1. Data Collected Through the Contact Form, Email, or Chat

This section applies to personal data you provide when contacting us through our website contact form, by email, or via chat.

1.1 Purpose of Processing

We process your personal data to respond to your inquiries, provide the information or assistance you request, and manage any follow-up communications related to your query.

1.2 Legal Basis for Processing

The legal basis for this processing is Croyten’s legitimate interest in responding to inquiries, managing communications, and maintaining business correspondence. Where required by applicable law, processing may also be based on your consent when you voluntarily submit your information.

1.3 Recipients of Your Data

Access to your personal data is limited to authorized personnel and to technology and service providers acting on our behalf (e.g., hosting providers, email service providers, or communication platform providers). These providers process personal data strictly in accordance with our instructions and under appropriate confidentiality and data processing agreements.

1.4 International Data Transfers

Where necessary to provide our services, your personal data may be accessed or processed by service providers located outside your country of residence, including outside the United States or the European Economic Area. Where such transfers occur, we ensure appropriate safeguards are in place, including reliance on the EU–U.S. Data Privacy Framework or other legally recognized transfer mechanisms, as required under applicable data protection laws.

1.5 Data Retention

We retain personal data collected for this purpose only for as long as necessary to respond to and resolve your inquiry, and for any additional period required to comply with legal obligations or to establish, exercise, or defend legal claims.

2. Data Processing of Job Applicants

This section applies to individuals who submit their curriculum vitae (CV), résumé, or other application materials to Croyten for employment consideration.

2.1 Purpose of Processing

We process your personal data to evaluate your qualifications and suitability for current or future employment opportunities at Croyten, to manage the recruitment process, and to communicate with you regarding your application.

2.2 Legal Basis for Processing

The legal basis for this processing is Croyten’s legitimate interest in assessing candidates for employment and managing its recruitment activities. Where required by applicable law, processing may also be based on your consent when you voluntarily submit your application materials.

2.3 Recipients of Your Data

Your personal data will be accessed only by authorized personnel involved in the recruitment process. We do not disclose applicant data to third parties, except where necessary to comply with legal obligations or where service providers acting on our behalf require limited access under appropriate confidentiality and data processing agreements.

2.4 Data Retention

We retain applicant data for a period of up to one (1) year from the date of submission, unless a longer retention period is required by law or you consent to a longer retention period for consideration of future opportunities.

3. Data Processing of Social Media Users

This section applies to individuals who interact with Croyten through official profiles or pages on social media platforms.

3.1 Purpose of Processing

We process personal data that you make available through your interaction with our social media accounts in order to communicate with you, respond to inquiries, manage comments and messages, and administer our online communities in accordance with the terms and policies of the relevant social media platform.

Please note that your use of a social media platform is also governed by that platform’s own privacy policy and terms of service.

3.2 Legal Basis for Processing

The legal basis for this processing is Croyten’s legitimate interest in maintaining an online presence, communicating with users, responding to inquiries, and managing its social media activities. Where applicable, processing may also be based on your consent as provided through the social media platform.

3.3 Recipients of Your Data

Personal data visible on social media platforms may be accessed by the relevant platform provider in accordance with its own policies. Within Croyten, access is limited to authorized personnel responsible for managing social media communications. We do not independently disclose social media user data to third parties, except where required by law.

3.4 Data Retention

We retain personal data obtained through social media interactions only for as long as necessary to respond to your inquiry or manage the interaction. However, content you post may remain on the social media platform in accordance with that platform’s data retention policies, which are outside of our control.

4. Data Processing of Supplier Representatives

This section applies to individuals who act as representatives, employees, contractors, or contact persons of vendors, suppliers, or freelance service providers that maintain a business relationship with Croyten.

4.1 Purpose of Processing

We process your personal data to manage, administer, and perform the contractual relationship between Croyten and the organization you represent (or directly with you, if you are an independent contractor). This includes maintaining business communications, managing services, ensuring compliance with contractual obligations, and handling administrative matters related to the business relationship.

4.2 Legal Basis for Processing

The legal basis for this processing is Croyten’s legitimate interest in managing its supplier relationships and conducting its business operations. Where applicable, processing may also be necessary for the performance of a contract.

4.3 Recipients of Your Data

Access to your personal data is limited to authorized personnel within Croyten who require such access for business purposes. We do not disclose supplier representative data to third parties except where necessary to fulfill contractual obligations, comply with legal requirements, or where service providers acting on our behalf require access under appropriate confidentiality and data processing agreements.

4.4 Data Retention

We retain your personal data for the duration of the contractual relationship and for any additional period necessary to comply with legal, accounting, or regulatory obligations, or to establish, exercise, or defend legal claims.

5. Exercise of Your Rights

Subject to applicable data protection laws, you may exercise the following rights in relation to your personal data:

• Right of Access – to obtain confirmation as to whether we process your personal data and, if so, to access the personal data and information regarding the processing activities carried out.
• Right to Rectification – to request correction of inaccurate or incomplete personal data.
• Right to Erasure – to request deletion of your personal data where applicable, including where the data is no longer necessary for the purposes for which it was collected or processed.
• Right to Restriction of Processing – to request limitation of processing where the accuracy, lawfulness, or necessity of processing is contested. In such cases, we may retain the data solely for the establishment, exercise, or defense of legal claims.
• Right to Object – to object to the processing of your personal data where processing is based on legitimate interest, including data processed in connection with:
• inquiries submitted through the contact form, email, or chat
• interactions through social media platforms
• evaluation of job applications, or
• management of supplier or business contact relationships
• Right to Data Portability – where processing is carried out by automated means and based on consent or contract, to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.

To exercise any of these rights, please contact us at contact@croyten.com. Your request should specify the right you wish to exercise and include sufficient information to allow us to verify your identity. Where necessary, we may request additional information to confirm your identity before processing your request.

6. Cookies and Similar Technologies

Croyten and our partners use cookies and similar technologies, including web beacons, pixels, and JavaScript, to enhance your experience on our website. These technologies are used to:

• Analyze website usage and trends
• Administer and improve the website
• Track user interactions and navigation
• Collect aggregated demographic information about our user base.

For detailed information on the types of cookies, we use, their purposes, and how you can manage or disable them, please refer to our Cookies Policy.

7. Data Protection Officer (DPO) and Contact Information

If you have any questions regarding this Privacy Policy, our privacy practices, or if you require this notice in an alternative format due to a disability, please contact us at: contact@croyten.com.

If you believe that Croyten has violated applicable data protection laws, you are encouraged to notify us at the same email address. We will review your concerns and take appropriate steps to address any issues promptly. We take the protection of your personal data seriously.

For additional information about your rights and our obligations, please also review our Terms of Use.

Effective Date

This Privacy Policy is effective as of March 03, 2026.
The policy was last revised on July 10, 2024.

Review History

• Version: v1.1
• Author/Reviewer: CISO
• Comments: Revision
• Date: March 03, 2026
• Approval: CEO
• Approval Date: March 03, 2026