Last updated on 1 August 2022
1.2 This Policy sets out how Secure Code Warrior collects, stores, processes, discloses and secures your personal information. It also sets out the rights you have in respect of your personal information. This Policy covers all our activities, including the operation of our website at www.securecodewarrior.com, use of the Security Code Warrior learning platform (SCW Learning Platform), the provision and marketing of our products, and services, recruitment, and the operation of our social media accounts including, but not limited to, Twitter, Facebook, Instagram, and YouTube channels.
2.1 We collect personal information relating to our customers, prospective customers, business contacts, suppliers, recruitment candidates, and individuals who access the Secure Code Warrior platform or participate in our tournaments, trials, competitions, or other promotional activities.
2.2 The type of personal information Secure Code Warrior collects is set out in Appendix B. In most cases the personal information collected will include, but is not limited to, the following: first and last name, employer, professional title, contact information (email, phone, physical address), localization and device identification data (example, IP address) and other information reasonably necessary for us to provide our services to you or which is otherwise reasonably necessary for us to carry out our functions and activities.
2.3 Secure Code Warrior generally collects personal information directly from you when you communicate with us including (but not limited to) when you contact us, register for our services, or supply us with goods or services. For example, when we receive an email from you, we are collecting your personal information. However, there may be circumstances where we collect information about you from third parties or via other methods. In some cases we may receive personal information about you from a customer in the context of providing services to that customer. We may also receive information about you from a partner in the context of that partner providing services to us.
2.5 If you do not provide some requested personal information, we may be delayed or prevented from providing our services or platform to you, your employer and/ or entity through wish you access the SCW Platform, or satisfying your request or inquiry.
3.1 Secure Code Warrior uses your personal information for its internal business and administrative purposes. In accordance with applicable data protection and privacy laws, we will only process your personal information if we have a lawful basis for doing so.
3.2 In respect of your personal information, these bases are:
Appendix C sets out the purposes for which we process your personal information, and the lawful basis on which we carry out such processing.
Please note, that these lawful bases may not be applicable where you are receiving services from a Secure Code Warrior entity based outside of the EU and UK and you are also based outside of the EU and UK, but the following purposes will still apply and the lawful bases should help you better understand the purposes.
3.3 Secure Code Warrior will only use your personal information for the purposes listed in Appendix C or for other related compatible purposes for which you would reasonably expect us to use it (and in such circumstances the lawful bases would be in line with those listed above). We may also use your personal information for other purposes, but only where you have provided your express consent.
3.4 You will always have the opportunity to object to, or unsubscribe from receiving marketing materials. You can do this either via links in the message or by contacting Secure Code Warrior, firstname.lastname@example.org
3.5 Secure Code Warrior may disclose your personal information in order to fulfill the purposes outlined in Appendix C. This will include sharing your personal information with other members of our corporate group and with external service providers such as those listed in Appendix E (on a confidential basis and in circumstances where those contracted service providers may only use your information for the purpose of Secure Code Warrior’s activities) to communicate with you and/or to store your contact details.
3.6 Secure Code Warrior may also disclose your personal information to:
3.7 In addition, Secure Code Warrior may use or disclose your personal information:
3.8 Secure Code Warrior may at other times notify you about our disclosure practices in respect of specific services that we provide in relation to our activities.
4.1 Secure Code Warrior may hold your personal information in a number of different formats, including but not limited to, software programs (located both onsite and offsite, including in the cloud), databases, filing systems and in offsite backup storage.
4.2 Personal information held by Secure Code Warrior may also be stored in email accounts that are accessible through mobile devices. Given the nature of our business and corporate structure we may disclose personal information about an individual to one of our related companies overseas for the purpose of the provision and improvement of our services. Where the recipient territory does not offer the same level of privacy and data protection legislation, Secure Code Warrior will ensure that adequate safeguards are in place to protect your personal information. If you would like further information about where we may disclose your personal information, please contact Secure Code Warrior’s Privacy Officer at email@example.com.
4.3 Secure Code Warrior takes all reasonable steps to protect your personal information from loss, unauthorised access, modification, disclosure or misuse. However, we cannot ensure the security of any information that you transmit to us over the Internet and you do so at your own risk.
4.4 For more information on how Secure Code Warrior protects your data, please visit our Trust Center.
5.1 Where Secure Code Warrior receives any personal information either in error or which was not requested by us, we will as soon as practicable delete and destroy that information. With your consent, if the information was sent for the purpose of securing employment with us, we may keep this information subject to the retention periods set out in Appendix B.
6.1 Secure Code Warrior will retain your personal information for so long as is necessary for the purposes outlined in this Policy (and Appendix B). In some circumstances we will be obliged by law to retain personal information for longer periods.
7.1 Privacy Laws give you certain rights in respect of your personal information, including the right to:
7.2 Please also note that your rights above are not absolute and we may be unable to comply with your request (in whole or in part). If we reasonably determine that your request is manifestly unfounded we reserve the right to refuse to comply with your request. We will provide you with a basis for any objection in this case. Your rights may vary depending on the Privacy Laws that apply to you.
7.3 If you wish to exercise a right that you have regarding your personal information, please contact our Privacy Officer at firstname.lastname@example.org
7.4 Secure Code Warrior will process your request within a reasonable time and in any event and unless otherwise stated within one month from the date that we received your request. In the event of particularly complex requests we may have to extend this period by up to two further months, but we will notify you of this.
7.5 If you have any cause for complaint about our use of your personal information, you have the right to lodge a complaint with your national data protection supervisory authority (details of some are set out at the end of this Policy), although we would ask that you contact us in the first instance using the contact details given below.
8.1 This Policy was last updated on 1 August 2022.
8.2 Secure Code Warrior may amend this Policy from time to time by publishing a revised Policy on our website, or in any associated registration forms, terms and conditions, additional privacy policies, forms and other notices. Any changes will be effective as of the date they are published. In the event of any material changes to this Policy, Secure Code Warrior may take additional reasonable steps to notify you of the changes.
9. Contact details and further information
9.1 If you have any questions in relation to privacy or you wish to access or correct your personal information, please contact our Privacy Officer directly by email at email@example.com
9.2 For further information about privacy issues (and to make complaints), see the UK Information Commissioner’s Office website at www.ico.org.uk, the Office of the Australian Information Commissioner’s website at www.oaic.gov.au, and the European Data Protection Board (https://edpb.europa.eu/edpb_en).
a. ENGLAND AND WALES
Secure Code Warrior Limited
Company Number 08559432
4 Ironstone Way
Brixworth, Northampton. NNG 9UD
b. NEW SOUTH WALES
Secure Code Warrior Pty Limited
ABN 97 608 498 639
c/o Vital Addition
5, 120 Sussex Street
Sydney. NSW 2000
Secure Code Warrior BVBA
Baron Ruzettelaan 5
bus 3 8310 Brugge
Security Code Warrior Inc
265 Franklin Street, Suite 1702
Boston MA 02110
Borgatun 24, 105,
* Only required for Trial Users
Whilst you have access to our platform, and thereafter for a period of 12 months, unless otherwise agreed.
We will retain this information for a period of 24 months from the date of our last contact with you unless, where you are entitled, request that we delete this information.
We will retain this information for the duration of the Competition, and for a period of 12 months from the date of our last contact with you unless, where you are entitled, request that we delete this information
We will retain this data for up to 7 years from our last contact with you, unless you request that we delete the data beforehand.
For unsuccessful we will retain this data for a period of twelve (12) months so that we may contact you regarding any future opportunities, unless you request that we delete the data beforehand.
¹ When you communicate with us through our websites:
We use Drift as one of our chatbots to allow customers to interact with us through our websites. Drift will only use the IP address for data enrichment, i.e. to determine if it is associated with a business to provide Secure Code Warrior with information such the industry and # of employees of the business.
We use Cookiebot to manage all cookies across our websites. Cookiebot allows Secure Code Warrior to:
³ Information is collected after consent is given
We will retain this data for a period of 12 months from the date of our last contact with you unless, where you are entitled, request that we delete this information.
1.Necessary to enable us to perform our contract with you:
2. Necessary for the performance of our contract with you where such communication relates specifically to our services, and legitimate interest to be able to handle such queries:
3. For legitimate interest to enable Secure Code Warrior to:
4. For legitimate interests to allow Secure Code Warrior to improve customer services offering:
5. With consent:
1. Necessary for the performance of a contract
2. For legitimate interests to enable Secure Code Warrior to conduct business
3. For legitimate interests to contact those who may benefit from our services
4. With consent
1.For legitimate interests to enable Secure Code Warrior to conduct business
2. For legitimate interests to contact those who may benefit from our services
3. With consent
1. Necessary for the performance of our contract with you, namely for the running of the competition and/ or tournament
2. With consent: to send out marketing materials
1. For legitimate interests to enable Secure Code Warrior for the performance of a contract where the supplier is an individual
2. To send and receive business communications.
3. To administer our relationship with our suppliers.
To enable Secure Code Warrior to recruit employees and assess potential candidates, that is to:
For legitimate interest to enable Secure Code Warrior to,
Secure Code Warrior (SCW) works with certain service providers (both locally and abroad) to run our business operations and to ensure that we can provide our contracted services to you. These service providers might (depending on the terms of their contracts with us) process your data:
Here is a full list of Secure Code Warrior’s service providers - our service providers are sometimes also referred to as Subprocessors on our website and/ or in any associated policies and terms and conditions.