Privacy Policy

1. Introduction

We value Your privacy and are committed to protecting Your personal data. This Privacy Policy ("Policy") explains how we collect, use, and store Your personal data when You use our platform and related services ("Platform").

2. Data We Collect

We may collect the following data:

2.1. Mandatory (required for registration / matching):

• Full Name
• Email Address
• Country
• Desired Position
• Language Skills
• Technical Skills
• Hourly Rate (USD)

2.2. Optional (require Your explicit consent):

• Avatar
• Video Presentation
• Date of Birth
• Phone Number
• Address
• Education
• Degree
• Professional Experience
• Resume
• GitHub & LinkedIn Profiles
• Portfolio
• Projects & Achievements
• Reference to Former Employer
• Preferred Project Type
• Work Location Preference
• Preferred Employment Type

2.3. Platform & Technical Data:

• IP address
• Device type
• Browser
• Login timestamps
• Cookies
• Activity logs

We collect only the data necessary to match You with client projects and operate the Platform.

By registering on the Platform, You confirm that the personal data You submit are accurate and up to date to the best of Your knowledge, and You agree to update Your profile if any of Your data changes.

Failure to provide mandatory data prevents account creation and project matching.

3. How We Use Your Data

We use Your data only for the following legitimate purposes:

• Creating and managing Your account
• Matching You with potential projects
• Communicating with You about opportunities, Platform updates and events
• Improving and securing the Platform
• Internal analytics, reporting, and business development
• Compliance with our legal obligations

4. Legal Basis for Processing

We process personal data under the following lawful bases:

1. Performance of a Contract (Art. 6(1)(b) GDPR):
   For account management, project matching, and service delivery.
2. Legal Obligations (Art. 6(1)(c) GDPR):
   For regulatory compliance, legal, tax, and record-keeping purposes.
3. Legitimate Interests (Art. 6(1)(f) GDPR):
   For professional profile matching, Platform operations, fraud prevention, and service improvement.
4. Consent (Art. 6(1)(a) GDPR):
   For optional profile data and marketing communications.

5. Automated Processing

Our Platform may use automated tools to assist human staff in matching candidates with client projects; however, no decision producing legal or similarly significant effects on a candidate will be taken solely based on automated processing without human review.

6. Sharing, Disclosure and International Transfer

We may share Your personal data with:

• Registered clients for the purpose of project matching
• Service providers (hosting, analytics, support, KYC) under data processing agreements
• Legal and tax advisors under data processing agreements
• Law enforcement or regulators, when required by law

If data is transferred outside the EU/EEA, we use:

• Standard Contractual Clauses (SCCs)
• GDPR-approved safeguards

We do not sell or rent Your personal data to third parties.

7. Data Retention

• Your personal data is retained only as long as necessary for registration, matching, or legal compliance.
• Inactive or deleted accounts are removed after 12 months unless retention is required by law.

8. Your Rights

You have the right to:

• Access and receive a copy of Your data
• Rectify inaccurate data
• Request erasure ("right to be forgotten")
• Object to processing
• Withdraw consent at any time
• Request restriction of processing
• Data portability

Requests can be submitted via dpo@program-ace.com.

9. Security

We implement technical and organizational measures to protect Your data, including:

• Secure hosting
• Encryption
• Role-based access control and limited permissions
• Regular security audit

10. Changes to Policy

We may update this Policy from time to time to reflect legal or operational changes. Updates will be posted on the Platform with a new effective date.

11. Contact

Questions or requests regarding Your personal data may be sent to:

Email: dpo@program-ace.com
Address: Program-Ace Europe Limited, Archiepiskopou Makariou III, 1, Mitsis Building No. 3, Flat/Office 310, 1065, Nicosia, Cyprus

You also have the right to lodge a complaint with the Office of Commissioner for Personal Data Protection (Cyprus Independent Supervisory Authority for Protection of the Individual) if You believe that Your personal data has been processed unlawfully or in violation of applicable data protection laws.