Legal
Privacy Notice
Last updated 10 September 2026
1. Scope
This notice explains how Kobano Ltd, trading as "Koton Trading" ("Koton", "we", "us", "our"), collects and uses personal data, and the rights you have over it. It applies to: (a) visitors to our website at www.koton-trading.com (the "Website"); and (b) individuals we consider, contact, or who apply for a role with us ("candidates").
This notice does not apply to clients, customers, investors, or business partners of Koton, as Koton does not solicit customers or accept capital from third parties in connection with the activities described on the Website.
2. Who is responsible for your data (the "Controller")
Kobano Ltd, a company incorporated in Gibraltar under company number 126164, with its registered office at Unit G02, Eurocity, Europort Avenue, Gibraltar ("Kobano"), trading under the brand name "Koton Trading", is the controller of your personal data within the meaning of Regulation (EU) 2016/679 (the "GDPR").
For any question regarding this notice or the processing of your personal data, please contact us at hello@koton-trading.com.
3. What personal data we collect
- Identity and contact details: name, email address, telephone number, and general location.
- Professional information: CV/résumé, work history, education, qualifications, skills, links to professional profiles (e.g., LinkedIn), and any other information you provide when you apply for, or are considered for, a role.
- Correspondence: records of communications you exchange with us.
- Website and device data: IP address, browser type, device identifiers, pages visited, and similar usage data, collected through cookies and similar technologies – see our Cookie Policy.
- Publicly available information: information you have made public, for example on LinkedIn or other professional platforms, which we may review and use to contact you about a potential role.
We do not intentionally collect special categories of personal data (e.g., health, racial or ethnic origin, religious beliefs) through the Website. Should this ever become necessary, we will do so only with your explicit, separate consent, and will update this notice accordingly.
4. Sources of your data
We obtain your data directly from you, when you use the Website, contact us, or apply for a role, and from publicly available professional sources, such as LinkedIn, when we proactively identify and approach potential candidates ("sourcing").
Where we obtain your data from a source other than yourself, we will provide you with the information required under Article 14 GDPR (including this notice) at the time we first contact you, and in any event no later than one month from obtaining the data.
5. Purposes and legal basis of processing
| Purpose | Legal basis |
|---|---|
| Assessing candidates, administering our recruitment process, and contacting individuals about current or future roles, including proactive sourcing and outreach. | Legitimate interest (Art. 6(1)(f) GDPR) in identifying and recruiting suitable candidates; where you have applied for a specific role, steps necessary prior to entering into a contract at your request (Art. 6(1)(b) GDPR). |
| Displaying and tailoring our roles and employer-branding content, including targeting and retargeting advertising. | Consent (Art. 6(1)(a) GDPR), given through our cookie banner. |
| Responding to your enquiries and correspondence, and ensuring the security and proper functioning of the Website. | Legitimate interest (Art. 6(1)(f) GDPR) in operating a secure and functional website and communicating with visitors. |
| Complying with our legal obligations. | Legal obligation (Art. 6(1)(c) GDPR). |
Where we rely on legitimate interest, we have assessed that our interests are not overridden by your interests or fundamental rights and freedoms. You have the right to object to this processing at any time – see Section 10 (Your rights).
6. Cookies
The Website uses cookies and similar technologies that are: (i) strictly necessary for the Website to function; (ii) used to understand how visitors use the Website (analytics); and (iii) used to support recruitment marketing, including targeting and retargeting advertising. Non-essential cookies (categories (ii) and (iii)) are set only once you have given your consent through our cookie banner, which you may withdraw at any time. Full details are set out in our separate Cookie Policy.
7. Who we share your data with
We only share your personal data with:
- service providers acting on our behalf and under our instructions (processors), such as providers of recruitment, applicant-tracking, email, hosting, analytics, and advertising tools;
- our professional advisers (e.g., legal, tax, or audit advisers), where necessary;
- public authorities, regulators, or law enforcement, where required by applicable law.
We do not sell your personal data to any third party.
8. International data transfers
Kobano Ltd is established in Gibraltar. Gibraltar is not a member of the European Union or the European Economic Area, and the European Commission has not adopted an adequacy decision in respect of Gibraltar under Article 45 GDPR. Where your personal data is transferred to, or accessed from, Gibraltar, or is otherwise transferred outside the EEA (for example, to a service provider established in a third country), we ensure appropriate safeguards are in place, in particular by relying on the European Commission’s Standard Contractual Clauses or another legally recognised transfer mechanism. You may request further information, or a copy of the relevant safeguard, by contacting us using the details in Section 2.
9. How long we keep your data
Candidate data is retained for the duration of the relevant recruitment process and for 12 months afterwards, so that we may consider you for other suitable roles, unless you ask us to delete it sooner. Website and cookie data is retained only for as long as necessary for the purpose for which it was collected, as further described in our Cookie Policy. Correspondence is retained for as long as necessary to address your enquiry, and for a reasonable period thereafter for record-keeping purposes.
We may retain data for longer where required to comply with a legal obligation, or to establish, exercise, or defend legal claims.
10. Your rights
Subject to applicable law, you have the right to:
- request access to the personal data we hold about you;
- request correction of inaccurate data;
- request erasure of your data;
- request restriction of, or object to, our processing of your data (including for outreach and marketing purposes);
- receive your data in a portable format;
- withdraw your consent at any time, where we rely on consent (this does not affect the lawfulness of processing before withdrawal).
To exercise any of these rights, please contact us at hello@koton-trading.com. We may need to verify your identity before responding.
You also have the right to lodge a complaint with the data protection supervisory authority in your country of residence, place of work, or the place where the alleged infringement occurred.
11. Security
We implement appropriate technical and organisational measures designed to protect your personal data against unauthorised access, loss, or misuse.
12. Changes to this notice
We may update this notice from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. The current version is always available on the Website, with the date it was last updated shown at the top.