Privacy Policy

1. Who We Are

Co Valere Technology Consulting Group Ltd (“Co Valere”, “we”, “us”, “our”) is a company registered in Cyprus. Our registered office is at Onisifirou Center, c/o Neophyto Nikolaidi & Kolokotroni Ave., Agios Theodoros, Paphos, Cyprus 8011.

We are the data controller in respect of personal data collected through www.covalere.com (the “Website”). This policy explains what data we collect, why we collect it, and how we handle it.

For questions about this policy or your personal data, contact us at info@covalere.com.

2. Scope of This Policy

This policy applies to all personal data collected through the Website, including data submitted via contact forms, job application forms, newsletter sign-up forms, and standard technical data collected automatically when you browse the Website.

It does not cover data we process under separate client or contractor agreements, which are governed by the applicable data processing agreements and contracts.

3. Data We Collect

3.1 Data you provide directly

When you use our contact, enquiry, or job application forms, we collect:

• Full name
• Email address
• Phone number
• Company name and job title
• LinkedIn profile URL
• CV, cover letter, and supporting documents (job applicants)
• Free-text content entered in message or enquiry fields

3.2 Data collected automatically

When you visit the Website, our analytics platform collects standard technical data, including:

• IP address (anonymised where possible)
• Browser type and version
• Operating system
• Pages visited and time spent
• Referring URL
• Date and time of access

This data is collected in aggregate to help us understand how the Website is used. It is not used to identify individual visitors.

3.3 Data we do not collect

We do not collect special category data (such as health information, racial or ethnic origin, or political opinions) through the Website. We do not collect payment card data or financial account details through the Website.

4. How We Use Your Data

We use your personal data only for the purposes for which it was collected:

• To respond to business enquiries and requests for information about our services.
• To assess and process job applications.
• To send you information about our services where you have requested it.
• To improve the Website and our content based on aggregated analytics.
• To comply with legal obligations.

We do not sell your personal data. We do not share it with third parties for their own marketing purposes.

5. Legal Basis for Processing

We process personal data under the EU General Data Protection Regulation (GDPR) and the UK GDPR. Our legal bases are:

• Legitimate interests: responding to business enquiries, assessing job applications, and operating the Website. We have assessed that these interests are not overridden by your interests or fundamental rights.
• Contractual necessity: where processing is required to take steps at your request prior to entering a contract, or to perform a contract with you.
• Consent: where we rely on your consent (for example, optional newsletter sign-up), you may withdraw it at any time by contacting info@covalere.com.
• Legal obligation: where we are required to process data to comply with applicable law.

6. Analytics and Cookies

6.1 Analytics

The Website uses an analytics platform to collect aggregated data about traffic and usage patterns. Where IP addresses are collected, they are anonymised before storage. We do not use analytics data to build individual profiles or for targeted advertising.

6.2 Cookies

The Website uses cookies. Cookies are small text files placed on your device. We use the following types:

• Strictly necessary cookies: required for the Website to function. These cannot be disabled.
• Analytics cookies: used to understand aggregate visitor behaviour. These are set only with your consent.
• Preference cookies: used to remember settings you apply during your visit.

You can manage or withdraw cookie consent at any time through your browser settings or via our cookie preference centre. Blocking strictly necessary cookies will affect the Website’s functionality.

7. Third-Party Services and Processors

We use a limited number of third-party service providers to operate the Website and our business processes. These providers act as data processors and process personal data only on our instructions.

Categories of processor include:

• Website hosting and infrastructure providers
• Analytics platform providers
• Email and communication tools
• Recruitment and applicant tracking systems

We require all processors to maintain appropriate technical and organisational security measures and to process data only for the purposes we specify. We do not authorise processors to use your data for their own purposes.

8. International Data Transfers

Co Valere Technology Consulting Group Ltd is headquartered in Cyprus, an EU member state. Co Valere Consulting Limited operates in the United Kingdom, which maintains an adequacy decision from the EU Commission for the purposes of international transfers.

Your data may be processed in both the EU and the UK. Where we transfer data to processors located outside the European Economic Area or the UK, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses approved by the European Commission or the UK Information Commissioner’s Office.
• Adequacy decisions applicable to the recipient country.

You may request details of the specific safeguards in place by contacting info@covalere.com.

9. Data Retention

We retain personal data for as long as is necessary to fulfil the purpose for which it was collected, and no longer than is required by applicable law.

Our standard retention periods are:

• Business enquiry data: 2 years from last contact, unless a business relationship is established.
• Successful job application data: retained for the duration of the employment or engagement, plus any legally required period thereafter.
• Unsuccessful job application data: up to 12 months from the date of the decision, unless you consent to a longer period for future opportunities.
• Website analytics data: aggregated data is retained for up to 26 months.

At the end of the applicable retention period, data is securely deleted or anonymised.

10. Your Rights

Under the GDPR and UK GDPR, you have the following rights in relation to your personal data:

To exercise any of these rights, contact us at info@covalere.com. We will respond within one calendar month. We may need to verify your identity before processing your request. Where requests are manifestly unfounded or excessive, we may charge a reasonable fee or refuse to act, and will explain our reasons.

You also have the right to lodge a complaint with a supervisory authority. In Cyprus, this is the Commissioner for Personal Data Protection (www.dataprotection.gov.cy). In the UK, this is the Information Commissioner’s Office (www.ico.org.uk).

11. Security

We apply technical and organisational measures to protect personal data against unauthorised access, loss, destruction, or alteration. Measures include:

• Encryption of data in transit using TLS.
• Access controls limiting data access to authorised personnel only.
• Regular review of our security practices.

No transmission over the internet is entirely secure. If you have reason to believe your data has been compromised in connection with us, contact info@covalere.com immediately.

12. Children

The Website is not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, contact us at info@covalere.com and we will delete it promptly.

13. Links to Third-Party Websites

The Website may contain links to third-party websites, including partner and client sites. We are not responsible for the privacy practices or content of those sites. We recommend you review the privacy policy of any third-party site you visit.

14. Changes to This Policy

We may update this policy from time to time to reflect changes in our practices or applicable law. When we make material changes, we will update the effective date at the top of this document. We encourage you to review this page periodically.

15. Contact Us

For any privacy-related queries or to exercise your rights, contact us:

• Email: dataprotection@covalere.com
• Cyprus (registered office): Onisifirou Center, c/o Neophyto Nikolaidi & Kolokotroni Ave., Agios Theodoros, Paphos, Cyprus 8011