Privacy Policy

Introduction

Chudovo OU, an international software development company, together with its affiliates and subsidiaries (collectively “Chudovo” or “we”), has prepared this Privacy Policy (“Policy”) to outline its online data protection practices. This Policy explains why and what information about you will be collected by Chudovo when you visit its websites at https://chudovo.com/ (“Website”) and when you contact Chudovo by sending an email, filling in the contact form or otherwise, or when you apply for a job posted on our Website. It also describes how the information about you will be used, how you, as a data subject, can control your personal data, and how to get in touch with us if you need to. This Policy also explains our use of cookies.

In light of the EU General Data Protection Regulation (“GDPR”), Chudovo is a controller and a processor of the personal data submitted through this Website and collected in other ways. This means that we are the organization that is legally responsible for deciding how and for what purposes your personal data is used and therefore, responsible for the data processing explained herein.

Please read this Policy carefully before browsing this website. By using this website, you accept this Policy and give us your consent to the processing of your personal data described herein.

We will process your data only as described in this Policy. Our website is not directed to children under the age of 16, and we do not knowingly collect personal data from children of this age group.

This Policy is an integral part of the Terms of Use of this Website. We might update this Policy in the future, so please make sure to read it from time to time.

Should you have any questions or comments on this Policy, please contact us at [email protected].

Personal Data We Collect

We may have access to/collect information that you voluntarily give us or our partners, affiliates, and other third parties via email or other direct contact from you, information we receive from your use of our website, and information we have obtained about you from publicly available sources for our marketing and recruitment activities, to fulfill contract obligations and other aims related to the mentioned above purposes.

If you are a candidate for one of the vacancies open at Chudovo, we are collecting and processing the following personal data either obtained directly from you, or from public sources (such as e.g. LinkedIn, Facebook): your name, phone number, email address, location, information on your CV, LinkedIn profile information, data on our communications with you. Such data is collected and processed for our recruitment endeavors to attract, assess, and onboard potential team members. This processing allows us to match candidates with suitable roles and ensure a fair and efficient hiring process. It is guided by our legitimate business interest in hiring the best talent or your consent when you contact us directly through our website or on our events. We are determined to ensure that all recruitment-related data processing respects the principles of fairness, transparency, accuracy, and confidentiality, providing candidates with clarity and control over their data at all times.

If you are a contact person at a company that is our existing or potential client, we are collecting and processing the following personal data obtained either directly from you, or from public sources (such as e.g. LinkedIn): your name, phone number, email address, location, LinkedIn profile information, your role/position, data on our communications with you. Such data is collected and processed to facilitate proactive client acquisition initiatives; for cultivating and nurturing strong, collaborative relationships with our clients, including, but not limited to, facilitating communication on projects and addressing any matters pertinent to the successful cooperation between us and our clients. This processing is required for Chudovo business operations, development, and growth, and ensures the efficiency and effectiveness of our client engagement processes. In this respect, we rely on our legitimate interests when we communicate with potential clients to engage them or get new projects from existing clients and on the legal basis of contract conclusion and execution for data that is used to communicate with our clients during the contract conclusion and execution.

Please note that we DO NOT collect personal data that is, by its nature, particularly sensitive. This is genetic data, biometric data, data revealing racial or ethnic origin, information about political opinions, sex life, sexual orientation, religion or other beliefs, data concerning health, trade union membership, or other sensitive information.

Please, be aware you may communicate personal data we do NOT require. We will not use this information in any way, besides storing it at our backup server. Please, do not share with us any personal data not requested from you directly.

Purpose of Collecting Your Personal Data

We will use your personal data for several purposes, which include:

• to contact you in order to let you know about products and services that we offer, products and services that our partners offer, to request the products and services you or your company offers, as well as open vacancies that we have and that you may potentially be interested in;
• to communicate with you, including to respond to you regarding the reason you contacted us;
• to improve website user experience;
• to improve our website;
• to improve customer service;
• to administer the contractual relationship;
• to comply with our legal obligations, or as necessary to perform tasks in the public interest, or to protect the vital interests of our users and other people.

Your personal data will be added to our internal secured CRM system or other internal secured databases only if you are our existing client.

Lawful Basis for Processing

We process your personal data on the following lawful basis and for the following reasons:

• Your consent

We rely on your consent when we use your personal data for optimizing and enhancing the operation of our website and developing new features and services (including when it is collected as a part of the aggregated data). We also rely on this legal basis when we respond to you upon you have contacted us, for example regarding open vacancies or cooperation opportunities as well as when you attend our events.

You have a right to withdraw consent to the processing of your personal data. You may enjoy this right at any time you wish. Please remember, that the withdrawal of consent does not mean that the processing before the withdrawal is considered thus illegal. Please also take into account that if you have withdrawn your consent to the processing of your personal data, we may be limited in responding to you and/or providing you with our services and job opportunities.

• Compliance with our legal obligations

We rely on this legal basis to identify you and verify your identity (when relevant) or to help prevent and detect fraud against you or us, to protect the security of systems and data, or for disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, (e.g., to record and demonstrate evidence of your consents, to retain HR and recruitment data as well as data related to contract execution).

All applicable laws depending on the relationship between you and us may affect the scope of personal data we collect, the ways we process your personal data, our ability to keep the confidentiality of your data and avoid their disclosure, duration of the planned retention, etc.

• For the performance of a contract with you or to take steps at your request before entering a contract

We rely on this legal basis to provide certain services to you or to engage in employment or other contractual relations with you or the company that you represent.

• To perform a task carried out in the public interest

We rely on this legal basis to report to the police or other competent enforcement agencies in case we discover fraud or any other violations of the applicable law or suspicious behavior or actions committed by you during your interaction with us, as well as in other cases when the disclosure of your personal data is required.

• For our legitimate interests or those of a third party

We rely on this legal basis to contact you regarding potential cooperation between you and/or the company you represent with us; to inform you about our open vacancies; to enable or administer our business (quality control, consolidated reporting, customer service), transfer of ownership and so on.

When we receive your explicit consent, we may run automated decision-making devices or software including those based on all the data aggregated, and may use personal information we collect about you for profiling.

You, as a Data Subject, have the right to:

• Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding or using it.
• Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request the erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground.
• Object to automated decision-making, including profiling, that is not to be the subject of any automated decision-making by us using your personal information or profiling of you.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
• Request transfer of your personal information in an electronic and structured form to you or to another party. This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
• Withdraw consent. You have the right to withdraw your consent to the collection, processing, and transfer of your personal information for a specific purpose at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. The withdrawal of consent will not affect the lawfulness of processing based on consent prior to its withdrawal.

If you want to exercise any of these rights, please contact us at [email protected]. The request response time is one month.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This is another security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Please exercise your rights wisely and note that abuse of rights may entail your liability.

Safety of Your Personal Data

We make sure to use appropriate technical and physical security measures to protect your personal data which is transmitted, stored, or otherwise processed by us, from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access.

Your personal data is securely stored by Chudovo on its servers and on the servers of the cloud-based database management services that Chudovo engages in, such as WP Engine.

We will not retain your data for longer than it is necessary to fulfill the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process it, and whether we can achieve those purposes through other means. We must also consider periods for which we might need to retain personal data in order to meet our legal obligations or to deal with complaints, and queries, and to protect our legal rights in the event of a claim being made. When we no longer need your personal data, we will securely delete or destroy it.

Data transfer

Since Chudovo is an international organization, we may disclose your data by transmission, dissemination, or otherwise making it available. To the extent permitted by applicable data protection laws, your personal data may be transferred between various locations of Chudovo and thus processed in the European Economic Area and outside of it, depending on the purpose of processing. Such transfer and processing are possible only as reasonably necessary for the purposes set out in this Policy and within the scope of the legitimate interest of Chudovo. In those cases, we will comply with applicable laws designed to ensure the privacy of your personal data.

Under data protection laws, we can transfer your personal data to third countries on the basis of an adequacy regulation or, where such is not available, under legally approved standard data protection clauses recognized or issued under the applicable data protection laws. In the event, that we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data to third countries unless we can do so on the basis of an alternative mechanism permitted by data protection authorities.

By interacting with us you consent to the transfer of information that we collect about you, including personal information, to any country in which we or our service providers are located.

Sharing of your personal data

We may share your information with the following recipients: our affiliated companies, professional advisers, third-party service providers, partners, contractors, and employees for the purposes described in this Privacy Notice or notified to you.

We engage service providers that help us provide, support, and develop our business and the website and understand how it is used. They provide services such as cloud hosting, content delivery, customer and technical support, recruitment and HR-related services, background checks, insurance services, marketing, analytics, event hosting, etc. We share your personal data with these service providers as necessary to enable them to provide their service to us.

As a global company, we are supported by certain entities within our corporate group. These entities process your personal data for us, as necessary to provide certain functions, such as storage, security, research and development, analytics, and customer and technical support.

In addition, we may share your information with competent law enforcement bodies, regulatory, government agencies, courts, or other third parties where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another person.

Children’s Privacy

Chudovo services and products are not provided for use by children. We do not knowingly collect or solicit any personal information from children under the age of 13 or 16 (depending on the EU member state country requirements). If Chudovo finds out that the child’s personal data is provided to us, we’ll delete it from our databases. If you are a parent or guardian of a child and believe that we have collected such personal data, please contact us as indicated in the “Contact information” section below and we’ll delete it as soon as possible.

Cookies Policy

When you visit our website, Chudovo may place cookies and similar analytical codes (collectively, “Cookies”) on your device, browser, or the webpage you are viewing, in order to personalize your experience, understand usage patterns, and provide, improve, and secure the website. Cookies are simple computer files made of text. Cookies do not typically contain any information that personally identifies someone, but personal data that we store about you may be linked to the information obtained from cookies.

Our website uses different types of Cookies for different reasons, as follows:

• Functional cookies. These Cookies are essential to enable you to move around the website and use its features. These Cookies make sure you can view the website and use it in a proper way. They also give you access to secured parts of our website.
• Analytical cookies and other cookies. These Cookies help us improve all our websites, collect anonymous information about how visitors use our websites, collect information about the most visited pages, and tell us whether and how many error messages were displayed.
• Third-party cookies. These Cookies help third parties to track and manage the effectiveness of, for example, their websites, ads, and number of visitors. More information about these Cookies may be available on the relevant third party’s website.

Based on how long they are valid, the Cookies on our website may be either persistent cookies or session cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

If you want to receive more information about the cookies we use, please contact us.

You can adjust your browser settings to delete some of our cookies or cookies set by third parties. You may also adjust your browser settings to prevent websites from setting cookies or third-party cookies altogether. If you prevent us from setting specific cookies, you may find that some functions are not available or that certain parts of the website will not load. Find out how to adjust the settings for different browsers:

Google Chrome

Mozilla

Microsoft Explorer / Edge

Safari

If you would like to ask something regarding this Privacy Policy, please contact us at [email protected] any time.