Effective August 25, 2020
When we use the term, “Personal Data”, we mean information or data that directly or indirectly identifies, describes, relates to or is reasonably capable of being associated with or can reasonably link to a particular individual.
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 (“Subscriber(s)”);
- The information provided through websites owned and controlled by us, including the website at https://coderpad.io (the “Site(s)”); and
- Our marketing and business development activities, including any social media properties we create, and emails that we send (“Marketing Activities”).
- HOW WE COLLECT YOUR PERSONAL DATA
- TYPES OF PERSONAL DATA WE COLLECT
- HOW AND WHY WE USE YOUR INFORMATION
- HOW WE SHARE AND DISCLOSE PERSONAL DATA
- DATA SECURITY
- RETENTION OF PERSONAL DATA
- CHILDREN’S PRIVACY
- FINANCIAL INFORMATION
- EMAIL MARKETING
- YOUR PERSONAL DATA CHOICES
- COOKIES NOTICE
- YOUR CALIFORNIA PRIVACY RIGHTS
- ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA
- 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 or demo page on the Site; by email; regular mail; social media or telephone;
- Visit our Site, through automated data tracking technology;
- 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; 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;
- Records of your correspondence with us, including support correspondence;
- Video chats, which may include visual information from which inferences may be drawn related to age, race, color, sex (including gender, gender identity, gender expressions, pregnancy or childbirth, medical conditions); and
- Technical job application information
Types of Information We Collect Through Technology:
When you use our Site, we use technology and Google Analytics to gather information on how visitors are using the Site and Services. Specifically, we use technology to gather information about the following:
- Internet connection
- IP address
- Browser version
- Time zone
- 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 Site
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 site is 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 Site, 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)
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 submit analytics and/or enhancing data.
HOW AND WHY WE USE YOUR INFORMATION
We only collect 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 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 Site is 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 Site;
- 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 Site to provide you with better services, for example, we may use your personal data to improve the layout of our Site based on the click path you utilized to access certain information within the Site; and
- To comply with legal obligations and professional responsibilities;
- To verify your identity or conduct internal audits or reviews; and
- 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.
We do not monitor or profile visitors to our Site or collect, in any automated manner, 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, may be necessary to fulfill our contractual commitments to you, or are necessary to serve our legitimate interests in the following business operations:
- 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;
- Analyzing your interactions with us and our Site, and improving our products, services, programs, and other offerings;
- Preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorized access to or use of Personal Data, our Site or data systems; or to meet legal obligations; and
- Enforcing our Terms of Service, Subscription Agreement, and other agreements.
HOW WE SHARE AND DISCLOSE PERSONAL DATA
We may disclose aggregated information that does not identify any individual (and therefore, is not deemed to be Personal Data) without restriction. 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.
- 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 the rights, privacy, safety or property of CoderPad, our affiliates, you and others; and (7) to enforce our terms and conditions.
CoderPad keeps 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 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, CoderPad cannot guarantee the security of any information you transmit to us through online forms and applications, and you do so at your own risk. The Site is not designed to store sensitive personal information such as financial, health or educational records and you should not use the site for that purpose. Please note that email is considered a nonencrypted (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.
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 or sharing passwords used on other websites, and keeping your password confidential. CoderPad employees will never ask for your password.
RETENTION OF PERSONAL DATA
This Site is only intended for individuals who are at least 16 years of age. We do not knowingly encourage or solicit visitors to this Site 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 Site 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 uses 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. Instructions on how to unsubscribe from these alerts and newsletters are included in each e-mail.
YOUR PERSONAL DATA CHOICES
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;
- Choose whether you wish to receive promotional and newsletter communications; and
- Choose whether you wish to share Personal Data with and use CoderPad integrations.
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 firstname.lastname@example.org. CoderPad will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Data. We will respond to your access request within 30 days. Please note that we may retain certain information, including cached or archived copies, as required by law or for legitimate business purposes.
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:
- We provide you the opportunity to “opt-out” of having your Personal Data used for certain purposes and instances. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by contacting us here. We offer an opportunity to opt-out of certain communications by contacting us using the information below.
- 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 by deleting your browser’s cookies. For more information, please review our Cookies Notice.
Exercising Access, Data Portability and Deletion 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@example.com.
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 cannot verify 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 contacting us as set forth in the How to Contact Us section below.
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. 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.
What are cookies and why are cookies used: A cookie is a piece of data that a website can send to your browser, which may then be stored on your computer as a tag that identifies your computer. While cookies are often only used to measure website usage (such as number of visitors and duration of visit) and effectiveness (such as topics visitors are most interested in) and to allow for ease of navigation or use and, as such, are not associated with any personal information, they are also used at times to personalize a known visitor’s experience of a website by being associated with profile information or user preferences. Over time this information provides valuable insight to help improve the user experience.
Cookies on our Sites are generally divided into the following categories:
- Necessary Cookies. These cookies are necessary to provide you with our Services and to use some of their features, such as access to secure areas. Because these cookies are strictly necessary to deliver the Services, you cannot refuse them without impacting how our Services function. These cookies do not collect identifying information about you, and they do not monitor or remember any of your internet browsing on sites other than CoderPad.
- Helpful Cookies. These cookies allow us to provide you with a better experience when you use our Site. For example, these cookies provide a getting started guide to interview candidates who have not used CoderPad before. These cookies do not collect identifying information about you, and they do not monitor or remember any of your internet browsing on sites other than CoderPad.
- Google Analytics and Customization Cookies. These cookies collect information that is used to help us understand how our Services are being used or how effective our marketing campaigns are, or to help us customize our Services for you to enhance your experience. This data is anonymous and only used for statistical purposes, analytics cookies do not collect or share any personally identifiable information. These cookies qualify as “third-party” cookies as they are not sent directly by CoderPad. You may see how Google uses data when you use this Site at google.com/policies/privacy/partners.
- Web Beacons. Pages of our the Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the CoderPad, for example, to count users who have visited those pages or [opened an email] and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- Targeting Cookies. These record your visit to our Sites, the pages you have visited and the links you have followed to recognize you as a previous visitor and to track your activity on the Sites and other Sites you visit. These Cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our Sites. You can delete these cookies via your browser settings. See below for further details on how you can control third-party targeting cookies.
To exercise choice regarding those Cookies, please see the Google Analytics Opt-out Browser Add-on at tools.google.com/dlpage/gaoptout. The opt-outs described above are device and browser specific and may not work on all devices.
YOUR CALIFORNIA PRIVACY RIGHTS
As of January 1, 2020, under the California Consumer Privacy Act (CCPA), California Residents have the right to request the following information from CoderPad by emailing firstname.lastname@example.org and CoderPad will provide the following information to you upon verification of your identity:
- The categories of Personal Data CoderPad collects about you;
- The categories of sources from which your Personal Data is collected;
- The business purpose for collecting your Personal Data;
- The categories of third parties with whom CoderPad shares your Personal Data; and
- The specific pieces of Personal Data CoderPad have collected about you.
You agree that in accordance with the CCPA, CoderPad 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, CoderPad will not discriminate against you for exercising any of your CCPA rights. Unless otherwise permitted by the CCPA, 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. Under the current definition of CCPA, CoderPad does not sell your Personal Data.
ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA
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”). CoderPad is a processor of personal information submitted to the Site or collected through the Site on behalf of or at the direction of our Subscribers. CoderPad does not control or own the data submitted by its Subscribers to the Service. 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 (the person or company that requested that you 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.
PRIVACY SHIELD 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 page for further details on our Privacy Shield compliance.
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.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 JAMS Privacy Shield Dispute Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.
LINKS TO OTHER SITES
HOW TO CONTACT US