Privacy Notice

This website/platform (as the case may be) is operated and powered by Secureflag Ltd ("us" or "we") and accordingly, this notice is designed to tell you about our practices, as data controller, regarding the collection, use and disclosure of personal data which may be collected in person from you, obtained via our website, platform, apps or collected through other means such as by an online form, email, or telephone communication.

SecureFlag Limited, is registered in England and Wales under company number 12368322 with address C/O Russell-Cooke LLP, 2 Putney Hill, London, England, SW15 6AB.

In general, our services relate to the provision of secure coding training services to users, whether on a community or an enterprise basis, and include defensive programming training through real-world exercises and analytics. We licence use of such services either directly to our clients or to clients via our authorised resellers (in either case, such party to be referred to as our “client” for the purposes of this notice.

This notice applies to personal data:

  1. provided by our clients (which may include the organisation who has subscribed to our software service on an enterprise basis and for whom you work) or our prospective clients and their staff;

  2. provided by you (for instance whether you are an end-user to the services or simply visiting the SecureFlag website;

  3. collected directly by us through publicly available information;

  4. relating to third party suppliers of SecureFlag, but this notice does not apply to information we hold in relation to our employees and staff. In this notice "you" refers to any individual whose personal data we hold or process.

This privacy notice is governed by the EU General Data Protection Regulation (the "GDPR"), the Data Protection Act 2018 and any other applicable data or privacy legislation (including the UK GDPR, as and when it is implemented into UK data protection law). This notice may be updated from time to time and you should check this page regularly for any updates. Changes to this notice are effective when they are posted on this page.

Personal data we collect and how we process this data

Below we have set out the categories of data we collect, the legal basis we rely on to process the data and how we process the data:

In addition to the lawful bases of processing set out above, processing SecureFlag is subject.

We generally collect information from you directly however we may also collect certain information from the organisation for whom you work (such as your contact information and job title/role) or other third party. If we obtain your personal data from a third party, your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this privacy notice.

Data Retention

Our current data retention policy is to delete or destroy (to the extent we are able to) personal data after the following periods:

For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data. The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).

We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or securely delete this data as may be required.

If you wish to request that data we hold about you is amended or deleted, please see below for your privacy rights.

Sharing your information

We may disclose information to third parties in the following circumstances:

If we do supply your personal data to a third party we will take steps to ensure that your privacy rights are protected and that such third party complies with the terms of this notice.

Cookies and IP Address

Like most websites, we use cookies to help provide you with the best experience whilst using our service. The cookies we use are split between the following categories:

On your first visit to our site from your browser we will display a notice to notify you that we are using cookies but we will not load any cookies, except for Strictly Necessary Cookies, until you have provided your consent by clicking the "Accept" button. If you click the "Accept" button on our cookies notice, Performance and Functionality cookies will also be loaded.

As well as cookies that are set by domains we control (first-party cookies), you may also see cookies set by a third party (third-party cookies). These are set when you interact with certain parts of our service and are used by these third-party services to understand your preferences and sometimes tailor content they show you.

Below is a list of the cookies currently set by us:

Refusing Cookies

You can change the way your browser handles cookies if you wish. You could accept or reject them by default or be notified when a website is trying to set or update cookie. Exactly how you disable cookies depends on the browser or device you are using. The help feature on most browsers will tell you how you how you can manage and or disable cookies. If you disable cookies on your browser, certain features or parts of our service may not function correctly or will have a degraded experience.

IP Address

An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our service, and to administer and improve the online service.

Security

We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):

We will ensure that our staff are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations.

This notice and our procedures for handling personal data will be reviewed as necessary.

Third party links

Our website may contain links to other sites that are not operated by us. This notice applies to our services only so if you click on a third-party link, we strongly advise you to review that site’s privacy policy.

We have no control over and are not responsible or liable for the content, privacy policies or practices of any third-party sites or services.

Your privacy rights

With respect to your personal data, you have:

All SARs and other requests or notifications in respect of your above rights must be sent to us in writing via email at support@secureflag.com or by post to SecureFlag Limited, C/O Russell-Cooke LLP, 2 Putney Hill, London, England, SW15 6AB.

We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).

Data breaches

If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to our data protection manager or officer (if an officer has been appointed) and the Information Commissioner’s Office (ICO) (as necessary).

If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.

Transferring your information outside the UK or EEA

We will not transfer your personal data in a systematic way outside of the UK or European Economic Area or UK ("EEA") but there may be circumstances in which certain personal data is transferred outside of the UK or EEA, in particular:

If we transfer your information outside of the UK or EEA, and the third country or international organisation in question has not been deemed by the Secretary of State or EU Commission (as the case may be) to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.

Contact us

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal data or how it is handled, you can do so via email at support@secureflag.com or by post to SecureFlag Limited, C/O Russell-Cooke LLP, 2 Putney Hill, London, England, SW15 6AB.

Complaints

If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk for further assistance.

Privacy Notice v1.2 - Updated January 2021

CCPA/CalOPPA Appendix

 

The contents in this appendix apply to individuals residing in California from whom we collect personal information in compliance with the California Consumer Privacy Act (“CCPA”) and California Online Privacy Protection Act (“CalOPPA”) and are intended to supplement the information already contained in our privacy notice.

 

Categories of Personal Information

Below we have set out the categories of Personal Information (as defined in the CCPA) collected in the previous 12 months and whether during such period, we have sold or otherwise disclosed such Personal Information for a business purpose (as defined in the CCPA).

 

Category of Personal Information

Collected

Sold

Disclosed for a business purpose

A. Identifiers

Examples: Name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

 

Yes

No

Yes

B. Categories of Personal Information in Cal. Civ. Code 1798.80(e)

Examples: Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical
information, or health insurance information.

 

Yes

No

Yes

C. Characteristics of Protected Classifications under California or Federal Law

Examples: Race, colour, ancestry, national origin, religion or creed, age (over 40), medical condition, genetic information, marital status, military and veteran status, mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, 

 

No

No

No

D. Commercial Information

Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Yes

No

Yes

E. Biometric Information

Examples: Physiological, biological, or behavioural characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

 

No

No

No

F. Internet or Other Electronic Network Activity Information

Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.

 

Yes

No

Yes

 G. Geolocation Data

Examples: physical location.

 

Yes

No

Yes

H. Sensory Information

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

 

No

No

No

 I. Professional or Employment Related Information

Examples: Job application or CV information, job history, job performance information.

 

No

No

No

J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)

Examples: education records that are directly related to a student maintained by an educational agency or institution or by a party acting on its behalf such as grades, transcripts, disciplinary records.

 

No

No

No

K. Inferences drawn from Personal Information

Examples: profiles reflecting an individual’s preferences, characteristics, psychological trends, preferences, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

 

No

No

No

 

Use, Collection and Disclosure of Personal Information

For details on how we use your personal information, please refer to the section “Personal data we collect and how we process this data”.

As set out above in our privacy notice, we generally collect information from you directly however we may also collect certain information from the organisation for whom you work (such as your contact information and job title/role) or other third party. If we obtain your personal data from a third party, your privacy rights under appendix are not affected and you are still able to exercise the rights contained within this appendix.

For details on who we share your personal information with, please refer to the section “Sharing your information” above.

 

Your California Privacy Rights

If you are a California resident, the CCPA provides you with certain specific rights in relation to your Personal Information, as set out below.

       The Right to Receive Information on Privacy Practices and Access to Information (including as part of an Access Request) – i.e. the right to request certain personal information we have collected about you (including the categories and specific pieces of personal information).

       The Right to Deletion – i.e. the right to request that we delete certain personal information which we have collected about you (subject to certain exceptions).

       The Right to Receive Information about Onward Disclosures – i.e. the right to request information about personal information we hold about you which is either disclosed for a business purposes or sold.

       The Right to Prohibit the Sale of your Information (also referred to as the Right to Opt Out) & the Right Not to be subject to Price Discrimination based upon the exercise of the Opt Out Right- however please note that we do not sell your personal information to third parties.

 

Other California Privacy Rights

       Shine the Light law (Civil Code Section 1798.83) permits users of our website/platform (as the case may be) that are California residents to request certain information regarding our disclosure of personal information to third parties for direct marketing purposes.

 

Contact Information

If at any time you would like to contact us with your views about our privacy practices, would like to exercise any of your rights as set out above or have another enquiry or complaint relating to your personal information, you can do so via email at support@secureflag.com or by post to Secureflag Limited, C/O Russell-Cooke LLP, 2 Putney Hill, London, England, SW15 6AB.

We will accordingly aim to get to back to you as soon as reasonably practicable. To the extent you have made a specific request as set out under “Your California Privacy Rights”, we will confirm receipt of the request within 10 business days and respond more substantively to the request within 45 days from the time the request is received.

CCPA/CalOPPA Appendix v1.0 - Updated January 2021