For General Data Protection Regulation (“GDPR”) purposes, the “data controller” means the person or organization who decides the purpose for which and the way in which any personal data is processed.
The data controller is Code and Theory and Code and Theory’s data protection officer is Ben Cifuentes, IT Support Technician, who can be reached at firstname.lastname@example.org.
For GDPR a “data processor” is a person or organization which processes personal data for the controller. Data processing is any operation or set of operations performed upon personal data or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organizing, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.
What information do we collect about you and how?
Code and Theory, as a data controller, may collect and store personal information that you choose to voluntarily provide to us when you contact us. Personal information includes, but is not limited to, your name, residential or business address, email address or phone number.
If you communicate with Code and Theory through any contact link on our Site, we may ask you for information such as your name, email address and telephone number so we can respond to your questions and comments.
Further information in relation to job application privacy can be found here.
Code and Theory also automates information collection through the following means:
We are committed to making your online experience with our Site informative and relevant. To achieve this, we collect an IP or Internet Protocol Address, which is a unique numerical address assigned to a computer as it logs on to the internet. Code and Theory does not have access to any personal identifiable information and we would never seek this information. Your IP address is logged when visiting our site, but our analytic software only uses this information to track how many visitors we have from particular regions. By collecting this information, we learn how to best tailor this Site to our visitors. We collect this information by various means, as explained below.
Cookies are text files put on your computer to collect standard log information and visitor behavior information. This information is then used to track visitor use of the website and to create statistical reports of website activity. For more information visit www.aboutcookies.org. You can set your browser not to accept cookies and the above website will tell you how to remove cookies from your browser.
We may also use third-party solutions to conduct web analytics, such as Google Analytics. Google Analytics is a service offered by Google Inc. (“Google”) that generates detailed statistics about a website's traffic and traffic sources and measures conversions and sales. Google Analytics uses “cookies” stored on your computer to help analyze how users use our website. The information generated by the cookies about your use of our website, including your IP address, will be anonymized by use of the appropriate settings (“_anonymizelp()” function or equivalent) and transmitted to Google servers in the United States. For more information on how IP anonymization works please see https://support.google.com/analytics/answer/2763052. These cookies do not store any personal information about you, such as your name and address. Google utilizes the statistics to monitor your use of this Site in order to compile information on website activity for website operators and providing other services pertaining to website activity and internet usage. Please be aware that Google may transfer this information to third parties where required by law, or where such third parties process information on Google’s behalf.
Use of The Information We Collect
At Code and Theory we take your privacy seriously and will only use your personal information for the purposes listed below. For prospective clients, our lawful reason for processing your personal information will be “legitimate interests”. Under “legitimate interests” we can process your personal information if We have a genuine and legitimate reason and We are not harming any of your rights and interests.
We may use information about you for various purposes, including to:
- Communicate with you with newsletters and/or industry updates;
- Respond to your comments, questions and requests;
- Provide Security alerts for the other purposes listed here;
- Monitor and analyze trends, usage and activities (including anonymized usage of personal information);
- In order to confirm compliance with any and all applicable legal requirements and industry standards and our policies; and
- Carry out any other purpose for which the information was collected. We will identify these other purposes at the time of collection.
Non-disclosure of Information
Security of The Information and Data Integrity
We take appropriate technical and organizational measures to protect personal information against accidental, unlawful destruction or accidental loss, alteration, unauthorized use, disclosure or access, in particular where the processing involves the transmission of data over a network and against all other unlawful forms of processing and misuse. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information to you transmit to us. Code and Theory restricts authorized access to your personal information to those persons who have a legitimate purpose to know that information to provide products or services to you and those persons you have authorized to have access to such information.
This Site may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked sites may have their own privacy policies or policies, which we strongly encourage you to review to better understand their procedures for collecting, using and disclosing personal information. We are not responsible for the content of the linked websites, any use of these sites, or the privacy practices of these sites.
Protection of Children’s Personal Data
The Site is not directed to children under 13. We do not knowingly collect, use or disclose personally identifiable information from anyone under 13 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her personal information without the parent/guardian’s consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 13, we will make reasonable efforts to delete such information from our records.
Right to Request Correction, Transfer and Deletion of Your Information
Otherwise in accordance to any and all applicable laws, you may have the right to request access to and receive information about the personal information that we maintain about you, update and correct your personal information and have the information modified or deleted, as applicable. Please be aware that your right to access personal information may be limited in some circumstances by applicable law requirements. To update your information or submit a request, please send your request to email@example.com. For verification purposes, we may require proof of identity in order to confirm that you are the individual entitled to request access, before providing information to you.
It is your right to lodge an objection to the processing of your personal data if you feel the “ground relating to your particular situation” apply. The only reasons We will be able to deny your request is if we can show compelling legitimate grounds for the processing of your information, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
It is also your right to receive the personal data which you have given Code and Theory, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if (i) the processing is based on consent or a contract and/or (ii) the processing is carried out by automated means.
Should you wish for us to completely delete all information that we hold about you please email firstname.lastname@example.org.
Length of Data Retention
We will hold your data for a period of 6 years. You will have the opportunity to opt out or update at any point as set forth herein.
If you feel that your personal data has been processed in a way that does not meet the GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory authority will then tell you of the progress and outcome of your complaint.
Privacy Notice for California Residents
Effective Date: December 2019
Information We Collect
Our Website collects 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, our website has collected the following categories of personal information from its consumers within the last twelve (12) months:
Category A: Identifiers
Examples: A real name, email address, or other similar identifiers.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Category C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
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; and
-- 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 you. For example, from forms you complete on our website.
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 you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry.
- To provide you with support and to respond to your inquiries.
- 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.
- We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose.
Sales of Personal Information
In the preceding twelve (12) months, Company had not sold 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 (Note: Code and Theory does not sell personal information for any business purpose):
-- 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 provider(s) to:
- 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.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- 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.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- 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 sending us a message on our website. 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.
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.
- 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. 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 forty-five (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. 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, specifically by electronic mail communication.
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.
Personal Information Sales Opt-Out and Opt-In Rights
Code and Theory does not sell your personal information.
In the event that Code and Theory does begin to engage in personal information sales, this website will be updated to provide you with information to exercise your right of opt-out and opt-in with respect to sales of your personal information.
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.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message through our website or write us at our address listed on our webpage.
Changes to Our Privacy Notice
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 post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
- Via email: email@example.com
- Write us at our New York address listed on our webpage.
- Or call us toll-free at 866.467.8688 and entering service code 222#