LAST UPDATED: APRIL 25, 2022
COLLECTION OF INFORMATION
Information You Provide to Us
We collect information you provide directly to us. For example, you share information directly with us when you create an account, sign up to review code, fill out a form, request customer support, or otherwise communicate with us. The types of personal information we may collect include your username, email address, profile picture, bio, and any other information you choose to provide.
Information We Collect Automatically When You Interact with Us
When you access or use our Services, we automatically collect certain information, including:
Device and Usage Information: We collect information about how you access and use our Services, including, data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Services, access times, pages viewed, links clicked, and the page you visited before navigating to our Services.
Location Information: In accordance with your device permissions, we may collect information about the precise location of your device. You may stop the collection of precise location information at any time (see the Your Choices section below for details).
Information We Collect from Other Sources
We collect information about you from other sources and links , such as your name and email address, if you create an account or log into our Services using your credentials from a third-party platform (such as Apple or Google), in accordance with the authorization procedures determined by such platform.
Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address.
USE OF INFORMATION
We use the information we collect to deliver the products and services you request and customize your experience with us. We also use the information we collect to:
Provide, maintain, and improve our products and services;
Personalize and improve your experience on our Services;
Send you technical notices, security alerts, and support and administrative messages;
Respond to your comments and questions and provide customer support;
Communicate with you about products, services, and events offered by CodeGov and others, and provide news and information that we think will interest you. By providing your email address, you agree to receive emails from CodeGov (see the Your Choices section below for information about how to opt out of these communications at any time);
Monitor and analyze trends, usage, and activities in connection with our Services;
Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of CodeGov and others;
Debug to identify and repair errors in our Services;
Comply with our legal and financial obligations; and
Carry out any other purpose described to you at the time the information was collected.
SHARING OF INFORMATION
We share personal information in the following circumstances or as otherwise described in this policy:
We share personal information with vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with web hosting, fraud prevention, and customer service;
If you post content in a public area of our Services, this information will be visible to other users of our Services;
We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of CodeGov, our customers, the public, or others;
We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests;
We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;
We may share personal information with our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership; and
We share personal information with your consent or at your direction.
We also share aggregated or de-identified information that cannot reasonably be used to identify you.
TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES
CodeGov is headquartered in the United States, and we have operations and service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.
COOKIES AND GOOGLE ANALYTICS
Types Of Cookies We Use
As mentioned above, we will collect certain information about you when you visit our website. We collect such information through the following technologies (collectively, “cookies”):
Cookies. Cookies are small pieces of information that a website assigns to your device while you are viewing a website. Cookies may be served by the entity that operates the website you are visiting (“first-party cookies”) or by other companies (“third-party cookies”). Additionally, some cookies may be temporary and erase when you close your browser (“session cookies”), and others may remain for a set duration (“persistent cookies”).
Log Files. Tools that track actions occurring on the site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
Web Beacons. These “tags” and “pixels” are electronic files used to record information about how you browse our website.
Cookies are very helpful and may be used for various different purposes such as delivering personalized services. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the Services quicker, easier and smoother. Our website may use the following types of cookies:
Strictly Necessary Cookies. These cookies are required for the operation of our website, and are essential to enable you to login, navigate around and use the features of a website, or to provide a service requested by you. We do not need to obtain your consent in order to use these cookies.
Functionality Cookies. These cookies allow the website to remember choices you make (such as your username, language, or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by using a cookie to store information about the region in which you are currently located, remember changes you have made to text size, fonts, and other parts of web pages that you can customize, and provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect remains anonymous and they cannot track your browsing activity on other websites.
Targeting/Advertising Cookies. These cookies are used to deliver advertisements tailored to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization. For more information about online behavioral advertising cookies and online privacy, please see the guide produced by the internet advertising industry available at youronlinechoices.com.
HOW TO CONTROL COOKIES
You can control our uses of cookies through your internet browser or through third party tools:
Internet Browser. You can control cookies through most browsers by changing your cookie settings. These settings will typically be found in the “options” or “preferences” menu of your browser.
Third Party Tools. You can also visit http://www.allaboutcookies.org/ where you will find comprehensive information on cookie management and blocking which pertains to a wide variety of cookies. As noted above, our website uses Google Analytics to collect information about how visitors are using our website. Google Analytics has its own cookies that it uses to track and aggregate this information. You can prevent the use of Google Analytics relating to your use of our website by downloading and installing the browser plugin available here.
ADVERTISEMENTS AND ADVERTISING TOOLS
We may use a third-party advertising technology to serve advertisements when you use the Services. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser). We may also use our third-parties and share with them Users’ information to assist us in evaluating the success of our advertising campaigns and help us retargeting our Users.
Advertising ID and Advertising Identifier
The Google Advertising ID is an anonymous identifier, provided by Google Play services. If your device has an Advertising ID, we may collect and use it for advertising and user analytics purposes. We may also use Apple’s Advertising Identifier (IDFA), which is a non-permanent device identifier provided by Apple, and any information obtained through the use of the Advertising Identifier, for the purpose of advertising. By downloading or using the Services you explicitly agree that we may associate your Advertising ID and your Advertising Identifier with your applicable persistent device identifier. This will facilitate our ability to improve your personalized experience. Further, we may use other persistent identifiers for non-advertising purposes. If your device does not have Advertising ID or Advertising Identifier respectively, we will use other identifiers.
How to Control Certain Advertising Technology
You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective sites: https://optout.networkadvertising.org or https://optout.aboutads.info [EU users may opt out of receiving targeted advertising through the European Interactive Digital Advertising Alliance] You may also control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences.
Additionally, your mobile device operating system may provide mechanisms that allow users to opt out of the use of information about their usage of mobile apps to deliver targeted ads to their mobile device. For more information, or to opt out using these mechanisms, consult your device settings.
FOR HOW LONG WE RETAIN YOUR INFORMATION
How long we keep your information will vary depending on the type of information and our reasons for collecting it. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and our legal obligations (as laws or regulations may set a minimum period for which we have to keep your information). In general, we will retain your information for as long as we require it to fulfil our contractual rights and obligations, resolve disputes and enforce our policies and agreements, or for periods required by our legal and regulatory obligations.
HOW WE PROTECT YOUR INFORMATION
We take great care in implementing and maintaining the security of the Services and your information. We will take reasonable steps and use technical, administrative and physical security measures appropriate to the nature of the information and that comply with applicable laws to protect information against unauthorized access and exfiltration, acquisition, theft, or disclosure. Although we take enhanced steps to safeguard information, given the nature of information security, there is no guarantee that such measures will always be successful. We cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that such access will be prevented. If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at email@example.com.
EU/UK BASED USERS AND THE GDPR
If you are an EU or UK data subject and the processing of your information is subject to the GDPR, please review this section in addition to the entire Policy.
(I) Grounds For Processing
We will only process your information in circumstances where we have established a lawful basis to do so. Our lawful bases for processing that information include:
Legitimate Interests. We process information for our legitimate business interest in managing and promoting our business, provided that our interest is not overridden by your interest. In identifying and relying on this basis for certain processing, we have weighed our legitimate interest as a business against your rights and freedoms and have determined that such processing will not unfairly impact your rights. Please note that you have a right to object to the processing of your information where that processing is carried on for our legitimate interest.
Legal Requirements. We may need to process your information in order to comply with certain legal and regulatory requirements, including to establish, exercise or defend legal claims, respond to a judicial process, law enforcement or governmental agency.
Contract. Depending on the circumstances, we may need to process your information for the performance of a contract to which you are a party, or related pre-contractual steps.
Consent. We may process your information with your consent, as required by the GDPR. You have the right to withdraw this consent at any time where we are relying on consent to process your information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
(II) Your Rights Under The GDPR
We respect your privacy rights and therefore you may contact us at any time and request:
Access. You have the right to know we collect certain information about you and to ask us for copies of your information. Please use the contact details provided at the end of this Policy.
Rectification. You have the right to request that we correct your information you think is inaccurate or incomplete.
Objection to processing. You have the right to object to processing in some circumstances, including where we are using your information for our legitimate interests and for direct marketing purposes, including by opting-out of marketing communications by contacting us using the contact details provided at the end of this Policy.
Erasure. You have the right to request that we erase the information we have collected about you in certain circumstances. The right to erasure is not absolute, and only applies if we no longer need your information to carry out the purpose that we collected it for, whilst in compliance with laws applicable to us; you have withdrawn your consent to our use of your information; you have objected to our use of your information and your interests outweigh our interests in using it; you believe we have processed your information unlawfully; or we have a legal obligation to erase your data. Subject to our retention policies, we will consider any request to erase information for any of the above reasons and endeavor to comply with the request to the extent permitted by law, but we may not always be able to comply with your request. We may be required to retain the information for certain retention periods in order to comply with legal and regulatory requirements under applicable laws and regulations to which we are subject. If we are unable to comply with your request, we will contact you in writing. If you wish to exercise this right, please contact us at: firstname.lastname@example.org.
Restrict processing. You have the right to ask us to restrict the processing of your information in certain circumstances, including if you have concerns regarding the accuracy of your information, where you have made an objection to our use of your personal data; or if you believe we processed your information unlawfully, but you do not want us to delete it.
Data portability. You have the right to receive a copy of the information that we collect about you in a way that is accessible and in a machine-readable format where the processing is based on your consent, the performance of a contract with you, or carried out by automated means. You have the right to request that such information be transmitted directly from us to another data controller, where technically feasible.
Withdrawal of consent. You can withdraw your consent at any time where we are relying on consent to process your information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
We will store your information only for as long as necessary for the purposes for which it was collected, including to provide the Services and to comply with our legal obligations, resolve disputes and enforce our policies and agreements. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client information, account opening documents, communications and anything else as required by applicable laws and regulations.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion. If you wish to make a complaint regarding our handling of your information, you can contact us at email@example.com. You may also make a complaint to the relevant supervisory authority for data protection issues. In the UK this is the Information Commissioner’s Office (“ICO”). Contact details for the ICO may be found at www.ico.org.uk.
(III) Transfer Of Information Outside The UK And/Or The EEA
Please note that some data recipients may be located outside the EEA and/or the UK. In such cases we will seek to ensure a similar degree of protection is afforded to it by ensuring that, where possible, information is generally transferred only to persons in countries outside the EU or the UK in one of the following circumstances:
transfers only to such countries as approved by the European Commission or the equivalent entity in the UK as providing adequate level of data protection;
to persons and undertakings to whom the transfer of such information is made pursuant to a contract that is compliant with the model contracts for the transfer of information to third countries from time to time approved by the European Commission (as supplemented where and if required) or the equivalent body in the UK;
to persons and undertakings outside of the EU or the UK pursuant to other appropriate safeguards for the transfer of information; and
only on one of the conditions allowed under the GDPR in the absence of (i) a decision by the European Commission or the equivalent entity in the UK that has deemed a country to provide an adequate level of protection for information (i.e. an adequacy decision) or (ii) appropriate safeguards such as a contract that is compliant with the model contracts for the transfer of information to third countries approved by the European Commission or the equivalent entity in the UK.
You can contact us through the information provided below for further information on specific mechanisms we utilize for transferring information outside the EU or the UK and the countries to which such transfer may be made.
ADDITIONAL INFORMATION FOR CALIFORNIA AND VIRGINIA RESIDENTS
The CCPA and CDPA impose certain obligations on us and grants certain rights to California and Virginia residents with regard to “personal information.” If you are a California or Virginia Resident, please review the following information about our privacy practices surrounding how and why we collect, use, disclose, and share your personal information and your potential rights with regard to your personal information. The rights described in this section are subject to exemptions and other limitations under applicable law.
Terms used in this section have the meaning ascribed to them in the CCPA. We are a “business.” “Personal information” as used in this section has the same meaning as in the CCPA. It does not include deidentified information, aggregate consumer information or publicly available information, as those terms are defined in the CCPA.
Notice At Collection And Use Of Personal Information
What Type of Information We Collect
Depending on how you interact with us, we may collect the categories of personal information listed above in the section “COLLECTION OF INFORMATION” above.
How We Use Collected Information
We may use your personal information for the business or commercial purpose listed above in the section “USE OF INFORMATION” and “SHARING OF INFORMATION” above.
Our Collection, Use, Disclosure, and Sharing of Information
What Information We Have Collected and the Sources from Which We Collected It
In the preceding 12 months, and depending on how you interact with us, we may have collected all or some of the personal information listed above in “COLLECTION OF INFORMATION” above. We may have collected personal information from all or some of the categories of sources listed in the above section, “COLLECTION OF INFORMATION”
Purposes for Collecting Information
We may collect the personal information for one or more of the following business or commercial purposes described in the above section, “USE OF INFORMATION” and “SHARING OF INFORMATION” above.
Our Disclosure, Sharing of Information
We do not sell your personal information. We do not knowingly sell the personal information of California residents under 16 years old. We may disclose your personal information to certain third parties for a business purpose. In the preceding 12 months, we may have disclosed for a business purpose your personal information to the following categories of third parties:
Companies and organizations that assist us in processing, verifying or refunding transactions or orders;
Identity verification agencies;
Fraud or crime prevention agencies;
Anyone to whom we lawfully transfer or may transfer our rights and duties under the relevant terms and conditions governing the use of personal information;
Any third party because of any restructure, sale or acquisition of our group or any affiliates; and
Regulatory and law enforcement authorities, where the law allows or requires us to do so.
We may share your personal information with our service providers, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA.
California and Virginia Resident’s Rights
If your personal information is subject to the CCPA or CDPA, you may have certain rights with regard to such personal information, including the right to:
Notice at Collection. Be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used.
Request to Delete. Request that we delete any personal information about you that we have collected or maintained, subject to certain exceptions. For example, we may be required to retain the personal information for certain retention periods in order to comply with legal and regulatory requirements under applicable laws and regulations to which we are subject. If you wish to exercise this right, please contact us at: firstname.lastname@example.org.
Request to Know. Request that we provide you with: (i) the categories of personal information we have collected about you; (ii) the categories of sources from which we collected the personal information; (iii) the business or commercial purpose for collecting or selling the personal information; (iv) the categories of third parties with whom we share personal information; (v) the specific pieces of personal information we have collected about you; and (vi) the categories of personal information about you we have disclosed for a business purpose.
Not to Be Discriminated Against. Not be discriminated against because you exercised any of your rights.
Opt-Out of Sale. Request that we not sell your personal information if a business sells your personal information (we do not).
Neither the CCPA nor the CDPA restricts our ability to do certain things like comply with other laws or comply with regulatory investigations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted or required by the CCPA or another law or regulation.
How to Submit a Rights Request
You can submit a Request to Know or Request to Delete, as described above, via email to email@example.com. When you submit a Request to Know, Request to Delete, or Request to Opt-Out, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name, email address and a copy of government issued identification. Any information gathered as part of the verification for a Request to Know, Request to Delete, or Request to Opt-Out will be used for verification or opt-out purposes only.
If you would like to use an authorized agent to submit a Request to Know or a Request to Delete, we may request proof that they are authorized to act on your behalf, or have a power of attorney. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.
We will deliver responses to verifiable consumer requests, free of charge by mail or electronically, at your election.
We will try to respond to your Requests to Know or to Delete within forty-five (45) days of receipt of the request. If we require more time, we will try to inform you of our need for an extension. Even with an extension, we will try to provide a response within ninety (90) days of initial receipt of the request.
Keep in mind that we are not required to provide information in response to Requests to Know more than twice in a 12-month period. Any response to a Request to Know will only cover the 12-month period preceding the verifiable request.
ADDITIONAL PRIVACY RIGHTS
You have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. Please note, however, that we do not currently disclose any of your personal information to third parties for their direct marketing purposes.
Some web browsers have a “Do Not Track” feature. This feature lets you tell Sites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers. Our website is not currently set up to respond to those signals.
You may update and correct certain account information at any time by logging into your account or emailing us at firstname.lastname@example.org. If you wish to delete your account, please email us at email@example.com, but note that we may retain certain information as required by law or for our legitimate business purposes.
When you first launch any of our mobile apps that collect precise location information, you will be asked to consent to the app’s collection of this information. If you initially consent to our collection of such location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. You may also stop our collection of this location information by following the standard uninstall process to remove all of our mobile apps from your device. If you stop our collection of this location information, some features of our Services may no longer function properly.
Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.
You may opt out of receiving promotional emails from CodeGov by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.