Privacy Policy
- Introduction
- Important information and who we are
- How to contact us
- Purpose of this privacy policy
- Third party links
- How is your personal data collected?
- What happens if you do not provide us with the personal data we have requested?
- What information do we collect about you?
- How do we use your personal data?
- Disclosure of your information
- International transfers
- Data Security
- How long we store your personal data for?
- Cookies
- Your rights
- Anonymous Analytics
1. Introduction
1.1. 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.
1.2. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
2. Important information and who we are
2.1. We are Codeplay Software Limited. We are a company incorporated and registered in England. Our company number is 04567874. Our registered address is: 2 New Bailey, 6 Stanley Street, Salford, Greater Manchester, UK, M3 5GS.
2.2. 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.
3. How to contact us
3.1. Questions, comments and requests regarding this policy are welcomed and should be addressed to our Data Privacy Manager at;
3.1.1. Name: Karon Davis
Email: [email protected]
Address: Level C, Argyle House, 3 Lady Lawson Street, Edinburgh, EH3 9DR
4. Purpose of this privacy policy
4.1. 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.
4.2. 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 supersede our previous privacy policy.
5. Third party links
5.1. 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.
6. How is your personal data collected?
6.1. We use different methods to collect data from and about you including through:
6.1.1. 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.
6.1.2. 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.
6.1.3. 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.
7. What happens if you do not provide us with the personal data we have requested?
7.1 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.
8. What information do we collect about you?
8.1. 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).
8.2. 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?).
8.2.1. If you want any further information about how we might collect or use your personal data, please contact us ([email protected])
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Customer: these are categories of personal data that may be processed about customers of Codeplay |
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Identity data: |
includes first name, last name, title, company name |
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Contact data: |
includes email address, postal and billing address, telephone number |
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Account management data: |
business discussions, email correspondence, contract history |
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Financial data: |
bank account details, payment card details |
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Marketing data: |
includes your preferences in receiving marketing from us and your communication preferences |
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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) |
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Identity data: |
includes first name, last name, title, company name |
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Contact data: |
includes email address, postal address or telephone number |
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Sign-up data: |
includes any password you have chosen when registering for an account on our website |
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Correspondence data: |
includes details of any correspondence between you and us |
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Technical data: |
includes internet protocol (IP) address |
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Marketing data: |
includes your preferences in receiving marketing from us and your communication preferences |
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Marketing. This is personal data which may be processed about contacts on our marketing databases |
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Identity data: |
includes first name, last name, title, company name |
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Contact data: |
includes email address, postal address or telephone number |
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Marketing data: |
includes your preferences in receiving marketing from us and your communication preferences |
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Suppliers: These are categories of personal data we may collect about third party suppliers. |
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Identity data: |
includes first name, last name, title, company name, job position |
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Contact data: |
includes email address, postal address, telephone number |
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Supplier management data: |
business discussions, email correspondence, contract history |
8.3. We will only use your personal data for the purposes for which we have 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> ([email protected]).
8.4. 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.
8.5. 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.
9. How do we use your personal data?
9.1. 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:
9.1.1. 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).
9.1.2. Where we have your prior consent to use your personal data (e.g. where you have consented to receiving marketing).
9.1.3. Where we need to comply with a legal or regulatory obligation.
9.1.4. 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.
9.2. 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.
9.3. 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;
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Customers |
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Purpose/activity |
Type of data |
Lawful basis for processing |
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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, |
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 |
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privacy policies and other relevant information Reviewing information which we hold about you to ensure accuracy |
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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 |
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To send you marketing materials |
Identity, contact and marketing data |
Necessary for our legitimate interest - in developing and growing our services Consent |
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Website users |
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Purpose/activity |
Type of data |
Lawful basis for processing |
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To respond to any query you make via our website |
Identity, contact and correspondence data |
Necessary for our legitimate interests – in running our business |
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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 |
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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 |
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To send you marketing materials |
Identity, contact and marketing data |
Necessary for our legitimate interest - in developing and growing our services Consent |
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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 |
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Marketing |
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Purpose/activity |
Type of data |
Lawful basis for processing |
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To send you marketing materials |
Identity, contact and marketing data |
Necessary for our legitimate interest - in developing and growing our services Consent |
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Suppliers |
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Purpose/activity |
Type of data |
Lawful basis for processing |
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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 |
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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 |
9.4. We will only use your personal data for the purposes for which we have 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. ([email protected])
9.5. 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.
9.6. 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.
10. Disclosure of your information
10.1. 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:
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Third party |
Detail |
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Service providers: |
including those who provide: • Webhosting, IT and system administration services • Metrics and analytics • Financial services • Marketing services. |
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Professional advisers: |
including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. |
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Authorities: |
including HMRC, regulators and other authorities who require reporting of processing activities in certain circumstances. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. |
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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. |
10.2. 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.
11. International transfers
11.1. 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.
11.2. 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:
11.2.1. 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.
11.2.2. If we use certain service providers based out with 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.
11.2.3. If we use providers based in the US, they will have signed and agreed to our standard contractual clauses, which follow the guidelines approved by the European Commission. 11.2.4. In any other case, we will obtain your explicit consent before any transfer takes place. 11.2.5. The table below sets out the service providers we use outside of the EU and the relevant safeguards in place;
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Service provider |
Description of service |
Safeguards |
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Mailchimp |
Marketing automation platform and email marketing service |
Data Protection Addendum with Standard Contractual Clauses |
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Otka |
Authentication Service |
Data Protection Addendum with Standard Contractual Clauses |
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Keen.io |
Event streaming platform |
Data Protection Addendum with Standard Contractual Clauses |
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Zendesk |
Support Services |
Data Protection Addendum with Standard Contractual Clauses |
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Discourse |
Support Services |
Data Protection Addendum with Standard Contractual Clauses |
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Insightly |
CRM database |
Data Protection Addendum with Standard Contractual Clauses |
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AWS |
Cloud hosting |
Data Protection Addendum with Standard Contractual Clauses |
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Zoom |
Video calls |
Data Protection Addendum with Standard Contractual Clauses (EU adequacy status) |
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Office365 |
Office suite and file sharing |
Data Protection Addendum with Standard Contractual Clauses |
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Codeplay External Website |
Public facing website |
Company privacy policy |
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Formspree |
Web form processor |
Data Protection Addendum with Standard Contractual Clauses |
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Mediatemple |
Web hosting |
Data Protection Addendum with Standard Contractual Clauses |
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Docusign |
Document signing service |
Binding Corporate Rules |
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Paxton Net2 |
Building security |
Company privacy policy |
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Github |
Software version control and distribution |
Data Protection Addendum with SCCs |
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Linode |
Cloud hosting |
Data Protection Addendum with Standard Contractual Clauses |
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Dropbox for Business |
Document sharing |
Data Protection Addendum with Standard Contractual Clauses |
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Adobe Suite |
Layout and page design software for print and digital media |
Data Protection Addendum with Standard Contractual Clauses |
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JetBrains Suite |
Tools for software developers and project managers |
Data Protection Addendum with Standard Contractual Clauses |
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Atlassian (Confluence & JIRA) |
Software used for project management, wiki pages, team project management, etc. |
Data Protection Addendum with Standard Contractual Clauses |
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KnowBe4 |
Security awareness software |
Data Protection Addendum with Standard Contractual Clauses |
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Crowdstrike |
Agent based sensor to manage policies, control reporting data, manage and respond to threats, etc. |
Data Protection Addendum with Standard Contractual Clauses |
11.3. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
12. Data Security
12.1. 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.
12.2. 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.
12.3. 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.
13. How long we store your personal data for?
13.1. 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.
13.2. 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.
13.3. Further Details about our key retention period can be obtained by contacting us or referring to the Data Retention Policy.
13.4. Where we anonymize your personal data (i.e. so that it can no longer be associated nor identified with you) for research and/or statistical purposes, then we will only hold onto this anonymized data until it is no longer useful or necessary to do so.
14. Cookies
14.1. 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.
15. Your rights
15.1. 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;
15.1.1. Access to your information
15.1.2. Request correction of your personal data
15.1.3. Request deletion of your personal data
15.1.4. Object to processing of your personal data
15.1.5. Request restriction of processing your personal data
15.1.6. Request transfer of your personal data
15.1.7. Right to withdraw consent
15.1.8. Right to review by an independent authority
15.1.9. 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. 15.1.10. 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.
15.1.11. We try to respond to all legitimate requests within one month. Depending on the nature of the request, 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 within 30 days you and keep you updated on the progress of your request.
15.2. 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.
15.3. 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.
15.3.1. 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.
15.4. 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.
15.4.1. 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.
15.5. 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.
15.5.1. 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.
15.6. Restriction of processing: This enables you to ask us to suspend the processing of your personal data in the following scenarios:
15.6.1. If you want us to establish the data's accuracy
15.6.2. Where our use of the data is unlawful but you do not want us to erase it
15.6.3. 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
15.6.4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
15.7. 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.
15.7.1. 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.
15.8. Withdrawing consent: 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.
15.9. 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.
Anonymous Analytics
We want to process as little personal information as possible when you use our website. That's why we've chosen Fathom Analytics for our website analytics, which doesn't use cookies and complies with the GDPR, ePrivacy (including PECR), COPPA and CCPA. Using this privacy-friendly website analytics software, your IP address is only briefly processed, and we (running this website) have no way of identifying you. As per the CCPA, your personal information is de-identified. You can read more about this on Fathom Analytics' website.
The purpose of us using this software is to understand our website traffic in the most privacy-friendly way possible so that we can continually improve our website and business. The lawful basis as per the GDPR is "Article 6(1)(f); where our legitimate interests are to improve our website and business continually." As per the explanation, no personal data is stored over time.