Codeplay's Privacy Policy

We will use every attempt to protect any data we collect.

Privacy Policy

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website, download products from our site or otherwise deal with us. It will also tell you about your privacy rights and how the law protects you.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.


1. IMPORTANT INFORMATION AND WHO WE ARE

2. HOW TO CONTACT US

3. PURPOSE OF THIS PRIVACY POLICY

4. THIRD-PARTY LINKS

5. HOW IS YOUR PERSONAL DATA COLLECTED?

6. WHAT HAPPENS IF YOU DON’T PROVIDE US WITH PERSONAL DATA WE HAVE REQUESTED?

7. WHAT INFORMATION DO WE COLLECT ABOUT YOU?

8. HOW DO WE USE YOUR PERSONAL DATA?

9. DISCLOSURE OF YOUR INFORMATION

10. INTERNATIONAL TRANSFERS

11. DATA SECURITY

12. HOW LONG WE STORE YOUR PERSONAL DATA FOR

13. COOKIES

14. YOUR RIGHTS

15. CHANGES TO OUR PRIVACY POLICY


Important information and who we are

We are Codeplay Software Limited. We are a company incorporated and registered in England. Our company number is 04567874. Our registered address is Regent House, 316 Beulah Hill, London SE19 3HF.

When we refer to “we”, “us” or ”our” in this policy, we are referring to Codeplay Software Limited. We are the data ‘controller’ in relation to the personal data you provide to us, which means we determine the purposes and the way in which your personal data is, or will be, processed and are responsible for it.

How to contact us

Questions, comments and requests regarding this policy are welcomed and should be addressed to our Data Privacy Manager at:

· Email: GDPR@codeplay.com

· Address: Level C, Argyle House, 3 Lady Lawson Street, Edinburgh, EH3 9DR

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data so that you can be confident when you use our website or otherwise interact with us that you know what your personal data is being used for and that it is being kept safe.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them but it does supercede our previous privacy policy.

You should be aware that our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave one of our websites, we encourage you to read the privacy notice of every website you visit.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your personal data by filling in forms or by corresponding with us in person, by email, by phone, by post or otherwise. This includes personal data you provide when creating an account with us and when you request marketing communications to be sent to you.

Automated technologies or interactions

As you interact with our website, we may automatically collect information about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see below on Cookies for further information.

Third parties or publicly available sources

We may receive personal data about you from various third parties and public sources. This includes, for example, information received from analytics providers such as Google

 

What happens if you don’t provide us with personal data we have requested?

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time

What information do we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect and process the different kinds of personal data about you. We have separated these out into tables depending on our relationship with you. Details of how we use the different categories of personal data (including our lawful basis for such use) is set out below (please see How do we use your personal data?).

If you want any further information about how we might collect or use your personal data, please contact us.

Customer: these are categories of personal data that may be processed about customers of Codeplay

Identity data:

includes first name, last name, title, company name

Contact data:

includes email address, postal and billing address, telephone number

Account management data:

business discussions, email correspondence, contract history

Financial data:

bank account details, payment card details

Marketing data:

includes your preferences in receiving marketing from us and your communication preferences

 

Website users: these are categories of personal data we may collect when you use our website (e.g. through the Contact Us section or when you sign up to download a product)

Identity data:

includes first name, last name, title, company name

Contact data:

includes email address, postal address or telephone number

Sign-up data:

includes any password you have chosen when registering for an account on our website

Correspondence data:

includes details of any correspondence between you and us

Technical data:

includes internet protocol (IP) address

Marketing data:

includes your preferences in receiving marketing from us and your communication preferences

Marketing. This is personal data which may be processed about contacts on our marketing databases

Identity data:

includes first name, last name, title, company name

Contact data:

includes email address, postal address or telephone number

Marketing data:

includes your preferences in receiving marketing from us and your communication preferences

Suppliers: These are categories of personal data we may collect about third party suppliers.

Identity data:

includes first name, last name, title, company name, job position

Contact data:

includes email address, postal address, telephone number

Supplier management data:

business discussions, email correspondence, contract history

How do we use your personal data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

· Where we need to perform the contract we have entered into with you or to take steps at your request prior to entering into a contract (e.g. when you purchase our services or download products from our website).

· Where we have your prior consent to use your personal data (e.g. where you have consented to receiving marketing).

· Where we need to comply with a legal or regulatory obligation.

· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Customers

Purpose/activity

Type of data

Lawful basis for processing

To manage our relationship with you which will include but not be limited to:

· Discussing work to be undertaken

· Discussing fees and payments

· Notifying you of updates to any contractual terms, privacy policies and other relevant information

· Reviewing information which we hold about you to ensure accuracy

Identity, contact and account management data

Necessary in order to perform our contract with you.

To comply with our legal obligations.

Necessary for our legitimate interest – to run our business and keep our records accurate

To provide our services to you

Identity, contact, account management data, financial data

Necessary in order to perform our contract with you.

To comply with our legal obligations.

Necessary for our legitimate interest – to run our business

To send you marketing materials

Identity, contact and marketing data

Necessary for our legitimate interest - in developing and growing our services

Consent

Website users

Purpose/activity

Type of data

Lawful basis for processing

To respond to any query you make via our website

Identity, contact and correspondence data

Necessary for our legitimate interests – in running our business

To register your account

Identity, contact and sign-up data

Necessary in order to enter into a contract with you

Necessary for our legitimate interests – in running our business

To provide you with our products available for download on our website

Identity, contact and sign-up data

Necessary in order to enter into a contract with you

Necessary for our legitimate interests – in running our business

To send you marketing materials

Identity, contact and marketing data

Necessary for our legitimate interest - in developing and growing our services

Consent

To use data analytics to improve and personalise our website and develop our user experience

Technical data

Necessary for our legitimate interests - to improve customer interactions

Consent

Marketing

Purpose/activity

Type of data

Lawful basis for processing

To send you marketing materials

Identity, contact and marketing data

Necessary for our legitimate interest - in developing and growing our services

Consent

Suppliers

Purpose/activity

Type of data

Lawful basis for processing

To enter into a contract with you in order for you to provide goods or services for us, and all related administrative procedures

Identity and contact data

Necessary in order to enter into a contract with you

To manage our relationship with you which will include but not be limited to:

· Discussing the services or goods to be provided by you

· Discussing fees and payments

· Notifying you of updates to any terms of business, privacy policies and other relevant information

· Reviewing information which we hold about you to ensure accuracy

Identity, contact and supplier management data

Necessary in order to enter into a contract with you

Necessary for our legitimate interests – in running our business

To comply with our legal obligations

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of your information

We may have to share your personal information for the purposes set out above (please see How do we use your personal data?) with the following third parties:

Third party

Detail

Service providers:

including those who provide:

· Webhosting, IT and system administration services

· Metrics and analytics

· Financial services

· Marketing services.

Professional advisers:

including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

Authorities:

including HMRC, regulators and other authorities who require reporting of processing activities in certain circumstances. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction

Corporate partners:

Includes third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Some of our external third parties may, from time to time, be based outside the European Union (EU) so their processing of your personal data will involve a transfer of data outside the EU.

If we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

· The country has been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

· If we use certain service providers based outwith the EU, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

· If we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

· In any other case, we will obtain your explicit consent before any transfer takes place.

The table below sets out details of the service providers we use outside of the EU and the relevant safeguards in place.

Service provider

Description of service

Safeguards

Mailchimp

Marketing automation platform and email marketing service

Privacy Shield

Otka

Authentication Service

EU Model Clauses incorporated into data processor agreement

Keen.io

Web Analytics

Privacy Shield

Zendesk

Support Services

 Privacy Shield

Discourse

Support Services

Eu-US Privacy Shield and Swiss-US Privacy Shield

Insightly

CRM database

EU-US Privacy Shield and Swiss-US Privacy Shield

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data Security

We have put in place appropriate security measures in accordance with industry best practice to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using SSL technology and using trusted third parties. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, no method of transmission of information via the internet is completely secure. However, we implement generally accepted industry standards so that we can do our best to protect your personal data.

How long we store your personal data for

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Key retention periods can be obtained by contacting us.

Where we anonymise your personal data (i.e. so that it can no longer be associated with you) for further research or statistical purposes, then we may use this information indefinitely without further notice to you.

Cookies

Our website uses cookies to help it function and to improve it. Cookies are small files saved to the user’s computer’s hard drive that track, save and store information about the user’s interactions and usage of the website. For information about the cookies we use, please see our Cookie Policy.

Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:


· Access to your information

· Request correction of your personal data

· Request deletion of your personal data

· Object to processing of your personal data

· Request restriction of processing your personal data

· Request transfer of your personal data

· Right to withdraw consent

· Right to review by an independent authority


If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Access to your information

You have the right to ask for a copy of the information which we hold on you (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Correcting personal data

You have the right to request that we correct personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold corrected, though we may need to verify the accuracy of the new data that you provide to us.

It is important that the personal data we hold about you is accurate and current, so please keep us informed if your personal data changes during your relationship with us.

Deleting personal data

You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. This is more commonly known as the ‘right to be forgotten’. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.

Please note, however, that we may not always be able to comply with your request to delete or remove personal data for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Objecting to processing

You have the right to stop us processing your personal data for direct marketing purposes. We will always inform you if we intend to use your personal data for such purposes, or if we intend to disclose your information to any third party for such purposes. You can usually exercise your right to prevent such marketing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at contact us.

You may also object to us processing your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Restriction of processing

This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• if you want us to establish the data's accuracy;

• where our use of the data is unlawful but you do not want us to erase it;

• where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Transferring your personal data

In certain circumstances, you may request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Where we are relying on consent to process your personal data you can withdraw your consent at any time. Please note that this will not affect the lawfulness of any processing carried out before you withdraw your consent.

Review by an independent authority

You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner’s Office. If you do have a complaint, we would appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance if possible.

Changes to our privacy policy

This version was last updated on 5th September 2018

Historic versions of this policy can be obtained by contacting us.