Privacy Policy | KB Associates

1. INTRODUCTION

KB Associates (referred to herein as “KB Associates,” “we,” “our,” or “us”) is a boutique Human Capital Consultancy operating across the AfME region and beyond, with its principal office in the United Arab Emirates. We are committed to protecting the privacy and personal data of all individuals with whom we interact — including clients, candidates, participants in our programs, visitors to our website, and all other stakeholders.

This Privacy Policy (the “Policy”) explains how KB Associates collects, uses, stores, discloses, and protects personal information in connection with:

Our consulting, training, coaching, and facilitation engagements;
Our website and any digital platforms operated by us;
Assessment centres, talent diagnostics, and leadership development programs;
Any correspondence, surveys, or communications you have with us;
Events, workshops, retreats, and other program activities we facilitate.

By engaging with KB Associates or providing us with your personal information, you acknowledge that you have read and understood this Policy. We encourage you to review this Policy periodically, as it may be updated from time to time to reflect changes in our practices or applicable law.

2. WHO WE ARE

KB Associates is a boutique Human Capital Consultancy specializing in organizational consulting services across four practice pillars: People, Organisation, Culture, and Leadership. Our services include, but are not limited to, capability development programs, leadership development journeys, executive coaching, assessment centres, competency framework design, change management advisory, and strategic alignment facilitation.

For the purposes of applicable data protection law, KB Associates acts as the data controller in respect of personal data collected through our own consulting activities, website operations, and direct client and program participant interactions. Where we collect and process personal data on behalf of our clients (for example, in connection with assessment centres or engagement surveys conducted for a client organization), we act as a data processor under the instructions of that client.

Data Controller: KB Associates, United Arab Emirates
Privacy Contact: Office@kbassociates.net
Postal Address: KB Associates, Creative Tower P.O.BOX 4422 Fujairah, UAE

3. PERSONAL INFORMATION WE COLLECT

The personal information we collect depends on the nature of your relationship and interaction with KB Associates. We collect only what is necessary for the purposes described in this Policy.

3.1 Information You Provide Directly

When you engage with KB Associates in any capacity, you may provide us with personal information such as:

Identity Information: Full name, title, professional designation, and photograph (where applicable);
Contact Information: Email address, telephone number, business address, and social media handles;
Professional Information: Employer name, job title, seniority level, career history, qualifications, and areas of expertise;
Assessment and Diagnostic Data: Responses to psychometric tools, 360° feedback instruments, competency assessments, role-play simulations, and other talent evaluation exercises;
Learning and Development Records: Program participation, attendance, assessment results, progress records, and certifications earned;
Coaching Information: Notes, goals, development commitments, and reflections arising from coaching engagements (held in strict confidence);
Survey and Research Responses: Opinions, feedback, preferences, and qualitative inputs provided through surveys or research activities;
Financial Information: Billing details, invoicing information, and payment records where relevant to a contractual engagement;
Communications Data: Content of emails, messages, or correspondence exchanged with our team.

3.2 Information Collected Through Our Website and Digital Platforms

When you visit our website or interact with our digital platforms, we may automatically collect:

Device and Technical Data: IP address, browser type and version, operating system, device identifiers;
Usage Data: Pages visited, time spent, links clicked, referral sources, and navigation patterns;
Cookie Data: Data collected through cookies and similar tracking technologies, as described in our Cookie Notice.

3.3 Information Received from Third Parties

In connection with our services, we may receive personal information about individuals from:

Client Organizations: Where a client engages us to deliver programs or assessments for their employees, we may receive information about participants from the client;
References and Nominators: Where an individual is nominated by a manager or HR team for a development program or assessment;
Publicly Available Sources: Professional profiles on LinkedIn and other publicly accessible platforms, relevant to our talent-related advisory services;
Partner Organizations: Program co-deliverers, co-facilitators, or accreditation bodies where jointly delivered solutions are involved.

3.4 Sensitive Personal Data

We do not routinely collect sensitive or special categories of personal data. In limited circumstances — for example, to accommodate dietary, health, or accessibility requirements at in-person events — we may collect such information with your explicit consent. Any sensitive personal data is handled with heightened care and is not used for any purpose beyond the immediate and specific reason for which it was collected.

4. How We Use Your Personal Information

KB Associates uses personal information only for legitimate, specified purposes. The table below sets out the primary purposes for which we process personal data and the legal basis on which we rely for each.

Purpose	Description	Data Categories	Legal Basis
Service Delivery	Delivering consulting engagements, capability programs, coaching, facilitation, assessment centres, and all other KB Associates services.	Identity, Contact, Professional, Assessment & L&D Data	Contractual necessity; Legitimate interests
Client Relationship Management	Managing and maintaining our business relationships with client organizations and key contacts, including communications, proposals, and project coordination.	Identity, Contact, Business & Communications Data	Legitimate interests
Assessment & Talent Diagnostics	Designing, administering, and reporting on competency-based assessments, talent diagnostics, 360° feedback tools, and other evaluation instruments on behalf of clients.	Assessment Data, Professional Information	Contractual necessity; Client instruction (as Processor)
Learning & Development Tracking	Recording program participation, progress, outcomes, and certifications to enable effective program management and impact measurement.	L&D Records, Identity Data	Contractual necessity; Legitimate interests
Executive & Team Coaching	Supporting confidential individual and team coaching engagements. Coaching session records are maintained under strict confidentiality and are not shared with third parties, including client organizations, without the explicit consent of the coachee.	Coaching Information, Identity Data	Contractual necessity; Consent (where applicable)
Marketing & Thought Leadership	Sending relevant communications about our services, thought leadership, events, and insights. You may opt out of such communications at any time.	Identity, Contact, Communications Data	Consent; Legitimate interests
Research & Impact Measurement	Conducting anonymized or aggregated research and analysis to measure program impact, improve our service quality, and produce industry insights. Individual data is not disclosed in any published output.	Aggregated / Anonymized Data	Legitimate interests
Legal and Compliance Obligations	Complying with applicable laws and regulations, responding to lawful requests from authorities, enforcing contractual rights, and maintaining appropriate records.	As required by applicable law	Legal obligation
Website and Platform Operations	Operating, maintaining, and improving our website and any digital platforms, including security monitoring, analytics, and user experience improvement.	Device, Usage & Cookie Data	Legitimate interests; Consent (cookies)

5. CONFIDENTIALITY OF COACHING ENGAGEMENTS

KB Associates applies the highest standards of professional confidentiality to all coaching engagements, consistent with the ICF (International Coaching Federation) Code of Ethics. The content of individual coaching sessions — including goals, challenges, reflections, and development commitments — is treated as strictly confidential and is not disclosed to the client organization, line managers, HR teams, or any other third party without the explicit written consent of the individual being coached.

Exceptions to this confidentiality obligation exist only where: (a) the individual gives informed consent to specific disclosure; (b) disclosure is required by applicable law or court order; or (c) there is a serious and imminent risk to the health or safety of the individual or another person.

Where team coaching is undertaken, KB Associates will agree confidentiality protocols with all team participants at the commencement of the engagement.

6. DISCLOSURE OF PERSONAL INFORMATION

KB Associates does not sell, rent, or trade your personal information. We share personal information only in the following circumstances and with appropriate safeguards:

6.1 Client Organizations

Where we deliver programs, assessments, or services on behalf of a client organization, we may share aggregated program reports or individual participant feedback with that client to the extent agreed in our engagement terms and disclosed to participants at the outset of the program. Individual coaching information is never shared with client organizations without explicit consent.

6.2 Service Providers and Sub-Processors

We may engage third-party service providers who process personal data on our behalf, including IT and platform providers, assessment tool vendors, translation or transcription services, and event management support. All such providers are subject to written data processing agreements requiring them to maintain appropriate security and confidentiality standards and to use personal data only for specified purposes.

6.3 Professional and Legal Advisors

We may disclose personal information to our legal counsel, auditors, insurers, or professional advisors where necessary for the conduct of our business or to protect our legal rights, in each case subject to appropriate confidentiality obligations.

6.4 Regulatory and Legal Requirements

We may disclose personal information where required to do so by applicable law, regulation, court order, or lawful authority request. Where permitted by law, we will notify the individual concerned of any such requirement prior to disclosure.

6.5 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or a portion of KB Associates’ business, personal information may be transferred to the successor entity, subject to equivalent privacy protections.

7. INTERNATIONAL DATA TRANSFERS

KB Associates operates across the AfME region and beyond. In delivering our services, personal information may be accessed by or transferred to team members, associates, or service providers located in countries outside the UAE. Where such transfers occur, we ensure that appropriate safeguards are in place — including contractual data transfer protections or equivalent mechanisms — to maintain the same standard of data protection regardless of the jurisdiction in which the information is processed.

8. DATA SECURITY

KB Associates is committed to protecting your personal information against unauthorized access, disclosure, alteration, or destruction. We implement appropriate technical and organizational security measures proportionate to the nature of the personal data we process and the risks involved. These include:

Restricted access controls — personal data is accessible only to KB Associates personnel and authorized associates who require it for the performance of their role;
Secure storage — personal data is stored using password-protected, encrypted systems;
Confidentiality obligations — all personnel and associates are subject to binding confidentiality obligations;
Vendor due diligence — third-party service providers are assessed for security standards prior to engagement;
Incident response — we maintain procedures to detect, contain, and respond to data security incidents in accordance with applicable law.

Notwithstanding the above, no method of electronic transmission or storage is entirely secure, and we cannot guarantee the absolute security of your personal information. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately at Office@kbassociates.net.

9. DATA RETENTION

KB Associates retains personal information only for as long as is necessary to fulfil the purposes for which it was collected, to meet our legal and contractual obligations, and in accordance with our internal data retention guidelines.

In determining the appropriate retention period, we consider: the duration and nature of the client engagement; the legal and regulatory retention requirements applicable in the UAE and relevant jurisdictions; the risk of harm from unauthorized disclosure; and the cost and feasibility of maintaining the information.

As a general guide:

Client engagement records (including program materials and reports): retained for the duration of the client relationship and for a period of up to 7 years thereafter, unless a shorter period is required by law;
Assessment and talent diagnostic reports: retained in accordance with the terms agreed with the client organization;
Coaching notes and records: retained only for the duration of the coaching engagement plus a reasonable period to address any post-engagement matters, and securely deleted thereafter;
Website usage and analytics data: retained for the period necessary to fulfil the specified analytics or security purpose, typically up to 24 months;
Marketing communications data: retained until you withdraw consent or request deletion.

Upon expiry of the applicable retention period, personal information is securely deleted or anonymized in accordance with our standard procedures.

10. YOUR DATA PROTECTION RIGHTS

Subject to applicable law and certain exceptions, individuals whose personal data we process have the following rights:

Purpose	Description
Right to Access	You have the right to request confirmation of whether we hold personal data about you and, if so, to receive a copy of that data together with information about how it is being used.
Right to Rectification	You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
Right to Erasure	You have the right to request that we delete your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where applicable law so requires.
Right to Restriction	You have the right to request that we restrict the processing of your personal data in certain circumstances — for example, where you contest its accuracy or object to its use.
Right to Data Portability	Where processing is based on your consent or on a contract, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format and to request that it be transmitted to another controller.
Right to Object	You have the right to object to the processing of your personal data where we rely on legitimate interests as our legal basis, or at any time where processing is for direct marketing purposes.
Right to Withdraw Consent	Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.
Right Not to Be Discriminated Against	We will not discriminate against you for exercising any of your data protection rights.

To exercise any of your rights, please contact us at Office@kbassociates.net. We will acknowledge your request within 5 business days and respond within 30 days, or such shorter period as may be required by applicable law. We may request reasonable verification of your identity before processing your request.

Please note that certain rights are subject to limitations and exceptions under applicable law. Where we are unable to comply with your request in full, we will provide a clear explanation of the reason.

11. COOKIES AND TRACKING TECHNOLOGIES

Our website uses cookies and similar tracking technologies to operate effectively, analyze usage, and improve the user experience. Cookies are small data files stored on your device when you visit our website.

We use the following categories of cookies:

Strictly Necessary Cookies: Essential for the basic functioning of our website. These cannot be disabled.
Performance and Analytics Cookies: Help us understand how visitors interact with our website, including which pages are most visited and where users encounter errors.
Functional Cookies: Enable enhanced functionality such as remembering your preferences.
Marketing Cookies: Used to deliver relevant content and track the effectiveness of our communications. These are enabled only with your consent.

You may manage your cookie preferences through your browser settings or via any cookie management tool available on our website. Disabling certain cookies may affect the functionality of our website. For further information, please refer to our separate Cookie Notice.

12. CHILDREN’S PRIVACY

KB Associates’ services are intended for professional and organizational audiences. We do not knowingly collect or process personal information from individuals under the age of 18. If we become aware that we have inadvertently received personal information from a minor, we will take prompt steps to delete such information. If you believe we have collected information from a minor, please contact us at Office@kbassociates.net.

13. LINKS TO THIRD-PARTY PLATFORMS

Our website or communications may contain links to third-party websites, platforms, or tools — including professional networks, assessment platforms, or event registration systems. KB Associates is not responsible for the privacy practices of third-party platforms and encourages you to review their privacy notices independently. This Policy applies only to personal information collected directly by KB Associates.

14. CHANGES TO THIS PRIVACY POLICY

KB Associates reserves the right to update or modify this Privacy Policy at any time to reflect changes in our business practices, services, or applicable law. Where changes are material, we will provide notice through our website or by direct communication to affected individuals. The effective date at the top of this document will be updated accordingly.

We encourage you to review this Policy periodically. Your continued engagement with KB Associates following notification of changes constitutes your acknowledgment of the updated Policy.

15. HOW TO CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or the way we handle your personal information, please contact us:

Company:: KB Associates
Email:: Office@kbassociates.net
Address:: KB Associates FZ LLC Fujairah - Creative Tower, P.O.Box 4422, UAE