Privacy Policy

Last updated: July 21 of 2023

Introduction

This is the privacy policy of Codly group of companies, which comprises Codly and our other subsidiaries and associated companies from time to time.

We take your privacy seriously and are committed to protecting your privacy rights. This privacy policy explains the information we collect through codly.com.br, as well as through other managed websites or pages where this privacy policy is posted or linked. This privacy policy also describes the personal information collected from or on behalf of end users of our services and software-as-a-service products.

What Personal Information We Collect

We collect both personal information and anonymized information. In general terms, the types of personal information we collect include:

• Basic and Identifying Info: Your given name, last name, user ID, secure password, email ID, profile picture, and any other details you share while engaging with us.
• Financial and Transaction Data: Records involving any financial dealings with us, encompassing your bank and card specifics as well as other payment-related details.
• Interaction and Technical Metrics: Data regarding your activity on our websites and use of our products, including log files, performance indicators, and technical specifics such as Internet Protocol addresses, device specifics, cookie identifiers, and activity metrics like clicks, scrolling, and viewed pages. We also compile information from helpdesk tickets.
• Geographical Data: The location details, either given by a mobile device that interacts with our websites and apps, or linked to your IP address during your use of our websites and services.
• External and Public Source Info: Data we obtain from third parties, public records, or collaborative business partnerships that assist us in delivering our products and services.
• User-Contributed Content: Any data or material you contribute while using our websites or services, such as blog posts, forum discussions, comments on our products, or any data you offer when engaging in interactive features, surveys, or customer support interactions.
• Permission and Preference Details: Specifics of any authorizations, consents, or preferences you indicate to us.

Codly and Our Clients – Our Dual Role as Data Processor and Storage Provider

Our Codly platform enables our clients to modify websites, introduce new elements, and generate various types of content. These customizations will subsequently be made available to the end-users of our clients. Additionally, we collect and store data regarding user interactions within these client-created experiences, as well as with any other elements specified by our clients.

We don't dictate the content or the specific types of personal information that our clients may choose to collect or manage using Codly. However, unlike typical data processors, we also provide data storage services. All the collected data is securely stored within the Codly platform for the use and benefit of our clients.

In these circumstances, our clients are the ones who control the processing of personal information. We serve in a dual role as both a data processor and a storage provider. We collect, handle, and store information under the guidance of our clients. We do not have a direct relationship with the individuals whose personal data is being processed. The terms that govern our processing and storage activities are laid out in a data protection agreement made between us and our clients.

If you have questions about how your personal data is managed by one of our clients, or if you have any related requests, you should contact the client responsible for the website or communication in question.

The personal information collected and stored through Codly is the responsibility of our clients. It is used, disclosed, and safeguarded according to their individual privacy policies and is not subject to this privacy policy.

Why Codly Collects Personal Information

The reasons we collect personal information may vary based on the kind of relationship we maintain with you.

Types of Personal Information Collected:

We collect General Information, Identity Information, Usage Information, Transaction and Payment Information, Location Information, Public/Third-Party Information, User-Generated Information, and Consents and Preferences Information.

Clients Using Codly for Business:

For Account Management and Service Provisioning:
We respond to client queries, offer technical support, and fulfill client requests.

For Processing Client Orders and Service Delivery:
We ensure seamless transactions and effective deployment of our products and services.

For Compliance and Regulatory Purposes:
We ensure that all financial transactions and business interactions comply with legal and regulatory requirements.

For Service Optimization and Business Analytics:
We focus on enhancing the service by analyzing both aggregated and individual data.

To Run, Sustain, and Enhance Our Offerings:
We are committed to continually running, sustaining, and refining our products and services. Alongside this, we observe market trends and accumulate combined data from our user community. These insights enable us to more effectively focus our marketing initiatives, such as seeking customer reviews for our offerings, activities that may be carried out in collaboration with partners or third-party organizations.

End-Users of Our Clients:

To Enhance User Experience:
We customize experiences based on user interactions and profile.

For Crime, Fraud, and Corruption Prevention:
We take various measures to ensure the integrity and security of user data.

Website Visitors

To Address Your Queries:

If you seek information or have questions, we use General Information and Identity Information to respond appropriately.

For Community Engagement:

We enable both you and us to post and share comments or user-generated content on our platforms. This requires General Information, Identity Information, and User-Generated Information.

For Targeted Advertising:

Our advertising partners utilize various types of information to deliver personalized ads on our behalf. This includes General Information, User-Generated Information, Usage Information, and Consents and Preferences Information.

To Enhance Website Effectiveness:

By tracking how you use our site, we can better understand your needs and adjust our strategies accordingly. This involves General Information, Usage Information, Location Information, User-Generated Information, and Consents and Preferences Information.

To Minimize Spam and Fraudulent Activities:

We utilize several types of data to identify and halt spam and fraudulent inputs, such as General Information, Identity Information, Usage Information, and Location Information.

The Methods Codly Utilizes to Gather Personal Data

We use an array of strategies to accumulate your personal information from different avenues, such as:

Direct Communication

You might willingly share your personal data with us through various methods, like:

• Asking questions about or showing interest in our services, whether you're a current or future customer, or a reseller.
• Creating a user profile on our website.
• Requesting technical help or customer support.
• Opting into our newsletters or other informational content.
• Choosing to receive promotional materials from us.
• Registering for or participating in events, contests, or surveys.
• Offering us feedback or initiating contact for other matters.

Data from Third-Parties and Client Contributions

Additionally, we collect information from third-party services and open public resources, which may encompass:

• Data analytics services like Google Analytics, Amplitude, and Hotjar.
• Ad networks.
• Search engine service providers.
• Partners offering technical, financial, and logistical solutions.
• Organizations that aggregate or broker data.
• Public databases or other sources accessible to the public.
• Data uploaded by clients, including their own proprietary and customer data, within the Codly ecosystem.

Automated Data Collection

As you browse our website or use our offerings, we automatically record specific data related to your actions and devices. For instance, we monitor the web pages you view and the links you engage with on our platform. Cookies, tracking logs, and other data-collection tech support this activity. More information can be found in our Cookies Policy.

How Codly Handles Data Sharing

Within Codly: Sharing Across Departments

Your personal data might be circulated among different internal units at Codly to provide you with efficient and accurate Products and Services. Because Codly operates globally, the transfer of your data can happen across international boundaries. To regulate this, we implement specific safeguards like geographic restrictions to ensure only authorized access.

Working With External Support Systems

To offer top-notch services, we collaborate with a variety of service providers, some of which are part of the Codly network, and others are independent third-party vendors. All these vendors serve as data processors on our behalf, bound by contractual obligations to comply with the principles outlined in this document.

List of External Service Providers

We partner with a range of third-party platforms to improve and support our operations, including but not limited to:

• Google Analytics – https://analytics.google.com/
• Amplitude – https://amplitude.com/
• Hotjar –https://www.hotjar.com/
• Hightouch –https://hightouch.com/
• Slack – https://slack.com/
• Atlassian – https://www.atlassian.com/
• Weblfow - https://webflow.com/
• Google Workspace (and all sub products) - https://workspace.google.com/
  

How Long Codly Retains Your Data

General Protocol

We generally keep your personal details for the time required to satisfy our obligations to you, as well as to meet legal standards. For clients or partners, we maintain records for the whole span of our business engagement. Some types of data might be held for extended periods, particularly if we expect potential legal issues.

For Those Using Codly Services

If you're a client or associate of Codly, your personal data will be retained for the time of our agreement. Beyond the contract term, your data will be either removed or anonymized within a year unless the law states otherwise. Financial documents like contracts and invoices might be stored for longer periods, up to seven years or more depending on local laws.

Inquiries and Sales Conversations

Your data will be retained unless they decide to opt out.

Subscriptions to Marketing Content

If you've opted in for our newsletters or other promotional content, we'll keep your data until you decide to unsubscribe. A year of inactivity will prompt us to either delete or make your data anonymous.

Special Cases of Personal Data Processing

Minors

We do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, please do not send any personal information about yourself to us. If we learn that we have collected personal information from a minor, we will delete that information as quickly as possible.

Sensitive Personal Data

Codly does not collect any Sensitive Personal Data, such as data concerning health, religion, political opinions, or other sensitive matters, unless explicitly provided by the user for a specified purpose.

Explicit Consent

GDPR Compliance for EU Users

If you are a resident of the European Union, you have the right to give explicit consent for the collection and use of your personal data. Before we collect any personal data from you, we will provide you with an opportunity to explicitly consent to its collection and the specific purpose for which it will be processed.

How to Give Consent

Upon your first visit to Codly, a consent banner or pop-up will appear, clearly asking for your permission to collect and process your personal data. By clicking "I Agree" or by continuing to use our service after being presented with this notice, you provide your explicit consent for the purposes outlined.

Withdrawing Consent

You have the right to withdraw your consent at any time. To do so, please visit your account settings or contact us at support@codly.com.br. Upon receiving a withdrawal request, we will cease to process your data for the purposes you originally consented to, except where we are required to do so by law.

Data Portability

Your Right to Your Data

You have the right to request a copy of your data in a machine-readable format for your own reuse or to transfer it to another service provider. You may exercise this right by contacting us at support@codly.com.br

Violation and Redress

Reporting and Accountability

Should there be any violation of this privacy policy or misuse of personal data, you are encouraged to report the issue to us at support@codly.com.br. We will investigate and provide redress in accordance with the applicable laws.

Changes to this Privacy Policy

Updates and Notifications

We reserve the right to update this privacy policy from time to time. All changes will be posted on this page, and if the changes are significant, we will provide a more prominent notice, which may include email notification.

How Codly Uses Cookies

Cookie Policy

Cookies are small files that are stored on your computer when you visit a website. We use cookies to improve our services, enhance user experience, and for analytics. 

Your Choices and Legal Rights

How to Unsubscribe from Codly Promotions

You're free to exit from our marketing communications whenever you wish by clicking the "Unsubscribe" option in any marketing email or visiting our designated opt-out page. Be aware that opting out from our emails doesn't exempt you from seeing our online ads.

How to Opt-out from Third-party Promotions

We don't control the marketing endeavors of our clients. To opt out from their promotional messages, you can click the "unsubscribe" option in their emails or reach out to them directly. If you suspect any of our clients are spamming using our platform, please reach out to us at support@codly.com.br

Contact Us

If you have any questions, concerns, or feedback about our privacy policy, or if you require more information on how we handle your personal data, we're here to help.

How to Contact Us:

• Email: For the quickest response, please email us at support@codly.com.br. We aim to reply to all inquiries within 72  business hours.

We strongly encourage you to contact us via email for faster and more secure communication.

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