Privacy Policy | ClearPass HR Solutions

1. Introduction

ClearPass HR Solutions ("ClearPass," "we," "us," "our") respects the privacy of individuals whose personal data we process. This Privacy Policy explains how we collect, use, share, and protect personal data through clearpassuae.com (this website) and in the course of providing employment visa management, PRO services, and payroll outsourcing services across the United Arab Emirates.

This Policy applies to visitors to this website, business clients who engage ClearPass services, employees of our clients whose data we process to deliver our services, and anyone who contacts us through this website, email, or telephone.

We process personal data in accordance with the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) and other applicable laws.

2. Who We Are

ClearPass HR Solutions (Clearpass Accounting & Bookkeeping LLC) is a service brand of Flexitalent, a company within the Farnek Group of Companies, registered in Dubai, United Arab Emirates. Our registered address is 109, EGGT Building, Al Quoz 4, P.O. Box 5423, Dubai, United Arab Emirates.

For any questions about this Privacy Policy or our data practices, you can reach us at info@flexitalent.com or +971 50 867 1829.

3. Personal Data We Collect

3.1 Data we collect from website visitors

When you visit clearpassuae.com, we may collect:

Information you provide through contact forms (name, email address, phone number, company name, message)
Information about your visit (IP address, browser type, pages visited, referring URL, dates and times of visits)
Information from cookies and similar technologies (see Section 11)

3.2 Data we collect from business clients

When you engage ClearPass services, we collect:

Business contact details (company name, trade licence information, registered address, signatory details)
Authorised representative details (names, roles, contact information, identification documents where required)
Financial information for invoicing and service payment

3.3 Data we process on behalf of business clients

When we deliver visa management and payroll services, we process personal data of our clients' employees, including:

Identification and immigration data (passport details, Emirates ID, photographs, biometric data where required by authorities)
Employment data (employment contract details, role, salary, allowances, deductions, leave records)
Health data (medical fitness test results required for visa issuance)
Family member data (where required for dependent visa applications)
Bank account details (for salary payment through the Wage Protection System)
Other data required by UAE government authorities for visa and labour card processing

[REVIEW WITH LEGAL COUNSEL] Confirm completeness of data categories handled. Add or remove categories as required.

4. How We Use Personal Data

We use personal data for the following purposes:

To respond to inquiries and provide information about our services
To deliver employment visa management and payroll services to business clients
To comply with our legal and regulatory obligations under UAE law
To submit applications and documentation to UAE government authorities on behalf of clients
To process payroll and submit Salary Information Files (SIF) to banks for WPS distribution
To send service updates, renewal reminders, and operational communications
To improve and secure our website and services
To pursue our legitimate interests in operating and developing our business, where these do not override the rights of data subjects

5. Legal Basis for Processing

We process personal data under the following lawful bases as set out in the UAE PDPL:

Consent: where data subjects have given specific consent
Contract: where processing is necessary to perform a contract with the data subject or to take steps prior to entering a contract
Legal obligation: where processing is required by UAE law (for example, to comply with MOHRE, ICP, and WPS requirements)
Legitimate interests: where processing is necessary for our or a third party's legitimate interests, balanced against the rights of data subjects

6. How We Share Personal Data

6.1 Government authorities

We submit personal data to UAE government authorities as required to obtain visas, labour permits, and other approvals, including:

Ministry of Human Resources and Emiratisation (MOHRE)
Federal Authority for Identity, Citizenship, Customs and Port Security (ICP)
General Directorate of Residency and Foreigners Affairs (GDRFA) in each Emirate
Other federal and emirate-level authorities as required by law

6.2 Banks

We submit Salary Information Files (SIF) to client banks to enable salary disbursements through the Wage Protection System.

6.3 Service providers

We use trusted service providers to support our operations (for example, software, hosting, document processing). These providers process personal data only on our instructions and under contractual data protection obligations.

6.4 Affiliates within the Farnek Group

We may share personal data within companies of the Farnek Group where doing so supports the delivery of services or our group operations.

6.5 Where required by law

We may disclose personal data where required by law, court order, or regulatory authority.

We do not sell personal data.

7. Data Security

We maintain technical and organisational measures designed to protect personal data against unauthorised access, loss, alteration, and disclosure. These include access controls, encryption in transit where appropriate, secure storage, staff confidentiality obligations, and regular review of our security practices.

8. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, including:

During the period of an active engagement with a client
After the engagement ends, where required for legal, regulatory, audit, tax, or accounting purposes
Where required for the establishment, exercise, or defence of legal claims

Specific retention periods are determined by reference to applicable UAE law, including labour law, immigration law, and tax and accounting requirements.

9. Your Rights

Subject to UAE PDPL and applicable law, you have the following rights regarding your personal data:

Right to be informed about how your data is processed
Right of access to your personal data
Right to rectification of inaccurate or incomplete data
Right to deletion of your personal data, in certain circumstances
Right to restrict or object to certain processing, in certain circumstances
Right to data portability, in certain circumstances
Right to withdraw consent, where processing is based on consent
Right to lodge a complaint with the UAE Data Office or competent regulatory authority

To exercise these rights, contact us using the details in Section 14. We will respond to your request within the time period required by applicable law.

10. Cookies and Tracking

Our website uses cookies and similar technologies to support functionality, analyse usage, and improve performance. You can control cookies through your browser settings. Disabling certain cookies may affect website functionality.

11. Children's Data

Our website and services are not directed to individuals under 18. We do not knowingly collect personal data from children. Where we process data of dependents under 18 for visa-related purposes, this is done on the basis of parental or guardian consent and only as required by UAE immigration law.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top of this page indicates when the Policy was most recently revised. Material changes will be communicated through this website or, where appropriate, directly to affected data subjects.

14. Contact Us

For questions, requests, or complaints regarding this Privacy Policy or our data practices, contact:

ClearPass HR Solutions (Clearpass Accounting & Bookkeeping LLC)
A service of Flexitalent, a Farnek Group company

Email: info@flexitalent.com
Phone: +971 50 867 1829
Address: 109, EGGT Building, Al Quoz 4, P.O. Box 5423, Dubai, United Arab Emirates

For our website Terms and Conditions, see our Terms and Conditions page.