PLACEMENT PRIVACY POLICY
Effective Date: 20 November, 2025
Last Updated: 20 November, 2025
1. Introduction
This Privacy Policy explains how Oxygen HealthCare Technologies LLC ("Company," "we," "our," or "us") collects, uses, processes, and protects personal data in connection with the MyPlacement software platform ("Platform").
The Platform operates exclusively within a closed university environment. Access is granted only to students, coordinators, and authorized personnel whose accounts are created under a formal contractual agreement ("B2B Agreement") between the Company and the partnering university or educational institution ("University Partner").
This Policy complies with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL), its Executive Regulations, and international best practices inspired by GDPR where appropriate.
2. Personal Data We Collect
We collect only the minimum necessary personal data required to deliver placement management services.
2.1 Student Personal Data:
- Full name
- University student ID or roll number
- University-issued email
- Placement assignment details
- Real-time location data collected strictly during active use of the Platform and scheduled placement duty
- Activity timestamps
2.2 Coordinator and University Personnel Data:
- Full name
- University-provided contact information
- Role, position, and authorization level
- Activity logs
2.3 What We Do NOT Collect:
- No biometric data
- No device identifiers or metadata
- No background tracking outside app usage
- No unrelated personal data
3. Legal Basis for Processing
- Performance of Contract
- Legitimate Interests
- Consent (where required)
- Compliance with Legal Obligations
4. Purpose of Processing Personal Data
- Placement assignment management
- Attendance verification
- Fraud prevention
- Coordinator supervision
- Audit logs
- Platform improvement
5. Location Tracking
Location is collected only during:
- Active app usage, and
- Scheduled placement duty.
Tracking is not active in the background and is disabled outside duty times.
7. International Data Transfers
Transfers comply with UAE PDPL and contractual safeguards.
8. Data Retention
- Location data: retained for a defined period (e.g., 90 days) unless required longer.
- Logs: retained per B2B Agreement.
- Accounts deleted on contract termination.
9. User Rights
Users may request access, correction, deletion, restriction, or withdrawal of consent.
10. Security Measures
Includes encryption, role-based access, audits, and monitoring.
11. Children’s Data
The Platform is intended for university-level students.
12. Policy Updates
We may modify this Policy anytime.
13. Contact Information
Data Protection Office
Oxygen HealthCare Technologies LLC
Sahab 1 Building - Al Nuaimia 1 - Ajman - United Arab Emirates
Email: info@oxygen-hc.com