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CODECADEMY PRIVACY POLICY
This Policy was last updated April 5, 2022.
Codecademy LLC (“Codecademy,” “we,” “our,” or “us”) is committed to protecting
your privacy. Our Privacy Policy (the “Policy”) explains how we collect, use,
disclose, and protect information about you or associated with you (“personal
information”), and your choices about the collection and use of your
information. This Privacy Policy applies to the online services offered by
Codecademy such as our website at www.codecademy.com, our mobile app Codecademy
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 Use 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.
Depending on where you are located or reside, you may be entitled to additional
rights.
1. If you are a data subject in the European Union, please see the “Additional
Disclosures for People in Europe” section below;
2. If you are a California resident please see the “Additional Disclosures for
California Residents” section below; and
3. If you are a Nevada resident please see the “Additional Disclosures for
Nevada Residents” section below.
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 in order to access most of the features of Service. Certain personal
information—such as a user name, email address—are 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 categories of information we collect and have collected
directly from you in the last 12 months:
* 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.
* Billing Data, including your payment instrument number (such as a credit or
debit card number), expiration date, and security code as necessary to
process your payments.
* 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 personal contacts. We collect data about your contacts
with your consent and in order 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 U.S. residents. By using this
functionality, you acknowledge and agree that both you and your contacts are
based in the U.S. 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.
2. INFORMATION COLLECTED AUTOMATICALLY
In addition, we automatically collect information when you use the Service. The
categories of information we automatically collect and have collected in the
last 12 months includes:
* 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 of time, 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 contains 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 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.
3. INFORMATION FROM OTHER SOURCES
We also collect information from other sources. The categories of sources we
collect information from including in the last 12 months, 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
grant us permission 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 Codecademy.
We collect this information for a number of 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 with respect to our business purposes for using information,
including in the last 12 months, include:
* Operate and manage our Service, including your registration and account.
* Perform services requested by you, such as respond 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 Codecademy 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 with respect to information
collected.
We share information we collect in accordance with the practices described in
this Privacy Policy. The categories of entities to whom we disclose and have
shared information with in the last 12 months, 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 in order 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 bootcamps,
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 process, 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.
* __Consent__. 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.
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 Codecademy
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 the U.S. 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 own
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 us uploading a customer list to a
technology service or incorporating a pixel from a technology service into our
own 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 own 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 with respect to 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. European data
subjects and California residents have additional rights as set forth in the
sections entitled “Additional Disclosures for Data Subjects in Europe” and
“Additional Disclosures for California Residents” below.
2. 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, there is
no industry consensus as to what site and app operators should do with regard
to these signals. Accordingly, unless and until the law is interpreted to
require us to do so, we do not monitor or take action with respect to “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.
3. 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 set forth
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 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.
4. 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 (as defined by the U.S.
Children’s Privacy Protection Act, or “COPPA”) from anyone under the age of 13
in a manner not permitted by COPPA. 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.
We do not “sell,” as that term is defined under the California Consumer Privacy
Act, the personal information of minors under the age of 16 who are California
residents. If you are a California resident under 18 years old and registered to
use the Service, you can ask us to remove any content or information you have
posted on the Service. To make a request, email us at the email address set out
in “Contact Us” section with “California Under 18 Content Removal Request” in
the subject line, and tell us what you want removed. We will make reasonable
good faith efforts to remove the post from prospective public view, although we
cannot ensure the complete or comprehensive removal of the content and may
retain the content as necessary to comply with our legal obligations, resolve
disputes, and enforce our agreements.
SCHOOL PRIVACY
In some circumstances, we may permit a schools to register Students to our
service for the purpose of providing educational services. Because Codecademy
provides the Service to schools to benefit and enhance a School’s curriculum,
Codecademy 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 the California Consumer Privacy Act, any personal
information of users collected through school accounts.
DATA SECURITY
Codecademy uses commercially reasonable administrative, technical, and physical
security safeguards designed to preserve the integrity and security of all
information collected through the Service. However, no security system is
impenetrable and we cannot guarantee the security of our systems 100%. In the
event that 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 in accordance with 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 Codecademy Service, such as social networks. Codecademy is not responsible
for the functionality or security measures of any third party.
INTERNATIONAL TRANSFER
We are based in the U.S. and the information we collect is governed by U.S. law.
If you are accessing the Service from outside of the U.S., please be aware that
information collected through the Service may be transferred to, processed,
stored, and used in the U.S. and other jurisdictions. Data protection laws in
the U.S. 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 U.S. and other
jurisdictions as set out in this Privacy Policy.
CHANGES TO THIS PRIVACY POLICY
Codecademy reserves the right to modify or update this Privacy Policy from time
to time to reflect the changes in our business and practices, and 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 own
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:
Codecademy, Inc. 600 Broadway 2nd Floor New York City, NY 10012
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 CALIFORNIA RESIDENTS.
These additional disclosures for California residents apply only to individuals
who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”)
provides additional rights to know, delete and opt out, and requires businesses
collecting or disclosing personal information to provide notices and means to
exercise rights.
1. NOTICE OF COLLECTION.
In the past 12 months, we have collected the following categories of personal
information enumerated in the CCPA:
* Identifiers, including name, email address, phone number account name, IP
address, and an ID or number assigned to your account.
* Customer records, billing and shipping address, and credit or debit card
information.
* Demographics, such as your age or gender. This category includes data that
may qualify as protected classifications under other California or federal
laws.
* Commercial information, including purchases, you subscription and engagement
with the Services.
* Internet activity, including your interactions with our Service, your
academic content, and performance data.
* Audio or visual data, including pictures or vides you post on our Service.
* Geolocation data, including location enabled services such as WiFi and GPS.
* Employment and education data, including information you provide when you
apply for a job with us.
* Inferences, including information about your interests, preferences and
favorites.
For more details on information we collect, including the sources we receive
information from, review the Information Collection section. We collect and use
these categories of personal information for the business purposes described in
the Use of Information section, including to provide and manage our Services.
Codecademy does not generally sell information as the term “sell” is
traditionally understood. However, to the extent “sale” under the CCPA is
interpreted to include advertising technology activities such as those disclosed
in the Analytics and Advertising section as a “sale,” we will comply with
applicable law as to such activity. We discloses the following categories of
personal information for commercial purposes: identifiers, demographic
information, commercial information, internet activity, geolocation data and
inferences. We use and partner with different types of entities to assist with
our daily operations and manage our Service. Please review the Sharing of
Information section for more detail about the parties we have shared information
with.
2. RIGHT TO KNOW AND DELETE
If you are a California resident, you have the right to delete the personal
information we have collected from you and the right to know certain information
about our data practices in the preceding 12 months. In particular, you have the
right to request the following from us:
* The categories of personal information we have collected about you;
* The categories of sources from which the personal information was collected;
* The categories of personal information about you we disclosed for a business
purpose or sold;
* The categories of third parties to whom the personal information was
disclosed for a business purpose or sold;
* The business or commercial purpose for collecting or selling the personal
information; and
* The specific pieces of personal information we have collected about you.
To exercise any of these rights, please submit a request through our online
privacy hub, or contact us through our Help Center. In the request, please
specify which right you are seeking to exercise and the scope of the request. We
will confirm receipt of your request within 10 days. We may require specific
information from you to help us verify your identity and process your request.
If we are unable to verify your identity, we may deny your request to know or
delete.
If personal information about you has been processed by us as a service provider
on behalf of a corporate customer or school customer and you wish to exercise
any rights you have with such personal information, please inquire with our
corporate or school customer directly. If you wish to make your request directly
to us, please provide the name of the corporate customer or school customer on
whose behalf we processed your personal information. We will refer your request
to that corporate customer or school customer, and will support them to the
extent required by applicable law in responding to your request.
3. RIGHT TO OPT-OUT
To the extent Codecademy sells your personal information as the term “sell” is
defined under the California Consumer Privacy Act, you have the right to opt-out
of the sale of your personal information by us to third parties at any time. You
may submit a request to opt-out by clicking Do Not Sell My Personal Information.
You may also submit a request to opt-out by contacting us through our Help
Center.
4. AUTHORIZED AGENT
You can designate an authorized agent to submit requests on your behalf.
However, we will require written proof of the agent’s permission to do so and
verify your identity directly.
5. RIGHT TO NON-DISCRIMINATION
You have the right not to receive discriminatory treatment by us for the
exercise of any of your rights.
6. SHINE THE LIGHT.
Customers who are residents of California may request (i) a list of the
categories of personal information disclosed by us to third parties during the
immediately preceding calendar year for those third parties’ own direct
marketing purposes; and (ii) a list of the categories of third parties to whom
we disclosed such information. To exercise a request, please write us at the
email or postal address set out in “Contact Us” above and specify that you are
making a “California Shine the Light Request.” We may require additional
information from you to allow us to verify your identity and are only required
to respond to requests once during any calendar year.
ADDITIONAL DISCLOSURES FOR NEVADA RESIDENTS.
Nevada consumers may submit requests directing businesses not to sell certain
kinds of personal information that the business has collected or will collect
about the consumer. A sale under Nevada law is the exchange of personal
information for monetary consideration by the business to a third party for the
third party to license or sell the personal information to other third parties.
If you are a Nevada consumer and wish to obtain information about our compliance
with Nevada law, please contact us through our Help Center.
ADDITIONAL DISCLOSURES FOR DATA SUBJECTS IN EUROPE.
1. ROLE
Data protection laws in Europe distinguish between organizations that process
personal data for their own purposes (known as “controllers”) and organizations
that process personal data on behalf of other organizations (known as
“processors”). Codecademy acts as a controller with respect to personal data
collected as you interact with our websites, emails, and advertisements.
2. LEGAL BASIS FOR PROCESSING
In the European Union (“EU”), the purposes for which we process your personal
data are:
1. Where you have given consent to the processing for one or more specific
purposes, either to us or to our service providers or partners;
2. Where we need to perform the contract we are about to enter into or have
entered into with you for the Service;
3. Where it is necessary for our legitimate interests (or those of a third
party) and your interests and fundamental rights do not override those
interests; and
4. Where we need to comply with a legal or regulatory obligation in the EU.
We have set out in Annex 1 below, found here, a description of all the ways we
plan to use your personal data, and which of the legal bases we rely on to do
so. Please contact by submitting a ticket through our Help Center if you need
details about the specific legal basis we are relying on to process your
personal data where more than one legal basis has been set out.
3. DATA TRANSFER
If your data is collected in Europe, we will transfer your personal data subject
to appropriate safeguards, such as Standard Contractual Clauses.
4. YOUR DATA SUBJECT RIGHTS.
If you are located in the EU or Switzerland, you have the following rights in
respect of your personal data that we hold:
* Right of access. The right to obtain access to your personal data.
* Right to rectification. The right to obtain rectification of your personal
data without undue delay where that personal data is inaccurate or
incomplete.
* Right to erasure. The right to obtain the erasure of your personal data
without undue delay in certain circumstances, such as where the personal data
is no longer necessary in relation to the purposes for which it was collected
or processed.
* Right to restriction. The right to obtain the restriction of the processing
undertaken by us on your personal data in certain circumstances, such as
where the accuracy of the personal data is contested by you, for a period
enabling us to verify the accuracy of that personal data.
* Right to portability. The right to portability allows you to move, copy or
transfer personal data easily from one organization to another.
* Right to object. You have a right to object to processing based on legitimate
interests and direct marketing.
If you wish to exercise one of these rights, please contact us using the contact
details at the end of 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 fulfil 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 personal 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
personal 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.
5. COMPLAINTS.
If you have a complaint about our use of your personal data or response to your
requests regarding your personal 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.
ANNEX 1
Legal basis for processing in the EU
Category of personal information Purpose/Activity Lawful basis for processing
including basis of legitimate interest Contact information and basic personal
details such as your first name, last name, e-mail address and date of birth. We
use this information to operate, maintain and provide to you the features of the
Service. The processing is necessary for: the performance of a contract and to
take steps prior to entering into a contract; and our legitimate interests,
namely administering the Service, for marketing purposes and communicating with
users. We use this information to communicate with you, including sending
Service-related communications (such as invoices and information about updates
to the Service, and any news, alerts and marketing communications (in line with
your settings and options)). The processing is necessary for: the performance of
the contract and to take steps prior to entering into a contract; and our
legitimate interests, namely administering the Service, for marketing purposes
and communicating with users. We use this information to deal with enquiries and
complaints made by or about you relating to the Service. The processing is
necessary for our legitimate interests, namely administering the Service, for
marketing purposes and communicating with users. Information about how you
access and use the Service including, for example, how frequently you access the
Service, the time you access the Service and how long you use the Service for,
whether you access the Service from multiple devices, the website from which you
came and the website to which you go when you leave the Service, and other
actions you take on the Service. We use this information to present the Service
to you on your device. The processing is necessary for our legitimate interests,
namely to tailor the Service to the user and improve the Service generally. We
use this information to administer the Service for internal operations,
including troubleshooting, data analysis, testing, research, statistical and
survey purposes, and to help us develop new products and services. The
processing is necessary for our legitimate interests, namely communicating with
users and responding to queries, complaints, and concerns, and for developing
and improving the Service. We use this information to detect and prevent fraud.
The processing is necessary for our legitimate interests, namely the detection
and prevention of fraud. Content you post to the Service including any content
you provide through messages, chat, or other functionality. We use this
information to operate, maintain and provide to you the features of the Service.
The processing is necessary for our legitimate interests, namely administering
the Service. We use this information to improve the Service. The processing is
necessary for our legitimate interests, namely for developing and improving the
Service. Location: When you use the Service, we will collect and process
location data. We use various technologies to determine location, including IP
address, GPS and other sensors that may, for example, provide Codecademy with
information on nearby devices, Wi-Fi access points and mobile towers. We use
this information to operate, maintain and provide to you the features of the
Service. The processing is necessary for our legitimate interests, namely
administering the Service. Information provided by social networks, including
LinkedIn, when you connect to the Service. The features and functionality of the
Service connects social networks, predominantly LinkedIn, to our Service. In
this case, we collect personal information from the social network in accordance
with your privacy settings on that social network. The connected social network
may provide us with information, such as your name, LinkedIn ID, profile
picture, network, gender, username, userID, age or age range, language, country,
connections and any other information you have agreed it can share or that the
social network provides to us. We will use the personal information provided to
allow you to log in to the Service, to help create a public profile for you, and
where we provide the functionality, we will also use the information provided to
assist you in sharing the content you create, or your experiences on the Service
with your contacts on the connected social network. The processing is necessary
for: the performance of the contract and to take steps prior to entering into a
contract; and our legitimate interests, namely administering the Service, for
marketing purposes and communicating with users.
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