Privacy Notice

Native Coders Sweden AB and its Kenyan subsidiary, Native Coders Co. Ltd., respect your privacy. This Privacy Statement outlines your rights to privacy and our commitment to safeguarding your personal data. Native Coders has business processes, management structures and technical systems in use within the corporate group. Native Coders provides services to private and public companies (customers), mainly in Sweden. Native Coders’ headquarters are located in Stockholm and Native Coders complies with European data protection legislation, including the General Data Protection Regulation (GDPR). All major decisions regarding privacy in Native Coders are made at a corporate level supervised by the Data Protection Officer (DPO).

1. How and when does the privacy statement apply?

This Privacy Statement applies to all business processes in Native Coders and to all of Native Coders’ websites, domains, mobile solutions, cloud services and communities as well as Native Coders’ branded websites (Native Coders’ websites). Service-specific appendices will be found in the Terms of Service, data processing agreements or equivalent information for the specific service in question. The Privacy Statement provides information about data processing carried out by Native Coders when Native Coders determine the purpose and means of the processing (Native Coders acts as a data controller). It also provides information on data processing Native Coders does on behalf of our Customers based on their instructions (the Customer acts as a data controller and Native Coders acts as a data processor). Personal data is information that can identify you as a person, such as an email address, street address, phone number etc. Processing your personal data is necessary for us to serve our Customers. Please do not use Native Coders’ websites or our services if you do not agree with how we process personal data according to this Privacy Statement.

2. Whose personal data does Native Coders process?

Native Coders process personal data about job seekers and contact persons or software users tied to our Customers. In addition we process personal data about persons representing potential Customers (leads) that approach us via Native Coders’ websites or other channels. Our statement in these regards is to be found in the data controller section. We also process data on behalf of our Customers of which the Customer controls. Our statement in these regards is to be found in the data processor section.In this Privacy Statement, data subjects may also be referred to as persons or you.

3. How does Native Coders process personal data as a data controller?

When a Native Coders subsidiary determines the purpose and means of processing your personal data, this company acts as a data controller. This includes scenarios where Native Coders collect personal data in the context of you being a job seeker, you being a representative for a Customer or Lead, or when you are a software user.

4. Why we process your personal data

4.1 About customer contacts and software users

To manage our Customer relations in general and to meet our Customer commitments, Native Coders need information about you in your role as a Customer contact person or a user of a service. The purposes of processing this personal data are:

Execute sales and contract process to Customers
Provide offers on products and services requested by Customers
Perform deliveries in accordance with agreements made with you or Customers
Offer support to users of our products and services
Improve and develop the quality, functionality, and user experience of our products, services, and Native Coders websites
Detect, mitigate, and prevent security threats, and perform maintenance and debugging

The legal ground for processing personal data according to the above-listed purposes in bullet points is mainly because Native Coders has a legitimate interest in processing your personal data from a business perspective in a manner that we believe does not conflict with your privacy rights or freedoms. The legal ground for processing personal data listed in the last bullet above is your consent.

4.2 About leads

Native Coders processes personal data about Leads for marketing purposes. The legal grounds for such processing is mainly your consent. You can read more about how you can withdraw your consent in the sections below.

4.3 About jobseekers

If you are a jobseeker, we process personal data in order to evaluate your potential to become a Native Coders employee. The legal grounds for such processing is your consent, which you leave when submitting your application

4.4 About visitors

5. How we collect your personal data

In general, Native Coders collects personal data directly from you or other persons linked to our Customer. These persons may be a manager or colleague. If the Customer you work for purchases Native Coders products or services via a Native Coders partner company, we may collect information about you from the partner company. We will also use cookies and other tracking technologies when you use Native Coders websites and interact with us per email in order to optimize your experience of Native Coders and our websites. Please see the paragraph describing automatic data collection tools for more information on how these technologies function and your rights in this context. In some cases, we may also collect information about you from other sources. These sources may be third-party data aggregators, Native Coders’ marketing partners, public sources or third-party social networks. Native Coders will be able to combine personal data about you obtained from one source with data obtained from another source. This gives us a complete picture of you, which also gives us the possibility of serving you in a more relevant way and with a greater degree of personalisation.

5.1 Automatic data collection tools

Native Coders uses different digital tracking technologies to collect information about your movements on Native Coders websites and when interacting with us.

5.2 Cookies and pixel tags

Cookies are small text files that contain a string of characters and uniquely identifies a browser. They are sent to a computer by website operators or third parties. Most browsers are initially set up to accept cookies, since this is required by most website owners in order to access their sites. You may be, however, able to change your browser settings to cause your browser to refuse cookies in general, block third party cookies or to indicate when a cookie is being sent. Pixel tags are scripts that executes when a user lands on a website or opens an email. The pixel itself is not visible and can only be seen in the HTML of the site or email. It calls an application on a server that will cause a third party cookie to be downloaded to your computer or registers that the email has been opened.If you would like to know more about cookies and how they work, there are different sources on the internet with good information.

5.3 Google cookies and technologies

Google Analytics: This cookie allows us to see information on user website activities including, but not limited to, page views, source and time spent on a website. The information is depersonalized and is displayed as numbers, meaning it cannot be traced back to individuals. This will help to protect your privacy. Using Google Analytics we can see what content is popular on our websites, and strive to give you more of the things you enjoy reading and watching. Google Analytics Remarketing: Places cookies on your computer which means that after you leave our website, Google can show you advertisements about Native Coders that you might be interested in based on your previous behavior on our website. This information is not personally identifiable. Google Ads: By using Google Ads code, we are able to see which pages helped lead to contact form submissions. This allows us to make better use of our paid search budget. This information is not personally identifiable. Google Ads Remarketing: Places cookies on your computer which means that after you leave our website Google can show you advertisements about Native Coders that you might be interested in based on your previous behavior on our website. This information is not personally identifiable. You can prevent the information generated by the Google cookie about your use of our Sites from being collected and processed by Google in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser.

6. What personal data we process

The type of personal data that Native Coders process about you may be:

Basic contact details such as name, address, telephone number, and email.
Demographic Information such as age and gender.
Employment information such as employer, title, position including preferences and interests in a professional context.
Feedback, comments, or questions about Native Coders or concerning our products and services.
Content you have uploaded such as photos and video.
Unique user information such as login ID, username, password, and security questions.
Traffic information as provided by your web browser such as browser type, device, language, and IP address.
Clickstream behavior and movement on Native Coders websites and in our products and services.
Email behavior such as which emails from Native Coders you open when and how.
Other personal data contained in your profile that you have freely given away on third-party social networks such as, for example, LinkedIn etc.

As a data controller, Native Coders does not normally process sensitive personal data about you.

7. How we share your personal data

7.1 Within the Native Coders group

It is important to us that we provide the best possible customer service and overall experience. In order to maintain a complete overview and insight into customers and related contact persons within the Native Coders Group, we will share your personal data among our companies.

7.2 Outside Native Coders group

Native Coders may also share your personal data with external third parties in the following contexts:

7.2.1 Business partners

7.2.2 Public authorities

The police and other authorities may demand the handover of personal information from Native Coders. In these cases, Native Coders will only hand over the data if there is a court order to do so.

7.2.3 Mergers and acquisitions

In connection with mergers, acquisitions or divestiture of all or parts of Native Coders’ business, the acquiring entity, as well as its consultants, will obtain access to data managed by the Native Coders entity/entities involved and this may in some cases include personal data. In such cases, external parties will enter into an NDA with Native Coders.

8. What are your rights?

8.1 Right to opt-out of marketing communications

You have the right to opt-out of receiving marketing communication from Native Coders and may do so by either:

Following the instructions for opt-out in the relevant marketing communication.
Change preferences under the relevant edit account section if you have an account with Native Coders.
Contacting us via our contact webform.

Please note that even if you opt-out from receiving marketing communications, you may still receive administrative communications from Native Coders, such as order confirmations and notifications necessary to manage your account or the services provided to Customers

8.2 Basic rights

You have the right to access your personal data by requesting an overview of the personal data we process about you. You also have the right to request that Native Coders correct inaccuracies in your personal data. If you have an account with Native Coders for a Native Coders Site or Service, this can usually be done through the appropriate “your account” or “your profile” sections on the applicable Native Coders Site or service. Further, you have a right to request deletion of personal data, and to restrict or object to our processing of your personal data according to this Privacy Statement or other service specific terms. Please use the contact webform at the bottom of this page to file all requests as mentioned in this section. Finally, you also have a right to file a complaint with the data protection authorities with regards to our processing of your personal data.

9. How does Native Coders protect and store personal data?

9.1 How we keep your personal data secure

Native Coders take the trust you and our Customers place in us very seriously. Native Coders is committed to preventing unauthorized access, disclosure or other deviant processing of personal data. Native Coders shall ensure the confidentiality of personal data we process, maintain the personal data integrity and secure its availability according to applicable privacy legislation. As part of our commitment, we utilize reasonable and appropriate organizational, technical and physical procedures and measures to safeguard the information we collect and process, taking into account the type of personal data and risk posed to you and our Customers upon breach. Since root causes for privacy breaches are most likely to be found internally, we believe that building a strong corporate culture where respect for and awareness around privacy among our employees are fundamental to ensure lawful processing and protection of your data The following measures are of particular importance in this regard:

9.2 Organizational procedures and measures

An internal work group is governing the lawfulness of the data processing and the privacy policies for Native Coders Group. The work group gathers competence within the privacy and information security area and reports to the groups Data Protection manager.

Data Privacy training is mandatory for all employees.
Data processing agreements are required for subcontractors that process data on behalf of Native Coders.

9.3 Technical procedures and measures

Classification of personal data to ensure implementation of security measures equivalent to risk assessment.
Assess the use of encryption and pseudonymization as risk-mitigating factors.
Limiting access to personal data to those that need access to fulfill obligations according to law or service agreement, etc.
Manage systems that detect, restore, prevent, and report privacy incidents.
Use security self-assessments to analyze whether current technical and organizational measures are sufficient to protect personal data, taking into account the requirements outlined in applicable privacy legislation.

9.4 How long we store your personal data

Native Coders will only retain your personal data for as long as necessary for the stated purpose, while also taking into account our need to answer queries or resolve problems and to comply with legal requirements under applicable laws. This means that Native Coders may retain your personal data for a reasonable period after you and our Customer’s last interaction with us. When the personal data that we collected is no longer required we erase it.

9.5 How does Native Coders protect and store personal data as a data processor?

Native Coders provides many different services to our Customers. Most of our services involve processing of the Customers’ data, hereunder their personal data. The purpose of processing is determined by our Customers not by Native Coders. Making the Customer the data controller. Native Coders do in such cases act as data processor and process the data on behalf of and according to instructions given by the Customer. The relationship between the Customer as the data controller and Native Coders as the data processor shall be regulated by a data processing agreement.

10. Customer and Native Coders obligations

When the Customer acts as a data controller the Customer shall, according to applicable privacy legislation, ensure the legal grounds for processing the personal data. Further, the Customer shall assess and establish ownership of the risks posed to data subjects by processing their personal data. Another important aspect of the Customer’s duty as a data controller is to comply with the information duty towards data subjects. Native Coders is a natural part of the Customers’ duties as a data controller, in the sense that Native Coders’ services constitute parts of the processing of personal data that the Customer must ensure are compliant with applicable privacy legislation. Thus, when NativeCoders processes personal data on behalf of its Customers, we must do so in accordance with privacy legislation applicable for data processors. In short, the Customer and Native Coders are obligated to cooperate to ensure privacy for data subjects. Native Coders shall provide the information necessary for the Customer to be compliant with applicable privacy legislation.

11. In what manner does Native Coders use subcontractors?

Native Coders uses subcontractors to process personal data and may export your or our Customers data outside the EU in this regard. These subcontractors are typically vendors of cloud services or other IT hosting services. When using subcontractors, Native Coders will enter into a data processing agreement (DPA) with subcontractors in order to safeguard your privacy rights and to fulfill our obligations towards our Customers. When subcontractors are located outside the EU, Native Coders ensures legal grounds for such international transfers on behalf of you or our Customers, hereunder by relying on Privacy Shield (US) or using the EU Model Clauses. Native Coders relies on some strategic external third parties to support our business processes and to provide our cloud services. More information on Native Coders’ subcontractors is provided in the service-specific terms or in a dedicated data processing agreement. In any case, you are always welcome to request an overview and more detailed information on Native Coders’ subcontractors, hereunder documentation of legal grounds for international transfers mentioned above.

12. Changes to this statement

If we modify our Privacy Statement, we will post the revised statement here, with an updated revision date. We encourage you to review the Statement regularly. If we make significant changes to our Statement that materially alter our privacy practices, we may also notify you by other means, such as sending an email or posting a notice on our websites and/or social media pages prior to the changes taking effect. We value your opinion. If you have any comments or questions about our Privacy Statement, any unresolved privacy or data use concerns that we have not addressed satisfactorily, or concerning a possible breach of your privacy, please send them via our contact webform. We will handle your requests or complaints confidentially. Our representative will contact you to address your concerns and outline the options regarding how these may be resolved. We aim to ensure that complaints are resolved in a timely and appropriate manner.

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