Revised: July 18, 2023
Your Personal Data are processed in accordance with the European Regulation “(EU) 2016/679” of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (GDPR), the French law “Informatique et Libertés”, n°78/17 of January 6, 1978, the Swiss Federal Act on Data Protection (“FDAP”) and the California Consumer Privacy Act (CCPA), hereinafter “Applicable Laws”.
This Policy may change from time to time. Your continued use of the Sites after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
The Data Controller depends on the entity you enter into relationships:
|CoderPad France (formerly known as CodinGame SA)|
396 Rue du Mas de Verchant
44 Montgomery Street, 3rd Floor
San Francisco CA 94104
When we use the term “Service(s)” we mean to refer collectively to:
- The provision of online programming, interviewing and communication tools and related services to those who purchase such tools and services in order to evaluate candidates’ skills (“Subscriber(s)”);
- The information provided through websites owned and controlled by us, including the website at coderpad.io and www.codingame.com (the “Sites”)
- The use by candidates of online programming tools for assessments, interviewing and related practice (“Authorized Users“)
- HOW WE COLLECT YOUR PERSONAL DATA
- TYPES OF PERSONAL DATA WE COLLECT
- HOW AND WHY WE USE YOUR PERSONAL DATA
- HOW WE SHARE AND DISCLOSE PERSONAL DATA
- DATA SECURITY
- RETENTION OF PERSONAL DATA
- CHILDREN’S PRIVACY
- FINANCIAL INFORMATION
- EMAIL MARKETING
- YOUR PERSONAL DATA CHOICES
- WITHDRAWAL OF YOUR CONSENT
- COOKIES NOTICE
- YOUR CALIFORNIA PRIVACY RIGHTS
- ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA, THE UNITED KINGDOM AND SWITZERLAND
- PRIVACY SHIELD AND ALTERNATIVE PROTECTIONS
- LINKS TO OTHER SITES
- HOW TO CONTACT US
HOW WE COLLECT YOUR PERSONAL DATA
We may collect your Personal Data through different means, when you:
- Decide to interact with us, either by providing us your information through the registration page, login page, forms or demo page on the Sites; by email; regular mail; social media or telephone;
- Contact us via online submission, telephone, electronic mail or regular mail,
- Visit our Sites, through automated data tracking technology;
- Complete surveys via the Service
- Become a Subscriber or an Authorized User or set up an account and provide us with information directly;
- Join an interview session;
- Are invited to join a team account;
- Post comments or opinions (e.g. on our Facebook page) or
- Authorize third parties to provide us Personal Data.
TYPES OF PERSONAL DATA WE COLLECT
We may collect the following types of Personal Data:
Types of Information You May Provide to Us:
- Name, alias, email address, postal address, telephone numbers, communication preferences, unique personal or online identifier, account name, employer, job title;
- Information that you authorize third parties to release to us;
- Persistent or probabilistic identifiers that organizations use to identify a particular consumer (cookies);
- Records of your correspondence with us, including support correspondence;
- Video chats (not recorded), which may include visual information from which inferences may be drawn related to age, race, color, sex, gender identity, gender expressions, pregnancy or childbirth, medical conditions (but CoderPad or CoderPad France (formerly known as CodinGame SA) will not process those information);
- Level of competence of the persons concerned (score, rank) and
- Technical job application information
Types of Information We Collect Through Technology:
When you use our Sites, we use technologies to gather information on how visitors are using the Sites and Services (the dates you access the Service, the amount of time you spend on the Service, the originating site when you arrive at the Service, your selections, what you click on, and how you navigate from page to page on the Sites). Specifically, we use technology to gather information about the following:
- Internet connection
- IP address
- Browser version
- Time zone/presumed country and presumed city
- Operating system and platform
- Referring/exit pages
- Account access date/time stamp
- Cookie data previously stored on your device
- Information about your interaction with the Sites
An IP address is a number automatically assigned to your computer whenever you access the Internet. IP addresses allow computers (including mobile devices and tablets) and servers to recognize and communicate with one another. We collect IP address information so that we can properly manage our system and gather information about how our Sites are being used. This includes the device type and browser you are using, location data, the pages you are viewing and your interactions on the page. Your IP address may be associated with records containing Personal Data. We collect details of visits to our Sites, including the volume of traffic received, logs and the resources that you have accessed. We may also collect certain location information such as your mobile device’s GPS signal, or information about nearby WiFi access points and cell towers. (Please also see our Cookies Notice for more details.)
We also record keystrokes and monitor cut and paste activity for the code playback for use by in our Services.
Types of Information We May Collect From Third Parties:
Our Subscribers electronically submit (or cause to be submitted) Personal Data to the Services, which may include names, email addresses, and/or notes about an interview.
Our business partners may process and submit analytics and/or enhancing data.
HOW AND WHY WE USE YOUR PERSONAL DATA
Our employees only collect and process the information reasonably necessary to respond to inquiries about our Services, to provide you the Services, to carry out our operations, as required by law, and for the other legitimate business purposes, under Applicable Laws, as provided below:
- To provide the Services, enforce our Terms of Service, Subscription Agreement, and other agreements; to manage your account, validate and keep your Personal Data accurate
- To inform you about the Services in which you have indicated an interest or to which you’ve subscribed; Respond to your questions and requests and improve customer service; To provide you with notices about your account and/or subscription, including expiration and renewal notices;
- To assist in business development and general marketing and building relationships; to create a list of actual and prospective users and Subscribers; to compile statistics regarding how the Sites are used in order to improve our products and Services;
- To record your name and contact information, and other Personal Data for legitimate business purposes, so that we can provide our Services;
- To authorize and manage access to the Sites;
- To ensure that content from the Service is presented in the most effective manner for you and your device and to provide you with content and features customized to your interests and the way you use the Service;
- To perform our contract with you if you become a Subscriber or Authorized User; satisfy contractual necessity to conduct our operations and provide you with the services and products we offer; to perform essential business operations and to manage your account; to contact you with information that may be of interest to you;
- To improve the Sites to provide you with better services, for example, we may use your Personal Data to improve the layout of our Sites based on the click path you utilized to access certain information within the Sites; and
- To comply with legal obligations and professional responsibilities;
- To verify your identity or conduct internal audits or reviews;
- To detect or prevent security incidents or other illegal activity; debug; verify or maintain quality or safety or improve or upgrade a service or device owned or controlled by us;
- To process data from websites or social networks (e.g. LinkedIn, Facebook, etc.) in order to better understand your profile. You can object to this as per the “Individual rights” section.
We do not monitor or profile users of our Sites or collect, any special categories of sensitive Personal Data about you. No automated decision-making, including profiling, is used when processing your Personal Data.
Additional Uses of Personal Data:
In addition to the uses described above, we may use your Personal Data for the following purposes if you become a Subscriber or Authorized User.
Some of these uses may, under certain circumstances be based on your consent:
- Providing you with newsletters, articles, alerts and announcements, and other information that we believe may be of interest to you;
- Providing you with marketing information about our services and;
- Conducting research, surveys, and similar inquiries to help us understand Subscriber or authorized user needs;
- Setting certain cookies;
Some of other uses are necessary to serve our legitimate interests in the following business operations:
- Preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorized access to or use of Personal Data, our Sites or data systems; or to meet legal obligations; and
- Preventing, detecting and investigating breaches of any agreements entered into between you and us and threats to the security of the Service.
- Analyzing some interactions with us and our Sites, and improving our products, services, programs, and other offerings;
- Serving marketing and business development activities, including any social media properties we create, and emails that we send.
HOW WE SHARE AND DISCLOSE PERSONAL DATA
We share Personal Data with the following categories of recipients:
- Corporate Affiliates: We may share your information with our corporate affiliates that are subject to this policy, and the employees, agents, officers, directors and contractors of the foregoing entities
- Business Transfers: When applicable, we may share your information in connection with a substantial corporate transaction, such as the sale of a Site, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
- With Your Consent or at Your Direction: We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction.
- Other Legal Reasons: In addition, we may use or disclose your Personal Data as we deem necessary or appropriate: (1) under applicable law; (2) to respond to requests from public and government authorities including public and government authorities; (3) to pursue available remedies or limit damages we may sustain; (5) to protect our operations or those of any of our affiliates; (6) to protect our rights, privacy, safety or property ; and (7) to enforce our terms and conditions.
In case of any request addressed to us coming from any public, governmental, regulatory, judicial or administrative body, authority, agency, court or tribunal to access the users or Subscribers’s Personal Data, we commit to first checked and, if relevant, challenged the legality of such request.
CoderPad Inc and CoderGame SA certify that they have not purposefully (or due to local laws or practices) (i) created backdoors or similar programming that could be used to access Personal Data and/or (ii) put in place business processes which facilitate access to Personal Data.
We shall remain responsible for any Personal Data that it transfers to a third party and remain liable if such third party processes any such Personal Data in a manner inconsistent with the Applicable Laws, unless we can demonstrate that it is not responsible for such violation.
We keep Personal Data on file, but does not share, sell, license or transmit this information to third parties or external vendors unless required to do so by legal, judicial or governmental proceedings, or to provide the Services.
We may also disclose aggregated information that does not identify any individual (and therefore, is not deemed to be Personal Data) without restriction.
We use reasonable organizational, technical and administrative measures to maintain the privacy and security of your Personal Data within our organization. Accordingly, we prevent unauthorized access by a secure firewall and use of security technologies to protect the integrity and privacy of any Personal Data you provide. Although we work hard to protect your Personal Data by implementing appropriate technical and organizational measures, we cannot guarantee the full security of any information you transmit to us through online forms and applications, but in case of problem, and if required by Applicable Laws, we will inform you of any breach of Personal Data .
The Sites are not designed to store sensitive personal information such as financial, health or educational records and you should not use the Sites for that purpose. Please note that email is considered a non-encrypted (and therefore nonsecure) form of communication, and it can be accessed and viewed by others without your knowledge and permission. For that reason, to protect your privacy, please do not use email to communicate information that you consider confidential.
Unfortunately, no data transmission or storage system can be guaranteed to be secure at all times. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below. We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
RETENTION OF PERSONAL DATA
The Sites are only intended for individuals who are at least 16 years of age. We do not knowingly encourage or solicit visitors who are under the age of 16 or knowingly collect Personal Data from anyone under the age of 16 without parental fiduciary consent. If we learn we have collected or received Personal Data from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us in accordance with the How to Contact Us section below. 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 Sites or provide any information to our Service without express parental consent. 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.
CoderPad and CoderPad France (formerly known as CodinGame SA) use Stripe to process online payments made to us (or we may use a similar online payment processor). We may also receive payments directly from you. In connection with the processing of online payments, we do not retain any personally identifiable information or any financial information such as credit card numbers. Rather, all such information is submitted directly to the payment processor. Any account information received from your direct payment by check or wire transfer to us is kept confidential.
We may periodically send you relevant alerts and newsletters by e-mail. To help improve our marketing activities, we often receive a confirmation when you open an e-mail or click on a link included in one of these emails, if your computer supports such capabilities.
We give users the option to use some of our Services free of charge or for a low cost. These free Services are made possible by the fact that some users upgrade to one of our paid Services or higher priced plans. If you register for our Services, we will, from time to time, send you information about upgrades when permissible. Users who receive these marketing materials can opt out at any time.
If you don’t want to receive a particular type of marketing material from us, click the ‘unsubscribe’ link in the corresponding emails.
YOUR PERSONAL DATA CHOICES AND RIGHTS
You have choices in how your Personal Data is used and shared. You have the right to:
- Update, access, and delete your Personal Data and/or account information;
- Limit a processing;
- Choose whether you wish to receive promotional and newsletter communications
You also have the right to portability of your Personal Data, the right to give instructions concerning your Personal Data in the event of your death and the right to withdraw your consent.
Account Information: If you are a Subscriber and have an account with us, you may update, correct, or delete your Personal Data, or deactivate your account at any time by emailing us at [email protected] if you are a company or [email protected] if you are a natural person.
Certain Exceptions to Deletion Request Rights: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, fulfill the terms of a written warranty, keep archives for our Subscribers, or otherwise perform our contract with our Subscribers.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Choice and Opt-Out:
- You will be notified when we share your Personal Data with any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your information with that party.
- You may opt out of personalized ads anytime. For more information, please review our Cookies Notice.
Exercising Access, Data Portability, Deletion or other privacy Rights: To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Submit your request to us at https://coderpad.typeform.com/to/lpJBMe or
- Emailing us at [email protected] or [email protected]
Verification of Your Identity: Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may make a verifiable consumer request for access or data portability twice within a 12-month period. You must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we have a doubt on your identity or authority to make the request and confirm the personal information relates to you.
WITHDRAWAL OF YOUR CONSENT
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 may do this by emailing us at [email protected].
RESPONSE TIMING AND FORMAT
We endeavor to respond to a verifiable consumer request within thirty (30) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Except if you are an European individual, any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
YOUR CALIFORNIA PRIVACY RIGHTS
As of January 1, 2020, under the California Consumer Privacy Act (CCPA), California consumers (as defined in the CCPA) have the following additional rights regarding your Personal Information (as defined in the CCPA) that CoderPad has collected, used, disclosed or sold:
A. The right to request the following information from CoderPad:
- The categories of Personal Information CoderPad collects about you, including what
categories of Personal Information CoderPad collected about you in the previous 12
- The categories of sources from which your Personal Information is collected;
- The business purpose for collecting your Personal Information;
- The categories of Personal Information that CoderPad disclosed for a business
purpose and the categories of third parties to whom CoderPad disclosed your Personal
- The specific pieces of Personal Information CoderPad collected about you.
B. The right to request that CoderPad delete your Personal Information collected by
C. The right to opt-out of the sale of your Personal Information. Under the current definition
of “sale”, CoderPad does not sell your Personal Information.
Consumers can make these requests by emailing
and CoderPad will
respond to your request upon verification of your identity. CoderPad will accept these requests
from your authorized agent. Before CoderPad will accept requests from an authorized agent, the
authorized agent must provide CoderPad with a Power of Attorney signed and dated by the
consumer and notarized by a notary public naming the authorized agent as your authorized
representative, and including your full name, physical California address, and month/year of
birth. Alternatively, CoderPad will accept a written authorization document that includes your
full name, physical California address, telephone number and valid email address, signed by you
and authorizing the authorized to act on your behalf in making such request(s).
Consumers may opt out of any marketing by us and from the disclosure of your Personal
Information to third parties at any time by emailing [email protected].
You agree that we may combine Personal Information for the purposes of detecting data security incidents or protecting against fraudulent or illegal activity. This combined Personal Information may include IP addresses, preferences, web pages visited prior to coming to your or another Business’ website, information about browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), and information about how other users interact with you (such as timestamps, clicks, scrolling, browsing times and load times).
Non-Discrimination: If you elect to exercise any of your rights under CCPA or CPRA, CoderPad will not discriminate against you for exercising any of your CCPA/CPRA rights. Unless otherwise permitted by the CCPA or CPRA, we will not: deny you goods or services, charge you a different price or rate for our goods or services, or provide you a different level or quality of goods or services because you exercised such rights.
As of January 1, 2023, under the California Privacy Rights Act (CPRA), California consumers
have the additional right to request that CoderPad correct inaccurate Personal Information about
you that CoderPad maintains. This right may be exercised in the same manner described above,
by emailing [email protected].
The CPRA adds California consumer rights to Sensitive Personal Information (as defined in the
CPRA); however, CoderPad does not collect, use, or maintain Sensitive Personal Information.
In addition, CoderPad does not share (as defined under the CPRA) Personal Information.
ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA, THE UNITED KINGDOM AND SWITZERLAND
As an exception to the above paragraph, if you use the Service only from https://www.codingame.eu/work, i.e., if you chose the “Europe” storage location when you created your account, no transfer of Personal Data will be made outside the EEA.
PRIVACY SHIELD; QUESTIONS AND COMPLAINTS; BINDING ARBITRATION; AND ALTERNATIVE PROTECTIONS
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.
In compliance with the Privacy Shield Principles, CoderPad commits to resolve complaints about our collection or use of your personal information. European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact CoderPad at: [email protected], or submit your request to our Privacy Request Form.
On July 16, 2020, the Court of Justice of the European Union issued a judgment declaring as “invalid” the European Commission’s Decision (EU) 2016/1250 of 12 July 2016 on the adequacy of the protection provided by the EU-U.S. Privacy Shield. As a result of that decision, the EU-U.S. Privacy Shield Framework is no longer a valid mechanism to comply with EU data protection requirements when transferring Personal Data from the European Union to the United States. This decision does not relieve CoderPad, as long as it is a participant in the EU-U.S. Privacy Shield, of our obligations under the EU-U.S. Privacy Shield Framework. As an alternative to the Privacy Shield, CoderPad adopts the Standard Contractual Clauses as part of our commercial Terms of Service.
We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within 30 days of receiving your complaint. For any unresolved complaints, CoderPad has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit AMS Privacy Shield Dispute Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with CoderPad and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s Privacy Shield Framework: Section C of Annex I at: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
The Federal Trade Commission has jurisdiction over CoderPad’s compliance with the Privacy Shield.
LINKS TO OTHER SITES
HOW TO CONTACT US