Privacy Policy

This Privacy Policy tells you about Codesmart Inc (hereafter CSI), also known as CSIs’ policies and practices for the collection, use, processing, storage, transfer, and disclosure of Personal Information that we may collect or observe. CSI collects or observes information through a variety of different contexts (collectively referred to as the “CSI”), and how we use, process, store, transfer, and disclosure of Personal Information varies based on the context through which it was collected.

Personal information in context

CSI collects personal information in a variety of contexts, each of which is defined below. The categories of information, types of information, sources of information, and our purposes for collecting, processing, using, and sharing such information are determined based on this context.

  • Websites CSI collects Personal Information through our websites, including, but not limited to, the website or subdomains of https://codesmartinc.com/(e.g., our group site or Workshop sites) or any website that posts this policy (collectively, the “Sites”). Personal Information collected through a website, but in a different context defined in this Policy, such as the Interactions with Job Applicants Context or Products and Services context, is treated in compliance with the stated context and not the Websites Context.
  • Products and Services CSI collects Personal Information through your use of products and services made available to you by us. This includes software (including software for mobile devices or “apps”), cloud data services, professional services, and support services.
  • Social Media CSI collects Personal Information through your use of our social media pages and apps, through HTML-formatted email messages that link to this Privacy Policy, through your interactions with third-party social media (such as LinkedIn, Facebook, Instagram, or Twitter), and when you publicly post using CSI services and solutions related hashtags.
  • Interactions with Job Applicants CSI collects Personal Information when you apply for a job at CSICareers interact with our third-party partners (such as LinkedIn) postings of job openings at CSI, or provide information to our internal or external recruiters via email or web forms.
  • Market Research CSI collects Personal Information from third-party service providers for the purpose of market research, product research, targeted advertising, and business development.
  • Offline When you interact in person with representatives from CSI, such as at an event we host or participate in or when you place an order over the phone or contact customer service by phone, you may disclose, or we may observe or infer Personal Information about you that you did not directly state.

CSI collects personal information in a variety of contexts, each of which is defined below. The categories of information, types of         information, sources of information, and our purposes for collecting, processing, using, and sharing such information are determined based on this context.

Offline When you interact in person with representatives from CSI, such as at an event we host or participate in or when you place an order over the phone or contact customer service by phone, you may disclose, or we may observe or infer Personal Information about you that you did not directly state.

Categories of personal information and types of information defined

“Personal Information” is information relating to, directly or indirectly, an identified or identifiable natural person or household. This includes things like your name, postal address, telephone number, and email address, as well as less obvious information, which are included in the following defined categories. We plan to collect, and have collected within the preceding 12 months, the following categories of Personal Information:

  • Individual Identifiers This includes information like your name, email address, physical address, telephone number, login alias, IP  address, or Other Information that identifies you regardless of your relationship to CSI.
  • Customer Records This includes information like your company name, job title, account number, customer identifier, or Other           Information that relates to you as a customer of CSI.
  •  Education information This includes information about your educational history, such as the schools you have attended, the courses of   study you followed, the status of any required continuing education for professional licensing, or Other Information relating to your  education.
  • Commercial Information This includes payment card data, financial account information, account information, records of products or  services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies of the customer, and Other  Information necessary to collect and process payment for products and services ordered by the customer.
  •  Electronic Network Information This includes information like browser and device data, and internet or network activity               information, such as activity on our Websites and Services, data collected through cookies, pixel tags and other technologies, and Other  Information that is generated through your use of the internet to access our websites.
  • Geolocation Data This includes information such as your precise location or city, state, county, or country, if you have such geolocation  data enabled when using the applicable social media application. For example, if you use Facebook to “Check-In” at a CSI-run event, we can collect that information.
  •  Audio, electronic, visual, or similar information This includes information that is captured on audio or video recording, such as if  a telephone or video call is recorded, or simply observable in such interaction or in an Offline Context
  •  Professional and Employment Related Information This includes your contact details, username, and password to be able to  access the Careers Site where you can apply for jobs, and information about your current or past employers, memberships in professional associations or trade unions, and professional licensing status if you make such information publicly available in the context from which  the Personal Information is collected, such as in your publicly available social media accounts, through a resume submitted to us, or by attending a professional event associated with an affinity group. This may also include your work authorization status, skills, information  relating to references, and any other information you elect to provide to us (e.g., employment preferences, willingness to relocate, current     salary, desired salary, awards or professional memberships)
  • Sensitive Information Protected under Law This includes characteristics of protected classifications under law, such as information about your age, race, religion, gender, gender identity, sexual preference, disability, political preference, trade union membership, philosophical views, marital status, medical or health information, genetic or biometric information, biometric templates, veteran status, background check information, judicial data or information on other judicial or administrative proceedings, or other pieces of information of particularly sensitive nature, if you make such information publicly available in the context from which the Personal Information is collected, such as in your publicly available social media accounts, through a resume submitted to us, or by attending a professional event associated with an affinity group.
  • “Other Information” means any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as the browser and device data, App usage data, data collected through cookies, pixel tags and other technologies, demographic information, and other data provided by you that does not reveal your specific identity, or other types of information that has been aggregated in a manner such that it no longer reveals your specific identity.

Categories of sources of information defined

  • Original Sources Information provided by an individual about that individual.
  • Customer Sources Information provided about an individual by a customer, such as when one employee of a customer provides information about a colleague in the course of setting up services. For example, a storage administrator for a customer entity may set up administrative accounts for their colleagues that include providing their colleagues’ email addresses and telephone numbers.
  • Third Party Sources Information collected from third-party sources, such as publicly available databases, social media, third-party providers of market research data, and our affiliates, business, and joint marketing partners who share information with us.
  • Services Sources Information sent to CSI by our services because you use our services.

Sale of personal information

CSI does not sell Personal Information collected in any Context under this Privacy Policy

Collection, use, and disclosure of personal information

The following disclosures reflect our treatment of personal information collected in the defined Contexts in which we do business

Websites

  • Categories and Types of Personal Information We Collect We collect Personal Information about you when you use the Sites, including Individual Identifiers, Customer Records, Inferences, and Electronic Network Information.
  • Categories and Types of Personal Information We Collect We collect Personal Information about you when you use the Sites, including Individual Identifiers, Customer Records, Inferences, and Electronic Network Information.

Products and services

CSI products and services send a variety of information to CSI in accordance with the product documentation and contracts for sales. This information is classified as follows, and as further defined in the sales contracts:

  • Customer Content Any information provided by Customer that CSI may operate on, where such operation is on the Customer’s behalf as part of providing Products or Services.
  • Functional Data Data, which does not contain Customer Content, which is generated by CSI’s providing the Product or Service, and which informs CSI in the development, deployment, operations, maintenance, and securing of the Product or Service.
  • Support Information Information, which is not Customer Content, provided to CSI by or for a customer for the purpose of providing technical support pertaining to the Product or Service and/or maintaining a Customer’s Product or Service.

Personal Information may be included in any of these data classifications. However, CSI only collects Functional Data and Support Information because Functional Data and Support Information are necessary for us to provide the products and services to you. We will process Customer Content in accordance with the applicable service terms, but this data is not specifically collected by CSI.

  • Categories and Types of Personal Information We Collect We collect Personal Information about you when you use the Products or Services, including Individual Identifiers, Customer Records, Electronic Network Information, Inferences, and Commercial Information.
  • Categories of Sources of Personal Information Personal Information collected in the Products and Services context is collected from Original Sources, Customer Sources, Product Sources, Services Sources, and Third-Party Sources
  • The purpose for Collecting and Basis for Processing Personal Information CSI collects and processes Personal Information collected through the Products and Services solely for the purpose of providing the services and commercial purposes ancillary to providing the products or services, and CSI will not retain, use, or disclose Personal Information collected through the Products or Services except as stated in this Privacy Policy.
  • Categories of Third Parties with Whom We Share Personal Information CSI uses third-party service providers and subprocesses to provide services on our behalf and may share Personal Information collected by the Products and Services with them to assist them in providing these services. These can include providers of services such as website hosting, data analysis, payment processing, order fulfilments, information technology, and related infrastructure provision, customer service, email delivery, auditing, and other services. We also may share Personal Information with channel partners or resellers if you inquire about our products or services typically fulfilled through channel partners or resellers. These channel partners or resellers may also use this information to inform you about third-party products or services that may be of interest. CSI uses third-party service providers and subprocesses in the provision of the Products and Services.
  • Third-Party Advertisement Personal Information collected through the Products and Services is not used for advertisement purposes.

Social media

  • Categories and Types of Personal Information We Collect We collect Personal Information about you in Social Media context including Individual Identifiers, Customer Records, Inferences, Electronic Network Information, Geolocation Data, Professional and Employment Information, and Sensitive Information Protected under the Law.
  • Categories of Sources of Information Personal Information collected in the Social Media context is collected from Original Sources, Third-Party Sources, and Customer Sources.
  • Third-Party Advertisement In addition to the third-party advertising companies we use to serve advertisements regarding goods and services that may be of interest to you when you access and use social media, a third-party social media provider may provide further advertising. Please review third party social media privacy policies for their advertisement and privacy policies.

Website security commitments

  • Data Protection: We are committed to implementing robust security measures to protect the confidentiality, integrity, and availability of user data. This includes employing encryption, access controls, and regular security audits.
  • Secure Transmission: We prioritize secure transmission of data between your systems and the web destinations. This involves using HTTPS encryption protocols, SSL certificates, and staying up to date with the latest security standards.
  • User Authentication: We implement strong user authentication mechanisms, such as password policies, advanced password protection and multi-factor authentication, to prevent unauthorized access to user accounts.
  • Regular Updates and Patches: We proactively monitor security vulnerabilities and apply necessary updates and patches to your systems, and networks to maintain a secure environment.
  • Privacy Policies: We have clear and transparent privacy policies that outline how user data is collected, stored, and used. We respect user preferences regarding data handling and adhere to relevant data protection laws.
  • Security Incident Response: In the event of a security incident, we have established incident response procedures to promptly address and mitigate any potential impact. We communicate openly and transparently with affected users and take steps to prevent similar incidents in the future.
  • Employee Training: We prioritize ongoing training and awareness programs to educate our employees about the importance of website security. This helps to ensure a culture of security-conscious individuals within our organization, and also sharing awareness mails every week to educate the organisational employees to create awareness.

Interactions with job applicants

  • Retention The criteria used to determine our retention periods for job applicants’ Personal Information are: (i) the duration of the application process; (ii) as long as we have an ongoing working relationship with you; (iii) as required by a legal obligation to which we are subject; (iv) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations). Your Personal Information will be added to CSI’s internal candidate database and can be retained and used to consider you for opportunities at CSI and its affiliates other than the one(s) for which you apply. If you do not wish us to do this, please contact us at info@CodeSmartInc.com
  • Law Applicable to Job Application The Careers Site allows you to apply for jobs worldwide, as a benefit of CSI’s centralized global recruitment function. This Careers Site is operated from India. Accordingly, any Personal Information you submit to the Careers Site will be collected in India and will be subject to the Republic of India. laws. However, if we share your Personal Information with an affiliate located in another country in the Interactions with Job Applicants context, the affiliate will handle your personal information in accordance with this Policy. Any hiring or other employment-related decisions will be made by the hiring affiliate in accordance with the law of the country where the job will be located.
  • Minors The Careers Site is not intended for minors under the age of 18.

Categories and Types of Personal Information We Collect We collect Personal Information about you when you interact with CSI or our service providers or contractors in the context of exploring or applying for job openings at Careers – Jobs – CodeSmartInc ,submitting applications for employment, attending job fairs or recruiting events, or otherwise engaging in employment and job application activities with CSI, including Individual Identifiers, Inferences, Employment Records, Education information, Electronic Network Information, Geolocation Data, audio, electronic, visual, or similar information, Professional and Employment Related Information, and Sensitive Information Protected under Law.

  • We will only collect this information where permitted by law
  • Any information you submit through the Careers Site must be true, complete, and not misleading. Submitting inaccurate, incomplete, or misleading information may lead to a rejection of your application during the application process or disciplinary action including immediate termination of employment. In addition, it is your responsibility to ensure that information you submit does not violate any third party’s rights.
  • If you provide us with the Personal Information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing that information to us.
  • Providing Personal Information to us through the Careers Site is voluntary. However, if you do not provide sufficient data, CSI may be unable to consider your employment application or, if you are hired, your subsequent promotion, transfer, or relocation.
  • The Careers Site is operated from India. Accordingly, any Personal Information you submit to the Careers Site will be collected in India.

Categories of Sources of Information Personal Information collected in the Interactions with Job Applicants’ context is collected from Original Sources and Third-Party Sources (such as LinkedIn and Indeed Career Builders), as well as from your prior employers and educational institutions you attended.

  • Third-Party Sources & Potential Candidates. We may use automated systems to enable us to find and recruit job candidates. These automated systems use personal information collected from Original and Third-Party Sources to determine whether an individual meets the requirements that apply for a specific job vacancy. Based on this analysis, our recruiters will be provided with an overview of the profiles that are potentially qualified for the relevant job and they will assess these recommendations and make individualized assessments as to applicant engagement and hiring.
  • Candidate Database We may keep your Personal Information in our candidate database, including updating the database from linked Third Party Sources, even if you are not hired from your original application. If you do not wish us to retain your Personal Information for future job opportunities, please contact us at info@CodeSmartInc.com Other sources may include your references, prior employers and educational institutions you attended.

The Purpose for Collecting and Basis for Processing of Personal Information Personal Information collected in the Interactions with Job Applicants context is used solely for the purposes of identifying, evaluating, screening, recruiting, and hiring candidates for employment and for business and commercial purposes ancillary to those purposes, as permitted by applicable law. This may include:

  • To process your application. We will engage in these activities to manage our prospective contractual relationship with you, based on our legitimate interests.
  • To assess your capabilities and qualifications for a job. We will engage in these activities to manage our prospective contractual relationship with you, based on our legitimate interests.
  • To conduct reference checks. We will engage in these activities to comply with a legal obligation or based on our legitimate interests.
  • To respond to your inquiries and communicate with you about your application, and to send you information regarding the Careers Site and changes to our terms and policies. We will engage in these activities to manage our prospective contractual relationship with you.
  • To comply with or monitor compliance with any applicable law or regulation. We will engage in these activities to comply with a legal obligation or based on our legitimate interests.
  • To comply with or monitor compliance with any applicable law or regulation. We will engage in these activities to comply with a legal obligation or based on our legitimate interests.
  • To preserve our other legitimate interests, for example, for administrative purposes, aggregate management reporting, internal Workshop, and as generally required to conduct our business within CSI and its affiliates.
  • If a job Applicant’s application is successful and results in hiring, Personal Information we collect in connection with the individual’s application can be incorporated into our human resources system and used to manage the new-hire process; any such information can become part of the individual’s employee file and used for other employment-related purposes.

As discussed below, in certain cases we will ask questions about Sensitive Personal Information Protected under Law for monitoring equal opportunity. We can also inquire about criminal records. We will do so only where permitted by applicable law. Otherwise, we ask that you avoid submitting data that may qualify as Sensitive Personal Information protected under Law, except where such data is legally required.

CSI is an equal opportunity employer, which means we offer equal treatment to all applicants. CSI does not discriminate, either directly or indirectly, on legally protected grounds: race, color, sex, gender identity, sexual orientation, nationality, national origin, ethnic origin, religion, beliefs or creed, age, disability, marital status, veteran status, or genetic information in any area or recruitment.

We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.

Third-Party Advertisement CSI does not use Personal Information collected in the Interactions with Job Applicants context to provide advertisements regarding goods and services.

Market research

  • Categories and Types of Personal Information We Collect We may collect or otherwise observe Personal Information from individuals in the market research context, including Individual Identifiers, Inferences, Employment Records, Education information, Geolocation Data, Audio, electronic, visual, or similar information, Professional and Employment Related Information, and Sensitive Information Protected under Law
  • Categories of Sources of Information Personal Information collected in the Market Research context is collected from Original Sources, Third-Party Sources, and Customer Sources.

Offline

  • Categories and Types of Personal Information We Collect We may collect or otherwise observe Personal Information from individuals offline, including Individual Identifiers, Inferences, Employment Records, Education information, Geolocation Data, Audio, electronic, visual, or similar information, Professional and Employment Related Information, and Sensitive Information Protected under Law.
  • Categories of Sources of Information Personal Information collected in the Offline context is collected from Original Sources, Third-Party Sources, and Customer Sources.
  • Third Party Advertisement We do not use third-party advertising companies to serve advertisements based on Personal Information we collected Offline

Purpose for collecting and basis for processing personal information

Unless otherwise limited by the context in which it was collected, Personal Information collected by CSI is used for our legitimate business purposes, including:

Accomplishing our business purposes
  • For improving the content of the CSI, for example, by incorporating information that is relevant to our clients.
  • For data analysis, for example, to improve the efficiency of the CSI
  • For audits, to verify that our internal processes function as intended and address compliance with legal, regulatory or contractual requirements.
  • For developing new products and services.
  • For enhancing, improving, or modifying our current products and services.
  • For identifying usage trends, for example, understanding which parts of the CSI are of most interest to users.
  • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
  • For operating and expanding our business activities, for example, understanding which parts of the CSI are of most interest to our users so we can focus our energies on meeting our users’ interests.
  • For identifying candidates for employment.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

Providing the functionality of the CSI and fulfilling your requests

  • To send administrative information to you, such as changes to our terms, conditions and policies and to notify customers about updates to the CSI.
  • To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you request to be registered for an event or a CSI conference.
  • To process your orders and provide you with related customer service.
  • To help you manage your Community and Support at your request.
  • To allow you to send messages to another person through the Services if you choose to do so.

We will engage in these activities to manage our contractual relationship with you and to comply with a legal obligation.

Providing you with our newsletter and/or other marketing materials and facilitating social sharing
  • To contact you for marketing and sales purposes, including notifications related to product enhancements, warranties, and renewals, that are related specifically to customer needs and interests.
  • To facilitate the social sharing functionality that you choose to use.

We will engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, or with your consent.

Analysis of Personal Information for business reporting and providing personalized services
  • To analyze or predict our users’ preferences to prepare aggregated trend reports on how our digital content is used, so we can improve our Websites and Services.
  • To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests, such as by displaying targeted advertising that might be tailored to your interests.
  • To better understand your preferences so that we can deliver content via our Websites and Services that we believe will be relevant and interesting to you.

We will provide personalized services either with your consent or because we have a legitimate interest.

Allowing you to participate in surveys, contests, or other promotions
  • To offer you the opportunity to participate in surveys, contests, or other promotions. Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information. We use this information to manage our contractual relationship with you.
  • To offer you the opportunity to participate in surveys, contests, or other promotions. Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information. We use this information to manage our contractual relationship with you.

Aggregating and/or anonymizing Personal Information

We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
Categories of third parties with whom we share personal information

Unless otherwise limited by the context in which it was collected, Personal Information collected by CSI can be disclosed to our subsidiaries for the purposes described in this Privacy Policy. CSI is the party responsible for the management of the jointly-used Personal Information.

CSI uses third-party service providers and subprocessors to provide services on our behalf and may share Personal Information with them to assist them in providing these services. These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology, and related infrastructure provision, customer service, email delivery, auditing, and other services. We also may share Personal Information with channel partners or resellers if you inquire about our products or services typically fulfilled through channel partners or resellers. These channel partners or resellers may also use this information to inform you about third-party products or services that may be of interest.

If you use communities, blogs, or chat rooms on CSI Services, you should be aware that any Personal Information you submit there can be read, collected, and used by other users of these forums, and could be used to send you unsolicited messages. You may also elect to disclose Personal Information through your social sharing activity.

How you can access, change or delete your personal information

Personal Information may be accessed, changed/corrected, or deleted directly by through the context it was collected. For example, Personal Information collected in the Products and Services context can be accessed, changed, or deleted through the features and functionality of the Products and Services, and Personal Information collected in the Interactions with Job Applicants context may be accessed, changed, or deleted through the job application tools. In the event, however, you cannot access, change/correct, or delete Personal Information through the context in which it was collected, or if you would like to restrict the use of your Personal Information, object to the processing of your Personal information or request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us at info@CodeSmartInc.com write to us at the address at the end of this document. We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to respond to your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase, you may not be able to change or delete the Personal Information provided until after the completion of such purchase).

We may exempt certain Personal Information from requests pursuant to applicable data protection laws or other laws and regulations.

Third party advertisement

Unless otherwise limited by the context in which it was collected, we use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you, including when you access and use social media.

You may receive advertisements based on information relating to your access to and use of the Websites and other websites or online services, including social media, on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. This is in addition to any advertisement that a third-party social media provider may provide. Please review third-party social media privacy policies for their advertisement and privacy policies.

Other uses and disclosures

We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable law: This can include laws outside your country of residence
  • To respond to requests from public and government authorities: These can include authorities outside your country of residence.
  • To cooperate with law enforcement: For example, when we respond to law enforcement requests and orders. For other legal reasons.
  • To enforce our terms and conditions; and to protect our rights, privacy, safety, or property, and/or that of our subsidiaries, you, or others.
  • In connection with a sale or business transaction: We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings) Such third parties may include, for example, an acquiring entity and its advisors.

Collection of other information

If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy.

Communications or utilization information

Through your use of telecommunications services to access the CSI, your communications data (e.g. Internet protocol (“IP”) address) or utilization data (e.g. information on the beginning, end, and extent of each access, and information on the telecommunications services you accessed) are technically generated. Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the CSI, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the CSI. We may also derive your approximate location and your company from your IP address.

Information collected automatically through your browser or device

When you access the PTG, we may automatically collect information such as type of Internet browser and operating system used, the domain name of the Web site from which you came, number of visits, average time spent on the site, pages viewed. We use this information to ensure the PTG function properly, monitor the relevancy of the PTG, and improve their performance or content.

Information collected automatically through your browser or device

When you access the CSI, we may automatically collect information such as type of Internet browser and operating system used, the domain name of the Web site from which you came, number of visits, average time spent on the site, pages viewed. We use this information to ensure the CSI function properly, monitor the relevancy of the CSI, and improve their performance or content.

“Cookies” – information stored automatically on your computer

A cookie is a piece of Electronic Network Information that is stored on your computer’s hard drive by your Web browser. When you revisit CodeSmartInc our server recognizes the cookie, giving us information about your prior visits. Most browsers accept cookies automatically, but you can alter the settings of your browser to prevent automatic acceptance. If you choose not to receive cookies, you can still use most of the features of the CSI, including ordering items. We do not currently respond to browser do-not-track signals.

We also use Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of the CSI and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by viewing their Privacy & Terms, and exercising the opt-out offered by ignoring the Reject option.

Clear gifs (web beacons, web bugs)

We employ software technology called clear gifs (also known as Web beacons or Web bugs) along with other technologies such as e-tags, and JavaScript that helps us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies that are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs, which are about the size of a period, are embedded invisibly on Web pages.

Uses and disclosures of other information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

Retention period

We will retain your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

  • The length of time we have an ongoing relationship with you and provide the CSI to you (for example, for as long as you have an account with us or keep using the CSI);
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

Minors

No services on the CSI are directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under sixteen (16).

Security

PTG uses reasonable and appropriate technical and organizational security measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Questions and Comments” section below.

Third party web sites and the PTG

The PTG may contain links to other Web sites or services. PTG is not responsible for the privacy, information or other practices of third parties, including any third party operating any website or service to which the PTG links, or for the content of other Web sites. The inclusion of a link on the PTG does not imply endorsement of the linked site or service by us or by our subsidiaries.

Cross-border transfers

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the CSI you understand that your information will be transferred to countries outside of your country of residence, including India, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Information

If you are located in the EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures such as Binding Corporate Rules to protect your Personal Information.

Sensitive information

Except as noted in specific contexts, we do not collect and ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion, or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the CSI or otherwise to us.

Updates to this privacy policy

As the Internet, technology and our systems mature, so will our Privacy Policy. We will post changes to our Privacy Policy on this page. Your use of the CSI following these changes means that you accept the revised Privacy Policy. Please check this page regularly to keep up-to-date.

California residents

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), if you are a California resident, you have the right to make the following requests:

Request to Know

  • You may request that we disclose to you the following information covering the 12 months preceding your request:
  • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
  • The specific pieces of Personal Information we collected about you;
  • The business or commercial purpose for collecting (if applicable) Personal Information about you; and
  • The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).

Request to Delete:

  • You may request that we delete Personal Information we collected from you

To make a Request to Know or a Request to Delete, please contact us at info@CodeSmartInc.com We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as email address, state of residency, or mailing address, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information.

If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

We do not sell and have not sold Personal Information within the preceding 12 months, as “sale” is defined in the CCPA. We do not sell the Personal Information of minors under age 16.

  • Proof of your registration with the California Secretary of State to conduct business in California;
  • A power of attorney from the California resident pursuant to Probate Code sections 4000-4465;
  • Written permission that the California resident has authorized you to make a request on the resident’s behalf. This permission must be signed (via physical or e-signature) by the California resident.

If you are making a Request to Know or a Request to Delete on behalf of a California resident and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4000-4465, we may also require the resident to:

  • Provide you with written permission signed by the resident to make the Request to Know or Request to Delete on the resident’s behalf;
  • Verify the resident’s own identity directly with us;

Directly confirm with us that the resident provided you permission to submit the Request to Know or Request to Delete.

Questions and comments

Codesmart Inc, located at 18300 NE Union Hill Road, Suite 210, Redmond, WA 98052, USA, is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy.

If you have any questions or comments about this Privacy Policy or would like to request information required to be disclosed under global privacy laws, please send us your questions and feedback. You can contact us at info@CodeSmartInc.com or at the following address:

Codesmart Inc,
18300 NE Union Hill Road,
Suite 210,
Redmond, WA 98052, USA

If you are located in the EEA, you also may lodge a complaint with a data protection authority for your country or region, or where any alleged infringement of applicable data protection law occurs.