Privacy Policy

Your right to privacy

Your right to privacy is important to us. We take the security of your information seriously and have policies and processes in place to ensure it remains safe. We are legally obliged to use your information in line with all laws concerning the protection of personal information.

This policy is provided for visitors to our website, potential customers, current customers, suppliers, contractors, and any other persons whose information is processed by Eficode UK as a data controller. This policy describes the way we collect information, how we use it and how we protect it.

In addition, privacy information is provided to Eficode UK employees via the employee handbook and to job applicants via the Recruitment Privacy Notice.

For more information about how Eficode UK protects and secures your data when acting as a data processor please view our Data Processing Agreement.

Our contact details

Name: Eficode UK Limited

Company registration number: 5643578

Address: Unit 15 Chalcroft Business Park,

Burnetts Lane,

Southampton,

SO30 2PA

Telephone: +44 (0) 2381 157 800

www.eficode.com

For all general enquiries regarding data protection and privacy you can contact us at legal_uk@eficode.com. If you wish to exercise your data rights you can make a request using our online form.

If you are based outside of the UK but within the EU you can contact our EU representative at dataprotection@eficode.com.

Information we hold about you

We currently collect and process the following information:

Name, address, telephone number and email address
Information about services you use and other related information
Information we need to process payments for you, for example bank details
Records of contact with you such as system notes, emails, and letters
Other information as may be required from time to time to respond to your enquiry, enter into a contract with you or deliver requested services
Technical information such as an IP address

How we get and use the information

Most of the personal information we process is provided to us directly by you for one of the following reasons:

Operate and improve our sites, products, and services
Understand you and your preferences to enhance and personalize your experience and when using our sites, products, and services
Enhance security, monitor and verify identity or service access, combat spam or other malware or security risks
To keep our records up to date
To fulfil our legal obligations and to maintain compliance with best practice
Process and deliver contest entries and rewards
Respond to your comments or questions or provide information requested by you
To provide customer service and account management functions
Provide and deliver products and services you request
To send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages
To send you marketing and promotional communications (where this is in accordance with your marketing preferences)
To communicate with you about one of our events or our partner events

We also receive personal information indirectly, using cookies. Please see our Cookie Policy for further information.

We may link to certain third party websites and applications. In those circumstances, your use of the sites will be subject to this privacy policy and our Terms of Use, whether you are required to click through or otherwise. In addition, the third party website may also impose its own terms and conditions and privacy policies on your activities on their website. However you access our sites, you agree to be bound by and comply with this privacy policy and the Terms of Use and waive any objection to the enforceability thereof with respect to your use of the sites.

The lawful bases we rely on for processing this information are:

(a) We have a contractual obligation; and/or

(b) we have a legal obligation; and/or

How long we keep your information

We will keep your personal information only for as long as necessary in line with regulatory and legal requirements and will destroy it securely when it is no longer needed. Eficode UK manages a retention schedule that prescribes data review points for different classes of data.

How we protect your information

The security of your information is important to us. We take all reasonable and appropriate steps to help protect your personal information in an effort to prevent loss, misuse, unauthorized access, disclosure, alteration, and unlawful destruction. Eficode UK maintains an externally approved and audited certification of compliance with the Information Security Standard ISO 27001. There is a dedicated section in our Trust Centre where you can learn more about our information security practices.

How we store your information

We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. Depending on the nature of your relationship with Eficode UK and what we hold your data for, we may use third party applications such as Salesforce to process your data. Full details of our sub processors can be found further on in this policy.

Where we process your information

Eficode UK operates in many countries. We may transfer personal data across international borders and may process personal data in jurisdictions other than the location of original collection.

We may transfer personal data that we collect to other Eficode UK affiliates or other companies performing support functions on our behalf (each as described below) based in other countries including to the United States or other countries outside the UK and European Economic Area or your country of residence, and this personal data lawfully may be stored and/or processed in such countries.

Whether your personal data is processed within your country of residence or beyond, we will take steps to ensure that your data is subject to appropriate safeguards required of us under the Privacy Policy, applicable data protection laws, and appropriate legally recognised data transfer adequacy mechanisms. Personal data that is transferred outside your country of residence may be subject to lawful access by courts, law enforcement and other governmental authorities in accordance with the laws of the foreign jurisdiction.

How we share your information

Eficode UK will never sell your information. From time to time we may send information to, receive information from, or exchange your personal information with:

Partners or agents who support us to deliver our products and services to you, or that we refer you to, or that refer you to us
Affiliates in the Eficode UK OY group of companies
Companies who perform essential services for us
Third-party organisations that conduct research, analysis, and marketing activities on our behalf
Regulators, courts, or other public authorities
The emergency services in the case of accident or emergency
In connection with or during negotiation of any merger, financing, acquisition, or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company

We will only share or exchange data with third parties with the protection of a written agreement and the ability to oversee their activities, unless information is required for legal or regulatory reasons.

Where we have relationships with other organisations that process your information on our behalf, we take care to ensure they have high data security standards. We will not allow these organisations to use your personal information for unauthorised purposes.

If the business is reorganised or sold to another organisation, we may transfer any personal information we hold to that organisation.

In the event that a third party may deliver all or part of the service requested by you, whilst the information you provide will be disclosed to them, it will only be used for the administration of the service provided and to maintain management information for business analysis.

Your data protection rights

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

If you wish to exercise your data rights you can make a request using our online form.

How to complain

You can also complain to the ICO if you are unhappy with how we have used your data and you are a data subject based in the UK. If you are not based in the UK you can make a complaint to your local data protection regulator.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

Eficode UK's registration number: ZA840636

Sub Processors

Where UK personal data is transferred internationally, we take all reasonably necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy and the requirements of the law. Such measures include, where applicable, by ensuring that the recipients to which it is sent are (i) within countries deemed adequate with respect to the data protection laws, or (ii) covered through the entering into data processing agreements, standard contractual clauses and International Data Transfer Agreements and monitoring such protections to ensure the adequacy of such measures.

The following third parties process personal data on behalf of Eficode UK.

Name	Description	Location
Atlassian Pty Ltd	Service Desk functionality for our customers using support services. Internal Service Desk functionality and collaborative task management	US
Google Suite	Email, calendar, document management and video meetings	US
Amazon Web Services	Hosting of customers applications via ClearHost and hosting of applications used by Eficode UK	EU
Basecamp LLC	Project management tool used to communicate with customers on project updates and document sharing for consultancy	US
Docusign Inc	E-Signature software used to sign contracts with customers	US
Slack Technologies Inc	Internal chat and video communication	US
Trust Pilot	Customer Reviews	EU
Artemis Internet Marketing Limited	ClearHub website hosting	EU
HubSpot	Customer Service Management System	EU
Loxo	Candidate Management System – ClearHub	US
Salesforce EMEA Limited	Customer Relationship Management System	EU
Hotjar Limited	Digital marketing services	EU
SEMrush Inc	Digital Marketing Services	US
Perf Labs Inc	Digital Marketing Services	US
ContractSafe LLC	Contract management system	EU
Oracle Corporation UK Limited	Finance & accounting system	UK
Edcast	Third party provider of GitLab training materials	UK
IR35 Shield Manager	IR35 Status Determination Statements for contractors	UK
Dragnet Technologies, Inc	Digital Relationship Management tool	US
J2 Martech Corp DBA Kickbox	Email verification tool	US
Zapier Inc	Tool automation	US

Recruitment Policy

Your right to privacy

This policy is provided for applicants that apply for an advertised employment position with Eficode UK, whose information is processed by Eficode UK as a data controller. This policy describes the way we collect information, how we use it and how we protect it.

Our contact details

Name: Eficode UK

Company registration number: 5643578

Address: Unit 15 Chalcroft Business Park,

Burnetts Lane,

Southampton,

SO30 2PA

Telephone: +44 (0) 2381 157 800

www.eficode.com

For all general enquiries regarding data protection and privacy you can contact us at legal_uk@eficode.com. If you wish to exercise your data rights you can make a request using our online form.

Information we collect about you

We currently collect and process the following information:

Name, address, telephone number and email address
Date of birth
Information regarding your educational and employment background
Copies of any relevant certificates or qualifications
CV, covering letter or any other information you choose to provide us as part of an application for employment
Employment references

If you are successful in your application we may also collect and process the following information, some of which is classed as ‘special category data’:

Right to work in the UK documents such as your passport
Credit references or reports
Criminal records checks
Information about your health or disabilities
Gender
Race

We will only collect and process special category data with your consent in order to carry out our legal obligations or exercise your rights in connection with your application i.e. we may collect information about your disability status or physical or mental health in order to ensure your health and safety in the workplace and to enable us to make reasonable adjustments for you during the application process and, to carry out our obligations under equality and diversity monitoring and reporting.

How we get and use the information

Most of the personal information we process is provided to us directly by you for one of the following reasons. We may also use third parties to collect data about you with your consent for example to gain employment references, conduct credit checks or criminal record checks:

To process an application you have submitted for an employment position with Eficode UK
To respond to an enquiry you have made with regards to an employment position with Eficode UK
To enter into a contract with you for an employment position with Eficode UK
To keep our records up to date
To fulfil our legal obligations and to maintain compliance with best practice

The lawful bases we rely on for processing this information are:

(a) Your consent; and/or

(b) we have a legal obligation; and/or

How long we keep your information

We will keep your personal information only for as long as necessary in line with regulatory and legal requirements and will destroy it securely when it is no longer needed. Eficode UK retains unsuccessful applicants’ data for a period of 6 months.

How we protect your information

How we store your information

We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. Access to your data is restricted to only those that require access to fulfil the lawful purpose such as our Recruitment Team, Human Resource team and Legal team as necessary.

Where we process your information

How we share your information

Eficode UK will never sell your information. From time to time we may send information to, receive information from, or exchange your personal information with:

Companies who perform essential services for us, such as background checks
Affiliates in the Eficode UK OY group of companies
Regulators, courts, or other public authorities
The emergency services in the case of accident or emergency
In connection with or during negotiation of any merger, financing, acquisition, or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company