We create high-quality software for customers across the Globe.

Introduction

This Privacy Policy outlines how Codellon Ltd, a company registered in Cyprus under registration number HE 416611 (“Codellon”, “we”, “our” or “us”), collects, uses, maintains, and discloses your personal information when you interact with us, apply for roles, or use our services. We are committed to ensuring that your privacy is protected and that we comply with our obligations under applicable data protection legislation, including the General Data Protection Regulation (GDPR).

Data Controller

Codellon Ltd is the data controller for any personal data you provide to us. Our registered address is 68 Agios Athanasios, Limassol, Cyprus 4102

Data Protection Officer

We have appointed a Data Protection Officer (DPO) to oversee compliance with this Policy. If you have any questions regarding this Policy or how we handle your personal data, please contact our DPO at: dpo@codellon.com.

What Personal Data We Collect

We may collect and process the following categories of personal information:

• Full name, postal address, email address, and telephone numbers.
• Date of birth, nationality, gender, and marital status.
• Employment history, qualifications, skills, and references.
• Identification documents such as passport or driving license details.
• Financial information related to payroll (e.g., bank details, social security number).
• Information collected during interviews, assessments, or communications.
• Sensitive personal data, such as health information (where required and permitted by law).
• Information relating to criminal records where legally required.

How We Use Your Personal Information

We use your information for the following purposes:

• Assessing your suitability for employment or engagement with Codellon or its clients.
• Communicating with you during the recruitment process.
• Managing our relationship with you as an employee, contractor, or candidate.
• Fulfilling our contractual obligations and employment requirements.
• Carrying out background checks where necessary and permitted.
• Maintaining internal records and administrative purposes.
• Improving our services and operations.
• Complying with our legal and regulatory obligations.

We will always process your personal data lawfully and only where we have a valid legal basis to do so, including consent (where required), legitimate interests, performance of a contract, and compliance with legal obligations.

Retention of Your Data

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Typically, if we have had no meaningful contact with you for a period of five (5) years, we will securely delete your data, unless there is a legitimate reason to retain it longer.

Data Security

We are committed to protecting your personal data. We have implemented appropriate technical and organizational measures to secure your information against unauthorized access, disclosure, or loss. Access to your personal data is limited to those employees, agents, contractors, and other third parties who have a business need to know.

Your Rights

Under GDPR, you have rights regarding your personal information, including:

• The right to access the information we hold about you.
• The right to correct inaccuracies in your data.
• The right to request erasure of your personal data.
• The right to object to the processing of your data where we rely on legitimate interests.
• The right to restrict processing under certain circumstances.
• The right to data portability to another service provider.

To exercise any of your rights, please contact our DPO at dpo@codellon.com. You also have the right to lodge a complaint with the supervisory authority, the Office of the Commissioner for Personal Data Protection in Cyprus.

Sharing Your Data

We may share your personal data with:

• Internal departments across Codellon entities globally.
• Clients of Codellon where

necessary for placement opportunities (with your consent).

• Third-party service providers, including IT providers, payroll providers, and background check agencies.
• Public authorities, if required by law.
• Our auditors, legal advisors, or insurers as necessary.

We require all third parties to respect the security of your data and to treat it in accordance with applicable laws.

International Transfers

As Codellon operates globally, your data may be transferred outside the European Economic Area (EEA). Where such transfers occur, we ensure that appropriate safeguards are in place to protect your personal data, such as standard contractual clauses or other recognized mechanisms.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Any substantial changes will be communicated to you, and the latest version will always be available upon request or via our website.

Contact

If you have any questions about this Privacy Policy or how we process your data, please contact:

Data Protection Officer
Email: dpo@codellon.com