We are skilled Ukrainian team that creates value to the customers and helps our nation fight for freedom! Up to 20% of our net income we donate to Ukrainians for their fight. Work with us is full fill your business goals as well as support freedom aspiration of the bravest nation in the 21st century
We are skilled Ukrainian team that creates value to the customers and helps our nation fight for freedom! Up to 20% of our net income we donate to Ukrainians for their fight. Work with us is full fill your business goals as well as support freedom aspiration of the bravest nation in the 21st century

Privacy Policy

Last updated: December 8, 2023

1. SCOPE 

1.1. All data subjects whose personal data is collected, in line with the requirements of the GDPR. 

2. RESPONSIBILITIES 

2.1. The Data Protection Officer is responsible for ensuring that this notice is made available to data subjects prior to KEETCODE LTD collecting/processing their personal data.

2.2. All employees, advisors, contractors and consultants of KEETCODE LTD who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured. 

3. PRIVACY NOTICE

3.1. KEETCODE LTD. WHO ARE WE? 

3.1.1. Our Data Protection Officer and data protection representatives can be contacted directly here:​ Anastasia Vasiliou, dpo@keetcode.com 

3.2. THE PERSONAL DATA KEETCODE LTD MAY COLLECT:

3.2.1. For potential and current client and their representatives: (a) basic information, including name (with title and/or name prefix), the company where the Data Subject works, and their title/position; (b) Contact information, such as email address, contact phone number, etc. (c) Identification information provided by the Data Subject to the KEETCODE LTD; (d) Payment-related information; (e) Information provided by the Data Subject for scheduling meetings and events.

3.2.2. For potential candidates (employees, contractors, advisors): (a) basic information, including name (with title and/or name prefix), the company where the Data Subject works or worked, and their title/position; (b) Contact information, such as email address, contact phone number, etc. (c) Identification information provided by the Data Subject to the KEETCODE LTD.

3.2.3. For current employees, contractors, advisers: (a) basic information, including name (with title and/or name prefix), the company where the Data Subject works, and their title/position; (b) Contact information, such as email address, contact phone number, etc. (c) Identification information provided by the Data Subject to the KEETCODE LTD; (d) Payment-related information.

3.2.4. Using the KEETCODE LTD services (“Esteeme project”): name, last name, mobile phone number, country, region, city, zip code, delivery address, clothes size, job position, department, manager, company, employment type, country, location, pronunciation. 

3.3. BASIS FOR UTILIZING PERSONAL DATA. The KEETCODE LTD uses Personal Data on the following grounds:

3.3.1 To fulfill contractual obligations for providing services.

3.3.2. For the establishment, exercise, or defense of legal claims or proceedings.

3.3.3. To comply with legal and regulatory obligations.

3.3.4. For legitimate business purposes.

3.3.5. Consent, where mandated by applicable laws.

4. CONSENT

4.1. By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. 

4.2. Consent is required for KEETCODE LTD to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used. 

4.3. You may withdraw consent at any time by contacting our Data Protection Officer - Anastasia Vasiliou, dpo@keetcode.com. 

5. DISCLOSURE

5.1 SHARING OF PERSONAL DATA. The KEETCODE LTD has the discretion to share Personal Data with specific third parties in alignment with existing contractual agreements, which may include:

5.1.1. Professional advisers, auditors, and potential transaction partners.

5.1.2. IT service providers, including those offering cloud services and client relationship management (CRM) services.

5.1.3. Third parties engaged in delivering requested services to customers.

5.1.4. Third parties involved in hosting or organizing meetings or events.

5.2. When deemed essential, Personal Data may be shared with regulatory authorities, courts, tribunals, government agencies, and law enforcement agencies. While the likelihood is minimal, the KEETCODE LTD may need to disclose Personal Data to adhere to legal or regulatory requirements. In such instances, the KEETCODE LTD will make reasonable efforts to notify the Data Subject before such disclosure, unless legally prohibited from providing such notification.

5.3. Moreover, the KEETCODE LTD may transfer Personal Data (either partially or in its entirety) to new affiliates, subsidiaries, assignees, or third parties involved in the KEETCODE LTD's business operations. In no circumstances does the KEETCODE LTD sell, rent, or commercially provide Personal Data to any third party without your prior permission.

5.4. Under no circumstances does the KEETCODE LTD sell, rent, or make Personal Data commercially available to any third party without your prior permission.

6. STORAGE PERIOD FOR PERSONAL DATA. 

6.1. The KEETCODE LTD will retain collected Personal Data for as long as necessary to fulfill the purposes for which it was collected and processed. To determine the appropriate retention period, the KEETCODE LTD will consider factors such as the volume, nature, and sensitivity of the data collected, the potential risk of harm from unauthorized use or disclosure, the purposes for which Personal Data is processed, and whether these purposes can be achieved through alternative means, as well as applicable legal requirements. Upon the expiration of the applicable retention period, we will securely destroy the collected Personal Data.

7. YOUR RIGHTS AS A DATA SUBJECT 

7.1. At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights: 

7.1.1. Right of access – you have the right to request a copy of the information that we hold about you.

7.1.2. Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

7.1.3. Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

7.1.4. Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.

7.1.5. Right of portability – you have the right to have the data we hold about you transferred to another organisation.

7.1.6. Right to object – you have the right to object to certain types of processing such as direct marketing.

7.1.7. Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling

7.1.8. Right to judicial review: in the event that KEETCODE LTD refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 8 below.

8. COMPLAINTS 

8.1. In the event that you wish to make a complaint about how your personal data is being processed by KEETCODE LTD (or third parties as described in 5.1 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and KEETCODE LTD’s data protection representatives or Data Protection Officer. The details for each of these contacts are: 

8.1.1. SUPERVISORY AUTHORITY CONTACT DETAILS: 

OFFICE OF THE COMMISSIONER FOR PERSONAL DATA PROTECTION

Ms Irene Loizidou Nikolaidou – Commissioner for Personal Data Protection

Iasonos Street, 1, 1082, Nicosia, Cyprus

P.O. Box 23378, CY-1682, Nicosia, Cyprus

Tel. +357 22 818 456

Fax +357 22 304 565

commissioner@dataprotection.gov.cy

8.1.2. DATA PROTECTION OFFICER​ CONTACT DETAILS: 

KEETCODE LTD

Griva Digeni, 34Α Office 202 3106, Limassol, Cyprus

Anastasia Vasiliou, 

dpo@keetcode.com 

9. ONLINE PRIVACY STATEMENT 

9.1. PERSONAL DATA

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person." 

9.2. HOW KEETCODE LTD USES YOUR INFORMATION

This privacy notice tells you how we, KEETCODE LTD, will collect and use your personal data for the purposes mentioned in clause 3.3.

9.3. WHY DOES KEETCODE LTD NEED TO COLLECT AND STORE PERSONAL DATA? 

For the purposes mentioned in clause 3.3. we need to collect personal data mentioned in the clause 3.2. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. In terms of being contacted for marketing purposes KEETCODE LTD would contact you for additional consent. 

9.4. WILL GCS SHARE MY PERSONAL DATA WITH ANYONE ELSE?

We may pass your personal data on to third-party service providers (clause 5.1.) contracted to KEETCODE LTD in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only for legitimate purposes. When they no longer need your data to fulfil this service, they will dispose of the details in line with KEETCODE LTD procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

9.5. HOW WILL KEETCODE LTD​ USES THE PERSONAL DATA IT COLLECTS ABOUT ME?

KEETCODE LTD will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. KEETCODE LTD is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

9.6. UNDER WHAT CIRCUMSTANCES WILL KEETCODE LTD CONTACT ME?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimize the risk of unauthorised access or disclosure. 

9.7. CAN I FIND OUT THE PERSONAL DATA THAT THE ORGANISATION HOLDS ABOUT ME?

KEETCODE LTD at your request, can confirm what information we hold about you and how it is processed. If KEETCODE does hold personal data about you, you can request the following information: 

  • Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.

  • Contact details of the data protection officer, where applicable. The purpose of the processing as well as the legal basis for processing. 

  • If the processing is based on the legitimate interests of KEETCODE LTD or a third party, information about those interests.

  • The categories of personal data collected, stored and processed.

  • Recipient(s) or categories of recipients that the data is/will be disclosed to.

  • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information. 

  • How long the data will be stored.

  • Details of your rights to correct, erase, restrict or object to such processing.

  • Information about your right to withdraw consent at any time.

  • How to lodge a complaint with the supervisory authority.

  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.

  • The source of personal data if it wasn’t collected directly from you.

  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing. 

9.8. WHAT FORMS OF ID WILL I NEED TO PROVIDE IN ORDER TO ACCESS THIS? 

KEETCODE LTD will request reasonable information to judge whether the requester (or the person the request is made on behalf of) is the person that the data is about. In any case, KEETCODE LTD will not request more information if the requestor's identity is obvious to us. 

Contact Us

If you have any questions about this Privacy Policy, You can contact us: