Privacy Policy

Codezero Technologies Inc., (“we”/”us”), is committed to protecting your privacy.  We make the Codezero website, Hub and Marketplace located at www.codezero.io, including all subpages and successor pages (together the “Site”) available together with our content, software and services as further described in the Codezero Terms of Service located at www.codezero.io/tos (the “Codezero Offerings”).  This Privacy Policy describes how we collect, use and disclose information about our users through the Site and in respect of the Codezero Offerings. 

The Codezero Site contains a portal through which software applications (“Apps”) are made available by third party publishers (“Publishers”) and by Codezero for purchase by users and potential users (“Users”).  Codezero is the provider of the technology and services to enable this portal and facilitate related transactions for Publishers who have made Apps available via the Codezero Marketplace.

Consent: By using the Site or the Codezero Offerings you consent to the use of your Personal Information as described in this Privacy Policy.  Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent. We will not actively collect Personal Information for the purpose of sale or marketing in a way that specifically identifies or targets individuals.  In other words, we don’t sell customer lists.  You may withdraw your consent to our processing of your Personal Information at any time.  However, withdrawing consent may result in your inability to continue using the Site and/or the Codezero Offerings.

Collection of Information: We aim to collect, use and disclose only Personal Information as is required to enable us to manage your Account (as defined below in Use of Information), to provide the Codezero Offerings, to maintain our customer/visitor lists, to respond to your inquiries or provide feedback, for identification and authentication purposes and for service improvement. We will maintain the confidentiality of any contact information or other Personal Information you provide to us on signing up for the Codezero Offerings or contacting us with questions or for further information and we will use it only for the purposes for which we have collected it (subject to the exclusions and disclosures we have listed below), unless you agree that we may disclose it to other third parties.

Two types of information may be collected through the Site and the Codezero Offerings: Personal Information and Non-Personal Information.  This Privacy Policy does not extend to the collection, use or disclosure of Non-Personal Information (as defined further below).

"Personal Information" is any information about an identifiable individual, such as your name, address, e-mail address, and credit card information.  At the time of collection, we will clearly identify the information being collected and the purposes for which it will be used.  It is always your choice whether or not to provide Personal Information but if you choose not to provide certain requested Personal Information, in some instances you may not be able to register for an account to use the Site and the Codezero Offerings or be able to access and use the Site or the Codezero Offerings at all.  In other instances, your choice not to provide certain other Personal Information may mean that you will not be able to use certain features of the Site and the Codezero Offerings.  We may collect Personal Information when you register for an account on the Site and/or the Codezero Offerings, during communications with you and/or information downloads in connection with the purchase of Apps, through user support, and/or by way of User surveys.

"Non-Personal Information" is information of an anonymous nature that is not linked to an individual, and may include an Internet Protocol Address (IP Address), the domain used to access the Site and/or the Codezero Offerings, and the type and version of browser or operating system being used by visitors to the Site.  It also includes aggregate information, such as demographic statistics of our Users (e.g. average age or geographical allocation of our Users), number of visitors, webpages accessed, and average time spent on the Site and/or Services.

Non-Personal Information is collected or derived by us in the course of operating this Site and the Codezero Offerings.  For example, our web servers may automatically collect Non-Personal Information that is provided through your browser or stored in a cookie when you choose to visit the Site and/or use the Codezero Offerings.

Use of Information: We collect information for the following purposes:

• Registration:  To create an account for accessing the Codezero Offerings (your “Account”), you must provide certain Personal Information to us such as your full name, address and email address.  In general, none of your Account registration information will be shared with any other Users of the Site or the Codezero Offerings.
• App Providers. Your Account information will be shared with our Publishers from whom you purchase Publisher Apps to enable the Publisher to provide you with Publisher Apps. In addition, individual Publishers may collect, use and disclose other Personal Information in order to provide Publisher Apps. In accordance with our Terms of Service, you agree to be bound by any applicable privacy policy of any Publisher provided for any Publisher App which you order (“Publisher Privacy Policy”). The Publisher Privacy Policy will govern any collection, use or disclosure of Personal Information by the Publisher.     
• Order Processing: Codezero uses a third-party payment processor to process payment transactions (“Payment Processor”). Unless otherwise stated in the Terms of Service, Users are required to provide valid credit card and billing information (“Billing Information”) to the Payment Processor when making purchases through the Codezero Marketplace. The collection, use and disclosure of all personal information by the Payment Processor is governed by the Payment Processor’s terms of service and privacy policy. Codezero does not collect this Billing Information. However, Codezero will be able to view and use the last four digits of your credit card as well as your postal code of your billing address for User identification and authentication purposes.
• Statistics: We also collect statistics about use of the Codezero Offerings, Publisher Apps purchased through the Site and general Site usage. This information will be kept confidential, however, aggregate statistics that do not personally identify an individual will be kept by us and such aggregate statistics may be made available to third parties. 
• System Logs & Cookies: We may use cookies to track content usage and traffic on the Site and/or the Codezero Offerings.  A cookie is a feature of your web browser that consists of a text file that is placed on your hard disk by a web server.  The Site and the Codezero Offerings may use cookies to help it compile aggregate statistics about usage of this Site and/or the Codezero Offerings, such as how many users visit the Site and/or Services, how long users spend viewing the Site and/or the Codezero Offerings, and what pages are viewed most often.  This information is used to improve the content of the Site and/or the Codezero Offerings.  You can set your browser to notify you when you are sent a cookie.  This gives you the chance to decide whether or not to accept it.  If you disable cookies, you may not be able to take advantage of all the features of the Site and/or the Codezero Offerings.  We do not link any of the information we use in cookies to any Personal Information submitted by you when you are on the Site and/or using the Codezero Offerings.
  
  Your IP address is reported by your web browser whenever you visit a page on the Site and/or access the Codezero Offerings.  This information is recorded together with your registration information on our databases. 

If we plan to use your Personal Information in the future for any other purposes not identified above, we will only do so after informing you by updating this Privacy Policy.  See further the section of this Privacy Policy entitled ‘Amendment of this Policy’.

Disclosures & Transfers:  We have put in place contractual and other organizational safeguards with our agents to provide a reasonable level of protection for your Personal Information (see further Security below).  In addition to those measures, we will not disclose or transfer your Personal Information to third parties without your permission, except as specified in this Privacy Policy (see further Important Exceptions below).

Codezero will provide Personal Information collected from you, including your name, address and email address, to Publishers as necessary in connection with your purchases through the Marketplace.  The Publisher’s collection, use and disclosure of any Personal Information we provide will be governed by the Publisher Privacy Policy.

Our servers are located in Canada (although this location may change from time to time) We reserve the right to store and process Personal Information outside of Canada and will use commercially reasonable efforts to provide you with at least 30 days’ notice of any such changes in the processing location.

From time to time we may employ third parties to help us improve the Site and/or the Codezero Offerings, whether through the provision of maintenance services, database management, Web analytics or otherwise. These third parties may have limited access to databases of Personal Information solely for the purpose of helping us to improve the Site and/or the Codezero Offerings and they will be subject to contractual restrictions prohibiting them from using the information about our Users for any other purpose.

Important Exceptions: We may disclose your Personal Information to third parties without your consent, where permitted by law, if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Site Users of the Codezero Offerings, or anyone else (including the rights or property of anyone else) that could be harmed by such activities.  We may also disclose Personal Information when we believe in good faith that such disclosure is required by and/or in accordance with the law.

We may also disclose your Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

Security: The security of your Personal Information is important to us.  We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment.  We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us.  We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff or other permitted persons or companies as are reasonably necessary to carry out the stated purposes we have communicated to you.

You are also responsible for helping to protect the security of your Personal Information.  For instance, never give out your Account information or password.

Retention: We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you.  We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, Non-personal Information, Account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy. 

Amendment of this Policy: We reserve the right to change this Privacy Policy at any time.  If we decide to change this Privacy Policy in the future, we will post an appropriate notice on the home page at www.codezero.io    Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted and any material changes will become effective 30 days from their posting on the Site or the Codezero Offerings.  Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about you.  The date on which the latest update was made is indicated at the bottom of this document.  We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes.  Your continued use of the Site and/or the Codezero Offerings signifies your acceptance of any changes.

Access and Accuracy: You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that Personal Information.  Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant Personal Information available to you such as where that information also pertains to another individual or as otherwise required or permitted by law.  In such circumstances we will provide reasons for the denial to you upon request.  We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate.  As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information, including the Publishers.  Having accurate Personal Information about you enables us to give you the best possible service.

Residents of the European Economic Area (“EEA”)

Individuals located in the EEA have certain rights under European law (including under the General Data Protection Regulation) (“EU Data Protection Law”) with respect to Personal Information, including the right to request access to, obtain, correct, amend, delete, or limit the use of your personal data. Individuals located in the EEA who wish to exercise these rights, should contact us at privacy@codezero.io. Individuals also have the right to make complaints to regulatory authorities in respect of our privacy practices.  EU Data Protection Law sets out a number of different reasons for which we may collect and process your personal data in certain circumstances. Where EU Data Protection Law applies, the legal bases we rely upon include:

• Consent
  We can collect and process your data with your consent, where required by the EU Data Protection Law. For example, if you have given your consent to receiving marketing material from us.
• Contractual obligations
  We need your personal data to comply with our contractual obligations. For example, where you have provided us with your email address to receive access to our Site and/or the Codezero Offerings, we will use this information in order to effectively deliver and communicate information to you in regard to such products and services.
• Compliance with legal obligations
  If the law requires us to, we may need to collect and process your data for legal compliance reasons. For example, we can pass on details of people involved in fraud or other criminal activity.
• Legitimate interest
  We may require your data to pursue our legitimate interests or those of a third party in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, it is in our legitimate interests to (a) ensure that content from our Site is presented in the most effective manner for you and your computer and that we provide you with the information, products and services that you request from us, (b) to keep our Site and the Codezero Offerings safe and secure;(c) for measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you (including individual and pseudonymous analysis and profiling); (d) to allow you to participate in interactive features of the Codezero Offerings (if applicable), and (e) to use marketing related information about you that we have lawfully collected.

If you are an EEA citizen, Personal Information hosted on our behalf is stored in Canada, however the Personal Information that we process in relation to you may be transferred and stored by our third party service providers at destinations outside the EEA that may not be subject to equivalent data protection law.   It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers.

We may transfer your personal data outside the EEA:

• in order to host or store it;
• in order to enable us to provide goods or services to and fulfil our contract with you or the company your work for;
• where we are legally required to do so;
• in order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
• Where your information is transferred outside the EEA, we take steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as where applicable relying on a recognized legal adequacy mechanism and contracts, to help ensure your rights and protections travel with your data and that your personal data is treated securely and in accordance with this Policy.

If you are an EEA Citizen, you have the following additional rights under certain circumstances:

• to be provided with a copy of your personal data held by us;
• to request the rectification or erasure of your personal data held by us;
• to request that we restrict the processing of your personal data (for example, while we verify or investigate your concerns about your information);
• to object to the further processing of your personal data, including the right to object to marketing; and
• to request that your personal data be moved to a third party.

Contact Us: You can help by keeping us informed of any changes to your Personal Information.  If you would like to access your information, have any questions, concerns, comments or suggestions, or if you find any errors in our information about you, please contact our Privacy Officer via email at privacy@codezero.io  or by mail to Code Zero Technologies Inc c/o LaBarge Weinstein LLP, 321 Water St #501, Vancouver, BC V6B 1B8.

 

Last Updated: February 18, 2024