Privacy Policy

Introduction

Welcome to Codico Distributor’s privacy notice.

This Privacy Policy describes how Codico Distributors (“we”, “us”, or “our”) collects, uses, and shares personal information when you visit our website (www.codico-distributors.com) (the “Website”). It also explains your rights regarding your personal information under the General Data Protection Regulation.

Important Information and Who We Are

Purpose of This Privacy Notice

We respect your privacy and we are committed to ensuring your personal data is protected. This privacy policy informs you how we ensure your personal data is secure when you visit our website, or when you communicate with us digitally, this includes; email, live chat, social media or in person by telephone, or in face-to-face meetings, and tells you about your privacy rights and how the law protects you.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and is not intended to override them.

Controller

Codico Distributors is the controller and is responsible for your personal data (collectively referred to as “Codico”, “we”, “us” or “our” in this privacy notice).

We have appointed a Data Protection Officer (DPO) who is responsible for this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact Details

Full Name of Legal Entity: Codico Distributors Ltd

Data Protection Officer: Daryl Daniels

Email Address: daryl.daniels@codico-distributors.com

Telephone Number: 051 379 933

Postal Address: Cleaboy Business Park, Old Kilmeaden Road, Waterford, Ireland, X91 K661

You have the right to make a complaint to the Data Commissioners Office (DPC), the ROI supervisory authority for data protection issues at any time. We would, however, appreciate the opportunity to deal with your concerns before you approach the DPC.

Changes to the Privacy Policy and Your Duty to Inform Us of Changes

This version was last updated on 20/06/23

It is important that the personal data we hold about you is accurate and current. Please keep us informed of your personal data changes during your relationship with us.

Third-Party Links

This website may include links to third-party websites, plugins and applications. Clicking on these links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites or platforms and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website or platform you visit.

The Data We Collect About You

Personal data or personal information is any piece of data that can be used to identify an individual. It does not include data where the identity has been removed (anonymous data)

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together;

Identity Data: first name, last name, username or similar identifier, title, date of birth and gender

Contact data: billing address, delivery address, email address and telephone numbers

Financial data: bank account and payment card details

Transaction data: details about payments to and from you and other details or products and services you have purchased from us. We will also log calls, emails and updates on sales processes

Technical data: internet protocol (IP) address, browser type and version, device information, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Profile data: Purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage data: information about how you use our website,  products and services

Marketing and Communications Data: Preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregate Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific web page or feature on our website. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If Your Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How is Your Personal Data Collected?

We use different methods to collect data from and about you including;

Direct interactions: You may give us your Identity, Contract and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Purchase our products or services
• Submit an online form
• Engage with us on social media platforms
• Interact with us through live chat
• Subscribe to our service or publications
• Request marketing to be sent to you
• Engage with our sales team through phone or email
• Enter a competition, promotion or survey
• Provide us with feedback
• Through a third-party partner

Automated Technologies or Interactions; As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Third-Parties or Publicly Available Sources; We may receive personal data about you from various third parties and public sources as set out below;

Technical Data from the following parties;

Analytics providers such as Google based outside the EU

Advertising Networks or social media platforms; and

Search information providers

Contact, financial and transaction data from providers of technical, payment and delivery services.

Identity and contact data from data brokers or aggregators

Identity and contact data from publicly available sources

Identity and contact data from third-party marketing activities, such as delegate lists provided by tradeshow/event organisers

IP Tracking

Introduction

 At Codico Distributors, we are committed to protecting the privacy of our website visitors and customers. As part of this commitment, we use Lead Forensics to identify business visitors to our website and improve our services and business activities. The below information explains how we collect, process, and protect personal data in compliance with the EU General Data Protection Regulation (GDPR).

What is Lead Forensics? Lead Forensics is a lead generation and analytics software that identifies businesses visiting our website, collects their IP address, and provides us with information such as company name, contact information, and the pages visited on our website. Lead Forensics does not identify individuals or collect any personal data beyond what is necessary to provide its service.

What personal data is collected? Lead Forensics collects the IP address of website visitors, which can sometimes be used to identify the business which the visitor works for. Lead Forensics does not process identifiable information, and only shares information such as business name, business contact number, business email address, address and pages visited. Lead Forensics’ sub-processors (Cognism and Rocket Reach) provide contact data (data such as name, contact number, email address and LinkedIn), if available, regarding employees in a business that has visited our website.

 

Sub-Processors are Listed and Explained below;

Cognism sources data through proprietary sources, such as Cognism Signatures, and fills in gaps from third-party data providers, publicly available sources, manual research and strategic partnerships. Data from Cognism is stored for 30 days upon the confirmed termination of the contract and 2 years in Lead Forensics’ backup.

Rocket Reach sources data from publicly available sources, professional profiles and third-party partnerships. Rocket Reach’s algorithm may then make assumptions based on publicly available information, such as basing company emails on common formats. Data from Rocket Reach is stored for 30 days upon the confirmed termination of the contract and 2 years in LeadForensic’s backup

IOMART which is a data storage/backup facility

Amazon AWM which is a data storage/backup facility

Why do we use Lead Forensics? We use Lead Forensics to identify businesses visiting our website and improve our business activities with our sales team. This helps us to better understand the needs of our customers and website visitors and provide more relevant content and services, and assistance to visitors. This system also enables our sales team to operate efficiently and engage with potential and existing customers who may have a specific need or query relating to our business activities.

Legal basis for processing personal data: Our legal basis for processing personal data collected by Lead Forensics is our legitimate interest in improving our sales efforts, services and understanding the needs of our customers and website visitors. We have assessed that our legitimate interest is not overridden by the rights and freedoms of the individuals whose personal data is processed.

How is personal data protected? We take the protection of personal data seriously and have implemented appropriate technical and organizational measures to ensure security. This data will be stored on password-protected systems, where only authorised individuals can access it. We have a Data Protection Officer who oversees our data protection policies and practices. Lead Forensics and its sub-processors are also committed to protecting personal data and they comply with GDPR and other data protection laws. Data is stored in secure, password-protected systems and only those authorised to access such data can.

How long is data stored? We do not store data collected by Lead Forensics for longer than necessary to achieve the purposes for which it was collected. We retain Lead Forensics data for up to 1 year, after this period, if it is decided that this information is no longer required, it will be deleted. Data is stored by Codico on password-protected systems such as SAP and SmartSheets, which can only be accessed through specific permissions and a valid password.

Lead Forensics and its sub-processors Cognism and Rocket Reach store data for 30 days upon the confirmed termination of the contract and is retained in a backup facility for 2 years. While IOMART and Amazon AWS store data for 2 years.

Rights of data subjects: Individuals whose personal data is processed by Lead Forensics and its sub-processors have the right to access, rectify, erase, and restrict the processing of their personal data. They also have the right to object to the processing of their personal data on legitimate grounds. To exercise these rights, individuals can contact our Data Protection Officer at daryl.daniels@codico-distributors.com.

Updates to this policy: We may update this policy from time to time to reflect changes in our use of Lead Forensics or changes in data protection laws. We will notify website visitors of any material changes to this policy.

 

As part of our Lead Forensics agreement, we have access to additional tools such as Cognism and Rocket Reach (Lead Forensics Sub-Processors), which allow Codico to access the name, email address, LinkedIn page and contact number of employees within an organisation. Please note that all data collected through Lead Forensics, including any data obtained through Cognism and Rocket Reach, is subject to the same strict data protection policies outlined in this GDPR policy. We will only use this data for the specific purposes outlined in this policy, and we will never share or sell this data to any third parties.

 

How we use Your Personal Data

We will only use your personal data when the law allows us to. Codico does not sell or rent your data to third-party organisations. Most commonly, we will use your personal data in the following circumstances:

• Where we have your explicit consent to do so, e.g. when you give us permission to send you marketing information. This may include invitations to participate in, and the supply of the output from, market research and analysis about our brand, and/or the products, services and offers from Codico. This may sometimes be conducted with help from a carefully selected third party carrying out a study on our behalf, both while you are a customer and for a reasonable time afterwards, to improve, optimise and personalise the experiences for those with whom we engage in our business activities.
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a Third Party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation

We rely on consent as a legal basis for processing your personal data in relation to sending direct marketing communications to you via email, post, or text message.

You have the right to withdraw consent to marketing at any time by emailing our DPO.

At certain times we may rely on Legitimate Interest as a legal basis to process data, however, this will not infringe on your rights as a data subject.

Purposes for Which We Might use your Personal Data

We have set out below, in a table format, a description of all the ways we might plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Personal Data

Purpose/Activity	Type of Data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer at your explicit request	Identity Contact	Performance of a contract with you
To identify you as a potential customer	Identity Contact	Legitimate Interest
To process and deliver your order including: (a)   Manage payments, fees and charges (b)   (b) Collect and recover money owed to us	Identity Contact Financial Transaction	Performance of a contract with you Necessary for our Legitimate Interests (to recover debts due to us)
To manage our relationship with you which will include: (a)   Notifying you about changes to our terms or privacy policy (b)   Asking you to leave a review or take a survey on the website (c)   To engage with you regarding warranty information, invitations to events, etc	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our Legitimate Interests (to keep our records updated and to story how our customers use our products/services and perceive our brand), while also ensuring customers are aware of warranty info, invitations, etc.
To enable you to take part in a prize draw, competition or complete a survey	Identity Contact Profiler Usage Marketing and Communications	As only customers will be sent survey information, etc it is in our legitimate interest to improve our service and product offering   It is also necessary to keep our records updated and to understand how our customers perceive our brand
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	(a)   Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)   (b)   Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	(a)   Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) (b)   For direct advertisements and marketing, we will obtain your explicit consent
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical Usage	(a)   Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) (b)   For direct advertisements and marketing we will obtain your consent
To make suggestions and recommendations to you about goods or services that you may be interested in	Identity Contact Technical Usage Profile	(a)   Necessary for our legitimate interest (to develop our products/services and grow our business) (b)   For direct advertisements and marketing, we will obtain your explicit consent

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. To alter your preferences, please contact our DPO.

Promotional Offers from Codico

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant to you.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing. You can change your marketing preferences by contacting our DPO.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any company, for marketing purposes, except those within Codico, contractors, subcontractors and consultants.

Change of Purpose

We will only use your personal data for the purposes for which we collected it.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules where this is required or permitted by law.

Disclosures of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above.

Internal Parties, such as subsidiary companies; Codico Distributors NI

External Third Parties, such as;

Insourced service providers e.g. market and competitive research and insight companies, marketing service providers

Authorised suppliers, e.g. providers who host or maintain data centres, service platforms, cloud-based solutions and other infrastructure and systems on our behalf that collect, process, transfer, host, or store your personal information

Cyber consultants: where necessary to report a cyber or privacy breach incident or for cyber security purposes, including to prevent unauthorised access to, or attacks on our systems.

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

International Transfers

If/when required we may share your data with a third party based in a different country. Our third-party suppliers are based in the EEA and comply with all required data security and GDPR requirements.

Data Security

We have ensured that the appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties. In the event of us sharing your personal data with a third party, we will also share your marketing preferences and third parties are subject to confidentiality and GDPR compliance.

We have put in place procedures to deal with any suspected personal data breach and will inform you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

How Long Will we use Your Personal Data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying and legal accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request Erasure below for more information or contact us.

In some cases, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

• Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the:

• Right to access your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide us,
• Request the erasure of your personal data. This enables you to request to have your data deleted or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Noe, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds where we are processing your personal data which overrides your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to request that we suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide you or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No Fee Usually Required

You may incur a small fee to access your personal data (or to exercise any other rights). If your request is clearly unfounded, repetitive or excessive, we may refuse to comply with your request.

What We May Need from You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We aim to respond to all legitimate requests within 30 days, occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

Authorised or Approved means companies, contractors, subcontractors and consultants who have permission from Codico to carry on one or more activities. We require all third parties to respect the security of your personal data to treat it in accordance with the law. We may pass on your marketing preferences to any third parties with whom we share your personal data.

Lawful Basis means the legal justification for processing your personal data.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience, while ensuring business goals are achieved. We make sure to consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.

Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Internal Third Parties

Codico Distributors NI

External Third Parties

Insourced service providers e.g. market and competitive research and insight companies, marketing service providers

Business partners, such as Domino Printing Group, ACI Laser Marking, Intrex Labelling

IP Tracking partners to identify companies that have visited our website, these partners may utilise sub-processors who may present the personal data of employees of a business that visited our website.

Website and Social Media Tracking, we use google analytics, cooking tracking and meta tracking to track various metrics and statistics from our website.

Please refer to this page for any changes that will be made to this policy in the future, where appropriate we will notify you by email.