1. Identity and Contact Details

Code Flick Ltd
Registered Address: Office 8368 321-323 High Road, Chadwell Heath, Essex, United Kingdom, RM6 6AX
Company registration number: 16645019
Director: Androsov Dmytro
Email: admin@codeflick.eu
Website: https://codeflick.eu/

We are the data controller for any personal data you provide or that we collect from you.

2. Types of Data We Collect

We may collect personal data directly from you, automatically through your use of the Website, and, in limited circumstances, from third-party sources that support our business operations. The categories of personal data we may process depend on the nature of your interaction with us.

When you contact us, request a consultation, send a message, inquire about pricing, discuss a potential business relationship, or otherwise communicate with us, we may collect identification and contact data such as your full name, business email address, telephone number, company name, job title, country or region, and any other information you choose to provide. Where relevant to a business inquiry, we may also process information relating to your organisation, your area of interest, your proposed use case, operational requirements, software or technical environment, or your interest in telecommunications solutions, interactive software, analytics, digital tools, or related information technology services.

When you use the Website, we may automatically collect technical and usage data. This may include your IP address, approximate location derived from technical routing data, browser type and version, operating system, device type, unique device or session identifiers, language settings, pages viewed, dates and times of access, referring URLs, navigation patterns, clicks, page interaction events, log data, diagnostic information, and performance data. We may also collect information through cookies and similar technologies. Additional information about such technologies is provided in our Cookie Policy.

If, in the future, the Website or our services include demonstrations, embedded resources, downloadable materials, newsletters, business development communications, support interactions, or account-related features, we may process the corresponding data associated with those functions, including communication records, support history, access records, preferences, and records of consent or objection. Where a specific relationship involves payment, invoicing, or contract administration, we may also process transaction-related and billing data to the extent necessary for financial administration, fraud prevention, recordkeeping, and legal compliance.

Personal data may also be obtained from several sources. A significant part of the information we process is provided directly by you when you complete a form, send an email, request information, or otherwise communicate with us. We also receive technical data automatically through your browser, device, and interactions with the Website. In limited cases, we may receive personal data from business partners, service providers, publicly available professional sources, referral sources, or corporate representatives acting on behalf of an organisation. Where data is not collected directly from you, we will handle that information in accordance with applicable transparency requirements.

We do not intentionally seek to collect more personal data than is reasonably necessary for the relevant purpose. You should avoid submitting sensitive or excessive information unless it is specifically and lawfully requested.

3. How We Use Your Data

We process personal data for lawful, specific, and proportionate business purposes connected with the operation of the Website and the provision, development, support, and promotion of our services.

In particular, we may use personal data to respond to inquiries, provide requested information, assess interest in our services, communicate with prospective or existing business contacts, arrange consultations, deliver materials relating to our products or capabilities, and manage contractual or pre-contractual communications. We may process data in order to operate, maintain, administer, secure, monitor, and improve the Website and related systems. This includes ensuring technical functionality, preventing misuse, detecting suspicious activity, troubleshooting, evaluating performance, improving content structure, and ensuring an appropriate user experience across devices and browsers.

We may also process personal data in connection with the development, presentation, and support of our activities in telecommunications, ready-made interactive software for recreation and entertainment, information technology services, analytics, digital information solutions, and related business communications. This may include understanding how users engage with informational content, service descriptions, demonstration materials, contact channels, and other business resources so that we can improve the Website, enhance the presentation of our services, and better organise our internal operational processes.

Where appropriate, we may also use personal data for internal administration, audit support, compliance with legal and regulatory obligations, the establishment or defence of legal claims, financial management, invoicing, tax and accounting obligations, supplier management, and business continuity planning. Where permitted by law, we may also use contact data to send business updates, service information, or marketing communications, subject to applicable consent requirements or other lawful conditions. Individuals may opt out of marketing communications at any time.

As a general rule, we do not use personal data to make decisions based solely on automated processing where such decisions produce legal effects concerning an individual or similarly significant effects. Should this practice be introduced in relation to a specific service or function, we will provide additional information to the extent required by law.

Our Website and business communications are generally intended for adults acting in a professional or business capacity. We do not target children and do not intentionally collect personal data from children through the Website. If we become aware that personal data relating to a child has been provided to us without appropriate authority or lawful basis, we will take such steps as we consider appropriate to address the situation.

4. Legal Basis for Data Processing

We process personal data only where we have a valid legal basis under applicable data protection law. Depending on the circumstances, one or more of the following legal bases may apply.

• Consent: We may process data on the basis of consent where you have freely given a specific, informed, and unambiguous indication that we may process your data for a particular purpose. This may apply, for example, to certain marketing communications, optional cookies, or other optional interactions where consent is the appropriate standard.
• Contract: We may process data where such processing is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract. This may apply when you request a consultation, seek information about our service offering in a way that may lead to a commercial relationship, receive support, or communicate with us regarding implementation, procurement, or service delivery.
• Legal Obligation: We may process data where necessary for compliance with a legal obligation to which we are subject. This may include obligations relating to company law, taxation, financial recordkeeping, fraud prevention, lawful disclosure, and other statutory or regulatory requirements.
• Legitimate Interests: We may also process data where necessary for the purposes of our legitimate interests or those of a third party, provided that such interests are not overridden by your interests, rights, or freedoms. Depending on the context, legitimate interests may include operating and securing the Website, responding to business communications, preventing misuse, improving our services and digital materials, maintaining records, managing ordinary business operations, understanding interest in our services, and carrying out proportionate B2B communications in a lawful manner. Where we rely on legitimate interests, we seek to consider necessity, proportionality, and the potential impact on individuals.

5. How We Protect Your Data

We implement reasonable technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or unauthorised access. Such measures may include access controls, role-based restrictions, secure communication protocols, logging, monitoring, supplier oversight, authentication mechanisms, backup procedures, contractual safeguards, staff awareness measures, and internal governance practices appropriate to the nature of our activities and the risks associated with the processing.

Data retention periods depend on the nature of your interaction with us. We seek to retain personal data for no longer than is reasonably necessary for the purposes for which it was collected, including compliance with legal, regulatory, tax, accounting, contractual, and security requirements, as well as dispute resolution needs. For example, inquiry data may be retained for the period necessary to process the inquiry, continue business communications, and maintain proper records. Contractual, transaction, and billing records may be retained for longer periods where necessary for financial reporting, tax compliance, audit purposes, or legal defence. Technical logs, analytics records, and security-related data may be retained for periods determined by operational necessity, system integrity, service provider settings, or incident response requirements. When retention is no longer necessary, we may delete, anonymise, aggregate, or otherwise securely dispose of the relevant data, subject to legal and technical constraints.

Despite the measures we apply, no method of transmission over the internet and no electronic storage environment can be guaranteed to be completely secure in all circumstances. Accordingly, although we seek to protect personal data through proportionate safeguards, we cannot guarantee absolute security.

6. Your Rights

Subject to applicable law, you may have the right to be informed about how your personal data is used, the right to request access to the personal data we hold about you, the right to request correction of inaccurate or incomplete data, the right to request deletion of personal data in certain circumstances, the right to request restriction of processing, the right to object to certain types of processing, the right to data portability where applicable, and the right to withdraw consent where processing is based on consent. The scope and availability of these rights may depend on the legal basis relied upon and the particular circumstances of the processing.

If you wish to exercise your rights, please contact us using the details set out below. Before responding to your request, we may ask for information necessary to verify your identity and clarify the scope of your request. You also have the right to lodge a complaint with a competent supervisory authority if you believe that your personal data has been processed unlawfully or in a manner inconsistent with applicable requirements.

7. Sharing Your Data

We do not sell personal data. We may disclose personal data only where there is an appropriate basis for doing so and where such disclosure is consistent with this Privacy Policy, applicable law, and the nature of the relevant business activity.

We may share personal data with service providers and processors that assist us with Website hosting, infrastructure, communications, analytics, security, anti-spam protection, document management, administration, accounting support, payment processing, customer relationship management, or other operational functions. Such providers are expected to process personal data only on documented instructions where required and subject to appropriate contractual, confidentiality, and security obligations.

We may also disclose personal data to professional advisers, auditors, insurers, banks, payment institutions, legal advisers, regulators, courts, law enforcement authorities, or other bodies where disclosure is required or reasonably necessary for compliance, risk management, dispute resolution, fraud prevention, or the establishment, exercise, or defence of legal claims. If our business, assets, or operations are restructured, financed, transferred, or become the subject of a merger, acquisition, reorganisation, or similar transaction, personal data may be disclosed to the relevant parties subject to appropriate confidentiality obligations and legal safeguards.

Where the Website uses tools or embedded services provided by third parties, those parties may also receive limited technical or usage data depending on the architecture of the relevant service and your settings. To the extent such parties process data independently, their own privacy documentation may apply.

8. International Data Transfers

Where our use of service providers, hosting arrangements, cloud systems, communication tools, analytics solutions, or other business technologies involves access to or processing of personal data outside the United Kingdom, we seek to ensure that appropriate safeguards are applied in accordance with applicable law. Depending on the circumstances of the transfer, such safeguards may include an adequacy decision, standard contractual clauses, the UK International Data Transfer Agreement or an applicable addendum, contractual control measures, transfer risk assessments, or other recognised legal mechanisms. International processing may also occur where service providers use infrastructure or support teams located in multiple jurisdictions.

9. Updates to This Privacy Policy

We may amend, revise, supplement, or otherwise update this Privacy Policy from time to time in order to reflect changes in law, regulatory guidance, business operations, service configuration, technical architecture, security practices, or internal compliance requirements. Any updated version will be published on the Website together with the revised effective date or last updated date, as appropriate. We encourage users to review this Privacy Policy periodically in order to remain informed about our current practices.