Privacy Policy

RADIACODE LTD (“we”, “us”, “our”) value your privacy and are committed to transparency in how we handle your personal data. This Privacy Policy lets you know how and for what purposes we are processing your information. We pledge that we will take reasonable steps to ensure that your personal data will only be used in ways that comply with this Privacy Policy and applicable regulations.

This Privacy Policy governs the processing of personal data in your interactions with us, including when you: (1) visit (use) our website located at: https://www.radiacode.com/ (the “Website”), (2) communicate with us and as otherwise described in this Privacy Policy.

Before you share any personal data with us, please review this Privacy Policy and our Terms and Conditions (the “Terms”).

When you choose to use our Radiacode App or RadiaVerse interactive radiation portal including the Interactive map, please, see the Privacy Policy for the Radiacode App and Interactive map for describes how your personal information is collected and used.

1. Who we are?

RADIACODE LTD, duly incorporated in and registered under the laws of the Republic of Cyprus, with a registered office at 10 Spyrou Kyprianou, Germasogeia, 4040 Limassol, Cyprus acts as a data controller. It means we determine the purposes and means of the processing of personal data.

We have appointed a Data Protection Officer to ensure compliance with the applicable data protection laws and oversee our state of compliance, also, to ensure your data protection related questions are answered.

Since we are registered under the law of the Republic of Cyprus, the personal data authority overseeing us regarding the personal data processing is Commissioner for Personal Data Protection. You always have the right to make a data protection related complaint at any time to a supervisory authority. You may also contact your local data protection authority. A list of local data protection authorities is available here.

If you would like to exercise your data protection related rights you can submit your request to our e-mail: [email protected].

2. How do we collect personal data?

We process personal data in the following ways:

• when you provide us with personal data. You provide us with your personal data in order to realize the purposes of the processing. For example, in order to create an account on the Website, and carry out marketing or informational mailings, we need the personal data we receive from you;
• when personal data is collected automatically. There are tools that allow us to collect technical personal data about you when you use Website. For certain purposes (e.g. to enable you to technically use the Website, to track and fix bugs on the Website), we automatically collect your personal data where there is a legal basis to do so.

3. How do we process personal data?

We process your personal data only when it is necessary to achieve the purpose of the personal data processing and only to the extent necessary to achieve the purpose of the processing. Furthermore, we keep your personal data for a limited period of time and once the processing period has expired, we delete all existing copies of your personal data.

Below we have provided you with a full description of the data processing purposes of the users (visitors) of the Website, what personal data we process, legal basis of data processing and information about the retention period.

Please note that we don’t process or have access to your personal data related to making payments (bank card details, payment card expiration date, the security code, others). Your personal data related to making a payment is processed by the third-party payment providers we engage to process and make your payment.

4. How long do we keep your personal data?

We keep your personal data for as long as necessary to fulfill the purpose of the processing. Specific timeframes are specified in Section 3.

Under certain circumstances, we may be required to retain your personal data for a longer period of time in accordance with applicable law or regulatory requirements. This may include but is not limited to, situations involving legal proceedings, investigations, or government inquiries. We will only retain your personal data for as long as necessary to comply with these legal obligations, and we will take appropriate measures to ensure its security and confidentiality during this period.

5. Sharing your data with third parties

Your privacy is of utmost importance to us, and we handle your personal data with the highest level of care and responsibility. While we endeavor to minimize the sharing of your personal data, there are certain circumstances where it becomes necessary to disclose it to third parties.

We share your personal data in such cases:

• to comply with applicable law.
  We are committed to complying with all applicable laws, regulations, and legal obligations. In certain situations, we may be required to disclose your personal data to comply with legal requirements, such as to respond to subpoenas, court orders, or other lawful government requests. We may also share your personal data if we believe in good faith that such disclosure is necessary to protect our rights, enforce our Terms, investigate fraud, or protect the safety of you.
• to accomplish the purposes set forth above.
  In an effort to provide an exceptional experience, we work closely with a select group of trusted partners and service providers. These partners play an important role in supporting various aspects of our business, thereby enhancing the quality of the Website. When selecting the partners with whom we share your personal data, we take a cautious approach, ensuring that we only work with companies that take strict measures to protect personal data from unauthorized access, disclosure, or misuse.

Although we carefully screen our partners, it is important to recognize that we cannot guarantee absolute compliance with data protection legislation in all cases. We encourage you to review the privacy policies of these third parties to gain an understanding of their practices in processing your personal data.

a. Hosting providers

We take responsibility for the storage of your personal data and store it only with trusted hosting providers. We use the following third parties services to store your personal data obtained through the Website:

• Microsoft Azure (Microsoft, USA).
  You may read Microsoft’s Privacy Policy here.
• Amazon Web Services (Amazon Web Services, Inc., USA).
  You may read AWS Privacy Policy here.

b. Third parties that provide us payment services

When making payments on the Website, you may be required to provide payment data. When you make payments using third-party services, such processing is subject to the privacy policy of third-party payment systems. We may share and disclose your personal data to the following data processors:

• PayPal (PayPal Inc., USA)
  You may read its Privacy Policy here.
• Stripe (Stripe, Inc., Ireland)
  You may read its Privacy Policy here.

c. Third parties that provide support services for communicate with you and provides services when you place an order on the Website

We try to make using our Website, and in particular communicating with us and placing an order, in the most convenient way for you. We therefore implement mechanisms on our Website to help us send you questions and suggestions, conveniently place orders, make payments and track your orders. We may transfer and disclose your personal data to the following data processors:

• Help Scout (Help Scout PB, USA)
  You may read its Privacy Policy here.
• TYPEFORM, S.L. (Spain)
  You may red its Privacy Policy here.
• Lightspeed Commerce Inc. (USA), Lightspeed Netherlands B.V. (Netherlands)
  You may red its Privacy Policy here.

We transfer your personal data to third parties within requirements under the GDPR. Where possible, we always enter into Data Processing Agreements with them and treat personal data transfer seriously. Where our partner has an appropriate data processing agreement in place, we may adjoin such a data processing agreement. If so, our relationship may regulate the transfer of the personal data to such partner by means of following data processing agreements:

• Amazon Web Services – https://d1.awsstatic.com/legal/aws-gdpr/AWS_GDPR_DPA.pdf;
• Microsoft – https://www.microsoft.com/licensing/docs/view/microsoft-products-and-services-data-protection-addendum-dpa;
• Stripe – https://stripe.com/en-de/legal/dpa;
• PayPal – https://www.paypal.com/us/legalhub/data-protection;
• Help Scout – https://www.helpscout.com/company/legal/dpa/.

6. How we process Cookies?

As a data subject, you have certain rights regarding your personal information. We are committed to uphIn order to enhance the functionality of the Website and make it more user-friendly, we may use cookies. A cookie is a piece of data that can be stored on the browser of your computer or mobile device you use to access the Website. It enables the Website to “remember” your activity or preferences for a certain period of time or during a specific session. The information does not always may identify you, but it can give you a more personalized web experience.olding these rights and ensuring that you can exercise them effectively.

We use the following types of cookies:

a. Necessary. Cookies categorized as “necessary” are essential for the proper functioning of the Website and for you to effectively use the features and services it provides. These cookies are crucial in enabling key functionalities such as security, network management, cookie preferences, and accessibility.

b. Performance. Performance cookies are used to see how you use our Website, eg. analytics cookies. These cookies are necessary for statistical purposes and work toward improving Website performance to create a more user-friendly environment for you.

Performance cookies are set by third parties such as Google Analytics, Yandex.Metrica, Microsoft Clarity.

c. Targeting cookies. Targeting cookies are used to deliver tailored ads to Website users based on their browsing habits and interests. They are specifically designed to gather information from you on your device to display advertisements to you based on relevant topics that interest you.

Targeting cookies are set by third parties such as Meta, Google AdSense, Dstillery, Microsoft Advertising.

d. Functional. Functional cookies allow you to navigate our Website and make full use of its features. Functional cookies process technical personal data and personal usage data.

If you do consent to the use of non-essential trackers, you can customize and withdraw your consent at any time (except concerning strictly necessary cookies) via your browser settings.

Below we have described how you can control your cookie settings:

a. Remove cookies from your device

In order to delete all cookies from your device, you need to follow these steps:

• go to the browser settings on the device;
• clear history, including advanced settings.

Please note that clearing your history in this way will result in the loss of your preferences on other sites, including your saved login preferences and passwords, as well as other personalized website settings.

b. Customize cookies settings on our Website

You can configure your cookie processing preferences in the pop-up cookie banner when opening the Website or in your browser settings.

c. Block cookies

Almost all browsers allow users to block the processing of cookies on all websites. However, a complete block will block, among other things, the processing of necessary cookies, which may lead to incorrect operation of the Website and other websites.

• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari (Desktop)
• Safari (Mobile)
• Opera
• Opera Mobile

7. Rights under GDPR

As a data subject, you have certain rights regarding your personal information. We are committed to upholding these rights and ensuring that you can exercise them effectively.

Below, you can find the information regarding your rights as a data subject under EU legislation:

Right of access

This right allows you to request access to the personal data we hold about you.

To exercise this right, please contact us at the e-mail indicated above. Upon receiving your request, we will provide you with a copy of the personal data we process in the form in which you have requested the provision of this information. Please note that in some cases we may charge you a reasonable fee for providing this information. If we are unable to fulfill your request for any reason, we will provide you with an explanation and inform you of your rights to appeal the decision.

Right to rectification

This right enables you to request the correction or updating of any inaccurate or incomplete personal data we hold about you.

You can exercise this right in two ways:

1. by yourself by following these steps:

• log in to your account on the Website
• open a personal profile on the Website
• locate personal data you wish to correct and edit it
• save the changes to update your data instantly

2. by contacting us at e-mail indicated above.

Upon receiving your request for rectification, we will review the accuracy and completeness of your personal data and make any necessary corrections or updates.

Right to erasure

This right allows you to request the deletion or destruction of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected or processed (or, as we all know, the “right to be forgotten”).

You can exercise this right by contacting us at e-mail indicated above.

Upon receiving your request for erasure, we will assess whether the conditions for erasure are met and, if so, promptly delete or anonymize your personal data from our systems and notify any third parties to whom the data have been disclosed.

Also, we may delete, block or anonymize the personal data that is linked to your account in the Products in accordance with clauses 11.2 of the Terms and Conditions.

Right to restrict processing

This right allows you to request the restriction of processing of your personal data in certain circumstances, such as when the processing is unlawful, when we no longer need the personal data, or when you have objected to the processing.

To exercise this right, please contact us at the e-mail indicated above. Upon receiving your restriction to processing will not process your personal data (except for storage) unless it is based on consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest.

Right to data portability

This right allows you to receive a copy of your personal data in a structured, commonly used, and machine-readable format if it is technically possible to do so and to transmit those data to another controller.

To exercise this right, please contact us at the e-mail indicated above. Upon receiving your request for data portability, we will provide you with a copy of your personal data in the requested format, where technically feasible.

Right to object

This right enables you to object to the processing of your personal data in certain circumstances, such as where the processing is based on legitimate interests or for direct marketing purposes.

To exercise this right, please contact us at the e-mail indicated above. Upon receiving your objection to processing, we will assess the validity of your objection and, if valid, cease processing your personal data for the purposes to which you have objected.

Right to withdraw consent

You have the right to withdraw your consent to the processing of your personal data at any time. This means that if we are processing your personal data based on your consent, you have the right to revoke that consent.

To exercise this right, please contact us at the e-mail indicated above. Upon receiving your request to withdraw consent if we do not have any other legal basis for processing your personal data, we will stop processing it.

Right to lodge a complaint

If you believe that our processing of your personal data violates applicable legislation, you have the right to lodge a complaint with a supervisory authority.

Please note that these rights are subject to certain limitations and exceptions as provided by law. To exercise any of these rights or for further inquiries, please contact us using the provided contact information.

We will review your request as soon as possible, but not more than within one (1) month. Please keep in mind that this period may be extended for an additional two (2) months, if necessary, based on the complexity and number of your requests. In that case, we will tell you about the extension within one (1) month of receipt of your request and explain the reasons for the delay.

8. Your US State privacy rights

If you are a California resident, you have certain rights under the California Consumer Privacy Act (the “CCPA”) amended with the California Privacy Rights Act (the “CPRA”) and other applicable laws regarding the collection, use, disclosure, and sale of your personal data. This section of our Privacy Policy outlines those rights and explains how you can exercise them:

Right to know

California residents have the right to request that we disclose the categories and specific pieces of personal data that we have collected about them, the categories of sources from which the personal data was collected, the purposes for which the personal data was collected, and the categories of third parties with whom we have shared the personal data.

To exercise this right, please contact us at the e-mail indicated above. Upon receiving and verifying your request, we will promptly provide you with the requested information for the 12-month period preceding your request free of charge in a readily usable format, unless an exception applies.

Right to delete

California residents have the right to request the deletion of their personal data that we have collected, subject to certain exceptions as permitted by law.

You can exercise this right by contacting us at e-mail indicated above.

Upon receiving and verifying your request, we will delete your personal data from our records and direct our partners to do the same, unless an exception applies.

Also, we may delete, block or anonymize the personal data that is linked to your account in the Products in accordance with clauses 11.2 of the Terms and Conditions.

Right to opt-out

California residents have the right to opt-out of the sale of their personal data. Sale is defined broadly in the CCPA to include “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating” the personal data of California residents.

Please, note, that we do not sell personal data to third parties. As we do not sell personal data, you do not need to take any action to exercise this right.

Right to non-discrimination

California residents have the right to non-discrimination under which we cannot refuse to provide goods or Services, charge you a different price, or provide goods or Services of a different level or quality just because you exercised your rights under the CCPA.

We will not deny websites, charge different prices, or provide a different level or quality of websites based on their exercise of CCPA rights.

Right to correct

California residents have the right to ask us to correct inaccurate personal data that we have about them.

You can exercise this right in two ways:

1. by yourself by following these steps:

• log in to your account on the Website
• open a personal profile on the Website
• locate personal data you wish to correct and edit it
• save the changes to update your data instantly

2. by contacting us at e-mail indicated above.

Upon receiving and verifying your request, we will promptly review your personal data and make corrections as appropriate, ensuring that it is accurate and complete.

Right to limit

California residents have the right to direct us to only use your sensitive personal data for limited purposes, such as providing you with the services you requested.

We do not process such sensitive personal data.

Right of access

This right allows you to request access to the personal data we hold about you.

To exercise this right, please contact us at the e-mail indicated above. Upon receiving your request, we will provide you with a copy of the personal data we process in the form in which you have requested the provision of this information. Please note that in some cases we may charge you a reasonable fee for providing this information. If we are unable to fulfill your request for any reason, we will provide you with an explanation and inform you of your rights to appeal the decision.

Right to data portability

This right allows you to receive a copy of your personal data in a structured, commonly used, and machine-readable format if it is technically possible to do so and to transmit those data to another controller.

To exercise this right, please contact us at the e-mail indicated above. Upon receiving your request for data portability, we will provide you with a copy of your personal data in the requested format, where technically feasible.

Please note that these rights are subject to certain limitations and exceptions as provided by law. For the rights to deletion and correction, we have specific procedures in place to ensure their effective realization. We encourage you to first utilize the account functions available to you to modify your data or delete your account for data removal. If you encounter any difficulties or if these options are not available, please contact us directly, and we will assist you in fulfilling your request. To exercise any rights or for further inquiries, please contact us using the provided contact information.

We will respond to your request within 45 calendar days or extend that deadline by another 45 days (90 days total).

9. Children's privacy

We do not knowingly collect or solicit your personal data to anyone under the age of 13 (in USA) or 16 (in European Economic Area) or knowingly allow such persons to use our Website. If you are under the age of 13 (or 16, where applicable), please do not provide any personal data to us. If we learn that we have collected personal data about a child under the age of 13 (or 16, where applicable), we will delete that personal data as soon as possible. If you believe that we might have any personal data from or about a child under the age of 13 (or 16, where applicable), please contact us at the e-mail indicated above.

10. Changes to the privacy policy

This Privacy Policy may be changed from time to time due to the implementation of new technologies, laws’ requirements or for other purposes. Your continued use of the Website after the effective date of the updated Privacy Policy will be subject to the new Privacy Policy. If we make any major changes to our Privacy Policy and will need your explicit consent for further processing of your personal data, we will request your consent or your renewed consent (in case it was obtained previously).