November 23, 2020
Thank you for choosing to be part of our community at
, doing business as
codex, by jbrew
codex, by jbrew
"we", "us", "our"). We are committed to protecting your
personal information and your right to privacy. If you have any questions or concerns about this privacy
notice, or our practices with regards to your personal information, please contact us at
visit our website
and more generally, use any of our services (the "Services",
which include the
appreciate that you are trusting us with your personal information. We take your privacy very seriously.
In this privacy notice, we seek to explain to you in the clearest way possible what information we
collect, how we use it and what rights you have in relation to it. We hope you take some time to read
through it carefully, as it is important. If there are any terms in this privacy notice that you do not
agree with, please discontinue use of our Services immediately.
This privacy notice applies to all information collected through our Services (which, as described above, includes our
), as well as, any
related services, sales, marketing or events.
Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you
register on the
express an interest in obtaining information
about us or our products and Services, when you participate in activities on the
or otherwise when you contact
The personal information that we collect depends on the context of your interactions with us and the
, the choices you make and the products and features you use. The personal information we
collect may include the following:
Personal Information Provided by You. We collect
and other similar information.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our
We automatically collect certain information when you visit, use or navigate the
. This information does not reveal your specific identity (like your name or
contact information) but may include device and usage information, such as your IP address, browser
and device characteristics, operating system, language preferences, referring URLs, device name,
country, location, information about how and when you use our
and other technical information. This information is primarily needed to maintain
the security and operation of our
, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
- Log and
Usage Data. Log and usage data is service-related, diagnostic, usage and performance
information our servers automatically collect when you access or use our
Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
Data. We collect device data such as information about your computer, phone, tablet or
other device you use to access the
Website . Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our
for a variety of business purposes described below. We process your personal
information for these purposes in reliance on our legitimate business interests, in order to
enter into or perform a contract with you, with your consent, and/or for compliance with our
legal obligations. We indicate the specific processing grounds we rely on next to each purpose
We use the information we collect or receive:
facilitate account creation and logon process. If you choose to link your
account with us to a third-party account (such as your Google or Facebook account), we use
the information you allowed us to collect from those third parties to facilitate account
creation and logon process for the performance of the contract.
post testimonials. We post testimonials on our
Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at [email protected] and be sure to include your name, testimonial location, and contact information.
- Request feedback. We may use your
information to request feedback and to contact you about your use of our
enable user-to-user communications. We may use your information in order to
enable user-to-user communications with each user's consent.
manage user accounts. We may use your information for the purposes of
managing our account and keeping it in working order.
send administrative information to you. We may use your personal
information to send you product, service and new feature information and/or information
about changes to our terms, conditions, and policies.
protect our Services. We may use your information as part of our efforts
to keep our
Website safe and secure (for example, for fraud monitoring and prevention).
enforce our terms, conditions and policies for business purposes, to comply with legal
and regulatory requirements or in connection with our contract.
- To respond to
legal requests and prevent harm. If we receive a subpoena or other
legal request, we may need to inspect the data we hold to determine how to respond.
- Fulfill and
manage your orders. We may use your information to fulfill and manage
your orders, payments, returns, and exchanges made through the
- Administer prize
draws and competitions. We may use your information to administer prize
draws and competitions when you elect to participate in our competitions.
- To deliver and
facilitate delivery of services to the user. We may use your information to
provide you with the requested service.
- To respond to
user inquiries/offer support to users. We may use your information to
respond to your inquiries and solve any potential issues you might have with the use of
- For other business
purposes. We may use
your information for other business purposes, such as data analysis, identifying
usage trends, determining the effectiveness of our promotional campaigns and to
evaluate and improve our
Website , products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
- Consent: We may process your data if
you have given us specific consent to use your personal information for a specific
- Legitimate Interests: We may process
your data when it is reasonably necessary to achieve our legitimate business
- Performance of a Contract: Where we
have entered into a contract with you, we may process your personal information to
fulfill the terms of our contract.
- Legal Obligations: We may disclose
your information where we are legally required to do so in order to comply with
applicable law, governmental requests, a judicial proceeding, court order, or legal
process, such as in response to a court order or a subpoena (including in response
to public authorities to meet national security or law enforcement
- Vital Interests: We may disclose your
information where we believe it is necessary to investigate, prevent, or take action
regarding potential violations of our policies, suspected fraud, situations
involving potential threats to the safety of any person and illegal activities, or
as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than
the period of time in which
users have an account with us
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our
is at your own risk. You should only access the
within a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the
you represent that you are at least 18 or that you are the
parent or guardian of such a minor and consent to such minor
dependent’s use of the
If we learn that personal information from users less than 18
years of age has been collected, we will deactivate the account
and take reasonable measures to promptly delete such data from
our records. If you become aware of any data we may have
collected from children under age 18, please contact us at
8. WHAT ARE YOUR PRIVACY RIGHTS?
In some regions, such
as the European Economic Area, you have rights that allow
you greater access to and control over your personal
You may review,
change, or terminate your account at any time.
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
If you have questions or comments about your privacy rights, you may email us at
If you would at any time like to review or change the information in your account or terminate your account, you can:
Contact us using the contact information provided.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our
To opt-out of interest-based advertising by advertisers on our
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:
Contact us using the contact information provided.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with
you have the right to request removal of unwanted data that you
publicly post on the
To request removal of such data, please contact us using the
contact information provided below, and include the email
address associated with your account and a statement that you
reside in California. We will make sure the data is not publicly
displayed on the
but please be aware that the data may not be completely or
comprehensively removed from all our systems (e.g. backups,
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name
B. Personal information categories listed in the California Customer Records statute
Name, contact information, education, employment, employment history and financial information
C. Protected classification characteristics under California or federal law
Gender and date of birth
D. Commercial information
Transaction information, purchase history, financial details and payment information
E. Biometric information
Fingerprints and voiceprints
F. Internet or other similar network activity
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements
G. Geolocation data
H. Audio, electronic, visual, thermal, olfactory, or similar information
Images and audio, video or call recordings created in connection with our business activities
I. Professional or employment-related information
Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us
J. Education Information
Student records and directory information
K. Inferences drawn from other personal information
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:
Receiving help through our
customer support channels;
Participation in customer
surveys or contests; and
Facilitation in the delivery
of our Services and to respond to your
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice
You may contact us
by email at
or by referring to the contact
details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data.
Your rights with respect to your personal data
Right to request deletion of the data - Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.
Right to be informed - Request to know
Depending on the circumstances, you have a right to know:
- whether we collect and
use your personal information;
- the categories of
personal information that we collect;
- the purposes for which
the collected personal information is used;
- whether we sell your
personal information to third parties;
- the categories of
personal information that we sold or disclosed for a
- the categories of
third parties to whom the personal information was
sold or disclosed for a business purpose; and
- the business or
commercial purpose for collecting or selling
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
- you may object to the
processing of your personal data
- you may request
correction of your personal data if it is incorrect
or no longer relevant, or ask to restrict the
processing of the data
- you can designate an
authorized agent to make a request under the CCPA on
your behalf. We may deny a request from an
authorized agent that does not submit proof that
they have been validly authorized to act on your
behalf in accordance with the CCPA.
- you may request to
opt-out from future selling of your personal
information to third parties. Upon receiving a
request to opt-out, we will act upon the request as
soon as feasibly possible, but no later than 15 days
from the date of the request submission.
To exercise these rights, you can contact us
at [email protected]
or by referring to the contact
details at the bottom of this document. If you have a complaint
about how we handle your data, we would like to hear from
11. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may
contact our Data Protection Officer
James Bradley Ross
, by email at
by phone at
or by post to:
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please
visit: [email protected]
. We will
respond to your request within 30 days.