Effective as of May 25th, 2018
We take the protection of the privacy of your personal information seriously. Your personal information will be treated in a secure and confidential manner in compliance with all applicable laws and regulations, including the European General Data Protection Regulation (“GDPR”).
What is the GDPR?
The General Data Protection Regulation (“GDPR”) is a new European privacy regulation replacing the EU Data Protection Directive. The GDPR aims to strengthen protection of personal data in the EU, and streamlines EU data protection law. It provides individuals with greater transparency into and control over use of their personal information.
To whom does the GDPR apply?
The GDPR applies to all organizations operating in the EU or processing “personal identifiable data” of EU residents. Personal data is any information relating to an identified or identifiable natural person.
This policy specifies:
- Types of personal information CoderPad collects and how it is used.
- How we collect personal information, including whether it is collected automatically.
- How long CoderPad retains your personal information.
- How and when CoderPad shares your personal information with others.
- How we protect your personal information.
- What rights are available to you regarding the use of your personal information, including how to access and update it.
- How CoderPad handles personal information submitted to the Website or collected through the Website on behalf of or at the direction of our subscribers.
- How to update your communication preferences.
- Policy on the use of the Website by children under the age of 13
- California privacy rights
firstname.lastname@example.org or CoderPad Inc, 995 Market St, Floor 2, San Francisco CA 94103
1. What types of personal information does CoderPad collect?
In general, we may collect information that identifies you, information about how you use the Website, and information that you create while you interact with the Website.
Information we collect from you may include the following:
- Information that can personally identify you, including name and email address.
- Information about your Internet connection or the device used to connect to the web.
- Information you provide directly when you submit forms on the Website.
- Records of support correspondence (including email addresses, Twitter handles, or telephone number) if you contact us for support.
- Details of subscriptions purchased through the Website.
2. How does CoderPad use my personal information
CoderPad generally uses personal information to effectively and securely provide technical interviewing services, manage user accounts and subscriptions, and provide customer service.
We may use this information in the following ways:
- To authorize and manage access to the Website.
- To provide you with notices about your account and/or subscription, including expiration and renewal notices.
- To carry out our obligations and enforce our rights that arise from any contracts entered into between you and us, including billing related matters.
- To notify you about functional changes to the Website, terms, or policies.
- To provide you with requested information or support.
- To create a list of actual and prospective users and subscribers.
- To compile statistics regarding how the Website is used in order to improve our product.
- To prevent fraud or abuse.
- To comply with any legal or regulatory obligations.
3. How does CoderPad directly collect my personal information?
- When you create an account to use the Website or invite a new user to join a team account.
- When you join an interview session
- When you subscribe to a paid plan
- When you contact us via a form on the Website, or via email/Twitter.
4. Does CoderPad collect personal information automatically?
CoderPad gathers a small amount of information automatically as you interact with the Website. This information helps us to improve the Website and prevent fraud or abuse. This information may be stored in log files.
Information that we collect from you automatically may include the following:
- IP addresses
- Browser version
- Referring/exit pages
- Account access date/time stamp
- Cookie data previously stored on your device
5. How long does CoderPad keep my personal information?
CoderPad retains your personal information for a period of time consistent with the original purpose of collection. For example, we retain your personal information during the time you are a subscriber and a reasonable period of time thereafter to wrap up our business relationship. We also may retain your personal information for a period of time needed to pursue our legitimate business interests, such as conduct audits, comply with legal obligations, or resolve disputes. Logs are stored for no longer than 12 months. Please contact us at email@example.com to request deletion of your account along with all associated personal data, and we will comply promptly.
6. When and how does CoderPad share my personal information with other parties?
CoderPad shares your personal information with a limited set of third-parties. This sharing is based on our business relationship with those third-parties, your consent, or legal or contractual obligations.
We may share your personal information as follows:
- With cloud service providers that facilitate or support the core functions of the Website, including activities like database hosting, payment processing, customer support and similar. These providers are GDPR compliant and in their role of data processor are bound to only use personal information for the purposes for which we disclose the information to them.
- To comply with any court order, law, or legal process (such as a subpoena), to investigate fraud, to respond to any government or regulatory request, lawful requests by public authorities, or to meet national security or law enforcement requirements.
- With Google Analytics, in anonymized, aggregate form.
- With third-parties that either display advertising on the Website or manage our advertising on other sites and applications. For any other purpose disclosed by us, when we request your consent regarding that purpose.
7. How does CoderPad keep my information secure?
CoderPad maintains industry standard technical and organizational security measures designed to protect your personal information from accidental loss, unauthorized use, or disclosure. Although we implement and maintain commercially appropriate security measures, please note that no security measures are perfect and any transmission of personal information is at your own risk. The Website is not designed to store sensitive personal information such as financial, health or educational records and you should not use the Website for that purpose
We are not responsible for any outcome if you circumvent any privacy settings or security measures. You are responsible for choosing a password of appropriate strength, not reusing passwords used on other websites, and keeping your password confidential. CoderPad employees will never ask for your password.
8. What rights are available to me regarding the use of my personal information?
To exercise any of the rights listed below, you may email us at firstname.lastname@example.org. We will respond to all requests and concerns within 30 days.
Right to access or correct personal information
You have the right to access and correct your personal information. If you want to review or correct your personal information, please contact us and we will promptly address your requests.
Right to be forgotten
You have the right to request deletion of personal information and we have the obligation to comply where at least one of the following applies:
- The personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed
- You withdraw consent on which the processing is based and there are no other legal grounds for the processing
- You object to the processing and there are no overriding legitimate grounds for the processing
- The personal information has been unlawfully processed
- The personal information has to be erased for compliance with a legal obligation in the European Union
Please contact us to request deletion of your account along with all associated personal data, and we will comply promptly. In some cases, we may not be able to remove all of your personal information, in which case we will let you know that we are unable to do so and why.
Right to data portability
You have the right to receive a copy of your personal information in a common machine-readable format, where:
- We are relying upon your consent or the fact that the processing is necessary for the performance of a contract to which you are a party.
- Personal information is processed automatically.
Right to restrict processing of personal data
You have the right to request the restriction of processing of your personal information, where:
- You contest the accuracy of the personal information (until we take sufficient steps to verify or correct its accuracy)
- Where the processing is unlawful but you do not want us to erase the personal information
- Where we no longer need the personal information for the purposes of the processing, but you require the information for legal purposes
- Where you have objected to processing on legitimate interest grounds (see below) pending verification as to whether CoderPad has compelling legitimate grounds to continue processing
Where personal information is subject to restriction we will only process it with your consent or for the establishment, exercise, or defense of legal claims.
Right to object to processing based on legitimate interest
We are relying upon legitimate business interests to process personal information. You have the right to object to that processing. If you object, we will stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your rights, or we need to process the personal information for legal purposes. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate necessary legitimate grounds, but we will consider each case on an individual basis.
Right to be informed of the appropriate safeguards where personal information is transferred outside the European Union
CoderPad is certified by and complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personally identifiable information transferred from the European Union to the United States. Please see our Privacy Shield page for further details on our Privacy Shield compliance.
Right to withdraw consent for processing
Where you have provided consent to process personal information, you have the right to withdraw such consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
You can do this by:
- Follow the unsubscribe instructions included in emails
- Email us at email@example.com to let us know what consent you withdraw.
9. Data submitted to the Service or collected through the Service on behalf of our subscribers
CoderPad subscribers electronically submit (or cause to be submitted) data to the Service for evaluation of technical candidates. As subscribers (or their internet clients or end users) control the data to be processed, CoderPad’s network and Service is used for the processing of personal information. The use of personal information collected through the Service at the direction of our subscribers shall be limited to the purpose of providing the Service for which the subscriber has engaged CoderPad.
Although CoderPad collects personal information related to subscriber personnel as they perform a subscriber’s desired use of the Service, CoderPad has no direct relationship with individuals whose personal information is hosted or transmitted through the Service by subscribers or their permitted internet clients or end users. Subscribers are responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the data to CoderPad for processing purposes.
Subscriber Data Purpose Limitation
As a data processor, CoderPad hosts, transmits, discloses, and processes data, which may include personal information about EU personnel of our subscribers administering, using or supporting the Service. CoderPad may process data to provide the Service, to prevent or address technical or service problems, to follow the instructions of our subscribers and their personnel who submitted the personal information, or in response to contractual or legal requirements. CoderPad does not control or own the data submitted by its subscribers to the Service.
Data Subjects Rights Regarding Subscriber Data
CoderPad acknowledges that an individual has the right to access their personal information. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate personal information should first direct his or her query to the CoderPad subscriber (i.e., the data controller) who requested that they participate in an interview using the Service. CoderPad will provide assistance with requests that subscribers are not able to complete. If the subscriber requests that CoderPad remove the personal information, we will respond to the request within 30 days.
Subscriber Data Retention
CoderPad retains the personal information we process on behalf of our subscribers for as long as needed to provide the Service to our subscribers and in accordance with our subscription agreements. To the extent that personal information is not deleted by our subscribers, CoderPad may also retain and use certain personal information for a reasonable period of time thereafter as necessary to pursue our legitimate business interests, conduct audits, comply with legal obligations, resolve disputes, and enforce our agreements.
10. Financial Information
11. Children’s Privacy
We are committed to complying with the Children’s Online Privacy Protection Act (COPPA). Our Service is not directed to children under the age of 13 and children under the age of 13 are not to use the Website or provide any information to our Service. We do not knowingly collect personal information from children under the age of 13. If we receive personal information that we discover was provided by a child under the age of 13, we will promptly destroy such information. Schools and parents should supervise their children’s online activities and consider the use of other means to provide a child-friendly, online environment. Additional information is available on the Direct Marketing Association’s home page at http://www.the-dma.org. If you would like to learn more about COPPA, visit the Federal Trade Commission home page at http://www.ftc.gov.
12. California Privacy Rights
California Civil Code Section § 1798.83 permits visitors to the Website who are California residents to request certain information regarding disclosure of personal information to third parties for direct marketing purposes. To make such a request, please contact us at firstname.lastname@example.org.