Privacy Policy

CodeSmashers Education Ltd.

CodeSmashers Education Ltd. (“CodeSmashers,” “we,” “our,” or “us”) is committed to protecting your privacy. Our Privacy Policy (the “Policy”) explains how we collect, use, disclose, process, and protect information about you or associated with you (“personal information”), and your choices about the collection and use of your information when you use the online and/or mobile services or website of CodeSmashers. This Privacy Policy applies to the online services offered by CodeSmashers such as our website at www.codesmashers.uk, our mobile app CodeSmashers Go, and any other online service location (collectively the “Service”) that makes this Privacy Policy available to you.

By using the Service, you agree to our Terms of Service and consent to our collection, use, and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree and consent, discontinue use of the Service.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section.

Information Collection

This section will discuss what type of information is collected. This includes categories of information that (1) you provide to us directly, (2) is collected by us automatically, and (3) we receive from third-party sources.

1. Information You Provide Directly to Us

You can browse our site without providing personal information, but you must register to access most of the features of the Service. Certain personal information—such as a user name, or email address—is required to create an account. However, after you set up an account, you may choose what additional information may be shared through public profiles, including your name, location, website, links to your social media profiles, and other information that may be considered personal information. Similarly, should you choose to engage in messaging through the Service, the contents of such messages may be processed and saved by us. You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.

The following are the categories of information we collect:

• Contact Data, including your first and last name, email address, postal address, and phone number.
• Account Credentials, including your username, password, password hints, and information for authentication and account access.
• Demographic Data, including your age, gender, and country.
• Profile Data, including your interests, inferences, preferences, and favorites.
• Content, including content within any messages you send to us (such as feedback and questions to customer support) or publicly post on the Service (such as in your public profile, in reviews, and comments) as well as any academic content that you generate and submit for grading. We also collect content within any messages you exchange with other users through the Service (such as if you use our chat functionalities).
• Personal Contacts Data, including the first and last name, email address, and phone number of your contacts. We collect data about your contacts with your consent and to fulfill a request by you, such as finding your contacts on the Service or inviting your contacts to join the Service. Such functionality is only intended for UNITED KINGDOM residents. By using this functionality, you acknowledge and agree that both you and your contacts are based in the UNITED KINGDOM and that you have your contacts’ consent for us to use their contact information to fulfill your request.
• Job Applicant Data, including your employment and education history, transcript, writing samples, and references as necessary to consider your job application for open positions.

You may choose to voluntarily provide other information to us, and, in such instances, you are solely responsible for such information.

1. Information Collected Automatically

In addition, we automatically collect information when you use the Service. The categories of information we automatically collect include:

• Service Use Data, including data about features you use, pages you visit, emails and advertisements you view, products and services you view and purchase, the time of day you browse, and your referring and exiting pages.
• Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad ID.
• Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level) and, with your consent, precise location data (such as latitude/longitude data).

We use various current – and later–developed tracking technologies to automatically collect information when you use the Service, including the following:

• __Log Files__, which are files that record events that occur in connection with your use of the Service.

• __Cookies__, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods and generally may be controlled through your browser settings.

• __Pixels__ (also known as web beacons), which is code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contain JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities that allow us to track our conversions, bring you advertising both on and off the Service and provide you with additional functionality, such as the ability to connect our Service with your social media account.

• __Device Fingerprinting__, which is the process of analyzing and combining sets of data elements from your device’s browser, such as JavaScript objects and installed fonts, to create a “fingerprint” of your device and uniquely identify your browser and device.

• __App Technologies__, which are technologies included in our apps that are not browser-based like cookies, and cannot be controlled by browser settings. For example, our apps may include SDKs, which is code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the Service and provide you with additional functionality, such as the ability to connect our Service with your social media account.

• __Location-Identifying Technologies__, which are technologies used to collect your location. For example, GPS, WiFi, and Bluetooth may be used to collect precise location data when you consent to precise location tracking through our apps. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.

For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.

1. Information From Other Sources

We also collect information from other sources. The categories of sources we collect information from include:

• Data brokers or resellers from which we purchase data to supplement the data we collect.
• Social networks when you engage with our content, reference our Service, or permit us to access information from the social networks.
• Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
• Publicly available sources, including data in the public domain.

Use of Information

This section discusses how collected information is used by CodeSmashers.

We collect this information for several business purposes including to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages.

The categories concerning our business purposes for using information include:

• Operate and manage our Service, including your registration and account.
• Perform services requested by you, such as responding to your comments, questions, and requests, and provide customer service.
• Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
• Preventing and addressing fraud, breach of policies or terms, and threats or harm.
• Monitoring and analyzing trends, usage, and activities.
• Conducting research, including focus groups and surveys.
• Improving the Service or other CodeSmashers websites, apps, marketing efforts, products, and services.
• Developing and sending you direct marketing, including advertisements and communications about our and other entities’ products, offers, promotions, rewards, events, and services.
• Conducting promotions, including verifying your eligibility and delivering prizes in connection with your entries.
• Sending you advertising.
• Fulfilling any other business or commercial purposes at your direction or with your notice and/or consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

Sharing of Information

This section explains our sharing practices concerning the information collected.

We share the information we collect following the practices described in this Privacy Policy. The categories of entities to whom we disclose include the following:

• Service Providers. We share information with entities that process information on our behalf for our business purposes. Service providers assist us with services such as payment processing, chat functionality, data analytics, marketing and advertising, website hosting, and technical support. We may permit our service providers to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
• Vendors and Other Parties. We share information with vendors for business and commercial purposes, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below.
• Affiliates. We share information with our related entities including our parent and sister companies for business purposes such as customer support, marketing, and technical operations. We also may share information with affiliates for commercial purposes.
• Corporate and School Customers. We share information with our corporate customers and schools that purchase our Service in connection with us processing information on their behalf. For example, we share information with our corporate and school customers to facilitate your orders, maintain and administer your online accounts, provide feedback, academic content, and student performance data to account managers and instructors, respond to your questions and comments, provide support, comply with your requests, market and advertise to you, and otherwise comply with applicable law.
• Partners. We share information with our partners (such as boot camps, interview prep organizations, and employment marketplaces) in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.
• Promotions. When you voluntarily enter a sweepstakes, contest, or other promotion, we share information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice, and/or likeness in advertising or marketing materials.

• __Public Information__. We share information you make public through the Service, such as information in your profile or that you post on public boards or other public sections of the Service. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Your Rights and Choices” section below.

• __Merger or Acquisition__. We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.

• Security and Compelled Disclosure. We share information to comply with the law or other legal processes, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security, and safety of us, the Service or anyone else.

• __Facilitating Requests__. We share information at your request or direction, such as when you choose to share information with a social network about your activities on the Service.

• We share information with notice to you and your consent.

Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below. In the event we share your sensitive personal data with a third party, such third parties shall be contractually bound to disclose further any such sensitive personal information disclosed to them.

Social Media and Technology Integrations

We offer parts of our Service through websites, platforms, and services operated or controlled by separate entities. In addition, we integrate technologies operated or controlled by separate entities into parts of our Service. Some examples include:

• Links. Our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us. We may get a commission if you purchase a product after clicking on a link to an affiliate’s website.
• Liking, Sharing, and Logging-In. We may embed a pixel or SDK on our Service that allows you to “like” or “share” content on, or log in to your account through social media. If you choose to engage with such integration, we may receive information from the social network that you have authorized to share with us. Please note that the social network may independently collect information about you through the integration.
• Brand Pages and Chatbots. We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page or via our chatbot on Facebook Messenger) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on social media (e.g., by using a hashtag associated with CodeSmashers in a tweet or post), we may use your reference on or in connection with our Service.

Please note that when you interact with other entities, including when you leave our Service, those entities may independently collect information about you and solicit information from you. The information collected and stored by those entities remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in India or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

Analytics and Advertising

We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.

As part of this process, we may incorporate tracking technologies into our Service (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).

We also use audience matching services to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). This is done by uploading a customer list to a technology service or incorporating a pixel from a technology service into our Service, and the technology service matching common factors between our data and their data. For instance, we incorporate the Facebook pixel on our Service and may share your email address with Facebook as part of our use of Facebook Custom Audiences. Some technology services may provide us with their data, which is then uploaded into another technology service for matching common factors between those datasets.

As indicated above, vendors may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, Interest-based Advertising, and Matched Ads, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.

Your Rights and Choices

You have rights and choices concerning information that relates to you, however, such rights will vary depending on the category of information, and the subsequent use of such information. This section further describes your rights.

1. Account Information.

You may access, update, or remove certain information that you have provided to us through your account by visiting your account settings. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements to the extent permitted under applicable law.

1. Tracking Technology Choices.

• Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
• Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, that there is no industry consensus as to what site and app operators should do about these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action concerning “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
• App and Location Technologies. You can stop all collection of information via an app by uninstalling the app. You can also reset your device Ad ID at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an app by uninstalling the app or withdrawing your consent through your device settings.

Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly.

1. Analytics and Interest-Based Advertising.

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/ .

The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).

To opt out of us using your data for Matched Ads, please contact us as outlined in the “Contact Us” section below and specify that you wish to opt out of matched ads. We will request that the applicable technology service not serve you matched ads based on the information we provide to it. Alternatively, you may directly contact the applicable technology service to opt-out.

You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).

Please note that if you opt-out using any of these methods, the opt-out will only apply to the specific browser or device from which you opt-out. We are not responsible for the effectiveness of, or compliance with, any opt-out options or programs, or the accuracy of any other entities’ statements regarding their opt-out options or programs.

1. Communications.

• E-mails. You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or by contacting us as set out in the “Contact Us” section below. Please note that you cannot opt out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations.
• Push Notifications. If you have opted-in to receive push notifications on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our app.

Please note that your opt-out is limited to the email address and device used and will not affect subsequent subscriptions.

Children’s Privacy

Our Service is generally not directed at children under the age of 16 and we do not knowingly collect or solicit personal information from anyone under the age of 13 in a manner not permitted under applicable law. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, please contact us through our Help Center. We will remove the data to the extent required by applicable law.

School Privacy

In some circumstances, we may permit schools to register Students to our service to provide educational services. Because CodeSmashers provides the Service to schools to benefit and enhance a School’s curriculum, CodeSmashers relies on the school to obtain and provide appropriate consent, if needed, to collect personal information of students. We do not “sell,” as that term is defined under applicable law, any personal information of users collected through school accounts.

Data Security

CodeSmashers uses commercially reasonable administrative, technical, and physical security safeguards designed to preserve the integrity and security of all information collected through the Service, at a minimum those mandated under the applicable law to safeguard and protect your data and information. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. If any information under our control is compromised as a result of a breach of security, we will take reasonable and appropriate steps to investigate the situation, notify those individuals whose information may have been compromised by any applicable laws and regulations, and take other steps as appropriate. Your privacy settings may also be affected by changes to the functionality of third-party sites and services that you add to the CodeSmashers Service, such as social networks. CodeSmashers is not responsible for the functionality or security measures of any third party.

International Transfer

We are headquartered in the UNITED KINGDOM and the information we collect is governed by UNITED KINGDOM law in addition to Indian law. If you are accessing the Service from outside of the UNITED KINGDOM, please be aware that information collected through the Service may be transferred to, processed, stored, and used in the UNITED KINGDOM and other jurisdictions. Data protection laws in the UNITED KINGDOM and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the UNITED KINGDOM and other jurisdictions as set out in this Privacy Policy.

Changes to this Privacy Policy

CodeSmashers reserves the right to modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, so you should review this page periodically. When we change the policy we will reflect the ‘last modified’ date at the top of this Privacy Policy.

Links to Other Websites and Services

The Services may, from time to time, contain links to and from websites, platforms, and other services not operated or controlled by us. If you follow a link to any of these locations, please note that these locations have their privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those locations.

Contact Us

If you have any questions about this Privacy Policy, our data practices, our compliance with applicable law, or the Service, please contact us by submitting a ticket through our Help Center, or by contacting us at:

128 City Road, London, United Kingdom,EC1V 2NX

This Privacy Policy has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us through the Help Center.

Additional Disclosures for Data Subjects in India

1. Your Data Subject Rights

If you are located in India, you have the following rights in respect of your data that we hold:

• Right of access. The right to obtain access to your data.
• Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete.

If you wish to exercise one of these rights, please contact us using the contact details in this Privacy Policy. We will respond to your request within 30 days. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

Please note that we retain information as necessary to fulfill the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

If your data has been processed by us on behalf of a business customer and you wish to exercise any rights you have with such personal data, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your data. We will refer your request to that customer and will support them to the extent required by applicable law in responding to your request.

1. Complaints

If you have a complaint about our use of your data or a response to your requests regarding your data, you may submit a complaint to the data protection regulator in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator, and would welcome you directing an inquiry first to us. In addition to the contact information above, please contact our Help Center.

1. Grievances

In the event you have any grievances related to the Privacy Policy, please inform the Company within 24 hours of the occurrence of the instance from which the grievance has arisen, by writing an email to the Customer Support Team.