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1. Introduction

Code as a Service B.V. (“Code as a Service”, “We” or “Us”) is offering consultancy and expert services in the IT landscape. Code as a Service respects the privacy of individuals and is committed to protecting the data of visitors to the website “Visitors” and individuals or entities that register to use the Code as a Service services through the Website “Customers”.

This privacy policy describes Code as a Service’s practices for collecting, using, maintaining, protecting and disclosing data in relation to Visitors on the website, https://www.codeasaservice.nl/. “Website”, Code as a Service’s marketing activities and Customers accessing, using the Website to register for the services.

Code as a Service encourages you to read the following carefully to understand our policies and practices regarding your data through the Website, through our marketing activities and how We will treat it. If you do not agree with our policies and practices, your choice is not to use our Website.

This privacy policy provides information about how Code as a Service handles data in its role as data controller, meaning all data We process for our own purposes. Where Code as a Service is a processor or a sub-processor of data, that processing is governed by a data processing agreement.

2. Personal data We collect and how We collect it.

2.1 Personal data you provide to Us:
  • You provide your Personal Data to us when you voluntarily complete our forms on our Website such as when you contact sales. This Personal Data may include: Your first and last name, company information such as your job title, work email address, phone number and the content of your request.

  • You may also share your Personal Data with Us through our Website when you sign up to register for an event, to receive our newsletter, subscribe to our blog, register for an event, register for an online webinar, download a whitepaper or complete a survey. This Personal Data may include: Your first and last name, company information such as your job title, work email address, phone number and the content of your request.

2.2 Personal Data We collect from Third Parties

Code as a Service may obtain your Personal Data from third parties, including, but not limited to, marketing event organizers and partners. This information may include your first and last name, company information such as your job title, work email address and your phone number. Code as a Service requires that any third party providing it with Personal Data has obtained the information lawfully and the third party has obtained the appropriate consent to share the Personal Data with Code as a Service.

2.3 Information We collect automatically

By using our services or browsing our Website, We automatically collect your Personal Data:

  • As you navigate through and interact with our Website, We may use cookies. Cookies are small files placed on your device, and web beacons, which are small files located on pages of the Website, to collect information about your equipment, browsing actions and habits.

  • The following Personal Data is collected from cookies and web beacons: Information from your web browser, such as the type and language of the browser and details of your visits to our Website, including traffic data, location data and logs, page views, length of the visit and website navigation paths as well as information about your computer and internet connection, including your IP address and how you interact with our Website. This Personal data is collected to improve our Website and the user experience of it.

  • When using our Website you can decide to accept these cookies, a banner is available to do so. If you have accepted the cookies and you wish to change your preferences, you can do so every time you visit our Website. 180 days after you’ve given your consent it automatically expires and we’ll ask you your consent again to place cookies. You can withdraw your cookies at our website by either deleting them via your browser as defined in the link above or by changing your preferences here or via the legal banner at the bottom of our website.

  • For more information about cookies, please visit: https://ico.org.uk/your-data-matters/online/cookies/

  • We do not support Do Not Track on our Website.

3. How Code as a Service uses your Personal Data

Code as a Service uses your personal data that We collected about you or that you provided to us in our legitimate interest to respond to a request from you, to carry out our legal obligations, to fulfill a contract with you, to provide you with notices and for other purposes you provided us your consent for as described below:

  • When you complete one of our forms on our Website We will use your Personal Data to contact you about that request. Our legal basis for processing this Personal Data is our legitimate interest in communicating with you to fulfill your request on our Website.

  • We also use your personal data for non-marketing and administrative purposes such as notifying you about major changes to the Website or for Customer service purposes. Our legal basis for processing your Personal Data is in the performance of our contract to provide the Website and other services to you.

  • We also use your Personal Data to provide you a secure and integer website and to ensure our business continuity (maintaining backups of our databases) and for the purpose of operating our Website. Our legal basis for processing your Personal Data is our legitimate interest for the administration and security of our Website.

  • We also process your Personal Data through tracking technologies about your interaction with our Website. This Personal Data is used to improve our Website in order to increase the user experience. Our legal basis for processing your legal data is our legitimate interest to provide you with a better user experience.

  • We also process your Personal Data through tracking technologies, for marketing purposes that for instance allow us to place advertisements for our website on other websites than ours. Our legal basis for processing your Personal Data is consent. You can withdraw it at any time as detailed above in the Cookie paragraph.

  • We may also use your Personal Data for the purposes of: (i) enforcing our agreements and policies, including the Terms and Conditions or Master Service Agreement, (ii) protecting or defending Code as a Service’s legal rights or (iii) to comply with a legal obligation.

  • We may use your Personal Data for any other business purpose as stated when collecting your Personal Data or as otherwise set forth in applicable data protection laws, such as the General Data Protection Regulation (GDPR).

4. Disclosing Personal Data

Code as a Service shall not disclose any Personal Data that we collect other than the practices as described below:

  • We may disclose Personal Data to our subsidiaries and affiliates. This Personal Data may include, first and last name, company information such as your job title, work email address, phone number and analytical data such as geolocation data and data about your interactions with our Website.

  • We may share your Personal Data with third party providers who need the access in order to perform services on behalf of Code as a Service, such as processing or storing information on our behalf. These third parties are subject to contractual obligations to keep Personal Data confidential and integer and only use it for the purposes We instruct them for. This Personal Data may include, first and last name, company information such as your job title, work email address, phone number, payment information such as credit card details and analytical data such as geolocation data and data about your interactions with our Website. These third parties are: AWS, Cloudflare, Hubspot, Gsuite, Google 360suite.

  • Code as a Service reserves the right to disclose your Personal Data that Code as a Service reasonably believes is appropriate or necessary to: (i) enforce our agreements and policies, including for billing and collection purposes, (ii) protect the confidentiality and integrity of the Website and services or (iii) to protect or defend Code as a Service’s legal rights.

  • Code as a Service may disclose non personally identifiable aggregated information about Visitors of the Website without any restriction for the purposes of published studies and white papers. This non-personally identifiable aggregated information may include, but is not limited to, amount of users, amount of vendors, amount of critical vendors managed. Code as a Service will make sure confidentiality of disclosed information is maintained.

  • Code as a Service may share Personal Data to third party partners or tools when you use our products or services as part of or integrated into third party products or websites.

  • Code as a Service may also disclose Personal Data that you provide to us or that We collect for any purpose when you provide your consent to do so.

  • In the event that Code as a Service is acquired by or merged with a third party entity, We reserve the right to transfer or assign your Personal Data We have collected from you as part of such merger, acquisition, sale or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors or the applicable laws or equitable principles affecting creditors rights generally, We may not be able to control how your Personal data is treated, transferred or used.

5. Selling Personal Data

Code as a Service does not, and does not have the intention to, sell your Personal data.

6. Transfer of Personal Data

The data servers Code as a Service utilizes to provide the Website are located in Europe. By interacting with the Website, you understand that your Personal Data will be transferred to Europe and you consent to such transfer.

7. Security of Personal Data

Code as a Service uses commercially reasonable physical, managerial, and technical safeguards designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration and disclosure or access to personal data transmitted, stored, or otherwise processed.

8. Your rights

Depending on the local data protection laws, you have rights that may include:

  • Information about our processing of your Personal Data
  • Access to your Personal Data that We hold
  • The right to have inaccuracies of your Personal Data corrected
  • The right to have your Personal Data delivered to you in a standard electronic format
  • To object to our processing of your Personal Data and to prevent solely automated decision making or profiling
  • To restrict our processing of your Personal Data
  • To have your Personal Data deleted

You may exercise your rights with respect to your Personal Data by emailing your request to [email protected]. We will respond to your request within 30 days.

If you wish to unsubscribe from an email list, please click the unsubscribe link found at the bottom of our emails. If you work for one of Code as a Service’s Customer’s, please refer to the Customer and ask them to delete your Personal Data.

If you want to raise a complaint about the way We process your Personal Data or the way We have handled your request, please contact Us. You may file a complaint with the data protection authority of any country where you live or work or where Code as a Service operates.

9. Data retention

Personal Data collected by Code as a Service for the purposes as identified in this privacy policy are not kept by Code as a Service for longer than is necessary for the specific purpose identified in this privacy policy unless Code as a Service is required to retain your Personal Data for a longer period of time to comply with our legal obligations, resolve disputes and to enforce our legal agreements and policies.

10. Children’s privacy

Code as a Service does not knowly collect or solicit Personal Data directly from Visitors of the Website that are under the of 16. If you are under 16, please do not provide or send us any Personal Data. If We learn that a child under the age of 16 has provided us their Personal Data, then We will delete that information.

11. Links to other websites

Our Website may contain links to other third party websites such as Facebook, LinkedIn or Twitter. This privacy policy does not apply for any third party websites, including through any application that may link to or be accessible from or on the Website and Code as a Service is not responsible for the privacy policies and the content of the third party websites.

12. CCPA

Most of the obligations under the CCPA are addressed in other provisions of this privacy policy. This supplement is used to fill the gaps.

As a CCPA Consumer you have the additional rights to:

  • The right to access and to know specific Personal Data we collect

  • The right to request disclosure of the Personal Data collected

  • The right to disclosure of information disclosed for valuable consideration

Where to submit a request under CCPA?

California residents may submit requests under the CCPA to Code as a Service by sending an email to [email protected].

13. Updates and changes to this privacy policy

Code as a Service reserves the right, at any time, to add to, change, update, or modify the content of this privacy policy. If, at our reasonable discretion, the changes are material, We will post a notice on our Website or send you an email. The modified privacy policy will be posted on this website along with the effective data.

14. Contact Us

If you have any questions, comments or concerns about this privacy policy, please send an email to [email protected].