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Our visitors can learn more about how we manage personal information, how our
visitors may access and correct their personal information, how they can
complain about a breach of privacy and contact us, in our Privacy Policy
Secure Code Warrior’s websites use different types of cookies. Some cookies are
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softwaresecuritygurus.com, www.securecodewarrior.com,
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Privacy Policy
LEGALS
PRIVACY POLICY
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1. GENERAL
1.1 Secure Code Warrior Limited, a company incorporated in England and Wales
with Company Number 08559432 and its related bodies corporate, listed in
Appendix A of this Privacy Policy (Policy) (all referred to as Secure Code
Warrior) recognise that the privacy of your personal data (also known as your
personal information or personally identifiable information (PII)) is important
to you.
At Secure Code Warrior we take our data protection and privacy obligations
seriously and we are committed to ensuring that we handle personal information
in accordance with the applicable data protection and privacy laws, including
the Data Protection Act 2018 and the Data Protection, Privacy and Electronic
Communications (Amendments etc) (EU Exit) Regulations 2019 in the United
Kingdom, the General Data Protection Regulation (EU) 2016/679 (known as the
GDPR) in the European Union, the Australian Privacy Principles contained in the
Privacy Act 1988, the California Consumer Privacy Act (so far as is applicable)
and the Personal Data Protection Act 2012 (PDPA) in Singapore (Privacy Laws).
1.2 This Policy sets out how Secure Code Warrior collects, uses, processes,
discloses and secures your personal information. It also sets out the rights you
have in respect of your personal information, including your right to access
your personal information and to have it corrected. 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 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.
1.3 This Policy applies exclusively to Secure Code Warrior. Where the Secure
Code Warrior website or the SCW Learning Platform contains links to other
websites, Secure Code Warrior is not responsible for the privacy practices and
terms of use of other organisations and websites.
2. COLLECTION OF YOUR PERSONAL INFORMATION
2.1 We collect personal information relating to our customers, prospective
customers, business contacts, suppliers, recruitment candidates, and individuals
who access the SCW Learning Platform or participate in our tournaments,
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: your title, name, address, email address,
telephone numbers, birthdate, nationality, location, job title, occupation,
transaction and payment details, purchase preferences, 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.
2.4 Secure Code Warrior may make a record of information relating to your visit
to the Secure Code Warrior website. Such information includes your server
address, domain name, IP address, the date and time of your visit, pages
accessed and documents downloaded. We will not collect personal information
about you where you follow us on our Secure Code Warrior social media sites. If
you do not wish information to be collected and recorded by means of a cookie,
you may reconfigure your web browser to not accept cookies. Further information
about cookies and how to disable them can be found here. For information on
Secure Code Warrior’s Cookie Policy click here.
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 Secure Code Warrior Learning Platform, or
satisfying your request or enquiry.
3. USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION
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:
A. if it is necessary to provide services to you under the performance of
the contract we have with you;
B. if we are required to do so in accordance with legal obligations;
C. if you have given your consent; and,
D. if it is in our legitimate interests to process your personal
information, provided that none of these prejudice your own rights, freedoms and
interests. 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 opt-out of, object to, or
unsubscribe from receiving marketing materials. You can do this either via links
in the message or by contacting Secure Code Warrior,
security@securecodewarrior.com.
3.5 Secure Code Warrior may disclose your personal information in order to
fulfil the purposes outlined set out 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 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:
A. specialist advisers to Secure Code Warrior who have been engaged to
provide us with legal, accounting, administrative, financial, insurance,
research, marketing or other services;
B. law enforcement bodies which may have a reasonable requirement to
access your personal information; and
C. any other person authorised and specified by you.
3.7 In addition, Secure Code Warrior may use or disclose your personal
information:
A. where required or authorised by or under the applicable Privacy Laws or
an order of a court or tribunal;
B. in accordance with the applicable Privacy Laws, including where we hold
a reasonable belief that the use or disclosure is required for certain
enforcement or health and safety purposes, or that use or disclosure is
necessary in relation to certain suspected unlawful activity or misconduct;
C. whilst negotiating any takeover, purchase, merger, joint venture,
partnership or other similar arrangement; or
D. if reasonably necessary for the establishment, exercise or defence of a
legal or equitable claim or for the purposes of confidential alternative dispute
resolution.
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. STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION
4.1 Secure Code Warrior may hold your personal information in a number of
different formats, including 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, including, in respect of transfers from the UK and EU,
standard contractual clauses and EU-US Privacy Shield Framework. if you would
further information about where we may disclose your personal information,
please contact Secure Code Warrior’s Privacy Officer at
security@securecodewarrior.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.
5. SENSITIVE INFORMATION
5.1 With the exception of sensitive information that Secure Code Warrior
collects about its employees, Secure Code Warrior does not generally collect any
sensitive information about you. If Secure Code Warrior holds any sensitive
information about you, that information will only be used and disclosed by
Secure Code Warrior for the purpose for which it was provided by you, and
otherwise in accordance with the applicable Privacy Laws.
6. UNSOLICITED INFORMATION RECEIVED BY US
6.1 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.
7. RETENTION
7.1 Secure Code Warrior will only 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.
8. YOUR RIGHTS TO YOUR PERSONAL INFORMATION
8.1 Privacy Laws give you certain rights in respect of your personal
information, including the right to:
A. request access to your personal information;
B. request correction of the personal information that we hold about you
as described below;
C. where required by law, request erasure of your personal information
where there is no good reason for us continuing to process it or where you have
exercised a right to object to processing (see (D) below);
D. object to processing of your personal information where we are relying
on a “legitimate interest” (or the interests of a third party) and there is no
compelling reason for us to continue processing your personal information;
E. object to processing your personal information for direct marketing
purposes;
F. object to automated decision-making including profiling by us using
your personal information which has a legal effect or similar significant effect
on you;
G. request the restriction of processing of your personal information (for
example, to suspend the processing of your personal information due to
inaccuracy or our stated reason for processing it);
H. request that we provide you or a third party the personal information we
hold regarding you in an electronically useable format; and
I. withdraw your consent for those purposes where we rely on consent, in
which case we will no longer process your information for the purpose or
purposes to which you originally consented, unless we have another lawful basis
for doing so.
8.2 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.
8.3 If you wish to exercise a right that you have regarding your personal
information, please contact our Privacy Officer using the details below or
clicking here.
8.4 We may need to request specific information from you to help us confirm your
identity and ensure your right to access the information (or to exercise any of
your other rights). This is a security measure to ensure that personal
information is not disclosed to any person who has no right to receive it and to
prevent unauthorised modification of your personal information.
8.5 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.
8.6 Please note that these rights may vary depending on the Privacy Laws that
apply to you.
9. CORRECTION OF YOUR PERSONAL INFORMATION
9.1 You may ask Secure Code Warrior at any time to correct personal information
we hold about you by contacting our Privacy Officer.
9.2 You should promptly notify Secure Code Warrior if there are any changes to
your personal information. If you have a direct account with us, please use the
email address connected to your account to make your request. If you have an
account via your employer, please direct your request to your supervisor or HR
department.
10. COMPLAINTS
10.1 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.
11. CHANGES TO THIS POLICY
11.1 This Policy was last updated on 31 July 2020.
11.2 Secure Code Warrior may amend this Policy from time to time by publishing a
revised Policy on our website. 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.
12. CONTACT DETAILS AND FURTHER INFORMATION
12.1 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 security@securecodewarrior.com.
12.2 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 Supervisor’s website at www.edps.europa.eu.
Appendix A
Appendix b
Appendix c
Appendix d
Appendix e
APPENDIX A - SECURE CODE WARRIOR LEGAL ENTITIES
a. UNITED KINGDOM (incorporated in England and Wales)
Secure Code Warrior Limited
Company Number 08559432
Ironstone House
4 Ironstone Way
Brixworth, Northampton. NNG 9UD
United Kingdom
b. AUSTRALIA
Secure Code Warrior Pty Limited
ABN 97 608 498 639
c/o Vital Addition
5, 120 Sussex Street
Sydney. NSW 2000
Australia
c. BELGIUM
Secure Code Warrior BVBA
Baron Ruzettelaan 5
bus 3 8310 Brugge
Belgium
d. USA
Security Code Warrior Inc
265 Franklin Street, Suite 1702
Boston MA 02110
USA
e. ICELAND
Motherji ehf
Borgatun 24, 105,
Reykjavik,
Iceland
APPENDIX B - COLLECTION OF PERSONAL INFORMATION
A. PLATFORM USER
As a user of the Secure Code Warrior platform we will hold the following
information about you
1. User name
2. Password
3. Employer
4. Job title
5. Location
6. Test results
7. IP Address
8. IMEI number
9. MAC Address
10. Browser type
This personal information will be held about you for so long as you have access
to our platform and thereafter for a further period of twelve (12) months or as
specified in your employers contract with us (whichever is the lower).
RECRUITMENT CANDIDATES
As potential employee of Secure Code Warrior we hold the following information
about you:
1. Contact details
2. CV
3. Date of Birth
4. Qualifications
5. References
Should you be 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.
CUSTOMERS
As an email contact or prospective customer to Secure Code Warrior we hold the
following information about you:
1. Name
2. Contact details
3. Employer
4. Job Title
5. Location
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.
PARTICIPANTS IN TOURNAMENTS AND OR COMPETITIONS
As a registrant, or participant in a tournament or competition we hold the
following information about you:
1. Name
2. Email address
3. Physical address where there may be a prize to be delivered
4. Region
This personal information will be held about you for so long as you have access
to our platform and thereafter for a further period of twelve (12) months.
SUPPLIERS
As a supplier to Secure Code Warrior we hold the following information about
you:
1. Name
2. Business/ Company Name
3. Contact details
4. Bank Details (if acting as a sole trader or using a personal account)
5. 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.
APPENDIX C - PROCESSING OF PERSONAL INFORMATION
A. PLATFORM USER
Necessary to enable us to perform our contract with you:
1. to set up, administer and manage a user’s account, verify a user’s identity,
provider users with our platform and services, and to receive and respond to
a user’s communications and requests.
2. to notify our users of updates to our platform and services necessary for
the performance of the contract we have with you.
3. to support any other purpose necessary for performance of our contractual
obligations or specifically stated at the time at which you provided your
personal information.
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:
1. to receive and respond to a user’s communications and requests.
For legitimate interest to enable Secure Code Warrior to:
1. carry out market research campaigns so that we can better understand the
functionality of our platform and how we can improve our platform and our
services.
2. prepare statistics relating to the use of our platform and services by our
users so that we can understand the use of, and improve our platform and
services.
For legitimate interests to allow Secure Code Warrior to improve customer
services offering:
1. to record and review customer service communications for training and
performance improvements to enable us to improve customer services.
To enable Secure Code Warrior to comply with a legal obligation:
1. to enable Secure Code Warrior to comply with legal obligations.
With consent:
1. to send users marketing materials where marketing materials have been
specifically requested.
RECRUITMENT
To enable Secure Code Warrior to recruit employees and assess potential
candidates, that is to:
consider applications for roles for which you may have applied, directly or via
a recruitment, and the negotiation of employment opportunities,
consider applicants for other roles within Secure Code Warrior for which they
may be suited,
obtain references from former employers.
CUSTOMERS, PROSPECTIVE CUSTOMERS OR BUSINESS CONTACTS
Necessary for the performance of a contract
1. conducting business and make our services available to customers,
For legitimate interests to enable Secure Code Warrior to conduct business
1. to send and receive business communications
2. to administer our relationship with customers, prospective customers and
business contacts
For legitimate interests to contact those who may benefit from our services
1. informing prospective customers and business contacts about our services.
With consent
1. to send out marketing materials where these have been specifically
requested.
PARTICIPANTS IN TOURNAMENTS AND OR COMPETITIONS
Necessary for the running of the competition and/ or tournament
With consent
1. to send out marketing materials
SUPPLIERS
for legitimate interests to enable Secure Code Warrior for the performance of a
contract where the supplier is an individual
1. to assess and appoint suppliers
Legitimate interests to conduct business
1. to send and receive business communications
2. to administer our relationship with our suppliers.
APPENDIX D - SECURE CODE WARRIOR RELATED WEBSITES
1. securecodewarrior.com
2. help.securecodewarrior.com
3. insights.securecodewarrior.com
4. discover.securecodewarrior.com
5. leadersinappsec.com
6. leadersindevsec.com
7. softwaresecuritygurus.com
8. scw.io
APPENDIX E - EXTERNAL SERVICE PROVIDERS
Please see list of our data sub-processors here.
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