PRIVACY POLICY

Welcome to Coddy, a web-based service that facilitate learning and practicing of code writing (the “Service”).

This Privacy Policy (“Privacy Policy”) explains how information about you is collected and used by the Service developed and operated by Coddy Inc. (“Coddy” or “we”, “us”, “our”).

Please read this Privacy Policy carefully.

PERSONAL DATA PROCESSED

We collect and process information you provide to us when you register directly to our Service or through a Third Party Provider account.

We collect and process your full name and email address when your register directly to our Service or through third party providers, such as Google (“Third Party Providers”). If you registered or logged in to our Service through a Third Party Provider account, we will process your account profile photo and user identifier.

We refer to this as “Registration Information”.

We collect and process information you provide to us when you sign up to our newsletter.

If you wish to sign up to receive our newsletter with information about our business and offers, we will ask you to provide your email address.

We collect and process your Payment Information when you submit a payment for our Service

When you wish to submit a payment for our Service, for example, to purchase additional premium services, we collect your full name and billing information.

We refer to this as “Payment Information”.

If you are a Content Creator (as defined in our Terms of Service) We collect, process and share with other users the Content you share on the Service.

We collect, process and share with other users the Content (e.g. lessons, text guides and excersises) and you prepare share with Coddy.

We refer to this as “Content”.

Please use discretion when creating content that includes the personal information of you or others. YOU ARE SOLELY LIABLE FOR PROTECTING THIRD PARTIES’ AND YOUR OWN PRIVACY, AND FOR OBTAINING THE PRIOR CONSENT OF INDIVIDUALS’ WHOSE PERSONAL INFORMATION IS INCLUDED IN YOUR CONTENT. WE WILL NOT BEAR LIABILITY FOR ANY DAMAGES THAT MIGHT INCUR TO YOU OR TO THIRD PARTIES AS A RESULT OF THE PUBLICATION OF PERSONAL INFORMATION.

We will process user inquiries you choose to send us.

You can submit an inquiry by emailing or writing to us. We will collect the information you provide in the inquiry, which typically includes your name, email address, other contact information and the text of your message.

We refer to this as “Inquiry Information”.

You do not have a legal obligation to let us process any of the above information. However, you will not be able to use the Service unless we process this information, because we require it to provide you the Service.

We collect and process measurements regarding your use of the Service.

We use analytic tools such as Google analytics and our internal event tracking system in order to collect meta-data and information regarding your use of the Service, your performances and progress while using the Service (e.g.-page views, the amount of sessions and the amount of times you visited the Service or certain pages, network requests to our build server and IP addresses).

We refer to this entire data as “Analytics Information”.

HOW YOUR PERSONAL DATA IS USED

We will not share your information with third parties, except in the events listed below or when you provide us your explicit and informed consent.

We will process your information to provide you the functionality of the Service.

We store and use your Registration Information, Your Content, and Analytics Information in order to provide you the functionality of the Service.

We will process your Payment Information to process your payment to our Service.

We process your Payment Information when you submit a payment for our Service, for example, to purchase premium services.

We will process your information to provide you our marketing newsletter.

If you signed up to receive our newsletter, we will process your email address to send you our periodic marketing newsletter.

If we obtain your contact information in the course of an order you place, we will give you a simple opportunity to refuse or opt out of our marketing newsletter.

We will use the Inquiry Information to handle and respond to your inquiry for quality assurance and for development and enhancement of the Service, to prevent fraud, resolve disputes, troubleshoot problems and related purposes.

We will use your Inquiry Information to contact you about your inquiry and handle and respond to your inquiry. If your inquiry is regarding any other information we have about you, we will process that other information to respond to your inquiry.

We use the Analytics Information for our business needs of developing and enhancing the Service, prevent fraud, resolve disputes, and troubleshoot problems.

We process the Analytics Information to assess the Service performance, drive product decisions, for example by analyzing your use of the Service, to maintain and improve the Service, for quality assurance and for development and enhancement of the Service.

We will also use the Analytics Information to prevent fraud and abuse, resolve disputes, troubleshoot problems, assist with any investigations, and enforce our terms of use for the Service.

We will use your email address to contact you with administrative message relating to the Service, this privacy policy, and our terms of use.

We will use your email address to contact with you regarding administrative issues related to the Services or support and maintenance.

We will share information with competent authorities if you violate any applicable law.

If you violated any applicable law, we may share information we have about you with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling of the violation.

WHOM WE SHARE YOUR DATA WITH

We will process information with our service providers helping us to operate our business.

We will process personal information with the assistance of our Service providers who assist us with the internal operations of the Service such as Google. These companies are authorized to use your personal information in this context only as necessary to provide these Services to us and not for their own promotional purposes.

We will process information with your organization (if your account is linked to a specific organization).

Some users connect to the Service through an account of a particular organization (e.g. university). If you connect to the Service via your organizations account, or if your use of the Service is in the context of your relation with such organizations, we may share your usage information with your organization to provide data on your progress and the effectiveness of the Service for you.

We will share information with competent authorities, if you abuse your right to use the Service, or violate any applicable law.

If you abused your rights to use the Service, or if you violated any applicable law, we will share information with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling of the violation or breach.

We will share your information if we are legally required to do so.

We will share information if we are required to do so by a judicial, governmental or regulatory authority.

We will share your Information with third parties in any event of change in our structure.

If the operation of our Service is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), we will share information only as required to enable the structural change in the operation of the business.

COOKIES

What are cookies?

Cookies are text files, comprised of small amount of data, that are saved on your computer or other device (e.g. smartphone, tablet, etc.) when you use the internet and visit various website.

The information that the cookies maintain is read by the Website you visit, during the session of your visit to the Website (these are called ‘session’ cookies), and when you return to visit it again (these are called ‘persistent’ cookies). We also use techniques called web beacons and web pixels for purposes similar to the use of cookies.

We use cookies necessary to operate the Service, for statistics, for marketing purposes and to remember your preferences.

We use cookies for a number of purposes, as briefly explained below.

Necessary. Cookies that are strictly necessary for the functioning of the Website. The Service cannot operate properly without these cookies. You can set your browser to block or alert you about these cookies, but some parts of the Service may not function properly.

Statistics. Cookies that help us understand how you and other users interact with our Service by collecting data that does not directly identify you.

Marketing. Cookies that track your use of the Service and allow us to tailor content, both on and off the Service, that we believe is relevant to you.

You can always delete or disable cookies.

Other than using the cookie add-on, you can always delete the cookies saved on your device through the settings of your computer browser or device. You can also disable cookies for future use through the settings of your computer browser or device.

SECURITY AND DATA RETENTION

We will retain your Information for as long as we need it for business purposes, and thereafter as needed for record-keeping matters.

We will retain your Information for the duration needed to support our ordinary business activities operating the Service. Thereafter, we will still retain it as necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims and enforce our agreements. If you wish to unsubscribe from our promotional emails such as updates and reminders, we will delete your email address of our subscribers list.

We implement measures to secure your information.

We implement some measures to reduce the risks of damage, loss of information and unauthorized access or use of information. In any event, these measures do not provide absolute information security. Therefore, although efforts are made to secure personal information, it is not guaranteed, and you cannot expect that the Service will be immune from information security risks.

INTERNATIONAL DATA TRANSFERS

We will internationally transfer information in accordance with applicable data protection laws.

If we transfer your personal data for processing at locations outside your jurisdiction, we will abide by data transfer rules applicable to these situations.

ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE UK OR THE EUROPEAN ECONOMIC AREA

Coddy is the data controller of the personal information collected via our Service.

The following is the data controller for the purposes of the personal data we collect via the Service:
Coddy Inc.
651 N Broad St, Suite 201, Middletown, 19709, Delaware.

Cross-border transfers.

Information we collect from you will generally be processed within the United States and the European Union. In doing so, we will use adequate safeguards determined by the EU Commission.

Legal basis under EU or UK law for processing your personal data.

The legal basis for processing your Analytics Information and Inquiry Information, is our legitimate interest in providing, maintaining, developing, and enhancing the Service.

The legal basis for collecting and processing your email address to send you our newsletter is your explicit consent.

The legal basis for collecting and processing your Registration Information, Payment Information and Your Content, is our legitimate interests in providing you with the Service and tailoring the Service to your preferences.

The legal basis for processing your data for the purpose of handling instances of abusive use of the Service is our legitimate interests in defending and enforcing against violations and breaches that are harmful to our business.

The legal basis under EU law for processing your data and sharing your data where we are legally required to share it, is our legitimate interests in complying with mandatory legal requirements imposed on us.

The legal basis for us processing and sharing your data in the event of a change in our corporate structure is our legitimate interests in our business continuity.

You have certain rights to access, update or delete your information, obtain a copy of your information, and object or restrict certain data processing activities.

If you are in the EU or the UK, you have the following rights under the GDPR:

Right to Access your personal data that we process and receive a copy of it.

Right to Rectify inaccurate personal data we have concerning you and to have incomplete personal data completed.

Right to Data Portability, that is, to receive the personal data that you provided to us, in a structured, commonly used, and machine-readable format. You have the right to transmit this data to another service provider. Where technically feasible, you have the right that your personal data be transmitted directly from us to the service provider you designate.

Right to Object, based on your particular situation, to using your personal data on the basis of our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise of defense of legal claims.

Right to Restrict the processing your personal data (except for storing it) if you contest the accuracy of your personal data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you oppose the erasure of the personal data and request instead to restrict its use; if we no longer need the personal data for the purposes outlined in this Policy, but you require them to establish, exercise or defense relating to legal claims, or if you object to processing, pending the verification whether our legitimate grounds for processing override yours.

Right to be Forgotten. Under certain circumstances, such as when you object to us processing your data and we have no compelling legitimate grounds to override your objection, you have the right to ask us to erase your personal data. However, we may still process your personal data if it is necessary to comply with a legal obligation that we are subject to under laws in EU Member States or for the establishment, exercise or defense of legal claims.

Right to withdraw your consent where your consent is required under applicable law, or it is the legal basis for the processing of your data. For example, when you want to withdraw your consent from receiving our newsletter.

If you wish to exercise any of these rights, contact us at info@coddy.tech

We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason for this.

You have a right to submit a complaint to the relevant supervisory data protection authority.

Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.

If you are in the UK, you can lodge a complaint to Information Commissioner’s Office (ICO) pursuant to the instructions provided here.

MINORS

The Service is not directed to users under 18.

The Service is not directed to users under the age of 18. We do not knowingly collect information or data from users under the age of 18 or knowingly allow children under the age of 18 to use the Website. Additional age restrictions may apply in your country.

CHANGES TO THIS PRIVACY POLICY

If we change this Privacy Policy, we will make efforts to proactively notify you of such changes.

From time to time, we may change this Privacy Policy. If we do so, we will make efforts to proactively notify you of such changes. In any event, the latest version of the Privacy Policy will always be accessible on our Website.

Last Update: July 18, 2022.