Koddi, Inc. (“Koddi”, “us,” “we” or “our”) has created this Privacy Policy (“Policy”) in order to comprehensively inform individuals about our privacy practices and to demonstrate our firm commitment to privacy. This Privacy Policy along with our International Privacy Policy (collectively, this “Policy”) describes how we collect, use, disclose, transfer, store, retain or otherwise process your personal information in the course of performing our general business activities, which includes the administration of the koddi.com website and their related sub-domains (the “Website”) and in email, text, and other electronic messages between you and us (collectively, our “Services”).
When we refer to “you” or “your,” we mean the person about whom we collect personal information or data. If the person accessing the Website does so on behalf of, or for the purposes of, another person, including a business or other organization, “you” or “your” also means that other person, including a business organization, if applicable.
We generally provide our Services to businesses and not to individual consumers. However, in the course of providing our Services, we may collect personal information of individuals, as will be described in this Policy. This may include personal information that we collect about you when you visit our Website, your business contact information if we provide our Services to a company that you work with, or if you are a sole proprietorship and you engage with our Services.
Please read this Policy carefully. Our Policy includes:
This Policy includes and hereby incorporates by reference the following: International Privacy Policy
Our data centers and Website are hosted in the United States. If you are visiting this Website from outside of the United States, please note that by providing us your information it is being stored or processed in the United States where our data center and servers are located and operated. If you are outside the United States and do not wish to allow the collection and storage of your personal information within the United States, you should not use this Website and you should opt-out of the collection of cookies by following the guidelines in How Can I Disable or Remove Cookies.
This Policy sets forth our data policies and practices for the United States. If you are outside of the United States, please also review the provisions of our International Privacy Policy. Depending on your country of residence, applicable privacy laws may provide you with a right to additional disclosures as well as special data subject rights with regards to your personal information.
This Policy applies only to our Website and Services, and not to other companies’ or organizations’ websites, mobile applications and services to which we link. We are not responsible for the privacy practices of other businesses or the content of other websites, including any websites that may indicate a special relationship or partnership with us (such as co-branded pages or “in cooperation with” relationships). To ensure protection of your privacy, always review the privacy policy of the companies with whom you engage.
In the course of performing our Services, we collect a variety of different kinds of personal information from a variety of different individuals. What information we collect and the purposes for which it is collected will depend on the context of our activities or the Service that is being performed. Therefore, just because this Policy lists a particular data collection practice does not mean that we have necessarily collected that data from you. Instead, please review the applicable disclosures below to learn about how we may have collected personal information from you depending on how you have interacted with us.
When You Visit Our Website
The personal information we collect may include: Identifier Information, Geolocation Information, Internet or Other Electronic Network Activity Information, and/or Device Information. More information can be found below.
Identifier Information*
* The personal information we collect may include your name, email address, address, internet protocol (IP) address, device IDs, cookie IDs, and other similar identifiers.
**We may disclose your personal information to our security monitoring providers, data analytics providers, database hosting vendors and our auditors.
Geolocation Information†
†The information we collect may include your geolocation.
††We may disclose your personal information to our security monitoring providers, data analytics providers, database hosting vendors and our auditors.
Internet or Other Electronic Network Activity Information ‡
‡The information we collect may include your time zone setting, auth0 logs, pages visited, pages viewed, events and page loads, browser plug-in types and versions.
‡‡We may disclose your personal information to our marketing services vendors, security monitoring providers, data analytics providers, database hosting vendors and our auditors.
Device Information⁂
⁂The information we collect may include your operating system and platform, device ID, and other technology on the devices you use to access the Website.
⁂⁂We may disclose your personal information to our security monitoring providers, data analytics providers, database hosting vendors and our auditors.
Deidentified and Aggregated Information
We may process your personal information into aggregated, anonymized or de-identified form for any purpose. Aggregated, anonymized or de-identified information is information that can no longer reasonably identify a specific individual and is no longer “personal information.” We will only maintain and use this type of information in deidentified form and we will not attempt to reidentify this information, except for the purposes of validating our deidentification process.
How Can I Disable or Remove Cookies
You can restrict the use of cookies on this website by visiting this “Cookie Notice.” A link to this “Cookie Notice” will be provided at the bottom of all webpages on the Site.
Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. If you choose to disable cookies, it may limit your use of certain features or functions on our Website. If you wish to restrict or block the cookies which are set by any website, including this Website, you should do this through each individual browser setting and on each device you use to access the Internet. You can allow cookies from specific websites by making them “trusted websites” in your Internet browser. The following links may be helpful to understand how you can change your browser settings to restrict the websites that can set cookies, or to stop your browser accepting cookies. The ‘Help’ option in your browser may also have further details.
Cookie settings in Chrome Cookie settings in Firefox Cookie settings in Internet Explorer Cookie settings in Safari web Cookie settings in iOS
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on our Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us by using the information provided under Contact Us. Please delete all Koddi related cookies and restrict further collection of cookies using the methods outlined in How Can I Disable or Remove Cookies.
We may retain your personal information for a period of time that is consistent for us to perform our Services, as well as to comply with applicable law, applicable statute of limitations and our data retention practices. We may also retain your personal information as we believe is reasonably necessary to comply with legal process or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems, to assist with investigations, to enforce other applicable agreements or policies or to take any other actions consistent with applicable law.
You may opt-out of receiving marketing and promotional messages from us, if those messages are powered by us, by following the instructions in those messages. If you decide to opt-out, you will still receive non-promotional communications that are necessary in the performance of our Services.
Transparency and Choice
People have different privacy concerns. Our goal is to be clear about what information we collect and how we use it, so that you can make meaningful choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your personal information:
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website at optout.networkadvertising.org.
At times, our Website may provide interactive areas. You are not required to provide any personal information when using these areas, but you may choose to do so. We strongly recommend that you DO NOT use your personal information as your user name and DO NOT post any personally identifiable information on line, since such information will be publicly available. We cannot ensure the security of any information you choose to make public in a chat room, forum, or message board. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy. Please exercise caution when deciding to disclose personal information in these areas.
We use remarketing services to advertise on third party websites to you after you visited the Website. We and our service providers use cookies to inform, optimize and serve ads based on your past visits to our Website. You can opt-out of this marketing by deleting all Koddi related cookies and restrict further collection of cookies using the methods outlined in outlined in How Can I Disable or Remove Cookies.
This Website has links to other websites. Once you link to another site, you are subject to the privacy policy of the new site and its operator. We encourage you to carefully review the privacy policy of each entity to which you provide information.
We understand that the safety of your personal information is extremely important to you. Accordingly, we work hard to protect Koddi and individual’s about whom we collect personal information from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
What Data Rights Do You Have?
There are a number of U.S. states that provide specific data rights to residents of those jurisdictions regarding their personal information. This section of this Policy describes the rights available to those individuals who are entitled to them. If you have questions, or want more information about how to exercise your data rights, please contact us using the information provided under the section titled Contact Us.
If you a resident of California, you have access to special data rights and disclosures that are described in this Policy under a separate section titled Data Rights For California Consumers.
If you are a consumer living in Colorado, Connecticut, Nevada or Virginia, you have the following rights with regards to your personal information. These rights are explained in further detail below.
How To Submit A Request
You can submit your request to exercise a data right through either of the below:
We recognize the Global Privacy Control (GPC) browser setting that allows individuals to automatically signal their opt-out of the sale of their personal information or sharing of their personal information for the purposes of targeted advertising. You can opt-out of this sale or share by activating the opt-out preference signal or Global Privacy Control (GPC) on your browser. More information regarding GPC is available here.
How We Process Data Rights Requests
Once we receive your request to exercise a right, we will confirm receipt and begin to evaluate, and if appropriate, process the request. Please note that:
If you fail or refuse to provide the necessary information, we may not be able to process your request.
If we reject a request for any reason, we will inform you of the basis of the rejection. We may not be able to comply with your request for a number of reasons, including:
If any of the above reasons apply, we will let you know in our response to your request.
Submitting A Request Through Browser Controls Or An Authorized Agent
Further, you may designate an authorized agent to make a request to “out-opt” of sale, profiling or targeted advertising, as those rights are described above. An authorized agent should make a request through the same mechanisms that are available to individuals as described in this policy. The request should clearly identify that the request is being made by an authorized agent and must include evidence of authorization. If we receive a request from an individual or an entity purporting to making the request on behalf of another individual, we can only comply with the request if we are able to sufficiently authenticate both the identity of the individual as well as the authorized agent’s authority to act on that individual’s behalf. California has special rules regarding submitting requests through agents, so please review the appropriate disclosure in the section titled Data Rights For California Consumers.
Appeals And Complaints
If you disagree with our decision to reject your request or to any portion of our request, you have the right to appeal our refusal within a reasonable period of time. If you wish to appeal, please clearly and plainly describe your basis of disagreement with our decision by responding through the same means by which we communicated our refusal or by submitting your appeal through the information provided under Contact Us. We will review your appeal and either change our decision or reject your appeal, and in either case, we will provide a written explanation of the reason for the decision. This decision will be final.
However, if you still disagree with our decision, you have the right to submit a complaint to your attorney general of your state of residence. Your attorney general will have an online portal with details regarding how to submit complaints:
The California Consumer Privacy Act (“CCPA”) provides the residents of California with the right to request the data rights as described in this section. For more information, or if you have questions, you can contact us using the information provided under Contact Us.
The categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for which we collect personal information and the categories of third parties to whom we disclose personal information are found in the general Policy under the section titled What Information We Collect And Disclose And For What Purposes.
California residents have a right to know if we are “selling” or “sharing” their personal information, what categories of personal information are “sold” or “shared,” and to whom.
We do sell and share some personal information, as these terms are defined by California law. Please review the disclosures in the section titled What Information We Collect And Disclose And For What Purposes for more information.
However, we do not use or disclose your “sensitive” personal information for any purpose other than for the specific purposes described under the CCPA regulation § 7027(m) and always in a manner reasonably necessary and proportionate for these permitted purposes. For information on how we use or disclose your “sensitive” personal information, please see the applicable disclosures in the section titled: What Information We Collect From You And For What Purposes.
California residents can designate an authorized agent to make requests under the CCPA on their behalf relating to the residents’ personal information. Only you as a California resident, or a person you have designated in writing as your authorized agent, may make a consumer request related to your personal information.
If you wish to have an authorized agent make a verifiable consumer request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your authorized agent, such as a power of attorney pursuant to California Probate Code sections 4000 to 4465. We will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we have collected personal information. We can deny any request made by a purported authorized agent who does not submit proof that they has been authorized by the California resident to act on the California resident’s behalf.
As we provide more services and/or functionality on our Website and as privacy laws and regulations evolve, it may be necessary to revise or update our Privacy Policy. It is our policy to post any changes we make to our Policy with a notice that the Policy has been updated on the Website home page. If we make material changes to how we treat our users’ Personal Information, we will notify you through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Privacy Policy to check for any changes. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.
To submit questions or to inquire about or submit a request relating to data rights, you can contact us by:
INTERNATIONAL PRIVACY POLICY
The above general Policy still applies to those individuals who reside outside of the United States or who have had personal information collected by Koddi, Inc. or its agents (“Koddi”, “us,” “we” or “our”) in a country other than the United States. However, due to various international regulations, those individuals may be entitled to additional disclosures and rights. This International Privacy Policy (the “International Policy”) supplements the above general Policy, but where the provisions of the general Policy and this International Policy cannot be construed consistently, this International Policy will govern.
Please note that by visiting the Website or by having personal information collected by us, your personal information is being stored or processed in the United States where our data center and servers are located and operated. The United States may not have privacy laws that are as strong or comprehensive as the privacy laws in your own country. Your personal information may also be stored in a multi-tenant cloud environment hosted by our service providers.
Depending on your country of residence, you may have data rights as provided by various laws, regulations and codes, which can include the Canadian Personal Information Protection and Electronic Documents Act, the European Union General Data Protection Regulation, the UK Data Protection Act 2018, the Swiss Revised Federal Act on Data Protection 1992 and Ordinance on the Federal Act on Data Protection, the New Zealand Privacy Act 2020, the Japanese Amended Act on Protection of Personal Information or the Australian Privacy Act 1988, among others. An interactive map showing the various privacy and protection laws around the world can be found here.
THIS INTERNATIONAL POLICY APPLIES TO ALL PERSONAL INFORMATION ABOUT YOU THAT WE COLLECT, HOLD, USE AND DISCLOSE, REGARDLESS OF THE WAY IN WHICH WE COLLECT IT (I.E. WHETHER THROUGH THE WEBSITE, THE SERVICES OR OTHERWISE).
Our International Policy includes:
You can find specific details about the personal information that we collect about you in the section titled What Information We Collect And Disclose And For What Purposes of the general Policy.
Where we are the data controller with regards to the personal information that we process, you may exercise your rights as a data subject, including the right to object to the processing of your personal information when it is processed based on legitimate interests, as described in this International Policy. However, when providing services to our customers, we primarily collect and process your personal information as a processor or service provider on behalf of our customers. This means that we collect, process and disclose your personal information at the direction of our customers. Where we are collecting your personal information on behalf of another entity (i.e., we are not the data controller), we will provide you with the identity of the data controller to the extent we are required to do so by law.
As a general matter, we collect your personal information to perform our Services and administer our Website. You can find specific details about the purposes for which we collect personal information about you in the section titled What Information We Collect And Disclose And For What Purposes.
We will only collect and process your personal information as is reasonably necessary for, or directly related to, one or more of our functions or activities, including for administering our Website or providing our Services to you or our customers. You can find specific details about the purposes for which we collect personal information about you in the section titled: What Information We Collect From You And For What Purposes of the general Policy.
Except when otherwise permitted by law or binding regulation, we will obtain the requisite consent from you prior to collecting and, in any case, prior to using or disclosing your personal information for any purpose other than as disclosed in this International Policy. You may provide your consent to us orally, in writing, by electronic communication, through your actions or any other means reasonably capable of conveying your consent.
Generally, we will seek to obtain your explicit consent if we collect, use or disclose sensitive personal information about you. However, your refusal to provide consent for collection (or your withdrawal of previously given consent) or to give your personal information when requested, can have negative consequences. For example, if you do not give consent for our collection of cookies, then the Website will not remember your preferences. In another example, if you do not provide your personal information when requested we may not be able to provide you with requested materials, disclosures or Services.
We remain responsible for all personal information communicated to other entities for processing on our behalf. As such, we ensure that other entities that are engaged to provide products or services on our behalf and are provided with personal information are required to observe the intent of this International Policy by having comparable levels of security protection or, when required, by assuring us (through a confidentiality agreement) that they will not use or disclose the personal information for any purpose other than the purpose for which the personal information was communicated. You can find specific details about to whom we disclose your personal information in the section titled What Information We Collect And Disclose And For What Purposes.
We only collect the personal information necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes or as required by law.
We do not use or disclose your personal information, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law.
We do not, as a condition of providing the Website or performing the Services, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal information beyond what is reasonably required for such purposes, or to comply with our obligations under applicable law or regulation.
We may keep a record of your personal information, including correspondence or comments, in a file specific to you. We will utilize, disclose, or retain your personal information only for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. We will establish minimum and maximum retention periods and procedures for maintaining and destroying your personal information. When personal information is retained to make a decision about you, we will retain such information for the period required in order to comply with our internal data retention policies.
There are a number of data privacy laws that provide specific data subject rights to residents of certain jurisdictions. This section of this International Policy describes the rights available to those individuals who are entitled to them. Not all individuals about whom we possess information will have access to these rights and we may not be able to provide these rights to everyone due to legal and jurisdictional limitations. We may not be able to comply with your request for a number of reasons, including:
If any of the above reasons apply, we will let you know in our response to your request. Note that we may be required to gather additional information from you in order to process your request. We will only use this information in the context of evaluating and responding to your request. If you fail or refuse to provide the necessary information, we may not be able to process your request.
Subject to the exceptions provided by applicable law or regulation, and depending on your country of residence, you may have the following rights regarding your personal information:
Finally, you have the right to raise a complaint with us or the appropriate data protection authority of your country of residence if you feel that our processing of your personal information violates your individual rights, is not in line with this International Policy or violates the privacy principals, laws or regulations of your country of residence.
You can request to exercise these rights by using the information provided under Contact Us. Please be as specific as possible in your request so that we can meet the applicable handling timelines.
We will make every reasonable effort to respond to your written request not later than 30 days after receipt of such request. We will advise you in writing if we cannot meet your request within this time limit. When applicable, you have the right to make a complaint to the appropriate supervisory authority, as detailed in this International Policy, with respect to this time limit.
We expect to be able to respond to your request without charge as a general matter. However, where allowed by law, we reserve the right to collect a reasonable charge when you request the transcription, reproduction or transmission of such information. We will notify you, following your request of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request.
We may require that you provide to us additional information to identify yourself before we provide information about the existence, use or disclosure of your personal information in our possession. Any such information that you provide to us shall be used only for this purpose.
You may opt-out of receiving marketing and promotional messages from us, if those messages are powered by us, by following the instructions in those messages. If you decide to opt-out, you will still receive non-promotional communications that are necessary to maintain the existing business relationship between you and Koddi, to the extent there is one.
We use remarketing services to advertise on third party websites to you after you visited the Website. We and our service providers use cookies to inform, optimize and serve ads based on your past visits to our Website. We only engage in remarketing with your consent through the acceptance of a cookie banner when you access appropriate webpages. You can opt-out of this marketing by deleting all Koddi related cookies and restrict further collection of cookies using the methods outlined in outlined in How Can I Disable or Remove Cookies.
We will use reasonable efforts to ensure that your personal information is kept as accurate, complete and up to date as possible. We do not routinely update your personal information in our possession, unless such a process is necessary. In order to help us maintain and ensure that your personal information is accurate and up to date, you must inform us, without delay, of any change in the data that you have provided to us.
You can at any time, challenge the accuracy or completeness of the personal information we have about you, subject to the exceptions provided by applicable law. If you demonstrate that the personal information we have on you is inaccurate or incomplete, we will amend the personal information as required. Where appropriate, we will transmit the amended data to third parties to whom we have communicated your personal information.
We use security safeguards appropriate to the sensitivity of personal information to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as security clearances and publishing this policy to appropriate personnel with instructions to act in accordance with its principles (for example, limiting access on a “need to know” basis), and technological measures, such as the use of passwords and/or encryption.
To submit questions or to inquire about or submit a request relating to data rights, our privacy office can be contacted at dataprivacy@koddi.com.