Makoro Privacy Statement

Last Updated: December, 2022

Your privacy is important to us. This privacy statement explains the personal data CodeData, Inc. (hereafter referred as CodeData) processes, how CodeData processes it, and for what purposes.

CodeData offers a wide range of products, including products used to help operate enterprises worldwide, and services developers use to build upon and extend our products. References to CodeData’s products in this statement include CodeData’s services, websites, apps, and software.

Please read the product-specific details in this privacy statement, which provide additional relevant information. This statement applies to the interactions CodeData has with you and our products listed below, as well as other CodeData products that display this statement.

Cookies

Most CodeData sites use cookies, small text files placed on your device which web servers utilize in the domain that placed the cookie can retrieve later. We use cookies to store your preferences and settings, help with sign-in, and analyze site operations.

Contact us

If you have a privacy concern, complaint, or question related to data usage and privacy, please contact us via email at support@codedata.io.

 

Personal data we collect

CodeData collects data from you, through our interactions with you and through our products. You provide some of this data directly, and we get some of it by collecting data about your interactions, use, and experiences with our products. The data we collect depends on the context of your interactions with CodeData and the choices you make, including your privacy settings and the products and features you use.

If you represent a business that utilizes Makoro™ Products from CodeData, please see the Makoro Products section of this privacy statement to learn how we process your data.

You have choices when it comes to the technology you use and the data you share. When we ask you to provide personal data, you can decline. Many of our products require some personal data to provide you with a service. If you choose not to provide data required to provide you with a product or feature, you cannot use that product or feature. Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing product you’re using, we may have to suspend or cancel it. We will notify you if this is the case at the time. Where providing the data is optional, and you choose not to share personal data, features like personalization that use such data will not work for you.

You have choices when it comes to the technology you use and the data you share. When you are asked to provide personal data, you can decline. Many of our products require some personal data to operate and provide you with a service. If you choose not to provide data required to operate and provide you with a product or feature, you cannot use that product or feature. Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing product you’re using, we may have to suspend or cancel it. We will notify you if this is the case at the time. Where providing the data is optional, and you choose not to share personal data, features like personalization that use the data will not work for you.

The data we collect can include the following:

Name and contact data. Your first and last name, business email address, business address, business phone number, and other similar contact data.

Credentials. Passwords, password hints, and similar security information used for authentication and account access.

Demographic data. Data about you such as your country, and preferred language.

Subscription and licensing data. Information about your subscriptions, licenses, and other entitlements.

Interactions. Data about your use of Makoro. In some cases, such as search queries, this is data you provide in order to make use of the products. In other cases, such as error reports, this is data we generate. Other examples of interaction data include:

  • Device and usage data. Data about your device and the product and features you use, including information about your hardware and software, how our products perform, as well as your settings. For example:
    • Payment and account history. Data about the items you purchase and activities associated with your account.
    • Browse history. Data about the webpages you visit.
    • Device, connectivity, and configuration data. Data about your device, your device configuration, and nearby networks. For example, data about the operating systems and other software installed on your device, including product keys. In addition, IP address, device identifiers (such as the IMEI number for phones), regional and language settings, and information about WLAN access points near your device.
    • Error reports and performance data. Data about the performance of the products and any problems you experience, including error reports. Error reports (sometimes called “crash dumps”) can include details of the software or hardware related to an error, contents of files opened when an error occurred, and data about other software on your device.
    • Troubleshooting and help data. Data you provide when you contact CodeData for help, such as the products you use, and other details that help us provide support. For example, contact or authentication data, the content of your chats and other communications with CodeData, data about the condition of your device, and the products you use related to your help inquiry. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded.
  • Interests and favorites. Data about your interests and favorites, such as the sports teams you follow, the programming languages you prefer, the stocks you track, or cities you add to track things like weather or traffic. In addition to those you explicitly provide, your interests and favorites can also be inferred or derived from other data we collect.
  • Text, inking, and typing data. Text, inking, and typing data and related information. For example, when we collect inking data, we collect information about the placement of your inking instrument on your device.

Content. Content of your files and communications you input, upload, receive, create, and control. For example, if you transmit a file using Skype to another Skype user, we need to collect the content of that file to display it to you and the other user. If you receive an email using Outlook.com, we need to collect the content of that email to deliver it to your inbox, display it to you, enable you to reply to it, and store it for you until you choose to delete it. Other content we collect when providing products to you include:

  • Communications, including audio, video, text (typed, inked, dictated, or otherwise), in a message, email, call, meeting request, or chat.
  • Photos, images, songs, movies, software, and other media or documents you store, retrieve, or otherwise process with our cloud.

Feedback and ratings. Information you provide to us and the content of messages you send to us, such as feedback, survey data, and product reviews you write.

Product-specific sections below describe data collection practices applicable to use of those products.

How we use personal data

CodeData uses the data we collect to provide you with rich, interactive experiences. We use data to:

  • Provide our products, which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data, when it is required to provide the service or carry out the transactions you request.
  • Improve and develop our products.
  • Personalize our products and make recommendations.
  • Advertise and market to you, which includes sending promotional communications, targeting advertising, and presenting you with relevant offers.

We also use the data to operate our business, which includes analyzing our performance, meeting our legal obligations, developing our workforce, and doing research.

In carrying out these purposes, we combine data we collect from different contexts (for example, from your use of two CodeData products) to give you a more seamless, consistent, and personalized experience, to make informed business decisions, and for other legitimate purposes.

Our processing of personal data for these purposes includes both automated and manual (human) methods of processing. Our automated methods often are related to and supported by our manual methods. For example, our automated methods include artificial intelligence (AI), which we think of as a set of technologies that enable computers to perceive, learn, reason, and assist in decision-making to solve problems in ways that are similar to what people do.

Makoro uses the data we collect to provide you rich, interactive experiences. In particular, we use data to:

  • Provide our products, which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data, when it is required to provide the service or carry out the transactions you request.
  • Improve and develop our products.
  • Personalize our products and make recommendations.
  • Advertise and market to you, which includes sending promotional communications, targeting advertising, and presenting you relevant offers.

We also use the data to operate our business, which includes analyzing our performance, meeting our legal obligations, developing our workforce, and doing research.

More on the purposes of processing:

  • Provide our products. We use data to operate our products and provide you with rich, interactive experiences. Additionally, as communications are a feature of various products, programs, and activities, we use data to contact you. For example, we may contact you by phone or email or other means to inform you when a subscription is ending or discuss your licensing account. We also communicate with you to secure our products, for example by letting you know when product updates are available.
  • Product improvement. We use data to continually improve our products, including adding new features or capabilities.
  • Product activation. We use data—such as device and application type, location, and unique device, application, network, and subscription identifiers—to activate products that require activation.
  • Product development. We use data to develop new products. For example, we use data, often de-identified, to better understand our customers’ computing and productivity needs which can shape the development of new products.
  • Customer support. We use data to troubleshoot and diagnose product problems, repair customers’ devices, and provide other customer care and support services, including to help us provide, improve, and secure the quality of our products, services, and training, and to investigate security incidents. Call recording data may also be used to authenticate or identify you based on your voice to enable CodeData to provide support services and investigate security incidents.
  • Help secure and troubleshoot. We use data to help secure and troubleshoot our products. This includes using data to protect the security and safety of our products and customers, detecting malware and malicious activities, troubleshooting performance and compatibility issues to help customers get the most out of their experiences, and notifying customers of updates to our products. This may include using automated systems to detect security and safety issues.
  • Safety. We use data to protect the safety of our products and our customers. Our security features and products can disrupt the operation of malicious software and notify users if malicious software is found on their devices.
  • Updates. We use the data we collect to develop product updates and security patches. For example, we may use information about your device’s capabilities, such as available memory, to provide you a software update or security patch. Updates and patches are intended to maximize your experience with our products, help you protect the privacy and security of your data, provide new features, and evaluate whether your device is ready to process such updates.
  • Reporting and business operations. We use data to analyze our operations and perform business intelligence. This enables us to make informed decisions and report on the performance of our business.
  • Legal compliance. We process data to comply with law. For example, we use the age of our customers to assist us in meeting our obligations to protect children’s privacy. We also process contact information and credentials to help customers exercise their data protection rights.

How to access and control your personal data

You can also make choices about the collection and use of your data by CodeData. You can control your personal data that CodeData has obtained, and exercise your data protection rights, by contacting CodeData. In some cases, your ability to access or control your personal data will be limited, as required or permitted by applicable law. How you can access or control your personal data will also depend on which products you use.

If you want to access or control personal data processed by CodeData directly through the CodeData products you use, you can always contact CodeData at the address in the Contact us section.

If your organization, such as your employer, provides you with access to and is administering your use of our products, contact your organization to learn more about how to access and control your personal data.

 

Your communications preferences

 

Cookies and similar technologies

Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie. We use cookies and similar technologies for storing and honoring your preferences and settings, enabling you to sign in, providing interest-based advertising, combating fraud, analyzing how our products perform, and fulfilling other legitimate purposes.

We also use “web beacons” to help deliver cookies and gather usage and performance data. Our websites may include web beacons, cookies, or similar technologies from third-party service providers.

You have a variety of tools to control the data collected by cookies, web beacons, and similar technologies. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies.

Products provided by your organization—notice to end users

If you use a CodeData product with an account provided by an organization you are affiliated with, such as your work account, that organization can:

  • Control and administer your Makoro™ product and product account, including controlling privacy-related settings of the product or product account.
  • Access and process your data, including the interaction data, diagnostic data, and the contents of your communications and files associated with your CodeData product and product accounts.

If you lose access to your work account (in event of change of employment, for example), you may lose access to products and the content associated with those products, including those you acquired on your own behalf, if you used your work account to sign into such products.

Please see the Makoro products section of this privacy statement. If your organization provides you with access to CodeData products, your use of the CodeData products is subject to your organization’s policies, if any. You should direct your privacy inquiries, including any requests to exercise your data protection rights, to your organization’s administrator. When you use social features in CodeData products, other users in your network may see some of your activity. To learn more about the social features and other functionality, please review documentation or help content specific to the CodeData product. CodeData is not responsible for the privacy or security practices of our customers, which may differ from those set forth in this privacy statement.

When you use a CodeData product provided by your organization, CodeData’s processing of your personal data in connection with that product is governed by a contract between CodeData and your organization. CodeData processes your personal data to provide the product to your organization and you, and in some cases for CodeData’s business operations related to providing the product as described in the Makoro products section. As mentioned above, if you have questions about CodeData’s processing of your personal data in connection with providing products to your organization, please contact your organization. If you have questions about CodeData’s business operations in connection with providing products to your organization as provided in the Product Terms, please contact CodeData as described in the Contact us section. For more information on our business operations, please see the Makoro products section.

  

Makoro account

When you or your organization (such as an employer) create your Makoro account tied to your email address provided by that organization, we refer to that account as a business account.

With a business account, you can sign in to Makoro products, as well as those of select CodeData partners. Personal data associated with your Makoro account includes credentials, name and contact data, payment data, device and usage data, your contacts, information about your activities, and your interests and favorites.

Signing into your business account enables personalization and consistent experiences across products and devices, allows you to make payments using payment instruments stored in your Makoro account, and enables other features.

 

Security of personal data

CodeData is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. When we transmit highly confidential data (such as a credit card number or password) over the internet, we protect it through the use of encryption. CodeData complies with applicable data protection laws, including applicable security breach notification laws.

 

Where we store and process personal data

 

Our retention of personal data

 

California Consumer Privacy Act

If you are a California resident, we process your personal data in accordance with the California Consumer Privacy Act (CCPA). This CCPA section of our Privacy Statement contains information required by the CCPA and supplements our Privacy Statement.

Sale. We do not sell your personal data. So, we do not offer an opt-out to the sale of personal data.

Rights. You have the right to request that we (i) disclose what personal data we collect, use, disclose, and sell and (ii) delete your personal data. You may make these requests yourself or through an authorized agent.

You have a right not to receive discriminatory treatment if you exercise your CCPA rights. We will not discriminate against you if you exercise your CCPA rights.

Personal Information Processing. In the bulleted list below, we outline the categories of personal data we collect, the sources of the personal data, our purposes of processing, and the categories of third-party recipients with whom we share the personal data.

Categories of Personal Data

  • Name and contact data
    • Sources of personal data: Interactions with users and partners with whom we offer co-branded services
    • Purposes of Processing (Collection and Sharing with Third Parties): Provide our products; respond to customer questions; help, secure, and troubleshoot; and marketing
    • Recipients: Service providers and user-directed entities
  • Credentials
    • Sources of personal data: Interactions with users and organizations that represent users
    • Purposes of Processing (Collection and Sharing with Third Parties): Provide our products; authentication and account access; and help, secure and troubleshoot
    • Recipients: Service providers and user-directed entities
  • Demographic data
    • Sources of personal data: Interactions with users and purchases from data brokers
    • Purposes of Processing (Collection and Sharing with Third Parties): Provide and personalize our products; product development; help, secure, and troubleshoot; and marketing
    • Recipients: Service providers and user-directed entities
  • Payment data
    • Sources of personal data: Interactions with users and financial institutions
    • Purposes of Processing (Collection and Sharing with Third Parties): Transact commerce; process transactions; fulfill orders; help, secure, and troubleshoot; and detect and prevent fraud
    • Recipients: Service providers and user-directed entities
  • Subscription and licensing data
    • Sources of personal data: Interactions with users and organizations that represent users
    • Purposes of Processing (Collection and Sharing with Third Parties): Provide, personalize, and activate our products; customer support; help, secure, and troubleshoot; and marketing
    • Recipients: Service providers and user-directed entities

Preview or free-of-charge releases

CodeData offers preview, insider, beta or other free-of-charge products and features (“previews”) to enable you to evaluate them while providing CodeData with data about your use of the product, including feedback and device and usage data. As a result, previews can automatically collect additional data, provide fewer controls, and otherwise employ different privacy and security measures than those typically present in our products. If you participate in previews, we may contact you about your feedback or your interest in continuing to use the product after general release.

 

Changes to this privacy statement

We update this privacy statement when necessary to provide greater transparency or in response to:

  • Feedback from customer, regulators, industry, or other stakeholders.
  • Changes in our products.
  • Changes in our data processing activities or policies.

 

 

How to contact us

If you have a privacy concern, complaint, or question, please contact us through our website. We will respond to questions or concerns as required by law and within a period no longer than 30 days. You can also raise a concern or lodge a complaint with a data protection authority or other official with jurisdiction. 

 

Makoro products

Makoro™ Products are CodeData’s products and related software offered to and designed primarily for use by organizations. They include:

  • The platform products, such as Makoro Mind.
  • Applications, such as Makoro
  • Professional services referred to in the Product Terms that are available with Makoro, such as onboarding services, data migration services, data science services, or services to supplement existing features in Makoro.

In the event of a conflict between this CodeData privacy statement and the terms of any agreement(s) between a customer and CodeData, the terms of those agreement(s) will control.

If any of the terms below are not defined in this Privacy Statement, they have the definitions below.

General. When a customer tries, purchases, uses, or subscribes to Makoro Products, or obtains support for or professional services with such products, CodeData receives data from you and collects and generates data to provide the service (including improving, securing, and updating the service), conduct our business operations, and communicate with the customer. For example:

  • When a customer engages with a CodeData sales representative, we collect the customer’s name and contact data, along with information about the customer’s organization, to support that engagement.
  • When a customer interacts with a CodeData support professional, we collect device and usage data or error reports to diagnose and resolve problems.
  • When a customer pays for products, we collect contact and payment data to process the payment.
  • When CodeData sends communications to a customer, we use data to personalize the content of the communication.
  • When a customer engages with CodeData for professional services, we collect the name and contact data of the customer’s primary contact and use information provided by the customer to perform the services that the customer has requested.

Makoro Products enable you to purchase, subscribe to, or use other products and online services from CodeData or with different privacy practices, and those other products and online services are governed by their respective privacy statements and policies.

CodeData sites use cookies, small text files placed on your device which web servers utilize in the domain that placed the cookie can retrieve later. We use cookies to store your preferences and settings, help with sign-in, and analyze site operations.