1. Who We Are
This Privacy Policy is issued jointly by:
- CoderTrails Pte. Ltd., a company incorporated in Singapore with its registered office at 100D Pasir Panjang Rd, #05-03 Meissa, Singapore - 118520 ("CoderTrails Singapore"), and
- CoderTrails Private Limited, a company incorporated in India with its office at Mulund - West, Mumbai - 400080, Maharashtra, India ("CoderTrails India"),
together referred to as "CoderTrails", "we", "us", or "our".
This Policy explains how we collect, use, disclose, store, and protect personal data when you visit www.codertrails.com (the "Website"), contact us, apply for a role with us, or otherwise interact with us.
Depending on where you are located and the nature of your interaction with us, either or both entities may act as the organisation responsible for your personal data under the Singapore Personal Data Protection Act 2012 ("PDPA") or as the Data Fiduciary under the Indian Digital Personal Data Protection Act, 2023 ("DPDP Act").
By using the Website or providing personal data to us, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, please do not use the Website and do not submit your personal data to us. Where consent is required by law, we will obtain it as described below.
2. Personal Data We Collect
We collect personal data that you provide directly, data collected automatically, and data received from third parties.
2.1 Data you provide to us
- Contact and enquiry data: name, email address, phone number, company name, job title, country, and the contents of any message you submit through our contact forms, chat interface, or email.
- Recruitment data (Careers section): name, email address, phone number, current location, CV/resume, cover letter, employment history, education, skills, certifications, expected compensation, notice period, work authorisation status, links you choose to share (such as LinkedIn, GitHub, or portfolio), interview notes and assessment results, and references.
- Business relationship data: information exchanged in proposals, agreements, invoices, and project communications if you are a client, prospective client, vendor, or partner.
- Newsletter and content data: email address and preferences if you subscribe to our updates or download our materials.
2.2 Data collected automatically
- Technical data: IP address, browser type and version, device type, operating system, screen resolution, and language settings.
- Usage data: pages visited, time spent, referring URLs, click behaviour, and interactions with features on the Website, collected through cookies and similar technologies (see Section 9).
- Chat interactions: if you use the AI assistant on our Website, the questions you submit and the responses generated are processed to provide the service and improve its accuracy. Do not share Aadhaar numbers, PAN, NRIC, passport numbers, financial account details, passwords, health records, or other sensitive or confidential information while using the chat.
2.3 Data from third parties
- Publicly available professional information (for example, from LinkedIn) where relevant to recruitment or business development.
- Information from referrers, recruiters, or references you nominate.
- Analytics and advertising platforms, where permitted by law.
We do not knowingly collect personal data from individuals under 18 years of age. If you believe a minor has provided us personal data, contact us and we will delete it.
Sensitive personal data: We do not seek to collect sensitive personal data (such as health information, financial account credentials, government-issued identification numbers, biometric data, religious beliefs, or sexual orientation) through the Website. Please do not submit such information through our forms, chat interface, or email. If you choose to provide it unsolicited, you do so at your own initiative and we may delete it without notice.
3. Purposes for Which We Use Personal Data
We use personal data only for purposes that a reasonable person would consider appropriate in the circumstances, and where required, with your consent. These purposes include:
General
- Responding to enquiries and providing requested information.
- Operating, maintaining, securing, and improving the Website and our services.
- Communicating service updates, administrative notices, and legal notices.
- Sending marketing communications where you have consented or where otherwise permitted by law. Every marketing email we send includes an unsubscribe link, and you may opt out at any time by using that link or by emailing info@codertrails.com. Opting out of marketing does not affect service-related or administrative communications.
- Complying with legal and regulatory obligations in Singapore, India, and other applicable jurisdictions.
- Establishing, exercising, or defending legal claims.
- Detecting, investigating, and preventing fraud, security incidents, and misuse of the Website.
Recruitment
- Evaluating your application, qualifications, and suitability for the role applied for or other roles we reasonably believe may interest you.
- Communicating with you about your application and scheduling interviews.
- Conducting interviews, assessments, and background or reference checks (with your consent where required by law).
- Verifying your identity and eligibility to work.
- Maintaining records of the hiring process for compliance and audit purposes.
- If your application is successful, using your data for onboarding and employment purposes, which will be governed by a separate employee privacy notice.
We do not use recruitment data for automated decision-making that produces legal or similarly significant effects without human review.
4. Legal Basis and Consent
Singapore (PDPA): We collect, use, and disclose personal data with your consent, or where an exception applies under the PDPA, including deemed consent by conduct, deemed consent by contractual necessity, legitimate interests, and business improvement purposes. Where we rely on legitimate interests, we have assessed that the benefit outweighs any adverse effect on you.
India (DPDP Act and DPDP Rules, 2025): We process digital personal data based on your consent, which is free, specific, informed, unconditional, and unambiguous, given through a clear affirmative action (for example, ticking the consent checkbox when submitting a job application). Consent requests are accompanied by a notice describing the personal data collected and the purpose of processing, in accordance with the Digital Personal Data Protection Rules, 2025. We may also process personal data for certain legitimate uses recognised under the DPDP Act, including data you voluntarily provide for a specified purpose, employment-related purposes, and compliance with law or court orders.
Withdrawing consent: You may withdraw your consent at any time by emailing us at info@codertrails.com with the subject line "Withdraw Consent", stating what you are withdrawing consent for. Withdrawing consent is as simple as the process by which you gave it, and we will act on your withdrawal within 30 days of receiving it. Withdrawal does not affect processing carried out before withdrawal and may mean we are unable to continue processing your application or providing certain services.
5. Disclosure of Personal Data
We never sell personal data, and we do not share personal data with third parties for their own marketing purposes without your consent. We may share personal data with:
- Group entities: between CoderTrails Singapore and CoderTrails India for the purposes described in this Policy, including centralised recruitment, administration, and service delivery.
- Service providers and data processors: hosting and cloud infrastructure providers (including Amazon Web Services), email and communication providers, applicant tracking and HR tools, analytics and measurement providers (currently including Google Analytics and Microsoft Clarity, as may be updated from time to time), and professional advisers, in each case bound by contractual obligations of confidentiality and data protection.
- AI service providers: where you interact with the AI assistant on the Website, inputs may be processed by third-party AI infrastructure providers under contractual safeguards.
- Referees and background check providers: in connection with recruitment, with your consent where required.
- Legal and regulatory recipients: courts, regulators, law enforcement, and government authorities where disclosure is required or permitted by law.
- Corporate transactions: a prospective or actual acquirer, investor, or successor in the event of a merger, acquisition, financing, or sale of assets, subject to confidentiality obligations.
6. International Transfers
CoderTrails operates from Singapore and India, and our service providers may be located in other jurisdictions, including the United States, United Kingdom, and other APAC countries.
Where personal data is transferred outside Singapore, we ensure the recipient is bound by legally enforceable obligations to provide a standard of protection comparable to the PDPA. Where personal data is transferred outside India, we do so in accordance with the DPDP Act and any restrictions notified by the Indian government from time to time.
7. Retention
We retain personal data for as long as reasonably necessary to fulfil the purposes for which it was collected, to comply with our legal, regulatory, tax, accounting, and audit obligations, and to establish, exercise, or defend legal claims, including for the duration of applicable limitation periods.
The following are indicative retention periods, not fixed commitments. Actual periods may be shorter or longer depending on the nature of our relationship with you, ongoing or anticipated disputes, and legal requirements:
- Enquiry and contact data: typically up to 24 months after our last interaction.
- Recruitment data: typically up to 24 months after the conclusion of the recruitment process, so that we may consider you for current and future roles. You may request earlier deletion at any time, subject to our right to retain data where reasonably necessary for compliance or the defence of legal claims.
- Client, vendor, and contractual data: for the duration of the relationship and thereafter as required for legal, tax, accounting, and audit purposes (typically 7 to 8 years).
- Website analytics data: in accordance with the retention settings of the analytics tools we use.
When personal data is no longer required for any of the above purposes, we delete it or anonymise it so it can no longer identify you.
8. Your Rights
Subject to applicable law and legal exceptions, you have the right to:
- Access the personal data we hold about you and information about how it has been used or disclosed in the past year.
- Correct inaccurate or incomplete personal data.
- Withdraw consent to our continued collection, use, or disclosure of your personal data, using the process described in Section 4.
- Erasure (India): request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to legal retention requirements.
- Grievance redressal (India): raise a grievance regarding our processing of your personal data, which we will address within the timelines prescribed under the DPDP Act.
- Nominate (India): nominate another individual to exercise your rights in the event of death or incapacity.
To exercise any of these rights, contact us using the details in Section 12. We may need to verify your identity before acting on a request. We will respond within 30 days of receiving a verified request, or within any shorter period required by applicable law. We may charge a reasonable fee for access requests where permitted under the PDPA.
If you are not satisfied with our response, you may contact the Personal Data Protection Commission of Singapore (www.pdpc.gov.sg) or seek remedies before the Data Protection Board of India in accordance with the Digital Personal Data Protection Act, 2023. We encourage you to contact us first so we can attempt to resolve your concern directly.
If you are located in a jurisdiction whose data protection laws grant you additional rights, you may contact us at info@codertrails.com and we will respond in accordance with the laws applicable to your request.
9. Cookies and Similar Technologies
The Website uses cookies and similar technologies in two categories:
Strictly necessary cookies: required for core Website functionality, security, and remembering your session preferences. These do not require consent under applicable law.
Analytics cookies: we use third-party analytics tools to understand how visitors use and interact with the Website. These currently include Google Analytics (traffic, pages visited, engagement) and Microsoft Clarity (heatmaps and anonymised session replays of scrolls, clicks, and mouse movement). These tools set cookies and process technical data such as your IP address and device information on behalf of their respective providers. We may add, replace, or remove analytics or similar measurement tools from time to time; the tools in use will be reflected in the consent notice on the Website. We use the resulting insights solely to improve the Website.
Advertising cookies: we do not currently use advertising or retargeting cookies. If we introduce any in the future, they will be listed in the consent notice on the Website, will remain off by default, and will be set only if you enable them through that notice.
Where required by applicable law, we obtain your consent before setting analytics cookies through the consent notice displayed on the Website. You may decline analytics cookies without affecting your ability to use the Website.
You can also opt out directly: manage or delete cookies through your browser settings, or use opt-out mechanisms provided by the relevant tool providers (for example, the Google Analytics opt-out browser add-on at tools.google.com/dlpage/gaoptout). To learn how these providers handle data, refer to their respective privacy policies. Disabling strictly necessary cookies may affect Website functionality.
"Do Not Track" signals: Some browsers can send "Do Not Track" signals. The Website does not currently respond to Do Not Track signals; instead, you can control tracking through the consent notice and the opt-out mechanisms described above.
10. Security
We implement reasonable technical and organisational security measures designed to protect personal data against unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks. These include encryption in transit, access controls, infrastructure hosted on established cloud providers, staff confidentiality obligations, and periodic review of our data handling practices.
However, while we take appropriate safeguards, no method of transmission or storage can guarantee absolute security. To the extent permitted by applicable law, we shall not be liable for unauthorised access or disclosure resulting from events beyond our reasonable control, provided we have complied with our legal obligations under applicable data protection laws.
Breach notification: In the event of a personal data breach affecting your personal data, we will notify you and the relevant authorities, including the Personal Data Protection Commission of Singapore and the Data Protection Board of India, within the timelines and in the manner required by the PDPA, the DPDP Act, and the DPDP Rules, 2025.
11. Third-Party Links
The Website may contain links to third-party websites (for example, LinkedIn or Instagram). We are not responsible for the privacy practices or content of those websites. We encourage you to review their privacy policies.
12. Contact Us
All privacy enquiries, rights requests, consent withdrawals, and grievances should be sent to: info@codertrails.com
Data Protection Officer (Singapore, PDPA): reachable at info@codertrails.com with the subject line "Attention: Data Protection Officer".
Grievance Officer (India, DPDP Act): Grievance Officer, CoderTrails Private Limited, reachable at info@codertrails.com with the subject line "Attention: Grievance Officer". Grievances will be acknowledged promptly and addressed within the timelines prescribed under the DPDP Act and the DPDP Rules, 2025.
Our registered office addresses are set out in Section 1 of this Policy.
13. Changes to This Policy
We may update this Policy from time to time to reflect changes in law, technology, or our practices. The updated version will be posted on this page with a revised "Last updated" date. Material changes will be notified through the Website or by email where appropriate. Your continued use of the Website after changes take effect constitutes acknowledgement of the updated Policy.
14. Governing Law and Jurisdiction
This Policy is governed by and construed in accordance with the laws of India. Subject to the paragraph below, any dispute arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the courts at Mumbai, Maharashtra, India.
Nothing in this Policy limits or excludes any mandatory statutory rights you hold under applicable data protection law, including your right to lodge a complaint with the Personal Data Protection Commission of Singapore in respect of processing by CoderTrails Singapore, or to approach the Data Protection Board of India in respect of processing governed by the DPDP Act.
Your Privacy Matters to Us
At CoderTrails, trust is engineered the same way our platforms are: deliberately, and built to hold up in production. This Policy reflects our commitment to transparent, responsible data practices in everything we do.
If you have questions, concerns, or suggestions about how we handle personal data, write to us at info@codertrails.com. Your feedback helps us improve and keeps us accountable.
Thank you for trusting us with your information.