Privacy policy
NextCode

Purpose and Scope;

The NEXTSPHERE INNOVATIONS LTD (the “Company”, “we”, “us” or “our”), strives to comply with applicable laws and regulations related to personal data protection in countries where the Company operates. This Policy sets forth the basic principles by which the Company processes your personal data, and indicates the responsibilities while processing personal data;

The Company does not knowingly attempt to solicit or receive information from children under 16 years of age.

The Company acknowledges and understands that you are aware of and care about your own personal privacy interests, and the Company takes that seriously. This Privacy Policy describes the policies and practices concerning the collection and use of your personal data and sets forth your privacy rights. The Company recognizes that data privacy is an ongoing responsibility, and, therefore, the Company will from time to time update this Privacy Policy and its privacy practice as the Company undertakes new personal data practices or adopts new privacy policies.

Company’s website;

The Company controls and manages www.nextcode.tech – hereinafter the “Website”) which may collect particular data for its business purposes.

Definitions of legal bases for the processing;

Consent – your clear agreement to the processing of your personal data for a specific purpose.

Contract – the reason why the processing is necessary is based on a contract you have with the Company, or because the Company has asked you to take specific steps before entering into that contract.

Legitimate Interests: the reason the processing of your data is necessary, which is based on the legitimate interests or the legitimate interests of a third party, provided those interests are not outweighed by your rights and interests. These legitimate interests are:

• Gaining insights from your behavior on the website;
• Delivering, developing, and improving the website;
• Enabling the Company to enhance, customize, or modify the website and services;
• Enhancing data security.

Consent rule;

If you have given consent to the processing of your data you can freely withdraw such consent at any time by emailing the Company to [email protected]

If you do withdraw your consent, and if the Company does not have another legal basis for the processing of your data, then the Company will stop the processing of your personal data.

If the Company has an additional legal basis for the processing of your data, it may proceed with the processing, subject to your legal interests and rights.

Company’s responsibilities;

If you are a registered user or a visitor to the Website the Company acts as the ‘data controller’ of personal data. This means that the Company determines how and why your data are processed.

Your responsibilities;

Read this Privacy Policy carefully.

If you provide the Company with personal data about other individuals, the Company will only employ that data for the special reason for which it was provided to the Company. By sending the data, you confirm that you have the right to dispose of to process the data on your behalf under this Privacy Policy.

Treat your personal data as confidential and secure.

Collected data;

The Company collects data when you interact with its website, especially when:

• Browse any page of the website;
• The company calls you;
• Use the website and receive services;
• Receive emails from the Company;
• Chat with the Company for customer support.

The company collects the following categories of data:

• Name and surname;
• Contact address;
• Contact details, such as your email address and phone number;
• Working experience and educational background;
• Data that identifies you, such as your IP address, login information, browser type and version, time zone setting, browser plug-in types, geolocation information about where you might be, operating system and version;
• Data on how you use the website, such as your URL clickstreams (the path you take through the website), goods or services viewed, page response times, download errors, how long you stay on webpages, what you do on those pages, how often, and other actions.

The recipients of the collected data are the highest management level of the Company, its employees and contractors, and other third-party service providers mentioned below.

Purposes and legal basis for the processing;

The Company processes the data for:

• Evaluating your personal and professional traits in the contractor engagement context for a particular position, helping facilitate your professional growth;

Communicating with you via respective means of communication about matters on contractual relationship:

• Details: The company needs to provide the above described via the Website.
• Legal basis: Consent; Contract; Legitimate Interests.

Keeping the Website running:

• Details: managing your requests, login, and authentication, remembering your settings, hosting, and back-end infrastructure.
• Legal basis: Contract; Legitimate Interests.

Improving the Website:

• Details: testing features, interacting with feedback platforms and questionnaires, managing landing pages, heat mapping the Website, traffic optimization, and data analysis and research, including profiling and the use of machine learning and other techniques over your data, and in some cases using third parties to do this.
• Legal basis: Contract; Legitimate Interests.

Customer support:

• Details: notifying you of any changes, solving issues, or any bug fixing.
• Legal basis: Contract; Legitimate Interests.

Preventing fraud:

• Details: evercookies. Evercookies is a javascript API available that produces extremely persistent cookies in a browser which helps us identify that no user creates an additional account.
• Legal basis: Legitimate Interests.

Your rights

You may choose not to provide the Company with personal data. If you choose to do so, you can continue to visit the Website and browse its pages, but the Company will not be able to provide its services without personal data.

You may turn off cookies in your browser via settings. You can block cookies on your browser by refusing cookies. You may delete cookies. If you turn off cookies, you can continue to use the Website and browse its pages, but the Website and certain services will not work properly.

You can exercise the following rights by sending us an email at [email protected].

• You have the right to access information about you, especially:
  • The categories of data;
  • The purposes of data processing;
  • Third parties to whom the data is disclosed;
  • How long the data will be retained, and the criteria used to determine that period;
  • Other rights regarding the use of your data.
• You have the right to make the Company correct any inaccurate personal data about you.
• You can object to the Company using your personal data for profiling you or making automated decisions about you. The Company may use your data to determine whether we should let you know information that might be relevant to you (for example, tailoring emails to you based on your behavior).
• You have the right to the data portability of your data to another service or Website. The Company will give you a copy of your data in readable format so that you can provide it to another service. If you ask us and it is technically possible, we will directly transfer the data to the other service for you.
• You have the right to be 'forgotten'. You may ask to erase any personal data about you if it is no longer necessary for the Company to store the data for purposes of your use of the Website.
• You have the right to complain about the use of your data by the Company. You can address any complaint to the Commissioner for Personal Data Protection.

In the context of the right to access information, the Company shall provide you with the information within one month of your request unless there is a justified requirement to provide such information faster.

Security

We have security and organizational measures and procedures to secure the data collected and stored. We have security policies and data processing agreements with all our employees and contractors who are obliged to follow and maintain appropriate technical and organizational measures. We have an internal Information Security Policy.

Connections to the Website are encrypted. We use servers that comply with strict international data security standards.

You acknowledge that no perfect security infrastructure exists, no data transmission is guaranteed to be 100% secure, and there may be some security risks.

You are responsible for your login information and password. You shall keep them confidential.

In case your privacy has been breached, please contact the Company immediately at [email protected]

Location of the processing of personal data

The personal data collected by the Company is processed at the Company’s offices. The Company is international and can have foreign branches and departments.

Retention period

We store and process your personal data until we do not need it for any of the purposes defined in this Policy unless a longer retention period is required or permitted by law, including to satisfy any legal, accounting, or reporting requirements, or any other lawful purposes.

In the case of most independent contractor data, it is retained for the duration of your contractual relationship with the company and for a particular period established under applicable laws and regulations concerning the storage of such data after that relationship terminates.

When we collect and process your personal data based on your consent, we will keep your personal data during a period specified in the consent or until the withdrawal of the consent. If the purpose for which we have processed the data is fulfilled, we will delete your data even if you do not withdraw the consent.

When we collect and process your personal data based on a contract, the period for the retention of data is the entire period of the validity of the contract, including warranty or any other periods arising from the concluded contract, unless we have a legal obligation for further storage of such data.

Transfer of your personal data

We may transfer your personal data to countries outside the EU and EEA (Ukraine, etc.) that are not determined to offer an adequate level of data protection based on article 45 of GDPR (adequacy decision) with appropriate safeguards as determined under the GDPR.

We only transfer your personal data to third parties within the requirements under the GDPR. Where possible, we always enter into Data Processing Agreements (DPAs) and Non-Disclosure Agreements (NDAs) with them and treat personal data transfer seriously. Where our contractor has an appropriate data processing agreement in place, we may adjoin such a data processing agreement. If so, we may regulate the transfer of Personal Data to such a contractor using this data processing agreement.

For transfers to countries that do not fall under requirements of Article 45 of the GDPR on the adequacy of the level of protection, we may transfer your personal data to third countries outside the EU and the EEA, including the onward transfers of the personal data from the third countries to other third countries, under Article 46 of the GDPR with the appropriate safeguards, including the SCC.

We disclose your personal data to countries outside the EU and the EEA in compliance with our internal international transfer procedure to adduce adequate safeguards concerning the protection of privacy and fundamental rights and freedoms of natural and legal persons.

We put supplementary technical and organizational measures in place when transferring data outside the EU and the EEA, e.g., prior assessment of the service supplier’s reliability and personal data protection practices, encryption of the transferred personal data, prompt reacting to any threats to confidentiality, integrity, and availability of the personal data, conducting transfer impact assessments (TIA) when necessary, etc.

Cookies

Cookies are pieces of data that a Website transfers to a user’s hard drive for record-keeping purposes.

The Company uses cookies to provide proper functionality on the Website and aggregate traffic data (e.g., what pages are popular). The Company may use every cookie concerning Legitimate interest only.

The Company uses the following types of cookies:

• Strictly needed cookies. These cookies are necessary for the Website to work correctly. They will allow you to move our Website and use its capabilities. These files do not identify you as a person. If you do not agree to use this type of file this may affect the proper work of the Website or its components.
• Cookies related to performance, efficiency, and analytics. These files help us understand how you interact with our Website by providing information about the areas visited and the amount of time spent on the Website, as well as showing problems in the operation of the Internet resource, for example, error messages. This will help us to improve the work of the Website.
• Cookies related to analytics. These files help us to measure the effectiveness of advertising campaigns and optimize the content of Websites for those who are interested in our advertising. This type of cookie shall not be used for Your identification. All information that is collected and analyzed is anonymous.
• Advertising cookies. These cookies record information about Your online activities, including visits to our Website, as well as information about the links and advertising that you have chosen to view. The Company uses such files to collect data about your activity on the Internet and determine your interests, which allows the Company to provide advertising that suits your interests and on which you have given your consent.

The Website captures limited data (user-agent, HTTP referrer, last URL requested by the user, client-side and server-side clickstream) about visits to the Website. The Company may use this data to analyze patterns and to perform system maintenance. You have several options for how to manage cookies on your device. All browsers allow you to block or delete cookies from your device. You may consult the privacy features in your browser to understand what you should do if you need to manage cookies.

Contact details of the Data Controller

NEXTSPHERE INNOVATIONS LTD Address: AGATHANGELOS COURT, Flat/Office 203, Limassol, 3041, Cyprus Email: [email protected]