PRIVACY & DATA PROTECTION

Personal Data Privacy and Protection

Notice on the collection, use, protection, and retention of personal data, and the rights of data subjects under the Saudi Arabia Personal Data Protection Law (PDPL).

Governing Law Kingdom of Saudi Arabia — Personal Data Protection Law (PDPL)
Headquarters Riyadh, Kingdom of Saudi Arabia
01

Introduction

COMATEC Saudi Arabia Limited is committed to conducting its business in accordance with all applicable Data Protection laws and to respecting your privacy and protecting your personal information in line with the highest standards of ethical conduct. This document explains what personal data we collect about you, why we collect it, whom we share it with, how long we keep it, and what rights you have in relation to that personal data.

02

Saudi Arabia Personal Data Protection Law (PDPL)

The Personal Data Protection Law (PDPL) aims to protect individuals' personal data privacy and regulate organizations' collection, processing, disclosure, or retention of personal data. It has been issued pursuant to Royal Decree No. M/19 dated 09/02/1443 (16/09/2021) and amended pursuant to Royal Decree No. M/148 dated 05/09/1444 (27/03/2023).

COMATEC Saudi Arabia Limited as a Data Controller processes personal data as per the principles stated in the PDPL. This includes ensuring that there is a legal basis for processing personal data, as well as ensuring that personal data is processed consensually, fairly, lawfully, transparently, and securely. In addition, safeguards are put in place to protect personal data from loss, damage, or destruction.

03

Sources of Personal Data Collection

We collect your personal data from the following sources:

  • From employee hiring and onboarding.
  • From client engagements.
  • From vendor interactions.
  • From official authorities and government authorized sources.
  • Anonymously from our website.
  • From registered users in our career portal.
  • From publicly available profiles in portals and services (e.g. LinkedIn).
  • From reputable and well-established third parties (e.g. recruitment agencies).
04

Personal Data Content

Typically, we process the following categories of information:

TypeDetails
PersonalName, nationality, photograph, gender, birth date, place of birth, religion, family information.
ContactEmail address, residential address, original/home country/permanent address, contact telephone number.
IdentityNational ID, Iqama Number, Passport number, Driver license, Visa, and any other government issued document.
FinancialBank account number, loans, bank requests, payroll, expenses, deductions.
SecurityCriminal or security history reported in a background check.
Education and EmploymentEmployer, title, level of education, educational institutions attended, degrees, professional certifications, prior experience and employers.
CCTV/VideoSurveillance of our premises for 30 days.
CommunicationsPhone numbers called and received and duration of calls. In some cases, recording of online meetings with audio and/or video.
BiometricFace and fingerprints for access control systems.
HealthMedical history and conditions, insurance and insurance related queries and cases, certain leave requests, and work-related injuries.
TransactionsEmails on company account, pages, documents, files and information stored or accessed on company servers, company provided online services, or company provided applications, limited tracking of site names accessed through company provided internet connections or company provided devices.
05

Purpose of Personal Data Collection

TypeDetails
Employee
  • Manage employment contracts, contractual changes, and probation.
  • Manage relocation.
  • Manage emergency contact information for emergency situations.
  • Comply with government and legal requirements.
  • Issue ID, login credentials, provide IT services and facility access.
  • Issue residency, work permits and visas to employees and family.
  • Manage COMATEC Saudi Arabia Limited Directory.
  • Administer payroll, benefits, deductions, allowances and entitlements.
  • Manage requests for leave.
  • Manage attendance.
  • Manage reimbursements for business-related expenses and travel.
  • Provide HR certificates and letters.
  • Manage performance and conflicts of interest.
  • Recognize employees' achievements and awards.
  • Manage grievance and disciplinary cases.
  • Comply with professional certification requirements.
  • Provide learning and development opportunities.
  • Conduct surveys to assess employee experience and competencies.
  • Promote COMATEC Saudi Arabia Limited to clients and the market.
  • Manage visit requests.
  • Assure HSEQ compliance.
  • Investigate and manage workplace health and safety incidents.
  • Manage illness and injury.
  • Carry out CCTV surveillance for security reasons.
Candidates
  • Contact candidate.
  • Evaluate skills and match against job requirements.
  • Schedule and perform job interviews.
  • Prepare a job offer.
  • Comply with government and legal requirements.
  • Ensure medical and security eligibility.
  • Prepare documentation for travelling and onboarding.
Clients
  • Provide products and professional services.
  • Prepare offers and proposals.
  • Prepare and sign contracts and other legal documents.
  • Invoice and collect the professional fees of products/services rendered.
  • Comply with government and legal requirements.
  • Collect client satisfaction/engagement data.
  • Maintain a proactive relationship and anticipate requirements.
Vendors
  • Procure products and professional services.
  • Receive offers and proposals.
  • Prepare and sign contracts and other legal documents.
  • Receive and pay invoices of products/services rendered.
  • Comply with government and legal requirements.
  • Rate and evaluate vendor performance.
  • Maintain a proactive relationship.
Visitors
  • Provide access to facilities.
  • Manage the logistics of the visit.
  • Assure HSEQ compliance during the visit.
  • Carry out CCTV surveillance for security reasons.
Website users
  • Improve user experience using cookies.
  • Collect anonymous website statistics.
06

Personal Data Marketing

We do not use personal data for unsolicited marketing or sales purposes. We do not sell or monetize your personal data in any way.

07

Necessity of Providing Personal Data

Mandatory data will be marked as such and it needs to be provided in order to engage with COMATEC Saudi Arabia Limited. Failure to provide required information may prevent COMATEC Saudi Arabia Limited from establishing an association with the person.

08

Personal Data and Automated Processing

Personal data may be used in automated processes for triggering events based on specific data and dates (for example, renewal of documentation). It may also be used to integrate and share personal data amongst different systems. COMATEC Saudi Arabia Limited does not use any personal data for profiling or automated decision-making.

09

Personal Data Retention Period

COMATEC Saudi Arabia Limited will retain your personal data for any period as mandated by the regulations, necessary for the purpose for which your personal data was collected, required by law, or where we may need it for our legitimate purposes such as maintaining records for analysis or audit purposes, responding to queries or complaints, defending or taking legal action, and responding to requests from government.

If you exercise your option to be removed from our records, we may keep a basic record of your request to ensure that the action has been carried out.

10

Personal Data Protection & Retention Method

COMATEC Saudi Arabia Limited implements internal technical and organizational measures to keep personal data safe and secure, including encryption, anonymization, and physical security measures. We require our staff and any third parties who carry out work on our behalf to comply with strict compliance standards, including agreeing to contractual obligations to protect any personal data.

When we collect personal data, we provide a safe, secure and confidential environment to ensure that your personal data remains private, used only for the purposes it was requested for, and accessible only to those authorized to process it. We have a legal obligation to keep your personal data confidential, except in circumstances where the disclosure of your personal data is imposed by a legal authority, or where the disclosure is made with your explicit consent or through a representative nominated by you.

We use a range of measures to keep your personal data secure and protected against unlawful processing, accidental loss, destruction and damage.

When we interact with external service providers, we require them to provide the same data protection standards to be assured.

If we become aware that a breach in the security of personal data has taken place, we will communicate with those affected and the relevant authorities to inform them and to try to remedy the breach.

11

Personal Data Sharing

TypeDetails
SubsidiaryFor the same purpose stated in this document.
Recruiter
  • To process your selection and hiring.
  • Perform a background check.
  • Perform a health and medical evaluation.
Travel agencyTo arrange travel documents and reservations.
Vendor
  • Provide training.
  • Provide medical insurance.
  • Provide accommodation.
  • Provide transportation or car rental.
  • Provide software, IT services and support for applications.
  • Carry out audits, 3rd party inspections and surveys.
  • Comply with signed contracts.
  • Collect statistics and optimize our website (anonymously).
  • Provide other services or products.
BanksIssue payments.
Emergency contactProvide details of an emergency incident.
Government
  • Provide GOSI information.
  • Provide Labor information to the Ministry.
  • Provide Tax information to ZATCA.
  • Obtain visa and permits.
  • Carry out audits of our activities.
  • Other cases as required by law.
Social Media
  • Promote COMATEC Saudi Arabia Limited.
  • Recognize merits, achievements and awards.
LegalIf requested by court, arbitration body, or law enforcement.
OtherIf you request it and provide explicit consent.
12

Personal Data Transfer Outside KSA

We are headquartered in Riyadh, Kingdom of Saudi Arabia. We may transfer your personal data to other countries where we may have service providers.

When we transfer personal data, we ensure it has an appropriate level of protection by including contractual clauses to assure confidentiality and privacy.

13

Children's Personal Data Protection

We do not provide services to, and do not knowingly solicit data from, persons under the age of 18. Employees of COMATEC Saudi Arabia Limited may provide information about their children to obtain services from COMATEC Saudi Arabia Limited, such as medical insurance or visa issuance.

14

Disclosures Required by Law, for Health, or Safety

Consistent with the Personal Data Protection Law, COMATEC Saudi Arabia Limited may disclose personal data if:

  • Requested to do so by a governmental entity:
  • For security purposes.
  • To implement a law.
  • To meet judicial requirements.
  • Disclosure is necessary to protect public health or safety, including to prevent a crime or protect national security.
  • Disclosure is necessary to protect the life or health of one or more individuals.
15

Subject's Rights

The PDPL provides you with certain rights regarding our processing of your personal data. COMATEC Saudi Arabia Limited will make a good faith effort to honor the rights of personal data owners and to fulfill legitimate and appropriate requests:

  • Right to know which data we collect, our contact details, the exact reason the data is being collected, the methods used for data collection, and whether this collected data will be shared or sold.
  • Right to request correction of any data collected if it is incomplete, inaccurate, or obsolete.
  • Right to request the destruction of data collected on them.
  • Right to withdraw your consent.
16

Contact at COMATEC Saudi Arabia Limited

To know more about your rights, or if there is any question, issue, or request regarding this Personal Data Privacy and Protection notice, please send an email to privacy@comatec.com.sa.

17

Web Cookies

Cookies are pieces of information that a website transfers to a customer's device to track browsing activity in order to improve the user experience. Cookies are used both on websites and in mobile applications. COMATEC Saudi Arabia Limited cookies cannot look into a customer's device to obtain information about them, and cannot read any material or file kept on that device. Only when a user logs in is the cookie associated with a specific user profile, at which point the data collected is associated with his or her personal data.

18

Types of Information Collected Using Cookies

COMATEC Saudi Arabia Limited collects the following information when customers use its website or mobile applications:

  • Browsing history.
  • Information about the customer's computer and internet connection, including IP address, country, browser type, and operating system.
  • Browser type.
19

Non-Compliance

Any individual who suspects that a Personal Data Breach has occurred due to the theft or exposure of Personal Data must immediately notify COMATEC Saudi Arabia Limited, providing a description of what occurred. Anybody found to have violated this document may be subject to disciplinary action, including termination of employment and termination of contract services.

20

Personal Data Privacy and Protection Document Review

COMATEC Saudi Arabia Limited reserves the right to make changes to this document at any time and for any reason. Any changes or modifications will be effective immediately upon posting the updated document. You are encouraged to periodically review this document to stay informed of updates. You will be deemed to have been made aware of, to be subject to, and to have accepted the changes in any revised document by your continued use of COMATEC Saudi Arabia Limited's sites and services after the date such revised document is updated.

COMATEC Saudi Arabia Limited Personal Data Privacy and Protection