Privacy policy

This Privacy Policy (Policy) is applicable to all information and personal data of all users accessing our website that is collected by Codeby and its affiliates and subsidiaries. The purpose of this Policy is to provide you with information about the collection, use, maintenance and disclosure of your information collected by Codeby.

The privacy of visitors to our website is very important to us, and we are committed to protecting it.

This policy explains what we will do with your personal information and is intended to make clear to all interested parties what types of data we collect, why we collect it, and how users of this website can manage or delete their personal information.

Acceptance of this Privacy Policy

Acceptance of this Privacy Policy ("Policy") will be accomplished in two ways: (1) when you access the Codeby Site and affirmatively accept cookies; and (2) when you access the Site and continue browsing the Site, even if you do not affirmatively express your agreement. If you do not agree to this Policy, please do not continue to browse or interact with the Site.

We inform you that there will be no collection, storage or any form of treatment of the users' personal data in a different manner or for purposes other than those stated in this Policy, unless there is a legal and/or regulatory obligation to be fulfilled by Codeby.

Sources of Personal Data

The amount and type of information collected by Codeby varies depending on your use of our Services. We will collect different data if you are visiting our website, using our software, using client services of our software, or using Codeby services. And to make these definitions and differences more accessible, we have segmented the collection of user data into 4 parts so that you can understand what specifically applies to you.

This Policy applies to Personal Data that we collect from or about you through the following sources:

Digital Results Sites. Consumer-facing websites operated by or for Codeby including websites that We operate under our own domains/URLs and mini sites that We maintain on third-party social networks such as Facebook (sites).

Digital Results mobile sites/applications. Consumer-facing websites or mobile applications operated by or for Codeby, such as smartphone apps.

Ad Interactions. Interactions with our ads (for example, if you interact with one or more of our ads on a third party website, we may receive information about that interaction).

Data created by Us. During our interactions with You, we may create Personal Data about You (for example, but not limited to, records of your purchases on our websites, and records of your interactions with our content and emails).

Events. Events hosted and organized by Codeby, as well as events in which Codeby participates as a sponsor or exhibitor.

It is also worth mentioning that we store information regarding all contacts ever made with our users, regardless of the type of user that made the contact. Such information includes content downloaded from our pages and e-mail interactions, such as opens and clicks.

By clicking on the social media content sharing buttons available on our pages, the user is publishing the content through his/her profile on the selected network. Codeby does not have access to the login and password of users on these networks, nor will it publish content on behalf of the user without the user having done so.

It is worth mentioning that all the data we collect is used to provide our services. Therefore, all data and information about you are treated as confidential, and we will only use them for the purposes described here and authorized by you, mainly so that you can use our services fully, always aiming to improve your user experience. In this sense, see section 2 for what applies to you.

Types of Information We Collect

Codeby collects data about you directly in order to help provide you with the best experience with our services and products. Codeby will collect information from you in three ways: 1) through websites operated by Codeby, 2) through your use of our services, 3) from information you provide to us, and 4) through the download of our materials.

If you provide us with payment information, we will use it solely as authorized under this Privacy Policy for you to use to purchase services and products offered from Codeby's website, including to verify your financial qualifications and to collect payments due. We use a service provider to manage credit card processing. This service provider is not permitted to store, retain or use the data you provide except for the sole purpose of credit card processing on behalf of us or our vendors.

Websites operated by Codeby

In connection with your visit to any Codeby owned website, Codeby may use third party websites and offered services to collect and store information, such as Hubspot and Shopify.

We do not control and are not responsible for the content or practices of these other sites. The fact that we provide third party site links does not constitute our endorsement of those other sites or their content, owners, or practices. This Privacy Policy does not apply to those other sites, which are subject to other privacy policies and other relevant policies.

Information Collected

Codeby may collect the following personal data from users who use its website:

  • Full Name;
  • Email Address
  • Phone Numbers;
  • Contact Messages;
  • Credit Card Information; and
  • Subject of Interest.

Purpose of Information Collected

The data provided by our users is collected for the following purposes:

  • - To send informational materials and educational content;
  • - To communicate offers, advertisements and promotions;
  • - To develop and improve our products, services and your browsing experience by personalizing the Sites;
  • - To improve;
  • - To send you printed direct mail regarding the promotion of our events;
  • - To contact you to deal with billing, account management and other administrative issues;
  • - To allow our employees to contact us via e-mail, telephone, chat and text messaging to conduct surveys;
  • - To investigate and assist in the prevention of security and abuse problems; or
  • - To comply with legal requests; and
  • - To fulfill any and all purposes for which you authorize us at the time of data collection.

Such purposes are fully consistent with article 10 of the General Data Protection Law.


Purpose

Personal Data

Legal Basis

Storage period

Site access

IP, date and time of access, geographic location, duration of visit, pages visited and cookies in general

Legal Obligation and Legitimate Interest.

For up to five (5) years after the user's last visit to the Site or for as long as the user is registered with the Site.

Registration

Name, cell phone, e-mail and password.

Consent and Execution of the contract.

For as long as the user is registered on the Site.

Marketing

Name, e-mail, phone number and cookies

Legitimate Interest

For up to five (5) years after the user's last visit to the Site or for as long as the user is registered with the Site.

Sales

Name, Email, Phone, Payment Information and Cookies

Consent and Performance of the Contract.

For up to five (5) years after the last visit of the user to the Site or for as long as the user is registered on the Site.

Types of Information NOT Collected

The following personal information may not be collected through the use of our services and you shall not provide any information regarding sensitive data, such as personal data about racial or ethnic origin, religious belief, political opinion, membership in a trade union or organization of a religious, philosophical or political nature, data concerning health or sex life, genetic or biometric data, in accordance with the LGPD (General Law on Data Protection).


Data sharing

As an online platform with e-commerce, Codeby may operate jointly with other companies in a wide range of activities, including to provide tracking functionalities, advertisers, sponsors and commercial partners, online and offline, as well as CRM, outreach tools and performance analysis. Thus, we reserve the right to share your information, pursuant to article 9, item V and article 18, item VII of the General Data Protection Law, including location, registration and interest data, with the companies indicated below, whenever possible, in an anonymous way, aiming to preserve as much as possible your privacy, using RD station tools, and anonymous Google analytcs, adwords. Company, with access to non-sensitive data is DDWB that manages the ads in Google.

We do not rent, sell or transfer your personal data to anyone, except to our partner companies. We may share your personal data only in cases of co-marketing content with partner companies that can be recognized through the Lading Page.

The stored data may be used for statistical (analytics) purposes in order for Codeby to understand who are the people visiting the Site. This Personal Data is pseudo-anonymizable and does not necessarily identify or make identifiable the subjects of the Personal Data, but only for the purpose of better understanding how the Site is accessed in order to improve the products and services offered and to target them in the interests of the user and for the protection of the rights of users, such as Police Agencies, public authorities or other organizations when required by law, or if there is a good faith belief that it is reasonably necessary to comply with legal obligation, process or request; enforce our terms, conditions and other agreements, including investigation of potential breach; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of ourselves, our users, third parties or the public as required or permitted by law (including exchanging information with other companies and organizations for fraud protection and credit risk reduction).

We require all third parties to respect the security of your personal data and handle it in compliance with the law. We do not allow our service providers to use your personal data for their own purposes and only allow them to process your personal data for specific purposes and in accordance with our instructions.

Personal Data will not be shared with third parties if we have received a request from the data subject not to do so. To submit a request simply contact the email address available at the end of this data policy.

Data Holders

Your personal data belongs to you and you can always choose not to disclose your data to us, but please keep in mind that some of this data may be necessary to register on our platforms or to use some of the features and products we offer you. Regardless of this, you will always have rights regarding the privacy and protection of your personal data, and we are not only concerned about the security of this data, but we are also concerned that you have access to and knowledge of all your rights regarding personal data.


In this way, we have summarized below all the rights that you have under the General Law of Data Protection (LGPD), the other Brazilian sectorial laws regarding data protection, and the General Data Protection Regulation (GDPR), which are


  • Right of access;
  • Right of rectification
  • Right of deletion;
  • Right to confirm the existence of processing;
  • Right to request blocking or erasure;
  • Right to information from public or private entities;
  • Right to restrict processing
  • Right to review automated decision;
  • Right to object to processing;
  • Right to explanation of the rationale behind the collection of your data;
  • Right to information about the possibility of not providing consent and the consequences of refusal;
  • Right to withdraw your consent.

In this regard, below is a brief explanation and examples of some of these rights:

Request for access to your personal data. This right enables you to request and receive a copy of your personal data that we hold about you.

Request for rectification of your personal data at Codeby. This right enables you at any time to request the correction and/or rectification of your personal data if you identify that some of it is incorrect. However, in order to effect such a correction, we will have to check the validity of the data you provide to us.

Request to delete your personal data. This right enables you to request us to delete your personal data from our platform. All collected data will be deleted from our servers when you so request or when it is no longer necessary or relevant for us to provide you with our services, unless there is any other reason for its retention, such as a legal obligation to retain the data or the need to preserve it for the protection of Codeby's rights. To change your personal information or delete it from our database, simply send an email to privacidade@codeby.com.br

Dight to object to data processing. Where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation that makes you wish to object to processing in this field, as you judge it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes e.g. In some cases, we may demonstrate that we have legitimate reasons for processing your data which override your rights, as in such cases it may be essential for the provision of the product and/or service.

Right to request blocking or deletion. This right allows You to ask us to stop processing your personal data in the following scenarios: (a) if You want us to establish the accuracy of the data; (b) when You need the data to be kept even if we no longer need it, as necessary to establish, exercise or defend legal claims; or (c) if You have objected to the use of your data, but in this case we need to check whether we have legitimate reasons to use it.

Restricting the processing of your personal data. This right allows You to ask us to suspend the processing of Your personal data in the following scenarios: (a) if you want us to establish the accuracy of the data; (b) when you need us to keep the data even if we no longer need it, as necessary to establish, exercise or defend legal claims; or (c) you have objected to the use of your data, but we need to check whether we have legitimate reasons to use it.

Right to withdraw consent at any time. You have the right to withdraw your consent, however, this will not affect the legality of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain products. And if this is the case, we will notify you at the time this occurs.

Right to Review Automated Decisions. You also have the right to request a review of decisions made solely on the basis of automated processing of your personal data that affect your interests.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise your other rights). This is a security measure to ensure that personal data is not disclosed to any person who is not entitled to receive it. We may also contact you for further information regarding your request in order to expedite our response. Your legitimate requests will be answered within five (5) business days. If your request is particularly complex, or if you have made multiple requests, we will notify you and update you on the progress of your request if it takes longer than this timeframe.

Codeby reserves the right to access, read, preserve, and disclose any Personal Data that it believes is necessary to comply with a legal/regulatory obligation or a court order; enforce this Policy, the Terms of Use, and other agreements; or protect the rights, property, or safety of Codeby, its employees, users, or others.

If you have any questions about these matters and how you can exercise these rights, please feel free to contact us through our "Help Center".

International transfers between Codeby companies

To facilitate our global operations, we transfer data to Germany and give access to such data to countries in which Codeby affiliates have operations for the purposes described in this policy.

This Privacy Policy applies even if we transfer Personal Data to other countries. We take steps to ensure that your Personal Data remains protected. When we share information about you among Codeby affiliated companies, we use the standard data protection contractual clauses approved by the European Commission and certify to the EU-US and Swiss-US Privacy Shield Frameworks to help protect the transfer of information we collect from the European Economic Area ("EEA"), the United Kingdom, and Switzerland.

Length of Time that Data is Stored

We will keep your personal data only for as long as is necessary to fulfill the purposes for which we collected it, including for the purposes of complying with any legal or contractual obligations, or request from competent authorities, as set out in the table above.

In determining the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purpose for processing your personal data and whether we can achieve such purposes through other means, and applicable legal requirements.

Codeby clarifies that the term of storage of Personal Data may change if Codeby needs to comply with legal and/or regulatory obligations.

Data Storage

Data is stored on the RD Station Marketing platform, which we use for base and marketing campaign management.

Company Information Security

Your account is protected with a password for your privacy and security. If you access your account through a third party website or service, you may have additional or different login protections through that website or service. You should prevent and avoid unauthorized third party access to your account and Personal Data by selecting and protecting your password and/or other login mechanism appropriately and limiting access to your computer or device and browser by logging out after you have completed access to your account.

In order to ensure your privacy and the protection of your personal data, Codeby adopts the best information security and secure development practices on the market, that is, we design products and services that promote the protection of your data and in which you can manage your information directly. And allied to this concept, we have adopted encryption practices for passwords and other critical information, TLS for data transfer between applications, cloud services with certifications and security seals, such as ISO 27001, SOC 1 and SOC 2/SSAE 16/ISAE 3402 and PCI DSS, 24/7 system monitoring, Edge Firewall with IDS (Intrusion Detection System) functionalities, Anti-malware, Anti-phishing, content control, and VPN.

We strive to protect the privacy of your account and other personal data we maintain about you in our records, but unfortunately we cannot guarantee total security. Unauthorized account entry or use, hardware or software failure, and other factors can compromise the security of your personal data at any time, so please help us maintain a safe environment for everyone. In addition to adopting good security practices regarding your account and your data, if you identify or become aware of anything that compromises the security of your data, You can refer to our FAQ here, or contact us through the available support channels.

Codeby reserves the right to exclude any user, representative or client from the Site if this Policy or the Terms of Use of the Site are not respected. As we value good relations, we recognize that you have the right to seek to understand the reasons and even contest them, which you may do at the following e-mail address [privacidade@codeby.com.br].


Cookies Policy

What are cookies?

As is common practice on almost all professional websites, the Site uses cookies, which are small files downloaded to your computer, to improve your browsing experience. This page describes what information they collect, how we use them, and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored, however, this may downgrade or 'break' certain elements of the Site's functionality.


How do we use cookies?

We use cookies for a number of reasons, detailed below. Unfortunately, in most cases, there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave all cookies if you are unsure whether or not you need them if they are used to provide a service that you use.


Disable Cookies

You can prevent cookies from being set by adjusting your browser settings (see browser Help to learn how to do this). Please be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will generally result in the disabling of certain functionality and features of this site. We therefore recommend that you do not disable cookies.


Cookies that we set

- Account-related cookies

If you create an account with us, we use cookies for managing the sign-up process and general administration. These cookies will usually be deleted when you log out, but in some cases they may remain afterwards to remember your site preferences when you log out.

- Login-related cookies

We use cookies when you are logged in so that we can remember that action. This saves you having to log in each time you visit a new page. These cookies are usually removed or cleared when you log out to ensure that you can only access restricted features and areas when you log in.

- Cookies relating to e-mail newsletters

This site offers newsletter or email subscription services and cookies may be used to remember if you are already subscribed and whether to show certain notifications valid only for subscribed / unsubscribed users.

- Survey-related Cookies

We periodically offer surveys and questionnaires to provide you with interesting information, useful tools, or to understand our user base more accurately. These surveys may use cookies to remember who has already participated in a survey or to provide accurate results after changing pages.

- Form-related cookies

When you submit data via a form such as those found on contact pages or comment forms, cookies may be set to remember the user's details for future correspondence.

- Site preference cookies

To provide you with an optimum experience on this site, we provide functionality to set your preferences for how this site runs when you use it. To remember your preferences, we need to set cookies so that this information can be called up whenever you interact with a page that is affected by your preferences.

Third-Party Cookies

- In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you may encounter through this site.

- This site uses Google Analytics, which is one of the Web's most widespread and trusted analytics solutions, to help us understand how you use the site and how we can improve your experience. These cookies can track things like how long you spend on the site and the pages you visit so that we can continue to produce engaging content.

For more information about Google Analytics cookies, please see the official Google Analytics page.

- Third party analytics are used to track and measure the use of this site so that we can continue to produce compelling content. These cookies may track things like the time you spend on the site or the pages you visit, which helps us understand how we can improve the site for you.

- Periodically, we test new features and make subtle changes to the way the site looks. When we are still testing new features, these cookies may be used to ensure that you receive a consistent experience while you are on the site, while we understand which optimizations our users like best.

- As we sell products, it's important for us to understand statistics about how many of our site visitors actually buy, and so that's the kind of data these cookies will track. This is important to you because it means we can make accurate business predictions that allow us to analyze our advertising and product costs to ensure the best possible price.


Changes to Privacy Policy

Codeby reserves the right to change its privacy policy at any time and will notify you by including an addendum to the privacy policy on our website. These changes will become effective on the day they are posted. Codeby encourages you to review the privacy policy frequently.

As technology and our services advance, we will also adapt our Policy and Site Terms of Use. When we do, we will post the updated version here, with the date of the revision made.

These terms have been prepared in compliance with the General Law on the Protection of Personal Data (Law 13.709/18), the Marco Civil da Internet (Law 12.965/14) and the EU Regulation (n. 2016/6790).

Conflict

In the event of conflict between this Privacy Policy and any other document sent to the data subjects by Codeby dealing with the same subject concerning the treatment of Personal Data, the more stringent Policy shall prevail, always taking into account the protection of the Data Subject.

Forum

This Privacy Policy is governed by the Brazilian laws, and the courts of the District of São Paulo are elected to resolve conflicts arising therefrom.

Contact Codeby

If you wish to have your data corrected, blocked or deleted, or if you have any doubts about this Privacy Policy, you may also contact us by e-mail contato@codeby.com.br.


This policy is effective as of May/2021.