Privacy Policy

Last updated: November 13, 2025

1. Who We Are

We are Codeworks Ltd, a software development company based in Limassol, Cyprus. Our H.O. address is Morfou 9A Street, Limassol, 3012, Cyprus.

We develop and provide payroll software for businesses in Cyprus, including a cloud-hosted version of our payroll system.

If you have any questions about this Privacy Policy or how we handle data, you can contact us via our contact form.

2. What This Policy Covers

This Privacy Policy explains:

What personal data we collect and process
Why we process it and how we use it
Who we share it with
How we protect it
Your rights under the GDPR

This policy applies to:

Visitors of our website
Clients who use our payroll software
The employees of our clients whose data is stored in our system

3. Personal Data We Process

When you use our payroll software (either on-premise or cloud-based), we may process the following types of data on behalf of our clients (employers):

Name and surname
Identification number and Tax Identification Number (TIN)
Social Insurance Registration Number, ARC, or passport number
Contact details (address, phone, email)
Salary, tax, and social insurance information
Employment-related data (e.g., fund participation, vacation records, deductions)

If you contact us directly (e.g., for support), we may also collect:

Your name and contact information
Details about your request or issue

4. Why and How We Use Personal Data

We process personal data only to provide our payroll software services to our clients.

Typical uses include:

Hosting and storing payroll databases in a secure cloud environment
Allowing clients to manage employee payroll records
Providing technical support and system maintenance
Performing backups to ensure data integrity

We do not use your data for marketing or sell it to any third parties.

5. Legal Basis for Processing

We process data:

As a data processor, on behalf of our clients (who are the data controllers)
As a data controller, for our own business operations (e.g., client account management, billing, support)

All processing activities comply with the EU General Data Protection Regulation (GDPR) and Cyprus Data Protection Law 125(I)/2018.

6. Where Data Is Stored

Our cloud servers are located in EU and are hosted by Velia.net in co-operation with Digitrade Ltd — a trusted European hosting provider. All data remains within the European Union, and no data is transferred outside the EEA.

7. How We Keep Data Secure

We take data security very seriously. Our security measures include:

Encrypted connections (SSL/TLS)
Access control and two-factor authentication
Daily encrypted backups
Servers accessible only from Cyprus
Secure hosting within the EU
Confidentiality agreements for authorized personnel

8. How Long We Keep Data

For payroll clients:

We retain client data for up to 90 days after service termination, unless deletion is requested earlier.
Backups are securely destroyed within the same timeframe.

For website inquiries or support requests:

We keep data only as long as necessary to respond to your inquiry or maintain our business relationship.

9. Sharing of Data

We may share personal data only with:

Our authorized technical staff for maintenance and support (when requested by clients)

We do not share, sell, or disclose personal data to third parties unless required by law.

10. Your Rights

Under the GDPR, you have the right to:

Access your personal data
Request correction or deletion
Restrict or object to processing
Receive a copy of your data (data portability)
Lodge a complaint with the Office of the Commissioner for Personal Data Protection (Cyprus)

If you wish to exercise any of these rights, please contact us via our Contact form.

11. Data Breach Notifications

If a data breach occurs that may affect your personal data, we will inform our clients without undue delay and follow all legal reporting requirements.

12. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our services or legal obligations. The most recent version will always be available on our website.