Qodo Privacy Policy

Last Revised: (September 29, 2024)

Introduction

This Privacy Policy details how Codium Ltd. and its affiliates, doing business as Qodo (“us“, ”we” or “Qodo“) process information of our customers’ employees who are registered users of our services or users of our Website, as applicable (each, “you“ or “User“) collected through our platform or through our website at https:/qodo.ai/ (the “Services“ and “Website“, respectively).

Qodo’s details are as follows:

Codium Ltd. (dba Qodo)

[email protected]

We may revise this policy from time to time, in our sole discretion, and the most current version will always be posted on our Website (as reflected in the “Last Revised” heading). We encourage you to visit this page regularly for any changes.

What information we collect

We may collect personal information about you, which means any information relating to an identified or identifiable natural person or “personal data” or “personal information” as otherwise defined under applicable privacy laws (“Personal Information“)

For Website Users:

We may collect information that you provide to us voluntarily such as your email address, for instance when you communicate with us via the ‘contact us’ option on the Website. In those cases, we will use such information to contact you in connection with your submission to us. Such information may also include Personal Information that is shared with us by third parties, based on your consent to be contacted for marketing purposes.
We may collect specific types of connection details and information with regard to your device, software or hardware that may identify you. Such information may include your browser type, OS version, device model, IP address, device location, network information, etc.
Information regarding User’s activity on the Website such as your clicks, actions and browsing on the Website.

For Services Users:

Information which we receive from our customers when signing-up or registering to our Services, which may include the following information: your name and email address.
We also collect information about your use of the Services, either on an identified basis, in connection with our Services to the applicable customer, or on an anonymized basis, for statistical purposes or to train and improve the Services’ performance, to improve our Website and to develop new products and services.

Legal basis of Processing:

Depending on the type of use as detailed below, Qodo processes Personal Information based on the following legal basis:

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract,
Processing is necessary for our legitimate interests and those of third parties in the purposes identified below
Processing is necessary to comply with our legal obligations
Consent (with regards to marketing communications).

How we use the information

We use the information in the manners described in this Privacy Policy. In addition to those purposes listed herein, the information we collect, which may include your Personal Information, is used for the following purposes:

To respond to inquiries and requests from our Users, or to provide you with further information about our products and services;
To provide our customers with the Services, including support in connection therewith;
To investigate and resolve disputes in connection with your use of the Services;
To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and
To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
To improve the performance of our Website.

With whom we share the information and for what purpose

We do not rent or sell any Personal Information. We may share Personal Information with the following recipients:

Our third-party vendors engaged in providing services in connection with the Services, the Website or sending marketing communications (the latter, with your consent);
Our subsidiaries and affiliated companies;
Auditors or advisers of our business processes; and
Any potential purchasers or investors in Qodo.

We may share Personal Information with our recipients for any of the following purposes: (i) storing or processing Personal Information on our behalf (e.g., cloud computing service providers); (ii) assisting us with our business operations (e.g., verifying and processing transactions); and (iii) performing research, technical diagnostics, personalization and analytics that will enable us to train and improve the Services and Website’s performance, and develop new products and services.

We may also disclose Personal Information, or any information you submitted via the Services or Website (as applicable) if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our agreements), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our affiliates, our users, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.

Third Party Tracking Technologies

We use cookies and other technologies in our related services, including when you visit our Website or access our Services. A “cookie” is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services.

Our Website uses cookies in order to provide you with Services, identify you for repeat visits, (for example to allow us to store your preferences for the next sign-in), and monitor and analyze our web access. We may also use cookies in order to associate your activities with other Personal Information found in third party databases, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses.

We also use a tool called Google Analytics to collect information about your use of the Services. This third-party service collects information such as how often users access the Services, what pages they visit when they do so, etc. We use the information we get from these tools only to improve our Services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your use of the Services is restricted by the Google Analytics Terms of Service and the Google Privacy Policy .

You may remove the cookies by following the instructions of your device preferences; You can find more information about cookies at www.allaboutcookies.org; however, if you choose to disable cookies, some features of our Service may not operate properly and your online experience may be limited.

International transfer

Since we operate globally, it may be necessary to transfer data, including Personal Information, to other countries than the country in which the information was collected. In these instances, we will transfer your data only based on standard data protection clauses adopted by the European Commission.

For how long we retain the information

We retain the information that we collect from our Users for as for as long as it is relevant based on the purpose it was collected for (for Website Users), and/or for long as we are providing the Services to the applicable customer (for Users of our Services). Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we may keep records containing Users’ Personal Information, account opening documents, communications and anything else as required by applicable laws and regulations.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Your privacy rights

Certain jurisdictions provide Users with certain statutory rights to their Personal Information. Subject to exemptions provided by law, and with proper identification, you may have the right to certain actions to your Personal Information such as:

Right to verify your Personal Information (to access, delete, change or update any Personal Information relating to you. For example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted);
Right to see what Personal Information about you we have;
Right to request that we erase Personal Information about you (subject to any other legal obligation that may require us to keep that information);
Right to restrict us from processing Personal Information pertaining to you (for example, you may request that we will stop using or sharing your Personal Information with third-parties); and
Right to export Personal Information in a portable format.

If you wish to exercise any of these rights, contact us at: [email protected]. When handling your request, we will ask for additional information to confirm your identity (which may include Personal Information). However, please note that if you choose not to allow us to process your Personal Information, we may be prevented from providing our Services or access to the Website.

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at: [email protected]

If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can file a complaint to the applicable data protection authority.