# Airfleet Privacy Notice _Last updated: 2025-07-14_ Coders Clan Ltd. ("CodersClan") collects Personal Data from coders, applicants, and website visitors to provide its coding services platform. This Privacy Notice describes what information CodersClan collects, how it processes and shares that data, your rights regarding your information, and the safeguards CodersClan implements. ## Legal entity and registration Coders Clan Ltd. is the data controller. Its registered office is Aba Hillel 7, Ramat Gan, Israel, with registration number 515120996. EU Individuals may have additional rights under applicable data protection law. "Personal Data" means any information that refers to, is related to, or is associated with an identified or identifiable individual, or as otherwise defined by applicable law. ## What Personal Data CodersClan collects CodersClan collects Personal Data in three categories: **Application Data** When applying to provide Services, you must provide: name, email address, location (city, country), professional experience, and availability. You may optionally provide additional professional experience details, expertise, previous work examples, hourly rate, and links to LinkedIn, Stack Overflow, GitHub profiles, or your CV. **Contact Information** When you request information or contact CodersClan for any reason, CodersClan collects any data you provide, such as your email address and the content of your inquiry. **Automatically Collected Data** When you visit the Site, CodersClan automatically collects: non-Personal Data such as operating system; Personal Data such as IP address, device ID, geolocation (subject to applicable law consent), screen recordings, and viewing history on the Site. ## How CodersClan uses your Personal Data CodersClan uses the data it collects for the following purposes: | **Type of Data** | **Uses** | **Legal Basis** | |---|---|---| | Application Data | Assess ability to provide Services; register as coder; respond to inquiries; provide support | Performance of contract; legitimate interests (fraud prevention, security, problem resolution) | | Contact Information | Respond to requests; provide newsletters | Performance of contract | | Automatically Collected Data | Review usage and operations; develop new products; improve content and services; prevent fraud; protect Site security; provide customized content and targeted advertising | Legitimate interests (product development, analytics, fraud prevention, legal protection, marketing) | CodersClan also compiles Statistical Information from all data received to understand trends and customer needs. CodersClan may share Statistical Information with partners without restriction on commercial terms determined in CodersClan's sole discretion. **Analytics** CodersClan and its service providers use analytics tools, including Google Analytics, to collect information about Site usage patterns. Google Analytics collects information about visit frequency, pages visited, and prior websites or apps used. Google's use of this data is restricted by the [Google Analytics Terms of Service](http://www.google.com/analytics/terms/us.html) and [Google Privacy Policy](http://www.google.com/policies/privacy/). **Direct Marketing** CodersClan may use your Personal Data to inform you about its products and services believed to be of interest to you. CodersClan will limit direct marketing to reasonable and proportionate levels and send only communications believed to be of interest or relevance to you. You can adjust your browser settings to manage cookies used for online advertising. ## How CodersClan shares your Personal Data CodersClan shares your information as follows: **Affiliates** CodersClan shares information with its affiliated company, CodersClan Inc., when necessary to provide products and services and for business management purposes. **Service Providers and Subcontractors** CodersClan discloses Personal Data to trusted service providers and subcontractors who have agreed to confidentiality restrictions and who use the information solely on CodersClan's behalf to: help provide the Site; understand how users use the Site; conduct direct marketing. These providers offer IT and system administration services, data backup, security, storage, data analysis, and advertising and marketing services. **Data Controllers** CodersClan discloses Personal Data to independent third-party controllers acting as separate data controllers. Facebook, Inc. (Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, USA) is listed as a controller. **Business Transfers** Your Personal Data may be disclosed as part of, or during negotiations of, any merger, sale of company assets, or acquisition (including liquidation). Your Personal Data will continue to be subject to this Privacy Notice. **Law Enforcement** CodersClan may share your Personal Data with third parties: (i) if disclosure is appropriate to protect CodersClan's or a third party's rights, property, or safety, including enforcement of the Terms and this Privacy Notice; (ii) when required by law, regulation, subpoena, court order, or other law enforcement issues, agencies, or authorities; (iii) as necessary to comply with legal or regulatory obligations. **Legal Uses** CodersClan may use your Personal Data as required or permitted by applicable law, for example, to comply with audit and other legal requirements. ## International transfer of Personal Data CodersClan uses subcontractors, service providers, and affiliates located in countries other than yours, including New Zealand, the USA, and Australia, and sends them information including Personal Data. CodersClan conducts such transfers for the purposes described above. CodersClan ensures third parties are subject to written agreements guaranteeing the same level of privacy and data protection as this Privacy Notice, including appropriate remedies for data protection rights violations. For transfers of Personal Data to third parties outside the European Economic Area (EEA), CodersClan ensures similar protection by implementing at least one of the following safeguards: - CodersClan transfers Personal Data only to countries deemed by the European Commission to provide adequate protection for Personal Data. - CodersClan uses specific contracts approved by the European Commission that give Personal Data the same protection as in the EEA. - For US-based service providers, CodersClan may transfer Personal Data if they are certified by the EU-US Privacy Shield, which requires similar protection to Personal Data shared between the EU and US, or any other arrangement approved by the European Commission or other authorized body. Contact data-privacy@codersclan.com for information about the specific mechanism used by CodersClan when transferring Personal Data out of the EEA. ## Security measures CodersClan has implemented and maintains appropriate technical and organizational security measures, policies, and procedures designed to reduce the risk of accidental destruction, loss, or unauthorized disclosure or access to Personal Data. **Safeguards** CodersClan employs physical, electronic, and procedural safeguards including secure servers, firewalls, antivirus protection, and SSL encryption of data. **Access Control** CodersClan limits access to authorized personnel on a need-to-know basis according to least privilege rules, reviews permissions quarterly, and revokes access immediately after employee termination. **Internal Policies** CodersClan maintains and regularly reviews and updates privacy-related and information security policies. **Personnel** CodersClan requires new employees to sign non-disclosure agreements according to applicable law and industry customary practice. **Encryption** CodersClan encrypts data in transit using secure SSL protocols. **Database Backup** CodersClan backs up its databases on a periodic basis for certain data and verifies backups regularly. Backups are encrypted, stored within the production environment to preserve confidentiality and integrity, tested regularly to ensure availability, and accessible only by authorized personnel. **Limitations** No method of transmission over the Internet or method of electronic storage is 100% secure. CodersClan strives to use commercially acceptable means to protect your Personal Data but cannot guarantee its absolute security. As security also depends on the security of your computer and how you protect user IDs and passwords, you should take appropriate measures to protect this information. ## Your rights regarding your Personal Data Subject to certain exemptions and depending on the processing activity, you have the following rights regarding the Personal Data CodersClan holds about you: **Right of Access** You have a right to know what Personal Data CodersClan collects about you and, in some cases, to have such Personal Data communicated to you. Subject to applicable law, CodersClan may charge a fee. CodersClan may not be able to provide all requested information and will explain why. **Right to Data Portability** If processing is based on your consent or performance of a contract with you and processing is carried out by automated means, you may request that CodersClan provide you or another party with a copy of the Personal Data you provided in a structured, commonly-used, and machine-readable format. **Right to Correct Personal Data** Subject to applicable law limitations, you may request that CodersClan update, complete, correct, or delete inaccurate, incomplete, or outdated Personal Data. **Deletion of Personal Data (Right to Be Forgotten)** You have a right to request that CodersClan delete your Personal Data if: (i) it is no longer needed for the purpose for which it was collected; (ii) processing was based on your consent and you have withdrawn your consent; (iii) you have successfully exercised your Right to Object; (iv) processing was unlawful; or (v) CodersClan is required to erase it for legal compliance. CodersClan cannot restore deleted information. To ensure CodersClan does not collect further Personal Data, you should terminate your account and clear CodersClan's cookies from any device where you have used the Site. CodersClan may retain certain Personal Data following your deletion request for audit, record-keeping, or as otherwise permitted or required under applicable law. **Right to Restrict Processing** You can ask CodersClan to limit processing of your Personal Data if: (i) you have contested its accuracy and wish processing limited until verification; (ii) processing is unlawful but you do not wish the Personal Data erased; (iii) the data is no longer needed for its original purposes but CodersClan needs it to establish, exercise, or defend a legal claim; (iv) you have exercised your Right to Object and CodersClan is verifying its legitimate grounds for processing. CodersClan may continue to use your Personal Data after a restriction request in certain circumstances. **Right to Object** You can object to any processing of your Personal Data based on CodersClan's legitimate interests if you believe your fundamental rights and freedoms outweigh CodersClan's legitimate interests. CodersClan then has an opportunity to demonstrate that it has compelling legitimate interests overriding your rights and freedoms. **Withdrawal of Consent** You may withdraw your consent in connection with any processing of your Personal Data based on previously granted consent. This will not affect the lawfulness of any processing prior to withdrawal. **Right to Lodge a Complaint** You may have the right to submit a complaint to the relevant supervisory data protection authority if you have concerns about how CodersClan is processing your Personal Data. CodersClan asks that you attempt to resolve any issues with CodersClan first. **Exercise of Rights** For any requests to exercise rights regarding information held by other controllers, contact the applicable controller directly. If you wish CodersClan to notify all independent controllers, specify that request when contacting CodersClan. CodersClan will investigate and attempt to resolve complaints and disputes, making every reasonable effort to honor your rights as quickly as possible and within timescales provided by applicable data protection laws. CodersClan may ask for reasonable evidence to verify your identity before providing information or complying with requests. Contact data-privacy@codersclan.com to exercise any of your rights. ## Data retention Subject to applicable law and regulatory obligations, CodersClan retains Personal Data as necessary for the purposes described above. CodersClan may delete information from its systems without notice once it deems the information no longer necessary. Retention by any processor may vary according to the processor's retention policy. Generally, CodersClan retains Personal Data you provide during the terms of your engagement for provision of Services. CodersClan may store your Personal Data for longer periods in circumstances such as: required legal, regulatory, tax, audit, or accounting compliance; maintaining accurate records of your dealings in event of complaints or challenges; or reasonable belief that litigation relating to your Personal Data or dealings is likely. CodersClan considers the following when determining appropriate retention periods: the amount, nature, and sensitivity of the Personal Data; potential risk of harm from unauthorized use or disclosure; purposes for which it processes the Personal Data; whether those purposes can be achieved through other means; and applicable legal requirements. Contact data-privacy@codersclan.com for details regarding retention periods for different types of your Personal Data. ## Cookies and similar technologies CodersClan uses cookies and similar technologies to help personalize your experience and to personalize ads served to you. Third parties through which CodersClan provides the Site and business partners may place and read cookies on your browser or use web beacons to collect information in the course of advertising served on different websites. **What are cookies?** A cookie is a small piece of text sent to a user's browser or device. The browser provides this text to the originating user's device when the user returns. - A "session cookie" is temporary and remains on your device until you leave the Site. - A "persistent" cookie helps save your settings and customizations across visits and remains on your device until you delete it. - First-party cookies are placed by CodersClan; third-party cookies are placed by a third party. CodersClan uses both. - CodersClan may use the term "cookies" to refer to all technologies storing data in your browser or device, collecting information, or helping identify you, such as web beacons or "pixel tags". **How CodersClan uses cookies** CodersClan uses cookies and similar technologies for the purposes described below. The specific names and types may change over time, but cookies generally fall into one of these categories: | **Type of Cookie** | **Purpose** | |---|---| | Necessary | Enable the Site to work correctly. Allow access to the Site, movement between pages, and access to different services, features, and tools. Examples include remembering previous actions when navigating back to a page in the same session. These cookies cannot be disabled. | | Functionality | Remember your settings, preferences, and choices (such as language or regional preferences) to personalize your experience and offer enhanced functionality and content. | | Security | Help identify and prevent security risks. May store session information to prevent others from changing your password without your login information. | | Performance | Collect information about how you use the Site, such as which messages or pages you have viewed and how long you spent on each page, to help CodersClan improve Site performance. | | Analytics | Collect information about your activity on the Site to help CodersClan learn which features are popular with users and how the Site can be improved. | | Advertising | Deliver content, including ads relevant and meaningful to you and your interests. May be used to deliver targeted advertising or limit how many times you see an advertisement. Help track how efficient advertising campaigns are for CodersClan's own services and other websites. May track your browsing habits and activity on the Site and third-party sites. | **Third-party cookies** The following third parties place cookies when you visit the Site: Facebook, Google Analytics, Mixpanel, Google Ads, Hotjar, and Drift. **How to adjust your preferences** Most web browsers are initially configured to accept cookies, but you can change this setting so your browser refuses all cookies or informs you when a cookie is being sent. You are free to delete any existing cookies at any time. Some features of CodersClan's services may not function properly when cookies are disabled or removed. By changing your device settings, you can prevent your device's ad identifier from being used for interest-based advertising or reset your device's ad identifier. Typically, you can find ad identifier settings under "privacy" or "ads" in your device's settings, though settings may vary. Adjusting your preferences does not mean you will no longer receive advertisements; it only means the advertisements you do see will be less relevant to your interests. ## Third-party applications and services All use of third-party applications or services is at your own risk and subject to such third party's terms and privacy policies. ## Communications CodersClan reserves the right to send you service-related communications, including service announcements and administrative messages, without offering you the opportunity to opt out. If you do not wish to receive such communications, you may cancel your account. ## Children CodersClan does not knowingly collect Personal Data from children under the age of sixteen (16). If you become aware that an individual under the age of sixteen (16) has enrolled without parental permission, please advise CodersClan immediately. ## Changes to the Privacy Notice CodersClan may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way CodersClan operates its business, and will place any updates on this webpage. You should return to this page regularly to ensure familiarity with the latest version. If CodersClan makes material changes, it will seek to inform you by notice on the Site or per email. ## Contact CodersClan If you have any comments or questions about this Privacy Notice or wish to exercise any of your legal rights, contact CodersClan at data-privacy@codersclan.com.