Privacy Policy

Updated October 2026

Codility Limited and its subsidiaries (“we,” “us” or “our”) are committed to protecting the privacy and security of your personal information. This notice explains how we collect and use personal information about you when you visit our website, contact us, do business with us, use the Codility platform, take an assessment, apply to work for us, join our programmer community or take part in our research, in accordance with the data protection laws that apply to you, including the UK GDPR, the EU GDPR and the privacy laws of the countries in which we operate.

Because we deal with different people in different ways, this notice is divided into sections. Please go to the section that describes you:

The following sections at the end of this notice apply to everyone: How we use artificial intelligence, international transfers, security, your rights, how to raise a concern, cookies, and additional information for residents of California and other US states. Our staff are covered by a separate privacy notice for employees, workers and contractors.

This notice replaces our previous Privacy Policy and Data Privacy Notice. We may update it from time to time and will publish the current version on our website. The date of the current version is shown in the change history at the end of this notice.

Who is responsible for your information

Codility Limited, 9th Floor, 107 Cheapside, London EC2V 6DN, United Kingdom, is the controller of the personal information described in this notice, with two exceptions: If you take an assessment or interview at the invitation of an employer, that employer is the controller and Codility is its processor, as explained in the section for candidates; and if you apply for a role with us, the Codility group company that is recruiting for the role is the controller, as explained in the section for job applicants.

Our Data Protection Officer can be contacted at [email protected]. Please use this address for questions about this notice and to exercise your rights.

Sections for each group

1. Visitors to our websites

This section applies when you visit codility.com or another website we operate. It does not cover the Codility platform itself, which is described in the sections for platform users and candidates.

The information we collect

Technical information sent by your browser, including your IP address, browser and device type, operating system and language settings.

  • Information about your visit, including the pages you view, the links you click, the website that referred you and the time and duration of your visit.
  • Cookie and similar identifiers, where you have accepted them, and the approximate location (usually city level) derived from your IP address.
  • Session recordings and heatmaps of how you move through the site, with anything you type into forms masked, where you have accepted analytics cookies.

This information comes from your browser and from the analytics and advertising tools on our website. We do not ask website visitors for special categories of personal information.

How we use it and why

PurposeInformation usedLawful basis
Operating, securing and troubleshooting the websiteTechnical information; information about your visitOur legitimate interests in running a secure and reliable website
Measuring website traffic and understanding how the site is used, so that we can improve itInformation about your visit; cookie identifiers; session recordingsYour consent, given through the cookie banner, for analytics tools that use cookies or similar technologies; our legitimate interests for aggregated analytics that do not use cookies and truncate your IP address
Advertising our services to people who have visited our website and measuring the performance of our campaignsCookie and similar identifiers; information about your visitYour consent, given through the cookie banner, for advertising cookies

Who receives it

Our website hosting and content delivery providers and our analytics providers process this information on our behalf. Where you accept advertising cookies, advertising and social media platforms receive cookie identifiers and information about your visit and use them under their own privacy policies to show you our advertisements elsewhere. Analytics providers may also use some information for their own purposes under their terms.

How long we keep it

Website analytics and advertising data is kept for the periods set in each tool, generally between a few weeks and two years, after which it is deleted or retained only in aggregated form. You can change your cookie choices at any time through the cookie settings on our website; see “Cookies” below.

2. People who contact us or subscribe to our content

This section applies when you fill in a form on our website, request a demo or pricing, ask a question through our website chat, email us, or sign up for our newsletters, webinars or other content.

The information we collect

  1. Your name, work email address, telephone number, job title and company.
  2. The content of your enquiry, message or chat conversation, and any other information you choose to give us.
  3. Where you arrived from, including the campaign, referring website or landing page that brought you to the form.
  4. Your subscription preferences and, for the emails we send you, whether they were delivered, opened or clicked.

This information comes from you. Our website chat is operated by an AI assistant; what you type into it is used to answer your question and, if you ask us to contact you, is passed to our sales team. Please do not include sensitive personal information in enquiries or chat messages.

How we use it and why

PurposeInformation usedLawful basis
Responding to your enquiry or request and routing it to the right teamContact details; content of your enquiry; where you arrived fromTaking steps at your request before entering into a contract; our legitimate interests in responding to people who contact us
Sending you the newsletters, product updates, event invitations and other content you have signed up for, and other information about our services that we think will interest you in your professional roleContact details; subscription preferences; email engagementOur legitimate interests in promoting our services, where the law allows us to send business email without consent; your consent, where the law of your country requires it or where we have asked for it
Keeping a record of people who have asked us not to contact themEmail address; unsubscribe statusLegal obligation
Understanding which campaigns and content lead to enquiriesWhere you arrived from; email engagementOur legitimate interests in measuring our marketing

You can opt out of marketing email at any time by using the unsubscribe link in any email or by contacting us. Opting out does not affect messages we need to send you about a request you have made or a service you use.

Who receives it

Providers of our website forms, chat assistant, customer relationship management and email delivery tools process this information on our behalf, as do the agencies and contractors that support our marketing and sales operations. If your enquiry leads to a business relationship, your details are handled as described in the next section.

How long we keep it

Enquiry and chat records are kept for a defined period after the matter is closed. Marketing contact records are kept for up to two years after our last meaningful contact with you. A record of your email address is kept indefinitely if you opt out, so that we can honour your choice.

3. Business contacts at prospective and existing customers

This section applies to people we deal with in their professional capacity at organisations that are, or may become, Codility customers or partners, including the people who negotiate, sign and manage contracts with us and those who handle billing.

The information we collect

  1. Your name, work email address, telephone number, job title, department, seniority and company.
  2. Our history of contact with you, including meetings, calls, emails, proposals, quotes and contracts, and notes of our conversations.
  3. Signals about your organisation’s interest in our services, such as engagement with our emails, website and advertising, and intent data about your organisation provided by third parties.
  4. For billing contacts, invoice and payment records, including VAT or tax numbers and the contact and address details on invoices. Payment card details are collected and processed by our payment providers, not by us.

Where it comes from

Most of this information comes from you or from colleagues at your organisation. We also obtain and verify the work contact details and job titles of people at organisations we would like to do business with from business contact data providers and from public sources such as professional networking sites and company websites, and we use data providers to check that email addresses are current. This applies to the business contact records we hold about you in our sales and marketing systems. It does not involve the information your organisation holds in the Codility platform. Where you also have a platform account, we process your account and usage information only on your organisation’s instructions, and we do not use that information for sales prospecting or data enrichment.

Where we obtain your information from a source other than you, we provide this notice at the latest when we first contact you, and in any case within one month.

How we use it and why

PurposeInformation usedLawful basis
Identifying and contacting people at organisations that may benefit from our services, and keeping our contact records accurate and up to dateContact and professional details; interest signalsOur legitimate interests in marketing our services to businesses. We contact people only in their professional capacity and follow the direct marketing rules that apply in each country
Managing our relationship with your organisation, including proposals, contracts, renewals and account reviewsContact and professional details; contact historyPerformance of our contract with your organisation, and our legitimate interests in managing customer relationships
Sending marketing email about our services, content and eventsContact details; email engagementOur legitimate interests, where the law allows us to send business email without consent; your consent, where the law of your country requires it or where we have asked for it; legal obligation, for keeping a record of people who have opted out
Invoicing, collecting payment, credit control, accounting and auditBilling contact details; invoice and payment recordsPerformance of our contract with your organisation; legal obligation under accounting and tax law; our legitimate interests in being paid
Reporting on our sales pipeline and planning our businessAggregated information from the aboveOur legitimate interests in running our business

Who receives it

Providers of our customer relationship management, sales engagement, contact data, email delivery, e-signature, billing and finance systems process this information on our behalf, together with the agencies and contractors that support our sales operations, marketing and finance. Business contact data providers and professional networking sites are the sources described above and are independently responsible for their own data. Our payment providers, banks, auditors and professional advisers receive billing and payment information where needed.

How long we keep it

Prospect records are kept for up to two years after our last meaningful contact. Customer contact records are kept for the life of the contract and for a defined period afterwards, and contract and financial records for the periods required by accounting and tax law. Records of people who have opted out of marketing are kept indefinitely so that we can honour their choice.

4. Users of the Codility platform

This section applies if you have an account on the Codility platform through your organisation, for example as an administrator, recruiter, hiring manager or interviewer, or if you have opened a trial or self-serve account. Codility Limited is the controller of your account information and of the information about how you use the platform. The candidates your organisation assesses are covered by the next section.

The information we collect

  1. Your name, work email address, username, job role and the organisation you belong to.
  2. Account and security information, including your hashed password, single sign-on identifiers, role and permissions, team membership, sign-in records, IP addresses and account settings.
  3. Information about how you use the platform, including the features you use, the actions you take, in-app messages you see, and your progress through any training we provide through the Customer Academy.
  4. Support requests you make, including the content of your tickets, attachments and our correspondence with you, and your responses to satisfaction and feedback surveys.
  5. For self-serve accounts, billing and transaction records, and signals used to detect fraudulent accounts and payments. Payment card details are collected and processed by our payment providers, not by us.

This information comes from you, from the person at your organisation who created or administers your account, and from the platform itself as you use it. We do not ask platform users for special categories of personal information.

How we use it and why

PurposeInformation usedLawful basis
Creating and administering your account, authenticating you, applying permissions and sending you application email and notificationsAccount and security information; name and contact detailsPerformance of our contract with you or your organisation
Keeping the platform secure and investigating security incidents and misuseAccount and security information; usage informationOur legitimate interests in the security and integrity of the platform
Onboarding and supporting you, including in-app guidance, satisfaction surveys and the Customer AcademyUsage information; support requests; survey responses; training progressPerformance of our contract with you or your organisation; our legitimate interests in helping customers get value from the platform
Monitoring account health and product adoption, and improving the platformUsage information, analysed in aggregate wherever possiblePerformance of our contract, which provides for the use of usage data to operate and improve the service; our legitimate interests in improving our products
Telling you about product updates, new features and events relevant to your use of the platformName and contact details; usage informationOur legitimate interests, where the law allows us to send business email without consent; your consent, where the law of your country requires it
For self-serve accounts, processing payments and refunds and preventing fraudBilling and transaction records; fraud signalsPerformance of our contract; our legitimate interests in preventing fraud; legal obligation under accounting and tax law

We do not use the information in your organisation’s Codility account, or the information about candidates that your organisation processes through the platform, for sales prospecting, data enrichment or research, other than in aggregated and anonymised form or as your organisation’s contract with us permits.

Who receives it

Our cloud hosting provider, our email delivery provider, and the providers of our support, in-app messaging, training and customer success tools process this information on our behalf, together with our published platform sub-processors. Your organisation’s administrators can see the information held in your account. If your organisation uses single sign-on, its identity provider receives your sign-in information. For self-serve accounts, our payment providers process payment information and carry out their own fraud prevention and regulatory checks.

How long we keep it

Account information is kept for the life of your organisation’s contract or your account and for a short, defined period afterwards, as set out in our platform terms. Support records are kept for a defined period after the matter is closed. Financial records are kept for the periods required by accounting and tax law.

5. Candidates taking an assessment or interview

This section applies if you have been invited to take a test, assessment or live coding interview on the Codility platform by an employer or other organisation that uses our services.

Who is responsible for your information

The organisation (i.e your prospective employer) that invited you to take the assessment is the controller of your personal information. It decides whether to assess you, which assessment to use, which features to enable and what happens to your results. Codility processes your information on that organisation’s instructions as its processor, under a data processing agreement. That organisation is responsible for telling you how it uses your information and for handling your requests to exercise your rights, so please direct questions about your assessment, your results and your rights to the organisation that invited you. If you contact us instead, we will pass your request on to it or ask you to contact the organisation directly.

The information processed on the prospective employer’s behalf

  1. Your name and email address, and any other details the inviting organisation includes in your invitation or asks you to provide.
  2. Your work during the assessment or interview, including code you write, answers you give, files you upload, and, in live interviews, the video recording, shared whiteboard and interviewer’s notes and scores.
  3. Scores and results generated by the platform, and feedback written by reviewers.
  4. Assessment integrity information, including your IP address, browser details, the time taken, copy and paste activity, switching between browser tabs, typing patterns, similarity to other submissions and indicators of the use of AI assistants, which the platform uses to flag possible irregularities for the inviting organisation to review.
  5. Where the inviting organisation has enabled identity verification, the result of a check that compares your identity document with a selfie. The check is carried out by a specialist identity verification provider; the document and selfie images are held by that provider and Codility receives only the outcome of the identity verification.
  6. Where the inviting organisation uses AI features, such as AI-generated summaries, follow-up questions or feedback, the inputs to and outputs of those features.

All of this information is used to deliver the assessment or interview and make the results available to the inviting organisation. Decisions about your application are made by that organisation, not by Codility. We do not make decisions about you that have legal or similarly significant effects.

The limited purposes for which Codility is the controller

Codility is the controller of a limited amount of information about candidates for the following purposes of its own:

PurposeInformation usedLawful basis
Keeping the platform secure, preventing fraud and misuse, and protecting the integrity of assessments across all customersAccount and sign-in information, IP addresses, browser details and platform logsOur legitimate interests in the security and integrity of the platform
Responding to support requests you send usYour name and email address, the content of your request and the platform records needed to answer itOur legitimate interests in supporting everyone who uses the platform
Validating and improving our assessments and products, including the statistical quality of our tests and the performance of our AI featuresAssessment data in aggregated and anonymised form only. We do not use identifiable candidate data for this purposeOur legitimate interests in improving our services
Asking for your feedback on the assessment experienceYour responses to an optional feedback surveyOur legitimate interests in improving the candidate experience

Who receives it

The inviting organisation receives your results and all the information listed above. Our cloud hosting provider, our email delivery provider, our video and identity verification providers and our other published platform sub-processors process candidate information on our behalf, under the same instructions. If you contact our support team, the provider of our support tools processes your request on our behalf.

How long we keep it

The inviting organisation decides how long your assessment information is kept and can delete it at any time. We delete or anonymise candidate information in line with that organisation’s instructions and our platform terms. Platform security logs and support records are kept for short, defined periods.

6. Job applicants

This section applies if you apply for a job or contractor role with Codility, send us your CV, or are put forward or approached for a role, whether or not your application goes any further. The Codility group company that is recruiting for the role is the controller: Codility Limited (United Kingdom), Codility Polska Sp. z o.o. (Poland), Codility Germany GmbH (Germany) or Codility Inc (United States).

The information we collect

  1. Your name, contact details, CV, covering letter, application form, and the information in your professional profiles.
  2. Your employment and education history, qualifications, skills, salary expectations and availability.
  3. Interview notes and scores, the results of any assessments or tasks we ask you to complete, and the opinions of the people who interview you.
  4. References, and the details of your referees.
  5. Information needed to confirm your right to work in the country of employment, which may include your nationality and immigration status, and the outcome of any background checks we carry out.
  6. Information about any disability or health condition you tell us about so that we can make adjustments to the recruitment process.
  7. Equal opportunities monitoring information, where we ask for it and you choose to provide it.
  8. If we make you an offer, the terms of the offer and your contract.

Nationality and immigration status, health and disability information, and equal opportunities information are special categories of personal information or otherwise protected by additional rules. We collect them only where the law requires or permits it, as set out below.

Where it comes from

Most of this information comes from you. We also receive information from recruitment agencies and the contractors who help us find candidates, from professional networking sites where we approach you about a role, from your referees, from background screening providers, and from the people who interview you.

How we use it and why

PurposeInformation usedLawful basis
Assessing your application, interviewing you and deciding whether to offer you a roleApplication and CV information; interview notes, scores and assessment results; referencesTaking steps at your request before entering into a contract; our legitimate interests in recruiting the right people
Confirming your right to work and carrying out background checks required by law or by our customer commitmentsRight to work information; background check resultsLegal obligation; our legitimate interests in meeting our commitments to customers. For nationality and immigration status, our obligations under employment law
Making reasonable adjustments to the recruitment processDisability or health information you give usOur obligations under employment law
Equal opportunities monitoringEqual opportunities informationReasons of substantial public interest under equality law, or your explicit consent, depending on the country
Keeping your details on file to contact you about future rolesApplication and CV informationYour consent, which you can withdraw at any time
Keeping records of our recruitment decisions to defend legal claimsApplication, interview and decision recordsOur legitimate interests in defending claims

We do not make recruitment decisions based solely on automated processing. If you do not provide information we need, we may be unable to consider your application.

Who receives it

The providers of our recruitment, human resources, document and collaboration systems process this information on our behalf, as do the recruitment contractors who support our hiring. Recruitment agencies, referees and background screening providers are independently responsible for the information they hold. If you are offered a role, your information is transferred to your employment record and covered by our privacy notice for employees, workers and contractors.

How long we keep it

If your application is unsuccessful, we keep your information for six months from the date of our decision, or for up to twelve months in our talent pool if you agree to that, after which it is deleted. Unsolicited CVs that we do not take forward are deleted within the same period.

7. Members of the Codility programmer community

This section applies if you join the free programmer community on the Codility platform to practise coding challenges, follow lessons and training, or take part in our programmer surveys. Codility Limited is the controller.

The information we collect

  1. Your name, email address and the sign-in details for your account, including any social login you use.
  2. The challenges you attempt, the code you submit, your results and certificates, and your progress through lessons and training.
  3. Your profile, where you choose to create one, and the information you share in it.
  4. Your responses to our programmer surveys.
  5. Technical information about your use of the community, including your IP address and sign-in records.

This information comes from you and from the platform as you use it. We do not ask community members for special categories of personal information.

How we use it and why

PurposeInformation usedLawful basis
Providing your account, the challenges, lessons, training and certificates, and showing your progressAccount details; challenge and training activity; profilePerformance of the community terms of use
Keeping the community secure and preventing misuseTechnical information; sign-in recordsOur legitimate interests in the security of the platform
Sending you service messages about the community and, if you have agreed, updates about new challenges and contentEmail address; preferencesPerformance of the community terms of use for service messages; your consent for other email, which you can withdraw at any time
Understanding how the community is used and improving it, and analysing survey resultsActivity and survey information, analysed in aggregate wherever possibleOur legitimate interests in improving the community

Who receives it

Our cloud hosting provider and our email delivery provider process this information on our behalf. If you use a social login, the provider of that login receives your sign-in information. Your profile is visible to other people only where you choose to share it.

How long we keep it

Your account and activity are kept while your account is active and are deleted or anonymised after a period of inactivity, or sooner if you ask us to delete your account. If we close the community, we will delete or anonymise all member information.

8. Research, survey and feedback participants

This section applies if you take part in a research study that we run to evaluate our assessments, or if you answer a survey or give us feedback about our platform or services. Codility Limited is the controller.

The information we collect

  1. For research studies run through a research recruitment platform, a participant identifier provided by that platform, the demographic attributes you have chosen to share for the study, and your responses.
  2. For surveys and feedback programmes, your responses, your opinions and any free text you write, together with your name and email address where the survey is not anonymous.

Some of our research studies ask for demographic information, which can include your ethnicity and other characteristics that are special categories of personal information. We collect this only where it is needed to evaluate whether our assessments are fair across different groups, only with your explicit consent given under the terms of the study, and we report the results in aggregate.

How we use it and why

PurposeInformation usedLawful basis
Evaluating and improving the fairness, reliability and quality of our assessmentsStudy responses and demographic attributesYour consent, given under the terms of each study, including your explicit consent for any special category information
Understanding your experience of our platform and services and improving themSurvey and feedback responsesOur legitimate interests in improving our services
Publishing research findingsAggregated and anonymised results onlyOur legitimate interests in sharing what we learn

Who receives it

The research recruitment platform through which you take part is responsible for its own participant panel under its own privacy policy. Our survey, data storage and analysis tools process your responses on our behalf. Findings are shared only in aggregate.

How long we keep it

Raw study responses are kept for a defined period after the study ends and are then anonymised or deleted. Survey and feedback responses are kept for a defined period and are then anonymised or deleted. Aggregated findings are retained.

9. Recorded calls, events and social media

This section applies if you join a call or meeting with us that is recorded, attend an event we run or take part in, appear in a testimonial or case study, or engage with us on social media or review sites. Codility Limited is the controller.

The information we collect

  1. For recorded calls and meetings, the audio and video recording, a transcript, the names and email addresses of participants, and notes and summaries generated by AI note-taking tools.
  2. For events, your registration details, attendance and, where used, a badge or sign-up list.
  3. For testimonials and case studies, your name, job title, company, photograph and the words you have agreed we can publish.
  4. For social media and review sites, the public profile information and content you share when you engage with our pages or review our services.

We tell you at the start of a call or meeting if it is being recorded, and where the law of your country or state requires it we ask for your agreement before recording. Please avoid sharing sensitive personal information on recorded calls.

How we use it and why

PurposeInformation usedLawful basis
Keeping an accurate record of calls and meetings, producing notes and actions, and training our teamsRecordings, transcripts and summariesOur legitimate interests in keeping accurate records and improving how we work; your consent, where the law requires it
Analysing the language customers and prospects use to improve how we describe our servicesTranscripts and AI-generated insightsOur legitimate interests in improving our communications
Running events and following up with attendeesRegistration and attendance informationOur legitimate interests in running events; performance of a contract where you have paid to attend
Publishing testimonials, case studies and photographsTestimonial and case study contentYour consent or written agreement
Running our social media pages and managing our profile on review sitesPublic profile information and contentOur legitimate interests in promoting our business

Who receives it

The providers of our conferencing, recording, transcription and call analysis tools process recordings on our behalf. Event platforms and venues receive registration details for events they help us run. Social media and review platforms are independently responsible for the information you share on them.

How long we keep it

Call recordings are kept for a short period and transcripts and summaries for somewhat longer; notes written to our customer records are kept with those records. Event attendee lists are kept for a defined period after the event. Testimonials and photographs are kept for as long as they are published and for a short period afterwards.

Applies to everyone

The sections below apply whichever group you are in.

Use of artificial intelligence

We use AI features in some of our tools, including the chat assistant on our website, note-taking and summarisation on recorded calls, features in our support tools that categorise and summarise requests, and generative AI assistants that our staff use for drafting and analysis. These tools process the information you provide in the course of that interaction and are not used to make decisions about you. The Codility platform also includes AI features that customers can use when assessing candidates; those features are described in the section for candidates.

We do not make decisions about the people covered by this notice based solely on automated processing that would have a legal or similarly significant effect on them.

International transfers

Codility operates in the United Kingdom, Poland, Germany and the United States, and many of our service providers are based in the United States or store data there. Your information may therefore be transferred to, stored in or accessed from countries outside your own.

Where we transfer information to group companies, service providers or other recipients outside the UK or the European Economic Area, we rely on adequacy regulations or adequacy decisions where they apply (including the Data Privacy Framework certification described below), and otherwise on standard contractual clauses or the UK international data transfer agreement together with any additional safeguards identified in a transfer risk assessment. You can ask the Data Protection Officer for more information about the safeguards we use.

Data Privacy Framework

Codility Inc. participates in and complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. Codility Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit: Data privacy framework website.

In compliance with the Data Privacy Framework (DPF) Principles, we are committed to informing our users about our practices regarding the transfer of personal information to third parties. In the event that we transfer personal information to a third party acting as a controller, we adhere to the Notice and Choice Principles of the DPF. This means that we provide clear notice to our users about such transfers and offer a choice where appropriate.

In accordance with the Recourse, Enforcement, and Liability Principle of the DPF, our organization takes responsibility for the processing of personal information we receive under the DPF Principles and subsequent transfer to a third party acting as an agent on our behalf. We shall remain liable if our agent processes such personal information in a manner inconsistent with the DPF Principles, unless we prove that we are not responsible for the event that caused the damage.

Security

We have technical and organisational measures in place to protect your information against accidental loss and unauthorised access, use, alteration or disclosure. Our information security programme is independently audited. Access is limited to those who need it for their role, and everyone with access is bound by confidentiality obligations. We have procedures for handling suspected personal data breaches and will notify you and the relevant authority where the law requires.

Other recipients

In addition to the recipients described in each section above, we may share information about anyone covered by this notice with our auditors, banks, insurers, and legal and other professional advisers; with tax and regulatory authorities, courts and law enforcement where required by law; and with prospective buyers or partners in the event of a sale, merger or restructuring of the business, subject to confidentiality and, wherever possible, on an anonymised basis until the transaction completes. We share information between Codility group companies for the purposes described in this notice, including sales and customer support, system administration, hosting and group reporting.

We require our service providers to protect your information and to use it only for the purposes we specify. We do not sell your personal information in exchange for money. Some of the advertising tools we use on our website may be treated as “sharing” personal information under United States state privacy laws; see the annex to this notice.

Your rights

Depending on where you are, you have the right to:

  1. Access the personal information we hold about you.
  2. Have inaccurate or incomplete information corrected.
  3. Have your information erased where there is no good reason for us to keep it.
  4. Object to processing based on our legitimate interests, where your particular situation gives you grounds to do so, and object to direct marketing at any time.
  5. Restrict our processing in certain circumstances.
  6. Receive a copy of the information you have provided to us in a portable format.
  7. Withdraw consent at any time where our processing relies on it, without affecting processing carried out before you withdrew it.

Where the tables above show that we rely on our legitimate interests, you can object to that processing and we will stop unless we can show compelling grounds that override your interests, rights and freedoms. Where we rely on consent, you can withdraw it. Where we rely on a contract or a legal obligation, we may be unable to provide the service or meet the obligation without the information, and we will explain this if it applies.

To exercise these rights, contact our Data Protection Officer at [email protected]. We do not charge for handling requests unless a request is clearly unfounded or excessive, and we may ask you to confirm your identity. If your request concerns an assessment you took at the invitation of an employer, we will pass it to that employer or ask you to contact them directly.

Raising a concern or complaint

If you have a concern about how we handle your personal information, please raise it with the Data Protection Officer in the first instance. We will acknowledge your complaint, investigate it, and respond to you in writing within the time allowed by law, explaining what we found and any action we have taken.

You also have the right to complain to a supervisory authority at any time. In the United Kingdom, this is the Information Commissioner’s Office. Contact details for supervisory authorities in the European Economic Area are available from the European Data Protection Board at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

Data Privacy Framework

In the United States, Codility Inc. has certified compliance with—the EU–U.S. DPF Principles (including the UK Extension). We recognise our responsibility to adhere to the EU–U.S. Data Privacy Framework (EU–U.S. DPF) Principles while being subject to oversight and enforcement by the Federal Trade Commission (FTC).

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Codility commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF should first contact Codility at: dpo@codility.com. We will respond within 45 days.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Codility commits to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) on unresolved DPF Principles-related complaints about our handling of human resources data and non-human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.

If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, you may contact the relevant authority free of charge:

EU individuals: the EU Data Protection Authorities (DPAs), listed at: https://www.edpb.europa.eu/about-edpb/our-members_en

UK individuals: the UK Information Commissioner’s Office (ICO), via https://ico.org.uk/make-a-complaint/uk-extension-to-the-eu-us-data-privacy-framework-complaints-tool/

Binding arbitration

If your complaint is not resolved by any of the mechanisms above, you may invoke binding arbitration under Annex I of the EU–U.S. Data Privacy Framework. For details on how to initiate arbitration, please visit Data Privacy Framework.

Cookies

We use cookies and similar technologies on our website. Our cookie notice explains what they are, why we use them and how you can manage them, and you can change your choices at any time through the cookie settings on our website.

Changes to this notice

We will publish any changes to this notice on our website. The date of the current version is shown in the change history at the end of this notice.

Annex: California and other US state privacy rights

This annex applies to residents of California and supplements the notice above under the California Consumer Privacy Act (CCPA). Residents of other US states with comprehensive privacy laws can exercise the rights available to them under those laws in the same way.

If you took an assessment or interview at the invitation of an employer, Codility acts as a service provider to that employer. Please direct requests about that information to the employer.

Categories of personal information we collect

The CCPA requires us to describe the personal information we collect using the categories listed in the law. In the last 12 months we have collected the following categories, as described in more detail in the sections above that apply to you:

  1. Identifiers, including name, email address, telephone number, postal address, IP address, account username and cookie or device identifiers.
  2. Personal information categories listed in the California Customer Records statute, including name, contact details and billing information.
  3. Commercial information, including subscriptions, purchases and transaction history.
  4. Internet or other electronic network activity information, including use of our website and platform, pages viewed, interactions with our emails and advertisements, and session recordings.
  5. Geolocation data, limited to approximate location derived from IP address.
  6. Audio and visual information, including recordings of calls and meetings where recording is enabled.
  7. Professional or employment-related information, including job title and employer and, for job applicants, employment history.
  8. Education information, for job applicants and programmer community members who provide it.
  9. Inferences drawn from the above, including engagement and purchase intent signals and account health scores.
  10. Sensitive personal information, limited to account login credentials, which we use only to provide and secure your account, and, for job applicants, the categories described in the section for job applicants.

Sources, purposes and disclosures

The sources of this information, the business and commercial purposes for which we collect and use it, and the categories of service provider and third party to which we disclose it are described in the section above that applies to you and under “Other recipients”. We use sensitive personal information only for the purposes permitted by California law and do not use it to infer characteristics about you.

Sale and sharing

We do not sell personal information in exchange for money. When you accept advertising cookies on our website, we share cookie identifiers, hashed email addresses and information about your visit with advertising and social media platforms so that they can show you our advertisements elsewhere, which is treated as “sharing” for cross-context behavioural advertising under the CCPA. You can opt out at any time through the “Do Not Sell or Share My Personal Information” link in the footer of codility.com or by declining advertising cookies in our cookie settings, and we treat a Global Privacy Control signal from your browser as a request to opt out. We do not knowingly sell or share the personal information of consumers under 16 years of age.

Retention

We keep each category of personal information for as long as needed for the purposes above and for the periods required by applicable law, as set out in our retention schedule and summarised in the section above that applies to you.

Your rights

You have the right to know what personal information we collect, use, disclose, sell or share about you; to request deletion of your personal information; to request correction of inaccurate personal information; to opt out of the sale or sharing of your personal information; to limit the use of your sensitive personal information; and not to be discriminated against for exercising these rights. We do not offer financial incentives in exchange for personal information.

To exercise these rights, contact us at [email protected]. We will verify your identity before responding, which may involve confirming information we already hold about you or, if you have an account, asking you to sign in. You may authorise an agent to make a request on your behalf, in which case we may ask for evidence of the authorisation and verify your identity directly.

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