CODERLAND is committed to protecting the personal data of all individuals with whom
it interacts, including customers, employees, suppliers, and users of our services. This
Privacy Policy aims to transparently inform you about how we collect, use, share, and
protect the personal data processed in the course of our business activities.
As the Company operates both in the Republic of Panama (where its headquarters are
located) and in other countries including Spain, we have adopted a single Privacy Policy
that integrates the requirements of all applicable personal data protection regulations:
• Panama: Law 81 of March 26, 2019 on Personal Data Protection, regulated by
Executive Decree No. 285 of May 28, 2021.
• European Union: Regulation (EU) 2016/679 of the European Parliament and of
the Council of April 27, 2016 (the “GDPR”).
• Spain: GDPR and Organic Law 3/2018 of December 5 on Personal Data
Protection and the guarantee of digital rights (“LOPDGDD”).
This regulatory integration ensures a high standard of protection for all data subjects,
regardless of their location (Panama or Spain), reinforcing transparency, control, and
security over personal data.
CODERLAND guarantees the security and confidentiality of personal data provided by
its customers. In accordance with applicable regulations (Law 81/2019, GDPR,
LOPDGDD), the customer/user is informed and provides consent for the processing of
their data for the purposes communicated in each case, including those to which
CODERLAND may have access as a result of browsing this website.
CODERLAND’s privacy policy guarantees, in all cases, the exercise of the rights
established under the GDPR. CODERLAND also ensures the adoption of the necessary
measures to guarantee the confidential processing of such data.
DATA CONTROLLER
CODERLAND CENTROAMERICANA, S.A.
RUC: 2271874-1-785327 DV67
Address: Province of Panama, District of Panama, Corregimiento of Ancón, Alberto
Tejada Street, Coderland Building, Apartment 342, Ciudad del Saber.
DPO: [email protected]; Excell Compliance, S.L.
CODERLAND SPAIN
Registered address in Spain: C. de Joaquín Costa, 59, Chamartín, 28002, Madrid.
DATA PROTECTION OFFICER (DPO)
DPO: [email protected]; Excell Compliance, S.L.
PURPOSE
You may consult the purpose for which CODERLAND processes personal data for each
processing activity in the Register of Processing Activities. [Link]
LEGAL BASIS
You may consult the legal basis for each processing activity carried out by
CODERLAND in the Register of Processing Activities. [Link]
DATA RETENTION
The personal data provided will be retained for as long as necessary to fulfil the
purpose for which they were collected and to determine any potential liabilities arising
from such purpose. Retention periods for each processing activity may be consulted in
the Register of Processing Activities. [Link]
DATA DISCLOSURE AND INTERNATIONAL
TRANSFERS
Due to the nature of our activity, which includes the placement of professionals in
companies located in different countries, the transfer of personal data to a third country
or international organisation may be necessary for the performance of a contract or
legal relationship between the data subject and CODERLAND, or for the conclusion or
performance of a contract between CODERLAND and another company.
Transfers of personal data outside Panamanian territory will only be carried out if one of
the following conditions is met, in accordance with Panamanian regulations:
• Adequacy decisions: Data may be transferred to countries or international
organisations that, in the opinion of the National Authority for Transparency and
Access to Information (ANTAI), provide a level of personal data protection
equivalent to or higher than that provided by Law 81/19 and Executive Decree
No. 285/21.
• Appropriate safeguards: In the absence of an adequacy decision, transfers will
be carried out where the receiving entity provides and demonstrates appropriate
safeguards to ensure compliance with data protection principles and rights.
Where a transfer is made from EU territory to countries outside the EU/EEA, the
provisions of the GDPR regarding international transfers shall apply.
International data transfers involve the flow of personal data from Spanish territory to
recipients established outside the EU/EEA. The EU adopts adequacy decisions for
certain countries. Where such decisions do not exist, CODERLAND will implement
appropriate measures to safeguard data subjects’ rights.
You may consult whether international data transfers occur for each processing activity
in the Register of Processing Activities. [Link]
AUTOMATED DECISION-MAKING
CODERLAND does not carry out profiling or automated decision-making.
RIGHTS
Data subjects may exercise the following rights:
• Right of access to personal data
• Right to rectification or erasure
• Right to restriction of processing
• Right to object to processing
• Right to data portability
• Right to withdraw consent
These rights may be exercised by contacting: [email protected].
If you are in Spain (EU/EEA), you also have the right to lodge a complaint with the
Spanish Data Protection Agency (AEPD), the competent supervisory authority.
SECURITY
CODERLAND’s commitment to the confidentiality and security of personal data is not
only a legal requirement but also a core value. The Company has adopted appropriate
technical, organisational, and legal measures to ensure the security, confidentiality,
integrity, and availability of personal data, in accordance with Article 32 GDPR and
Article 31 of Law 81/2019 and Executive Decree 285/21.
TALENT PRIVACY POLICY
PURPOSE
The personal data provided will be used to collect and process CVs submitted through
the CODERLAND website or any other means, in order to manage the talent pool for
current and future job opportunities offered by CODERLAND and its clients.
Your CV will be retained for 4 years, after which it will be securely deleted, ensuring
full confidentiality. If your professional profile is not of interest, your data will be deleted.
No automated decision-making or profiling will be carried out.
LEGAL BASIS
By completing the form and accepting this Privacy Policy, you provide your explicit
consent for your data to be processed in order to assess your suitability for potential
job vacancies.
Fields marked with an asterisk (*) are mandatory; failure to complete them may prevent
CODERLAND from processing your request.
RECIPIENTS
Data may be disclosed to companies linked to CODERLAND for the same purposes, as
well as to service providers acting as data processors, under the corresponding data
protection agreements.
RIGHTS
The rights listed above may be exercised via [email protected], including identification
details and the specific right you wish to exercise.
PRIVACY POLICY FOR THE CONTACT FORM
DATA CONTROLLER
CODERLAND CENTROAMERICANA, S.A.
RUC: 2271874-1-785327 DV67
Address: Province of Panama, District of Panama, Corregimiento of Ancón, Alberto
Tejada Street, Coderland Building, Apartment 342, Ciudad del Saber.
DPO: [email protected]; Excell Compliance, S.L.
CODERLAND SPAIN
Registered address in Spain: C. de Joaquín Costa, 59, Chamartín, 28002, Madrid.
PURPOSE
The personal data provided will be used to send administrative, technical,
organisational and/or commercial information regarding our products and services.
Data will be retained for as long as the commercial relationship with the data subject is
maintained and no deletion is requested, without prejudice to longer retention periods
required by applicable law.
CODERLAND will not carry out automated decision-making, profiling, or any other
automated logic applied to your data.
LEGAL BASIS
By completing this form and accepting this Privacy Policy, you provide your explicit
consent for CODERLAND to process your data in order to send you administrative,
technical, organisational and/or commercial information regarding our products and
services.
Fields marked with an asterisk (*) are mandatory. Failure to complete them may prevent
CODERLAND from processing your request.
RECIPIENTS
Data may be disclosed to companies within the CODERLAND corporate group for the
same purposes, as well as to data processors engaged to perform subcontracted
activities, with whom CODERLAND has formalised the corresponding data protection
agreements.
RIGHTS
You may exercise the following rights:
• Right of access
• Right to rectification or erasure
• Right to restriction of processing
• Right to object to processing
• Right to data portability
• Right to withdraw consent
These rights may be exercised by contacting [email protected], including identification
details (full name) and the right you wish to exercise.
ADDITIONAL INFORMATION
CODERLAND’s commitment to the confidentiality and security of personal data is not
only a legal requirement but also a value upheld on a daily basis. The Company has
adopted appropriate technical, organisational, and legal measures to ensure the
security, confidentiality, integrity, and availability of personal data, in accordance with
Article 32 GDPR and Article 31 of Law 81/2019 and Executive Decree 285/21.
