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Plaicer — Privacy Policy

Last updated: 17 April 2026

Effective date: 17 April 2026

1.Who We Are

Plaicer Tech Ltd is a limited liability company registered in Malta, with its registered office at Unit No. SG26 SOHO Savoy Gardens, Rue D’Argens, Gżira GZR 1362, Malta (“Plaicer”, “we”, “us”, or “our”).

We are the data controller for the personal data we process about you when you use our platform (plaicer.com, our coding challenges and assessments, our virtual skills CV feature, and any related services — together, the “Service”).

We take your privacy seriously. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, who we share it with, how long we keep it, and what rights you have.

2.Legal Framework

This Privacy Policy is issued under the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) and the Maltese Data Protection Act (Chapter 586 of the Laws of Malta). The supervisory authority in Malta is the Information and Data Protection Commissioner (IDPC).

3.Personal Data We Collect

We collect the following categories of personal data:

3.1 Information You Give Us

  • Email address (used for account creation and login).
  • Any information you choose to include in your Virtual Skills CV. Because this feature is designed to be privacy-protective, we ask you not to include personal contact details (name, email, phone number, address, photograph) in your Virtual Skills CV.
  • Information you provide when you contact us — for example, by email to privacy@plaicer.com — including the content of your messages.

3.2 Information Generated by Your Use of the Service

  • Challenge attempts, submissions, and Results — including which Challenges you attempt, whether you pass or fail, your scores, and the reasoning generated by the Service in connection with your Submissions.
  • For Challenge categories that allow mid-challenge saving, your in-progress code is stored temporarily until you submit or abandon the Challenge; once that happens, the code is discarded and only the Result is kept.
  • We do not retain the code of your Submissions after you submit a Challenge. Only the Result is stored.
  • Account activity, such as the dates and times you sign in, the features you use, and email notifications we send you.

3.3 Information Collected Automatically

  • Technical data, including your IP address, browser type and version, device type, operating system, and referring URL.
  • Cookies and similar technologies (see Section 9).
  • Error and performance data — for example, if something breaks in your browser, we may log the error so we can fix it.

3.4 What We Do Not Collect

We do not ask for, and we do not intentionally collect, special categories of personal data (for example, data revealing racial or ethnic origin, political opinions, religious beliefs, health, or sexual orientation). Please do not include this kind of information in your Virtual Skills CV or in messages to us.

4.How We Use Your Personal Data and Our Legal Bases

We process your personal data for the following purposes, on the following legal bases under Article 6 GDPR:

4.1 To Provide the Service (Contractual Necessity — Article 6(1)(b))

  • Creating and managing your Account.
  • Sending you one-time login codes when you sign in.
  • Running your code Submissions against Challenge test cases and generating Results.
  • Storing your Results and making them available to you through your Account.
  • Sending you service-related emails that are essential to your use of the Service, such as login codes, security alerts, and notifications about changes to these documents.

4.2 To Keep the Service Safe, Reliable, and Improve It (Legitimate Interests — Article 6(1)(f))

  • Detecting and preventing fraud, abuse, account misuse, cheating, and unauthorised AI-assisted submissions.
  • Monitoring performance, diagnosing errors, and improving the reliability of the Service.
  • Understanding how Users interact with the Service in aggregate, so we can make it better.
  • Protecting our rights, property, and the rights of other Users.

Where we rely on legitimate interests, we have considered and balanced those interests against your rights and freedoms, and we have concluded that our processing does not override them. You have the right to object to processing based on legitimate interests (see Section 11).

4.3 To Send You Non-Essential Notifications and Product Updates (Legitimate Interests — with opt-out)

  • Daily challenge emails and feature notifications. These are sent on the basis of our legitimate interest in keeping you engaged with the Service.
  • You can turn off any non-essential notification at any time from your Account settings, and every such email includes a one-click unsubscribe link.

4.4 To Send Marketing Emails (Consent — Article 6(1)(a))

If and when we introduce marketing emails (for example, promotional content or newsletters unrelated to your direct use of the Service), we will only send them if you have given us explicit opt-in consent, and you will be able to withdraw that consent at any time.

4.5 To Comply with Legal Obligations (Article 6(1)(c))

We may process your personal data to comply with our legal obligations — for example, to respond to lawful requests from public authorities, to comply with tax or accounting obligations (if you have paid for a future paid tier), or to meet our obligations under data protection law.

5.Automated Evaluation of Your Submissions

When you submit a Challenge, our systems automatically run your code against pre-defined test cases in a sandboxed execution environment (or, for comprehension-style Challenges, compare your selection against the expected answer) and generate a Result.

This evaluation is automated, but it does not produce decisions that have legal or similarly significant effects on you. Your Results are an educational and self-assessment tool; they are not used by Plaicer to make any automated decision about you that could affect your legal rights or access to services.

6.Who We Share Your Data With

We do not sell your personal data. We share your personal data only with the categories of recipients described below, and only to the extent necessary for the purposes described in this Privacy Policy.

6.1 Service Providers (Processors)

We work with carefully selected third-party service providers who process personal data on our behalf, under written agreements that require them to protect your data and to process it only on our instructions. These include:

  • Amazon Web Services (AWS) — cloud hosting, databases, code execution infrastructure, and transactional email delivery (via Amazon SES). Data is hosted in the EU (eu-north-1, Stockholm).
  • Google (Google Workspace / Gmail) — our business email, used by our team to respond to your enquiries.
  • Google (Google Analytics) — analytics on how the Service is used (only if you consent to analytics cookies; see Section 9).
  • Stripe — if and when we introduce paid features, payment processing will be handled by Stripe. Stripe acts as an independent controller of payment card data; you can read Stripe’s privacy policy at https://stripe.com/privacy.

This list may be updated from time to time. We will keep it current in this Privacy Policy.

6.2 Legal and Safety Recipients

We may disclose your personal data where required by law, by a court, or by a competent regulator; to enforce our Terms; or to protect the rights, property, or safety of Plaicer, our Users, or others, including investigating fraud, abuse, or security threats.

6.3 Corporate Transactions

If Plaicer is involved in a merger, acquisition, reorganisation, or sale of all or part of its assets, your personal data may be transferred as part of that transaction. If this happens, we will notify you and ensure that your data continues to be protected in line with this Privacy Policy, or we will seek your consent to any changes.

6.4 What We Do Not Do

  • We do not sell your personal data.
  • We do not share your personal data with advertisers for cross-context behavioural advertising.
  • We do not use your Submissions to train third-party AI models.

7.International Data Transfers

Your personal data is primarily stored and processed in the European Union, in Amazon Web Services’ eu-north-1 region (Stockholm).

Some of our service providers are based outside the European Economic Area (EEA), including in the United States (for example, Stripe, and some Google services). When we transfer personal data outside the EEA, we rely on one of the transfer mechanisms permitted by the GDPR, such as:

  • the European Commission’s Standard Contractual Clauses;
  • adequacy decisions issued by the European Commission (for example, for organisations certified under the EU–US Data Privacy Framework); or
  • other lawful safeguards required by the GDPR.

You can request more information about the specific transfer mechanism we use for any given service provider by contacting us at privacy@plaicer.com.

8.How Long We Keep Your Data

We keep your personal data only for as long as necessary for the purposes described in this Privacy Policy, or as required by law.

8.1 Active Accounts

While your Account is active, we retain your Account details and your Results for as long as you continue to use the Service, so that you can see your history and build your Virtual Skills CV.

8.2 Account Closure

When you close your Account (or when we terminate it), we delete your Account data and your Results within ninety (90) days of closure. A limited set of records may be retained beyond this period where we have a legal obligation to do so (for example, accounting records relating to any paid services) or where it is necessary to establish, exercise, or defend legal claims.

8.3 Mid-Challenge Code

In-progress code saved during a Challenge is discarded as soon as you submit or abandon the Challenge. It is not kept beyond that point.

8.4 Backups

Deleted data may persist for a short time in encrypted backups. It is not accessible in normal operations and is fully purged when backups are rotated according to our retention schedule.

8.5 Support and Security Logs

Communications with our support team, and security and access logs, are kept for a reasonable period (typically up to 24 months) for support, quality, and security purposes.

9.Cookies and Similar Technologies

We use cookies and similar technologies on plaicer.com. A cookie is a small text file stored on your device by your browser. We use cookies in the following categories:

9.1 Strictly Necessary Cookies

These are essential for the Service to function — for example, to keep you signed in, to maintain your session during a Challenge, to protect against cross-site request forgery, and to route traffic across our servers. These cookies do not require your consent because you cannot use the Service without them.

9.2 Analytics Cookies

We use Google Analytics to understand how the Service is used in aggregate, so we can improve it. Analytics cookies will only be set if you give consent through our cookie banner. You can withdraw your consent at any time by reopening the cookie settings at the bottom of plaicer.com.

9.3 Your Choices

You can also manage cookies through your browser settings, including by blocking or deleting cookies. Blocking strictly necessary cookies will prevent you from using parts of the Service. Blocking analytics cookies will not affect your ability to use the Service.

10.How We Protect Your Data

We take appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

  • hosting your data in a reputable, security-certified cloud environment (AWS, EU region);
  • encryption of data in transit (TLS/HTTPS) and at rest;
  • running Submissions inside isolated, sandboxed execution environments to reduce the risk that Submissions can affect our infrastructure or your data;
  • restricting access to personal data to the Plaicer team members who need it for their role, under confidentiality obligations;
  • login-code authentication (no password reuse risks) and email-based account recovery; and
  • regular review of our security practices and infrastructure.

No system can be guaranteed to be 100% secure. If we become aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the IDPC and, where required by law, you — without undue delay.

11.Your Rights

Under the GDPR and the Maltese Data Protection Act, you have a number of rights regarding your personal data. These include:

  • Right of access — the right to confirmation as to whether we process your personal data and, if so, to obtain a copy of it and information about the processing.
  • Right to rectification — the right to ask us to correct inaccurate personal data or complete incomplete personal data.
  • Right to erasure (“right to be forgotten”) — the right to ask us to delete your personal data in certain circumstances, for example when it is no longer needed for the purposes for which it was collected.
  • Right to restriction of processing — the right to ask us to restrict how we use your personal data in certain circumstances.
  • Right to data portability — the right to receive your personal data in a structured, commonly used, machine-readable format, and to have it transmitted to another controller where technically feasible.
  • Right to object — the right to object to processing based on our legitimate interests, and an absolute right to object to processing for direct marketing purposes.
  • Right to withdraw consent — where we process your data on the basis of your consent, the right to withdraw that consent at any time, without affecting the lawfulness of processing before the withdrawal.
  • Right to lodge a complaint — the right to complain to the Information and Data Protection Commissioner (IDPC) in Malta or to any other supervisory authority in the EU Member State where you live or work.

11.1 How to Exercise Your Rights

You can exercise most of these rights directly from your Account settings (for example, you can update your email, manage notifications, and close your Account).

You can also contact us at privacy@plaicer.com with your request. We will respond within one month of receiving it, as required by the GDPR. In complex cases we may extend this period by up to two further months, and we will let you know if we do. There is no fee to exercise your rights, although we may charge a reasonable fee or refuse to act where a request is manifestly unfounded or excessive.

11.2 Contacting the IDPC

If you believe we are not handling your personal data properly, we encourage you to contact us first so we can try to resolve your concern. You also have the right to complain to the Information and Data Protection Commissioner:

Information and Data Protection Commissioner

Level 2, Airways House, High Street, Sliema SLM 1549, Malta.

Telephone: +356 2328 7100.

Email: idpc.info@gov.mt.

12.Children

The Service is not intended for use by children under 16, and we do not knowingly collect personal data from anyone under that age. If you believe that a person under 16 has provided us with personal data, please contact us at privacy@plaicer.com so we can delete it.

13.Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will update the “Last updated” date at the top of this document. For material changes, we will notify you by email and/or by prominently displaying a notice in the Service before the changes take effect.

14.Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us:

Plaicer Tech Ltd

Unit No. SG26 SOHO Savoy Gardens, Rue D’Argens, Gżira GZR 1362, Malta

Email: privacy@plaicer.com