Table of contents:
1. WHAT PERSONAL DATA WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
|Specific personal data we collect
|Why is the personal data collected and for what purposes?
|Legal basis (GDPR only, if applicable)
|Third parties with whom we share your personal data
|Consequences of not providing the personal data
|When you browse or visit our Website
|Cookies, analytic tools and log dataFor more information, please read our cookies policy here: https://www.securecoding.com/cookie-policy/
|· For the Website to function properly, including to maintain page history.·to analyze and improve your use of the Website
|Google AnalyticsGoogle tag managerFacebookLinkedInTwitterBing
|Cannot collect and store the information.Certain Website features may not be available.
|For marketing purposes
|We cannot customize your Website experience, or offer you additional services you may find interesting.
|When you subscribe to our mailing list(s) / newsletter(s)
To add you to our mailing list and keep you updated with new that you may find interesting
Cannot add you to our mailing list and keep you updated
Cannot send you marketing communications
To send marketing communications
|When you commence direct communications with us (for example through our Contact Us page on the Website)
|· To process and answer questions.
|Legitimate interest (e.g., respond to a query sent by you)
|We will not be able to respond to your query.
2. PERIOD OF STORAGE OF COLLECTED INFORMATION
● Retention Personal Data. Your personal data (as described above) will be stored until we: (i) no longer need the information and proactively delete it or (ii) you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws.
3. HOW WE PROTECT YOUR PERSONAL DATA
4. HOW WE SHARE YOUR PERSONAL DATA
In addition to the recipients described in the table above, we may share your personal data as follows:
● To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
● If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third-party purchaser of our business or assets, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.
● Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
● Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
For more information on the recipients of your personal data, please contact us at: firstname.lastname@example.org
6. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA
● Internal transfers: We ensure transfers with the affiliated companies of Secure Coding will be covered by an agreement entered into by members of the Secure Coding group which contractually obliges each member to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred to.
● External transfers: Where we transfer your personal data outside of the EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual commitments and or assurances from them to protect your Personal Data or rely on adequacy decisions issued by the European Commission. Some of these assurances are well recognized certification schemes, which you can read more about here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en; and
● Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal data is disclosed.
7. YOUR RIGHTS
● The following rights (which may be subject to certain exemptions or derogations), shall apply to individuals who are protected by the GDPR. Some of these rights may also apply under your applicable law:
● You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
● You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;
● You have the right to request the erasure/deletion of your personal data (e.g., from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
● You have the right to object, to or to request restriction, of the processing;
● You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
● You have the right to object to profiling;
● You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
● You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
● You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
You can exercise your rights by contacting us at email@example.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
8. ANALYTIC TOOLS
9. LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS
10. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA LAW
· Access Requests. California Civil Code Section 1798.83 (and other, similar state statutes) permits our customers who are California residents (or residents of states with similar statutes) to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org. Please note that we are only required to respond to one request per customer each year.
· Deletion of Content from California Residents. If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Data you have publicly posted. If you wish to remove such content or Personal Data and you specify which content or Personal Data you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Data you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
· Our California Do Not Track Notice. We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about an individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personal information, subject to applicable law, about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.
11. USE BY CHILDREN
We do not offer our products or services for use by children. If you are under 18, you may not use the Website, or provide any information to the Website without the involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.
12. CONTACT US
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at email@example.com
Last updated: July 2020