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(GDPR compliant)

Codal Inc. Privacy Policy

Last modified: January 1, 2021

This privacy policy (“Privacy Policy”) covers our treatment of personally identifiable information (“Personal Information”) that we gather when you are accessing or using our websites and service (“Services”) offered at codal.com (“Codal”, “we”, “us” or “our”) but not to the practices of companies we don’t own or control, or people that we don’t manage.

The EU General Data Protection Regulation (“GDPR”) and the UK GDPR are included in our Privacy Policy and the specific section applies to our processing of personal information of European, United Kingdom, and Swiss consumers.

What information do we collect and for what purpose? 

The following chart shows the categories of personal information that we have collected during the past twelve (12) months, the sources of such information, and the business or commercial purposes for which we may use such information. For all categories of personal information collected, we may disclose data to our service providers and other third parties to help us accomplish the business purposes described below.

The table below is intended to be illustrative and not exhaustive.

Categories of Personal Information

Sources of Personal Information

Business and Commercial Purposes

Personal identifiers (e.g. name, address, e-mail address, phone number(s)) 

  • Website or services (information collected directly from user)
  • Industry affiliates
  • Third party providers
  • Third party advertisers/ promoters 
  • User support and feedback
  • Process, fulfilment, and maintenance 
  • Delivery of marketing communications
  • Analytics
  • Account administration

Commercial information (e.g. services purchased, obtained, or inquired about)

  • Website or services (information collected directly from user)
  • Industry affiliates
  • Third party providers
  • Third party advertisers/ promoters
  • User support and feedback
  • Process, fulfilment, and maintenance 
  • Delivery of marketing communications
  • Analytics

Internet or Network Activity (e.g. IP address, browser and operating system, referral URL, pages viewed, date/ time of visit)

  • Website or services (information collected directly from user)
  • Third-party advertisers/ promoters
  • Delivery of marketing communications
  • Analytics

Inferences drawn from any of these personal information categories (e.g. interest based on analytics)

  • Website or services (information collected directly from user)
  • Third party providers
  • Third party advertisers/ promoters
  • User support and feedback
  • Process, fulfilment, and maintenance 
  • Delivery of marketing communications
  • Analytics

Financial information (e.g. credit card information, bank account information)

  • Website or services (information collected directly from user)
  • Process, fulfilment, and maintenance 
  • Account administration

 

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce agreements to which you and we are a party.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our employees, customers, or others.

 

We are constantly improving our Services, so we may need to change this Privacy Policy from time to time as well. We post any changes we make to our Privacy Policy on this page. The date the Privacy Policy was last updated is identified at the top of this page. You are responsible for periodically visiting our website and this Privacy Policy to check for any changes. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is used. 

How we use cookies and other tracking technology to collect information

“Cookies” are unique identifiers that we transfer to your browser or device to allow us to recognize your browser or device for future visits to help us ascertain how and when you use certain pages and features of our website. We use cookies and similar technologies to recognize your repeat visits and preferences, as well as to measure the effectiveness of campaigns and analyze traffic. Through cookies we place on your browser or device or through our browser extension, we may collect information about your online activity after you leave our Services. Just like any other usage information we collect, this information allows us to improve the Services and customize your online experience, and otherwise as described in this Privacy Policy. 

The Help feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the Website of its manufacturer. Because cookies allow you to take advantage of some of our essential features, we recommend that you leave them turned on.

Keeping your information safe

We care about the security of your information and use commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through our Service. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

Your specific rights in respect of your personal information if you are located in the EU, UK, or Switzerland 

For the purposes of EU data protection laws, Codal is a data controller (i.e., the company who is responsible for, and controls the processing of, your personal data). If you are located in the EU, UK, or Switzerland, per the GDPR and UK GDPR you have the following rights in respect of your personal data that we hold:

  1. Right of access. The right to obtain access to your personal data;
  2. Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete;
  3. Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed;
  4. Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data;
  5. Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another; and
  6. Right to object. You have a right to object to processing based on legitimate interests and direct marketing. 

You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.  

If you wish to exercise one of these rights, please contact us at [email protected] and write in the subject line: “GDPR PRIVACY REQUEST – [INSERT NAME]”.

International Users outside of the United Kingdom, European Union, and Switzerland

If you are receiving Services from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, be advised that through your continued use, which is governed by the law of the United States and this policy, you will be transferring your personal information into the United States and you consent to that transfer. Your information may be stored and processed in any country where we have facilities or in which we engage third party service providers. By using our Services, you consent to the transfer of information to countries outside your country of residence, which may have different data protection rules than in your country. While this information is outside of your country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

While you do not have the same extensive rights of data access and deletion as users from the EU, UK, and Switzerland, you may still make a privacy request and we will do our best to comply with your request, provided it is no more egregious than the rights given in the GDPR. 

Contact Us

If you have any questions regarding this Privacy Policy, please contact us via email at [email protected]

 

Codal Inc. Privacy Policy