Privacy Policy – Codeego Website and Services

This Privacy Policy (the “Policy”) explains how TrustCloud Ltd, together with its affiliated entities acting on its behalf where relevant (the “TrustCloud Group”, “TrustCloud”, “we” or “us”), collects, uses and otherwise processes personal data through the commercial website available at www.codeego.com (the “Website”).

Codeego is a product name and commercial brand operated by TrustCloud Ltd. This Policy applies to personal data processed in connection with use of the Website, including for informational, marketing and commercial purposes, as well as, where applicable, the creation of user accounts, the purchase of products or services, and access to and use of Codeego products or services made available via the Website.

Certain processing activities relating to the use of Codeego products or services may be governed by additional contractual documentation, terms of service or supplemental privacy information made available at the point of purchase or use. In the event of any inconsistency, such documentation shall prevail in respect of the relevant products or services.

Please read this Policy carefully before using the Website. By accessing or using the Website, you acknowledge that you have read and understood this Policy. If you do not agree with its terms, you should not use the Website.

1. Scope of this Policy

This Policy applies to the processing of personal data in the following contexts:

• Use of the Website for informational, marketing and commercial purposes, including enquiries and pre-contractual communications; and
• Where applicable, the creation and administration of user accounts, the purchase of products or services, and access to and use of Codeego products or services made available via the Website (the “Services”).

Certain processing activities relating to the Services may be governed by additional contractual documentation, terms of service or supplemental privacy information provided at the point of purchase or use. In the event of any inconsistency, such documentation shall prevail in respect of the relevant Services.

2. Data Controller

The data controller responsible for the processing of personal data in connection with the Website and the Services is:

TrustCloud Ltd
Building 3 Chiswick Park,
566 Chiswick High Road,
London, W4 5YA

Data Protection Officer: [email protected]

TrustCloud Ltd may operate internationally through affiliated entities acting on its behalf. However, for the purposes of personal data processed in connection with the Website and the Services, TrustCloud Ltd acts as the sole data controller.

Where third-party service providers are engaged in connection with the Website or the Services, including payment service providers or infrastructure providers, such providers act either as independent data controllers or as processors in accordance with applicable contractual arrangements and data protection law.

3. Collection of Information

TrustCloud may collect personal data where you voluntarily provide it through your use of the Website, where you create or use an account in connection with the Services, or where you otherwise contact us in a business-to-business context, including by submitting enquiries or requesting information.

The categories of personal data that may be processed in connection with the Website and the Services are limited to the following:

• Identity Data: name, surname, professional role or job title.
• Contact Data: business email address, company name, telephone number (where provided), and the content of any messages, enquiries or communications submitted via the Website or the Services.
• Marketing and Communications Data: marketing preferences, consent records, and correspondence with TrustCloud.
• Technical Data: internet protocol (IP) address, browser type and version, device and operating system information, and other technical data necessary for the operation, security and administration of the Website and the Services.
• Account Data: user identifiers, login credentials, authentication information and account settings associated with a user account.
• Transactional Data: records of purchases, billing information, invoices, payment status and related transaction identifiers. Payment card details are processed by third-party payment service providers and are not stored by TrustCloud.
• Usage Data: records relating to access to and use of the Services, including timestamps, feature interaction data, system logs and support-related communications.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

The Website and the Services do not collect, process or store source code, technical analysis data, valuation outputs, or any proprietary or confidential business information entered into the valuation calculator or other Website features.

The provision of personal data is voluntary. However, where certain personal data is required to create an account, process a purchase, or provide the Services or requested information, failure to provide such data may result in TrustCloud being unable to do so.

4. Valuation Calculator

The free valuation calculator made available on the Website operates on a non-persistent and standalone basis and does not store, retain, log or otherwise record any data entered by users for the purposes of generating valuation estimates.

Any data entered into the valuation calculator is processed solely in real time to generate the requested output and is not used for analytics, profiling, automated decision-making, product optimisation, or any other secondary purpose.

Use of the valuation calculator is optional and does not require the creation of a user account. Where you elect to submit your contact details following use of the valuation calculator, such personal data will be collected and processed independently from any calculator input and will be used solely for the purposes of responding to your enquiry and engaging in commercial communications, in accordance with this Policy.

5. Purpose of Processing

TrustCloud processes personal data in connection with the Website and the Services for the following purposes:

Website and commercial communications

• to respond to enquiries, requests for information and other communications submitted via the Website;
• to manage pre-contractual discussions and business-to-business commercial communications;
• to provide information relating to Codeego products and services where requested;
• to carry out business-to-business marketing activities, where such processing is permitted by applicable law and, where required, based on consent;
• to operate, maintain and improve the Website, including monitoring its performance, security and usage;

Provision of the Services

• to create, administer and manage user accounts;
• to process purchases, payments and subscriptions and to administer billing and invoicing;
• to provide access to, operate and maintain the Services;
• to provide customer support, service communications and incident management; and
• to enforce applicable terms and conditions and to manage contractual relationships;

Legal and compliance purposes

• to comply with applicable legal, regulatory and compliance obligations.

6. Legal Basis for Processing

TrustCloud processes personal data in connection with the Website and the Services on the basis of one or more of the following lawful grounds under UK data protection law:

• Consent, where this is required under applicable law, including in relation to certain marketing communications;
• Performance of a contract, where processing is necessary to enter into or perform a contract with you, including to create and manage user accounts, process payments and subscriptions, and provide access to the Services;
• Legitimate interests, pursued by TrustCloud in managing and developing business-to-business relationships, responding to enquiries, operating and improving the Website, and promoting its products and services, except where such interests are overridden by the interests or fundamental rights and freedoms of data subjects; and
• Legal obligations, where processing is necessary for compliance with applicable legal or regulatory requirements.

7. Disclosure of Information

TrustCloud may disclose personal data processed in connection with the Website and the Services to the following categories of recipients:

• other entities within the TrustCloud Group, where such disclosures are necessary for internal administrative and business management purposes and subject to appropriate safeguards;
• third-party service providers engaged by TrustCloud in connection with the Website or the Services, including providers of hosting, information technology, analytics, communication and payment processing services, who act either as processors on TrustCloud’s behalf or as independent data controllers, as applicable, and who process personal data in accordance with applicable contractual arrangements and data protection law; and
• competent public authorities, regulators or law enforcement bodies, where disclosure is required by applicable law or a valid legal request.

TrustCloud does not sell, rent or otherwise commercially exploit personal data processed in connection with the Website or the Services.

8. Retention and International Transfers

Personal data will be retained only for as long as is necessary to fulfil the purposes for which it is processed, as described in this Policy, including the duration of any pre-contractual, commercial or contractual relationship, and thereafter for such periods as are required or permitted under applicable legal, accounting or regulatory obligations. Where processing is based on consent, personal data will be retained until such consent is withdrawn, unless a longer retention period is required by law.

Personal data relating to user accounts, Services usage and transactions will be retained for the duration of the contractual relationship and thereafter in accordance with applicable statutory retention requirements and limitation periods.

Where personal data is transferred outside the United Kingdom or the European Economic Area, TrustCloud ensures that such transfers are subject to appropriate safeguards in accordance with applicable data protection laws, including, where relevant, adequacy regulations and the use of standard contractual clauses or other approved transfer mechanisms.

9. Security

TrustCloud implements appropriate technical and organisational measures designed to protect personal data processed in connection with the Website and the Services against unauthorised or unlawful processing and against accidental loss, destruction or damage.

While no system can guarantee absolute security, TrustCloud regularly reviews and updates its security measures taking into account technological developments, risk assessments and applicable regulatory requirements.