Last modified on: July 25, 2024

Data Privacy Policy

This Data Privacy Policy provides details on how we collect and process your personal data.

1. Who Are We?

Code Cicada is responsible for processing your data and we are responsible for your personal data (referred to as "we," "our," or "us" in this privacy notice).

Our email address is: contact@codecicada.com

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at contact@codecicada.com.

2. The Data We Collect About You, the Purpose for Which We Collect It, and the Grounds on Which We Process It

Personal data refers to any information that can identify an individual. It does not include anonymized data.

We may process the following categories of personal data about you:

  • Communication Data includes any communication you send to us, whether through contact forms on our website, by email, SMS, social media messaging, social media posting, or any other communication you send to us. We process this data for communication with you, for record-keeping, and for the establishment, pursuit, or defense of legal claims. Our legal basis for this processing is our legitimate interests, which in this case are to respond to communications sent to us, keep records, and establish, pursue, or defend legal claims.

  • Personal Contact Data includes data such as your name, title, address, email address, phone number, and contact details. We process this data to communicate with you, for record-keeping, and for the establishment, pursuit, or defense of legal claims. Our legal basis for this processing is our legitimate interests, which in this case are to respond to communications sent to us, keep records, develop our business, maintain contact with you, and establish, pursue, or defend legal claims.

  • Transaction Data includes any data you may provide to us related to the services we provide, the member groups we operate, the products we sell, and the events and programs we organize. It also includes communications and other data generated during the transaction. It also includes details of payments between us and other details of purchases made by you and the bank account and payment card details you have submitted. We process this data to provide our services and deliver all the products, events, programs, and member groups we offer. Our legitimate grounds for processing this data are the performance of a contract to which you are a party and our legitimate interest in managing our business.

  • Job Applicant Data includes any data submitted to us by potential job candidates. Our legitimate grounds for processing this data are for the purposes of our company's legitimate interests in recruiting new staff. Please refer to the privacy notice in any specific job offer for more information on how we process candidate data concerning the advertised position.

  • User Data includes data on how you use our website and any online services, as well as any data you post for publication on our website or through other online services. We process this data to operate our website and ensure that relevant content is provided to you, to ensure the security of our website, to maintain backups of our website and/or databases, and to enable the publication and administration of our website, other online services, and business. Our legal basis for this processing is our legitimate interest, which in this case is to allow us to properly administer our website and business.

  • Technical Data includes data on your use of our website and online services such as your IP address, login data, details about your browser, the duration of visits to pages on our website, page views and navigation paths, details about how often you use our website, timezone settings, and other technologies on the devices you use to access our website. The source of this data comes from our analytics tracking system. We process this data to analyze your use of our website and other online services, to administer and protect our business and website, to provide relevant website content and advertisements to you, and to understand the effectiveness of our advertising. Our legal basis for this processing is our legitimate interests, which in this case are to allow us to properly administer our website and business and to grow our business and decide on our marketing strategy.

  • Marketing Data includes data about your preferences in receiving marketing communications from us and your communication preferences. We process this data to enable you to participate in our promotions such as competitions, prize draws, and free giveaways, to deliver relevant website content and advertisements to you, and to measure or understand the effectiveness of this advertising. Our legal basis for this processing is our legitimate interests, which in this case are to study how customers use our products/services, to develop them, to grow our business, and to decide on our marketing strategy.

We may use communication data, personal contact data, user data, technical data, and marketing data to provide you with relevant website content and advertisements (including Facebook ads or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our legal basis for this processing is a legitimate interest which is to grow our business. We may also use this data to send you other marketing communications. Our legal basis for this processing is either consent or legitimate interests (namely to grow our business).

Special Categories of Data

We do not collect any sensitive data about you, and you should not submit any to us via our website or otherwise. Sensitive data refers to data that includes details about your race or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political opinions, union membership, information about your health, and genetic and biometric data. We do not collect any information about criminal convictions and offenses, and you should not submit such information to us via our website or otherwise.

We do not perform any automated decision-making or any automated profiling.

3. How We Collect Your Personal Data

We may collect data about you by you providing the data directly to us (for example by filling out forms on our site or by sending us emails and correspondence by mail or by talking to us over the phone and at meetings). We may collect data from third parties from whom you authorize us to obtain data on your behalf (e.g., a government agency, financial institution, or other professional or adviser).

We may automatically collect certain data from you as you use our website using cookies and similar technologies. Please see our cookie policy for more details about this.

We may collect data from third parties such as analytics providers like Google based outside the EU, advertising networks like Facebook based outside the EU, search information providers like Google based outside the EU, technical service providers, payment and delivery services, such as data brokers or aggregators.

We also collect data from publicly available sources.

4. Marketing Communications

Our legal basis for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications by email if (i) you have made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications, and in each case, you have not opted out of receiving such communications since.

We will not share your personal data with any third party for their own marketing purposes without your express consent.

You can ask us to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message sent to you.

You can ask us to stop sending you marketing messages by mail at any time by emailing us at contact@codecicada.com.

If you opt out of receiving marketing communications, this opt-out does not apply to personal data that we may need to process to execute any contract we may have with you or that we are required to obtain a record of for the purpose of complying with our obligations.

5. Disclosures of Your Personal Data

We may need to share your personal data with the parties set out below:

  • Service providers who provide IT and system administration services, including cloud-based services.
  • Service providers who provide business administration services, including third-party typing and transcription services, and external file storage and archiving services.
  • Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
  • Risk management auditors and quality control companies.
  • Revenue Commissioners, the Data Protection Commission, and other regulators and authorities based in Ireland and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
  • Third parties to whom we sell, transfer or merge parts of our business or assets.
  • We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

Countries outside the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited the transfer of personal data outside the EEA unless the transfer meets certain criteria.

Some of our third-party service providers are based outside the European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of data security by ensuring that at least one of the following safeguards