, partners, contractors and consultants	Name, job title, business contact details, company and tax registration details, bank details for payments, contracts and contractual records, certifications, audit and assessment results, transaction history, KYC and compliance information
Job applicants, trainees and referred candidates	Name, contact details, CV, cover letter, education, employment history, skills, references, interview notes and assessment results, nationality and right-to-work information, salary expectations, and any other information you choose to provide
Employees	In addition to applicant data: photograph, date of birth, gender, nationality, identity documents, emergency contacts, bank and payroll details, benefits, leave and attendance records, performance and training records, disciplinary records, health information where required by law, background verification results, IT and system usage data, access logs and CCTV footage
Office visitors	Name, company, contact details, the person you are visiting, visitor registration logs, entry and exit times, access credentials and CCTV footage of our premises

We do not intentionally collect special categories of personal data, such as health, religious or political data, except where required by law (for example, health information for workplace safety) or where you choose to provide it. Please do not include such information in your CV or messages unless it is necessary.

6. How We Collect Personal Data

We collect personal data:

directly from you, for example when you fill in a form on our Website, email or call us, attend a meeting, apply for a job, sign a contract or visit our offices;
automatically, through cookies and similar technologies on our Website, our IT systems, access control systems and CCTV;
from third parties, such as job portals, recruitment agencies, referrals from our employees, professional networking platforms such as LinkedIn, references, background verification providers, credit and compliance screening providers, your employer (where you are a business contact), and public sources such as company registers and official websites;
from internal processes, such as onboarding forms, HR and payroll systems, training programmes, performance appraisals and visitor management systems.

7. How We Use Personal Data: Applicants, Employees, Trainees and Consultants

We use the personal data of applicants, employees, trainees and consultants to:

assess applications, contact candidates and conduct interviews and assessments;
send job alerts, where you have asked to receive them;
verify identity, qualifications, references and right to work, and carry out background checks where permitted by law;
carry out onboarding, prepare employment or service contracts and manage the working relationship;
administer payroll, benefits, expenses and taxes;
manage performance, training, development and internal mobility;
administer leave, attendance and absence;
conduct disciplinary and grievance procedures;
protect health and safety in the workplace;
organise engagement activities and internal communications;
manage IT accounts, access credentials and building access;
comply with employment, tax, social security and other legal obligations.

Legal bases: taking steps before entering into a contract and performing a contract; compliance with legal obligations; our legitimate interests in recruiting suitable candidates and managing our workforce; and your consent where required, for example to keep your application for future vacancies.

8. How We Use Personal Data: Customers, Suppliers, Partners, Contractors and Visitors

We use the personal data of customers, suppliers, vendors, service providers, partners, contractors and visitors to:

respond to enquiries and provide customer support;
negotiate, enter into, administer and perform contracts;
assess and onboard suppliers, vendors and partners, including KYC, due diligence and compliance checks;
process payments and invoices;
manage the supply chain, quality control, audits and sustainability reporting;
send relevant business communications, conduct surveys and, where permitted, carry out marketing (see Section 9);
improve our Website and services, including through analytics where you have consented;
protect our Website, systems and premises, and prevent fraud, spam and misuse;
arrange visitor appointments and manage visitor registration and access credentials;
comply with legal and regulatory obligations and establish, exercise or defend legal claims.

Legal bases: performing a contract or taking steps before entering into one; compliance with legal obligations; our legitimate interests in running, developing and protecting our business; and your consent where required, for example for analytics cookies and certain marketing communications.

9. Marketing

We may use business contact details to send information about our services, events and industry updates that we believe are relevant to you. Depending on applicable law, we do this on the basis of our legitimate interest in business-to-business marketing, or with your consent. Every marketing email includes an unsubscribe link, and you can opt out at any time by contacting us.

10. Recruitment and Candidate Data

Applications through our Website. When you apply through our career page, your application, including your CV, is stored securely in our systems and made available only to the people involved in the recruitment process.

Future vacancies. If your application is unsuccessful, we will only keep it for future vacancies if you have given your consent, for example by ticking the relevant box on the application form. You can withdraw this consent at any time.

Referrals. If an employee or another person refers you, we use the information they provide only to contact you about the relevant vacancy. Before referring someone, the referrer must inform that person and obtain their agreement. If you do not wish to proceed, we will delete the referral data, and you may revoke your consent to the referral at any time.

Recruitment portals and agencies. Where you apply through a job portal or agency, we process your data in line with the consent you gave on that platform and this policy.

11. Sharing Personal Data

We do not sell personal data. We share personal data only where necessary for the purposes described in this policy, including service administration, assessing and responding to queries, data analysis, measuring Website performance and, where permitted, marketing, promotional activities, brand awareness and demand generation.

Recipients may include:

our group companies, subsidiaries, affiliates and joint ventures;
service providers acting on our behalf, such as website hosting and security (DigitalOcean, Cloudflare), consent management (CookieYes), analytics and anti-spam services (Google), email and IT providers, payroll, recruitment and background check providers;
subcontractors, agents, manufacturers and logistics partners involved in delivering our services;
professional advisers, auditors and insurers;
our directors and officers, where necessary for their duties;
courts, tribunals, arbitral tribunals, dispute resolution bodies, regulators, tax authorities, law enforcement, investigating agencies and other public or judicial authorities, where required or permitted by law;
any party you instruct us to share your data with;
a buyer or successor in the event of a merger, acquisition or sale of all or part of our business.

Confidentiality safeguards. We require all recipients to keep personal data confidential, to use it only for the purposes for which it was shared and not for any unauthorised purpose, and to protect it to a standard equivalent to this policy. Service providers that process personal data on our behalf are bound by written contracts that impose these obligations.

12. International Transfers

Because we operate in several countries and use international service providers, your personal data may be transferred to and processed in countries other than the one in which it was collected, including the United Arab Emirates, the United Kingdom, the European Union, Türkiye, Egypt and the United States.

Where the law requires, we transfer personal data only on one of the following bases:

an adequacy decision or equivalent recognition that the destination country provides an adequate level of protection;
standard contractual clauses or other approved contractual safeguards;
your explicit consent;
where the transfer is necessary to perform a contract with you or to take steps at your request before entering into one;
where the transfer is necessary to protect your vital interests or those of another person;
where the transfer is necessary to establish, exercise or defend legal claims;
where the transfer is necessary for important reasons of public interest;
where the data is taken from a public register, in line with the conditions for accessing that register;
any other mechanism permitted under applicable law, including any country-specific transfer restrictions.

You can request more information about the safeguards we use by contacting us.

13. Data Retention

We keep personal data only for as long as necessary for the purposes for which it was collected, or as required by law.

Data	Retention Period
Website enquiries and related correspondence	2 years after our last contact, unless a business relationship follows
Unsuccessful job applications	6 months after the end of the recruitment process, or 12 months if you consent to being considered for future vacancies
Employee records	Duration of employment plus the period required by applicable employment, tax and social security laws
Customer, supplier and partner records	5 years after the end of the business relationship, or longer where required by law
Office visitor logs	12 months
CCTV footage	30 days, unless needed for an investigation
Analytics data	14 months
Cookie consent records	12 months (your choice stored in your browser, and the consent log kept by our consent management provider as proof of consent)

At the end of the retention period, we securely delete or anonymise personal data, or archive it securely where the law requires us to keep it longer. Where appropriate and practicable, for example for candidates kept for future vacancies, we will notify you before deletion. For questions about retention, contact us at [email protected].

14. Security

We use appropriate technical and organisational measures to protect personal data, including encrypted connections, access controls, restricted access to applications and CVs, security monitoring, bot protection and staff confidentiality obligations. No method of transmission or storage is completely secure, but we work to protect your data and review our measures regularly.

15. Cookies and Similar Technologies

Our Website uses cookies and similar technologies that are necessary for security and for remembering your consent choices. With your consent, we also use analytics cookies to measure traffic and understand how visitors use the Website, so that we can improve it. We do not currently use advertising, personalisation or social media cookies. Third-party providers, such as Google, set some of these cookies.

You can accept or refuse non-essential cookies in our cookie banner, change your choices at any time through Cookie Settings, and block cookies in your browser. Full details, including a list of the cookies we use, are in our Cookie Policy.

16. Your Rights

Depending on the law that applies to you, you may have the right to:

be informed about how we process your personal data;
access your personal data and receive a copy of it;
have inaccurate or incomplete data corrected;
have your data erased;
restrict or object to our processing, including processing based on legitimate interests and direct marketing;
receive your data in a portable format and have it transmitted to another controller;
not be subject to decisions based solely on automated processing that significantly affect you;
object to a result against you arising from the analysis of your data exclusively through automated systems;
claim compensation for damage caused by unlawful processing;
lodge a complaint with a supervisory authority (see Section 18).

Withdrawing consent. Where we rely on your consent, you can withdraw it at any time: for cookies, through Cookie Settings in our cookie banner; for marketing, through the unsubscribe link in our emails; and in all other cases, by contacting us. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

17. Notice for United States Residents

Residents of certain US states have rights under state privacy laws, including the right to know, access, correct and delete their personal information, and the right to opt out of the "sale" or "sharing" of personal information and of targeted advertising.

We do not sell personal information and do not share it for cross-context behavioural advertising. If you wish to make a request, including a request not to sell or share your personal information, use our Do Not Sell or Share My Personal Information link or contact us at [email protected]. We will not discriminate against you for exercising your rights.

18. Requests and Complaints

How to make a request or complaint. Send any request relating to your personal data, including requests to exercise your rights under Section 16, and any privacy complaint or grievance to [email protected], or write to us at Premises No. 4EB 733-SD40, Seventh Floor, Building 4 East B, Dubai Airport Freezone, Dubai, United Arab Emirates. This mailbox is monitored regularly, and all requests and complaints are handled within the deadlines set by applicable law.

Identity verification. To protect your data, we may ask you to verify your identity before we respond. If you make a request on behalf of someone else, we may ask for proof of your authority.

Response time. We will respond within one month of receiving your request, or within any shorter period required by applicable law (for example, 30 days under KVKK). Where permitted, we may extend this period for complex or numerous requests and will tell you why.

Requests we may decline. We may decline or charge a reasonable fee for requests that are manifestly unfounded, frivolous, excessive or repetitive, or where the law allows or requires us to refuse. We will explain our reasons.

Complaints to a supervisory authority. If you are not satisfied with our response, you may lodge a complaint with the supervisory authority where you live, work or where the alleged infringement took place, including:

United Kingdom: the Information Commissioner's Office (ico.org.uk);
Spain and the EU: the Spanish Data Protection Agency (aepd.es) or your local EU supervisory authority;
Türkiye: the Personal Data Protection Authority (kvkk.gov.tr);
United Arab Emirates: the UAE Data Office;
Egypt: the Personal Data Protection Center.

We would appreciate the chance to address your concerns before you contact a supervisory authority.

19. Third-Party Websites and Services

Our Website may contain links to third-party websites, services and social media platforms. We are not responsible for the content, services, privacy practices or legal compliance of those third parties. Their own privacy policies apply, and we encourage you to read them.

20. Children's Privacy

Our Website and services are not intended for anyone under 18 years of age. We do not knowingly collect personal data from minors. If we learn that we have collected a minor's personal data without valid consent from a parent or guardian, we will delete it promptly. If you believe this has happened, please contact us.

21. Accuracy of Data from Third Parties

Where personal data is provided to us by service providers, recruitment agencies, referrers or other third parties, we rely on them to ensure that it is accurate and lawfully provided. We are not responsible for the authenticity or accuracy of personal data supplied by third parties, but we will correct or delete inaccurate data when we become aware of it.

22. Intellectual Property

All content on our Website, including text, graphics, logos, trademarks, service marks, trade names, images, software, domain names, technology and processes, is owned by or licensed to Spring Near East FZCO and is protected by intellectual property laws. You may not use, copy, reproduce or distribute it without our prior written consent, except as permitted in our Terms & Conditions.

23. Severability

If any provision of this policy is found to be invalid, illegal or unenforceable, that provision will be severed and the remaining provisions will continue in full force and effect.

24. Changes to This Policy

We may update this Privacy Policy from time to time. The date at the top of this page shows when it was last updated. Where changes are significant, we will take reasonable steps to inform you, for example through a notice on our Website.

25. Contact Us

For any questions about this policy, personal data requests or privacy complaints, contact:

Spring Near East FZCO Premises No. 4EB 733-SD40, Seventh Floor, Building 4 East B, Dubai Airport Freezone, Dubai, United Arab Emirates Email: [email protected]