Privacy Policy

We are fully committed to protecting the privacy and security of our customers. You have the right to know what data we collect (and how we use it), as well as the right to move or delete this data as you see fit. The following policy explains Koddi’s current practices regarding data collection, use, and security.

We also process data on behalf of our clients. Please refer to the appropriate client privacy policy for more information about 1) how this data is collected and used and 2) your rights in relation to this data.

What kinds of data does Koddi collect?

We collect data that helps us to optimize our clients’ advertising efforts, connecting users to the best possible travel experiences.

This data can include:

• Pages browsed by users
• IP addresses
• Aggregated technical information related to the user’s browser and device

We do not collect or process ‘sensitive data,’ such as any information pertaining to a user’s racial or ethnic origin, political opinions, criminal offenses, religious beliefs, or physical and mental health.

How does Koddi use this data?

To begin with, we store our users’ email addresses, passwords, and 2-factor secrets for authenticating account logins to provide account notifications and “Forgot your password” functionality. We also store users’ currency preferences to help format reporting values into this preferred currency. Additionally, Koddi verifies its users’ authentication after they log in by utilizing cookies to keep users authenticated and collecting IP addresses, a practice that also prevents brute force attacks. When browsing the Koddi Enterprise Platform, users’ IP addresses are recorded per page view and file uploads. This information is used for security and account auditing; however, this data is not used for remarketing or tracking purposes. Finally, when connecting to a third-party data provider, we store any access tokens associated with connecting to their API.

How can Koddi users control and manage their data?

We rely on data to provide the most efficient, meaningful experiences possible.
That said, we deeply value transparency and accessibility.

Users in California have:

• The right to know whether their personal information is being collected about them
• The right to request the specific categories of information a business collects upon verifiable request
• The right to know what personal information is being collected about them
• The right to say “no” to the sale of personal information
• The right to delete their personal information
• The right to equal service and price, even if they exercise their privacy rights

To make any of the above requests (or to reach out with additional questions) contact us at dataprotection@koddi.com.

Users in the European Union can easily manage the data we collect by:

• Requesting an electronic copy of the personal data we have collected, free of charge
• Requesting that their data be transmitted to a new controller
• Requesting that their data be permanently erased

To make any of the above requests (or to reach out with additional questions) contact us at eudataprotection@koddi.com.

How does Koddi protect this data?

We work hard to make sure that your data is protected by the highest levels of security across all of our products and services. In addition to our internal controls, we also engage third-party specialists to audit our security practices and systems as needed.

We use the following tools to safeguard your information 24/7:

• User passwords and secrets are encrypted using SHA-256 hashing
• Access tokens and secrets for third-party APIs are encrypted using SHA-256 hashing
• All stored IP addresses are encrypted and stored for one year

How long does Koddi retain data?

Personal account information, such as a user’s email addresses and passwords, are stored until the user’s account is removed from Koddi’s Enterprise Platform. Access tokens to third-party APIs vary on a case-by-case basis and are refreshed based on expiration dates sent from the providers. Refresh tokens are stored until the user disables the API connection within the Enterprise platform. Session cookies are destroyed upon logout and are invalidated after 30 minutes of inactivity. Encrypted IP addresses are stored for a year, after which time they are removed from our system.

Cookies and Tracking Tools:

We use cookies in addition to third-party tracking tools. When we set cookies, they will expire within 30 days.

Legal Notice:

Koddi may be required to disclose data in response to lawful requests by public authorities, such as national security or law enforcement. We may also disclose your information as required by law to comply with a subpoena, court order, or other legal processes when we believe in good faith that disclosure is necessary for the prevention, detection, or prosecution of criminal acts or to prevent other damage, or in response to legal action, or to enforce our rights and claims.

Privacy Statement – California

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of Koddi, Inc. and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our clients or their agents.
• Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
• Directly and indirectly from activity on our website (www.koddi.com). For example, from submissions through our website portal or website usage details collected automatically.
• From third-parties that interact with us in connection with the services we perform.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from contracts.
• To improve our website and present its contents to you.
• For testing, research, analysis, and product development.
• For analysis on behalf of our clients.
• As necessary to evaluate you for employment opportunities.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial Information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category I: Professional or employment-related information.
Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

• Our affiliates.
• Our clients.
• Service providers.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 1.888.320.1190
• Emailing us at: dataprotection@koddi.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If making a request on behalf of another, you must provide us with sufficient information to establish that you are authorized to make such request.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. At a minimum, please provide us with your name, telephone number, physical address, and email address.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Policy:

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you through a notice on our website homepage.

Last Updated:

This policy was last updated on May 8, 2020.

Contact Us:

Questions about this privacy policy or our data practices?

Email us outside the EU: at dataprotection@koddi.com
Within the EU: eudataprotection@koddi.com