Privacy Notice

1. Who we are

Cool Software Ltd (“Cool Software”, “we”, “us” or “our”) is a company registered in Malta under company number C 117046. Our registered office is Regus Tower Business Centre, Level 2, Triq it-Torri, Swatar, Birkirkara BKR 4013, Malta.

We are the controller of personal data processed for the website, business enquiries and recruitment activities described in this notice. This means we decide why and how that personal data is used.

For questions about this notice or to exercise your data protection rights, email contact@coolsoftware.ai.

2. What this notice covers

This notice explains how we handle personal data when you visit our website, contact us about our business or submit a recruitment enquiry or application.

Our website describes our work in digital identity, digital wallets and related software infrastructure. This notice does not describe the processing of identity verification records, wallet information or other end-user data through software supplied to customers. Any such processing requires separate privacy information and contractual arrangements appropriate to the service and our role.

3. Personal data we collect

Depending on how you interact with us, we may process:

• Enquiry information: your name, email address, telephone number, company, job title, message and any attachments or other details you choose to provide.
• Business contact information: professional contact details and correspondence needed to discuss a potential business relationship.
• Recruitment information: your CV, employment and education history, qualifications, portfolio and information you provide during recruitment discussions.
• Technical information: information generated when you access the website, such as your IP address, browser and device information, pages requested, access times and technical or security logs, where recorded by our website infrastructure.
• Privacy request information: your correspondence and any information reasonably needed to verify your identity and respond to a request.

Please avoid sending unnecessary personal data. Do not send passwords, private keys, seed phrases, identity documents or sensitive verification materials through general enquiries unless we specifically request them and provide an appropriate secure method.

Please also avoid including sensitive personal information in recruitment materials unless it is relevant and requested. Where we need to process special-category data, we will identify an applicable additional legal condition and provide appropriate information.

4. Where personal data comes from

We generally receive personal data directly from you through email, enquiries or recruitment communications. Technical information may be generated automatically when you access the website.

If someone introduces you to us or submits information on your behalf, we may receive your name, professional contact details and information relevant to the introduction. We will provide any additional privacy information required for that collection, including information about the source.

5. Why we use personal data

We process personal data only where we have an applicable legal basis under the General Data Protection Regulation (GDPR).

Where we rely on legitimate interests, we consider the necessity of the processing and balance those interests against your rights and reasonable expectations. You may object to processing based on legitimate interests as explained below.

If we ask for consent for a particular activity, we will explain what you are consenting to. You can withdraw that consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

6. Whether you need to provide personal data

You can generally browse the public website without providing enquiry or recruitment information. Technical information may still be processed as described above.

Providing information for an enquiry or application is voluntary. If you do not provide information needed to respond or assess your application, we may be unable to do so. We will explain any mandatory requirements when they arise.

7. Who receives personal data

Access is limited to people and organisations who need the information for the purposes described in this notice. Depending on the activity, recipients may include:

• Authorised personnel handling enquiries, recruitment, website administration or legal matters.
• Service providers supporting website hosting, email, IT, security and other relevant administrative functions.
• Professional advisers, such as legal advisers, where necessary.
• Courts, regulators or public authorities where disclosure is required by law or necessary to establish, exercise or defend legal claims.

Where a provider processes personal data on our behalf, we require appropriate data protection arrangements. Some recipients, such as professional advisers or authorities, may act as independent controllers.

8. International transfers

When assessing service providers, we consider where personal data will be stored and accessed. Any transfer of personal data outside the European Economic Area must meet applicable data protection requirements, including an applicable adequacy decision or appropriate safeguards where required.

For information about the locations in which your personal data is processed and any applicable transfer safeguards, contact contact@coolsoftware.ai.

9. How long we keep personal data

We keep personal data for no longer than necessary for the relevant purpose, taking account of applicable legal requirements and any need to establish, exercise or defend legal claims.

We determine retention by reference to the following criteria:

• Business enquiries: the time needed to respond, complete any related discussions and maintain necessary records of an ongoing business relationship.
• Recruitment: the time needed to assess an application, complete recruitment and address any related questions or claims. Keeping an application for unrelated future opportunities requires a separate, appropriate basis and information to the applicant.
• Successful applications: necessary recruitment records may become part of the employment record, subject to the privacy information provided to employees.
• Technical and security records: the time needed to diagnose faults, protect systems and investigate identified security incidents.
• Privacy requests and complaints: the time needed to respond, demonstrate compliance and address any related dispute.

Retention decisions also take account of the sensitivity of the data, whether the purpose can be met with less information, applicable legal retention requirements and relevant limitation periods. Records retained for a legal obligation or claim are restricted to that purpose. Backup copies are subject to the relevant system’s deletion and overwrite cycle.

10. Keeping personal data secure

We use technical and organisational measures appropriate to the nature of the personal data and the risks involved to help protect it against unauthorised access, loss, misuse or disclosure.

No website or method of electronic transmission can be guaranteed completely secure. Please use an agreed secure channel when sharing sensitive information with us.

11. Your rights

Subject to the conditions and exceptions in applicable law, you may have the right to:

• Access your personal data and obtain a copy.
• Correct inaccurate data and complete incomplete data.
• Request deletion of your personal data.
• Request restriction of processing.
• Object to processing based on legitimate interests on grounds relating to your particular situation.
• Receive data you provided in a structured, commonly used, machine-readable format, and request its transfer to another controller, where processing is automated and based on consent or a contract.
• Withdraw consent where processing relies on it.

If your personal data is used for direct marketing, you have the right to object to that use at any time.

To exercise your rights, email contact@coolsoftware.ai. We may request information proportionate to the circumstances to confirm your identity.

We normally respond within one month of receiving your request. Where the law permits an extension because of the complexity or number of requests, we will explain the reason and notify you within that first month. Requests are generally free of charge, subject to the exceptions allowed by law.

12. Complaints

If you have concerns about how we handle your personal data, you can contact us at contact@coolsoftware.ai.

You also have the right to lodge a complaint with a competent data protection supervisory authority, particularly in the EU Member State where you habitually live or work, or where you believe an infringement occurred.

In Malta, the supervisory authority is the Information and Data Protection Commissioner (IDPC). Information about submitting a complaint is available at idpc.org.mt/file-a-complaint.

You do not have to contact us before lodging a complaint with a supervisory authority.

13. Third-party websites

Links on our website may take you to third-party websites. Those organisations are responsible for their own personal data processing. Please review their privacy information before providing personal data to them.

14. Changes to this notice

We may update this notice to reflect changes in our activities or legal requirements. The latest version will be published on this page with an updated date. Where required, we will provide additional notice of material changes.

15. Contact us