Privacy Notice​

Effective as of Jul 6th, 2023.

This Privacy Notice describes how Codeney Pte. Ltd. ("we", "us" or "our") handles and protects personal information that we collect through our digital properties that link to this Privacy Notice, including our website (collectively, the "Service"), as well as through social media, our marketing activities, and other activities described in this Privacy Notice.

Personal information we collect​

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your name and email address.
• Account data, such as the username and password that you may set to establish an online account on the Service.
• Communications data based on our exchanges with you, including when you contact us through the Service, the chatbot, social media, or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Other data not specifically listed here, which we will use as described in this Privacy Notice or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Public sources, such as social media platforms, and other publicly available sources.
• Third-party services, such as social media/networking and other online services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or general geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

How we use your personal information​

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery. We may use your personal information to:

• provide, operate and improve the Service and our business;
• personalize your experience with the Service and our communications, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
• establish and maintain your account on the Service;
• enable security features of the Service, such as by sending you confirmation of account creation via email, and remembering devices from which you have previously logged in;
• communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
• provide support for the Service, and respond to your requests, questions and feedback.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, identify issues, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Compliance and protection. We may use your personal information to:

1. comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
2. protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
3. audit our internal processes for compliance with legal and contractual requirements or our internal policies;
4. enforce the terms and conditions that govern the Service; and
5. prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

Retention. We generally retain personal information to fulfill the purposes for which we collected it as described in this Privacy Notice. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we may either delete it or anonymize it.

How we share your personal information​

We may share your personal information with the following parties and as otherwise described in this Privacy Notice or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, consumer research, marketing, and website analytics).

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processor, Stripe. Stripe may use your payment data in accordance with its privacy notice, available at https://stripe.com/en-sg/privacy.

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.

Third parties designated or consented by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so. We will share personal information that is needed for these other companies to provide the services that you have requested.

Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party's use of the shared information will be governed by its privacy notice and the settings associated with your account with the third-party service.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in us, our parent, our affiliates, or our subsidiaries (including, in connection with a bankruptcy or similar proceedings).

Your choices​

Access or update your information. You may have the right to access and update your personal information in accordance with applicable data protection laws.

Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies and Do Not Track. You may adjust your internet browser settings to disable, block or deactivate cookies, delete your browsing history or clear the cache from your Internet browser. The settings may be contained within the "History", "Preferences", "Settings" or "Privacy" section of your internet browsers, or you may otherwise consult the help section of your internet browser for more information. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track", please visit http://www.allaboutdnt.com.

Advertising choices. You may be able to limit use of your information for interest-based advertising through changing your Internet web browser settings or limiting use of the advertising ID associated with your mobile device for interest-based advertising purposes.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other sites and services​

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security​

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

International data transfer​

We are headquartered in Singapore and may use service providers that operate in other countries. Your personal information may be transferred to Singapore or other locations where privacy laws may not be as protective as those in your state, province, or country. When we transfer your personal information internationally, we will comply with our legal and regulatory obligations in relation to your personal information, including putting appropriate safeguards in place as required by applicable data protection laws.

Children​

The Service is not intended for use by children under the age specified by applicable data protection laws. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Notice​

We reserve the right to modify this Privacy Notice at any time. If we make material changes to this Privacy Notice, we will notify you by updating the date of this Privacy Notice and posting it on the Service or other appropriate means. Any modifications to this Privacy Notice will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Notice indicates your acceptance of the modified Privacy Notice.

How to contact us​

Email: legal@greatfrontend.com