Last Updated 5th June 2017
1. Web Site Covered.
2. Information Collected
Codio (the “Company”) offers a variety of services that are collectively referred to as the “Products”. Codio collects information from individuals, companies, universities, schools, institutions and other legal entities who visit the Company’s Web site (“Visitors”) and from individuals, companies, schools, institutions and other legal entities who register to use the Products for themselves and for their underlying users (“Customers”).
When expressing an interest in obtaining additional information about the Products or registering to use the Products, Codio may require you to provide the Company with personal contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”). When purchasing the Products, Codio requires you to provide the Company with financial qualification and billing information, such as billing name and address, credit card number, and the number of employees within the organization that will be using the Products (“Billing Information”). Codio may also ask you to provide additional information, such as company annual revenues, number of employees, or industry (“Optional Information”). Required Contact Information, Billing Information, and Optional Information are referred to collectively as “Data About Codio Customers.”
As you navigate the Company’s Web site, Codio may also collect information through the use of commonly used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Web site (such as the Web pages viewed and the links clicked).
3. Use of Information Collected
3.1 Users in Education Institutions
Codio does not use student data for marketing purposes whilst a student is a member of an education institution that holds an institution license to use the Codio Products.
Codio will only communicate with student users where their use of Codio is associated with a valid education institution license, and only in the following instances:
- where a student user makes use of “contact us” in the product; if the content of a student-initiated communication using “contact us” relates to operational use of the Codio product, Codio customer support will respond; in all other instances, Codio will refer the student user to the organization owner or faculty member or teacher leading the relevant class;
- where a student is a member of a “self-pay” education institution organization, and the student raises a billing enquiry, Codio customer support will respond directly to the student user;
- where a student ceases to be a member of an education institution organization in Codio, e.g. where the student leaves the institution or is no longer required to have access to the institution account in Codio, we will communicate with these users to offer them options for continuing their use of Codio, and to explain options for downloading, storing or saving their content;
- where important changes are released into the Product, we will communicate these changes to all users including students, at a minimum via a notification inside the Product and potentially also by email.
All Other Users
The Company uses data about Codio Customers to provide the Products requested. For example, if you fill out a “Contact Me” Web form, the Company will use the information provided to contact you about your interest in the Products.
The Company may also use data about Codio Customers for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in the Products and to send you information regarding the Company and its partners, such as information about promotions or events.
Codio uses credit card information solely to check the financial qualifications of prospective customers and to collect payment for the Products. Codio does not store any credit card information whatsoever and any such information collected is passed securely to our payment provider (Braintree) for processing.
Codio uses Web Site Navigational Information to operate and improve the Company’s Web site. The Company may also use Web Site Navigational Information alone or in combination with data about Codio customers to provide personalized information about the Company.
4. Web Site Navigational Information
Codio uses commonly used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company’s Web site (“Web Site Navigational Information”). This section describes the types of Web Site Navigational Information that may be collected on the Company’s Web site and how this information may be used.
If you have chosen to identify yourself to Codio, the Company uses session cookies containing encrypted information to allow the Company to uniquely identify you. Each time you log into the Products, a session cookie containing an encrypted, unique identifier that is tied to your account is placed in your browser. These session cookies allow the Company to uniquely identify you when you are logged into the Products and to process your online transactions and requests. Session cookies are required to use the Products.
Codio uses persistent cookies that only we can read and use to identify browsers that have previously visited the Web site. When you purchase the Products or provide us with personal information, a unique identifier is assigned you. This unique identifier is associated with a persistent cookie that we place on your Web browser. Codio is especially careful about the security and confidentiality of the information stored in persistent cookies. For example, we do not store account numbers or passwords in persistent cookies. If you disable your Web browser’s ability to accept cookies, you will be able to navigate our Web site, but you will not be able to successfully use the Products.
Codio may use information from session and persistent cookies in combination with Data About Codio customers to provide you with information about Codio and the Products – subject to certain exclusions including those set out in 3.1 above relating to student data.
4.2 Web Beacons - Codio uses web beacons alone or in conjunction with cookies to compile information about Customers and Visitors’ usage of our Web site and interaction with emails from Codio. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular web site tied to the web beacon, and a description of a web site tied to the Web beacon. For example, we may place Web beacons in marketing emails that notify us when you click on a link in the email that directs you to our Web site. Codio uses Web beacons to operate and improve our Web site and email communications.
Codio may use information from Web beacons in combination with data about Codio customers to provide you with information about Codio and the Products, again subject to certain exclusions relating to student data as set out in 3.1 above.
4.3 Flash Cookies - Codio may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on our site to personalize your visit. Third parties, with whom Codio partners to provide certain features on our site or to display advertising based upon your web browsing activity, use Flash cookies to collect and store information.
Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored. Cookie management tools provided by your browser will not remove Flash cookies.
4.4 IP Addresses - When you visit our Web site, we collect your Internet Protocol (“IP”) addresses to track and aggregate non-personal information. For example, Codio uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Web site.
4.5 Third Party Cookies - From time-to-time, Codio engages third parties to track and analyze usage and volume statistical information from individuals who visit our Web site. Codio may also use other third-party cookies to track the performance of Company advertisements. The information provided to third parties does not include personal information, but this information may be re-associated with personal information after we receive it.
4.6 Google Analytics - Codio uses Google Analytics to track information about site behavior.
5. Public Forums, Refer a Friend, and Customer Testimonials
Codio may provide bulletin boards, blogs, or chat rooms on the Company’s Web site. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages – subject to certain exclusions as set out in 3.1 above. Codio is not responsible for the personal information you choose to submit in these forums. Codio may post a list of Customers and provide customer testimonials or customer case studies on the Company’s Web site that contain information such as Customer names and titles. Codio always obtains the consent of each Customer prior to posting any information on such a list or posting testimonials or case studies.
6. Sharing of Information Collected
Codio may share Data About Codio Customers with the Company’s service providers so that these service providers can contact Customers and Visitors who have provided contact information on our behalf. Codio may also share Data About Codio Customers with the Company’s service providers to ensure the quality of information provided. Unless described in this Privacy Statement, Codio does not share, sell, rent, or trade any information provided with third parties for their promotional purposes. Sharing of information collected is also subject to exclusions relating to student data as set out in 3.1 above.
Codio uses a third-party service provider (Braintree) to manage credit card processing. This service provider is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on the Company’s behalf. Codio does not store any credit card information on its own systems whatsoever.
Codio reserves the right to use or disclose all or any information provided directly or indirectly by a Customer or a Visitor if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process. In the event of a request by law enforcement agencies to obtain information, we will a) notify you within 24 hours of the receipt of such a request, and b) give you the opportunity to engage with the law enforcement agencies to determine whether you wish to seek a protective order
7. International Transfer of Information Collected
To facilitate Codio global operations, the Company may transfer and access Data About Codio Customers from around the world, including the United States and the United Kingdom. This Privacy Statement shall apply even if Codio transfers Data About Codio Customers to other countries.
8. Communications Preferences
Codio offers Customers and Visitors who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the unsubscribe link located on the bottom of the Company’s marketing emails. Additionally, you may send a request specifying your communications preferences to email@example.com.
Customers cannot opt out of receiving transactional emails related to their account with Codio or the Products. However, Codio will only communicate with student users in specific instances, as set out in 3.1 above.
9. Correcting and Updating Your Information
Customers may update or change their registration information by logging in to their accounts at https://codio.com. Requests to access, change, or delete your information will be handled within 30 days.
Codio uses adequate administrative, technical, and physical security measures to protect Data About Codio Customers. For further information please request a copy of Codio’s security statement.
11. Changes to this Privacy Statement
Codio reserves the right to change this Privacy Statement. Codio will provide notification of the material changes to this Privacy Statement through the Company’s web site at least seven (7) business days prior to the change taking effect.
12. Contacting Us
Questions regarding this Privacy Statement or the information practices of the Company’s Web site should be directed to firstname.lastname@example.org or by mailing:
Codio c/o Codio Ltd.
51 Queens Road,
Effective 20th July 2017