Privacy Policy

Last Updated: December 1, 2023

CodeComply.AI, Corp. (“we”, “us”, or “our”) respects the right to privacy of our users (“you”). This Privacy Policy describes our practices with respect to the collection, transfer, manipulation, disclosure and other uses of Your Information and certain other information collected by us through our Services. For purposes of this Privacy Policy: (a) “Your Information” means information about you which may be of a confidential nature and may include personally identifiable information, including your first and last name and email address; and (b) “Services” means, collectively: (i) our proprietary artificial intelligence platform known as “CodeComply” (the “Platform”); (ii) our website (https://www.codecomply.ai/) and its related domains; and (iii) any email notifications or other mediums, or portions of such mediums, through which you have accessed this Privacy Policy. This Privacy Policy applies to information collected by us through our Services, but does not apply to information collected by any person or entity other than us, even if related to our Services (such as by our third-party service providers)

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING OUR SERVICES. BY USING OUR SERVICES OR BY CLICKING TO ACCEPT OR AGREE TO OUR TERMS WHEN THIS OPTION IS MADE AVAILABLE TO YOU, YOU ACCEPT AND AGREE TO BE BOUND AND ABIDE BY OUR TERMS, INCLUDING THIS PRIVACY POLICY. IF YOU DO NOT WANT YOUR INFORMATION USED OR DISCLOSED IN THE MANNER DESCRIBED IN THIS PRIVACY POLICY, OR IF YOU DO NOT AGREE WITH ANY TERM OR CONDITION IN OUR TERMS, INCLUDING THIS PRIVACY POLICY, THEN YOU MUST NOT ACCESS OR USE OUR SERVICES (IN WHOLE OR IN PART) OR SUBMIT YOUR INFORMATION TO US.

This Privacy Policy may change from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Policy. Amendments will take effect immediately on our posting of the updated Privacy Policy. Your continued access or use of our Services after receiving the notice of changes means you accept the updated Privacy Policy, so please check this policy periodically for updates.

By using our Services, you expressly agree to our collection, storage, use, processing and disclosure of Your Information as described in this Privacy Policy.

E.U. General Data Protection Regulation

We have taken steps in an effort to comply with the EU GENERAL DATA PROTECTION REGULATION (“GDPR”) as set forth by the Council of the European Union and European Parliament, which became enforceable May 25, 2018, regarding the collection, use, transmission, processing, and retention of personal identifiable data of natural persons from European Union member countries. We are committed to protecting your data in a secure and transparent manner. We process, use, and exchange personal data for our legitimate business purposes only in the limited uses described herein.

Our Services may require personal information from our users, such as name and email address, to facilitate user management, usage monitoring and provide our Services. Such data is stored in our infrastructure as well as with external vendors to the extent necessary to provide our Services. We do not use personal information for any purpose outside of providing the Services as set forth in this Privacy Policy. To learn more about our obligations, and your rights under the GDPR, please visit https://eugdpr.org.

Information Collected From Our Services

We collect data to provide the Services you request, ease your navigation on our Services, communicate with you, and improve your experience using our Services. Some of this information is provided by you directly, such as when you create an account on our Services, request a trial and/ or purchase a Service. Some of the information is collected through your interactions with our Services. We collect such data using technologies like cookies and other tracking technologies, error reports, and usage data collected when you interact with Services.

The data we collect depends on the Services and features thereof that you use, and includes the following:

Name and contact data. We collect your first and last name, e-mail address, postal address, phone number, and other similar contact data.

Credentials. We process passwords and related security information used for authentication and account access, and information security purposes.

Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number).

Usage data. We collect personalized information about your use of our Services, to better understand uses thereof and identify potential improvements, including to teach and refine the machine learning and artificial intelligence techniques utilized by the Services.

Examples include:

• Information based on your use of our Services. This includes the types and frequency of features being used, the frequency and duration of your use, the size and nature of projects, and anonymized information regarding project data.
• Information on the web pages you visit on and off our Services.
• Information regarding the performance of our Services and any problems you may experience while using them. This information enables us to diagnose problems and offer support in resolution.
• Data about your device and the network you use to connect to our Services, including IP address, device identifiers, and regional and language settings.

Web requests. We collect information regarding every web request sent to the relevant servers. This information is used to provide support, as well as to assess usage and performance of our Services. The data collected for each request can include such things as timestamps, any exception messages, user agent, IP address, e-mail address, request time and duration, as well as file names.

Location data. We collect your IP address and infer location such as city or postcode therefrom, when necessary, in order to provide you with the Services or to send you promotional communications or for customer relationship management purposes.

Communications. We may collect the content of messages you send to us, such as feedback or questions you ask our technical support representatives, when necessary to provide you with the Services you use. When you contact us, phone conversations or chat sessions with our representatives may be monitored and recorded in order to improve our services, or facilitate the processing and resolution of your request or complaint.
If you post information on public areas of the Services (or elsewhere on the Internet) that information may be collected and used by anyone, including us.

Customer Content. Content, including construction data, uploaded to the Services, or results provided by the Services to you in connection with the Services.

Information from Other Sources. We may receive information about you from other sources, including through third party services and organizations to supplement information provided by you. This information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.

Third-Party Content, Features or Application Providers May Collect Information. Some content, features or applications on our Services may be served by third parties, including our third-party service providers, ad networks and servers, content providers and other application providers. These third parties may collect information about you when you use our Services using cookies alone or in conjunction with web beacons or other tracking technologies. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. Please note that the information collected by these third parties may be associated with Your Information and that these third parties may collect information, including Your Information, about your online activities over time and across different websites and other online services.

Cookies and Similar Technologies

We and third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. We use technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us to record certain pieces of information whenever you visit or interact with our Services, and to recognize you across devices. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly. We use third party analytics such as Google Analytics to gather and analyze aggregated anonymous user information. For more information about Google Analytics, please visitwww.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. We also use Facebook Messenger Chatbot for our Services. Please review Facebook’s Terms of Service, Cookie Policy and Data Policy before utilizing the Chatbot within our Services. These can be found at: https://www.facebook.com/terms/, https://www.facebook.com/policies/cookies/, https://www.facebook.com/privacy/explanation/.

How We Use Data

We use information that we collect from customers and visitors for the purposes of:

• Providing or improving our Services.
• Research and development of new products and services.
• Providing ongoing support.
• Customizing the content and advertising you see.
• Communicating with you, including promotional communications and customer relationship management (“CRM”).
• Providing information about other services.
• Helping us run our company, for example, to improve our Services or our security, train staff, or perform marketing activities, including CRM.
• Complying with our legal obligations and enforcing our legal rights, including the authorized use of our Services.
• Accounting and other administrative purposes.
• Teaching and refining the machine learning and artificial intelligence techniques utilized by the Services.
• Providing anonymous aggregate reporting.

We may use the information and data we collect (including Your Information) to analyze, improve, and manage our Services, products, service offerings, and operations. For example, we might obtain feedback regarding our Services, products, and service offerings, to:

• Understand and anticipate your needs and preferences.
• Better understand your use of our Services or products or service offerings.
• Customize and tailor website content and advertising.
• Improve our marketing and promotional efforts.
• Engage in statistical analysis.
• Provide feedback or information to our business partners, vendors, advertisers, and other third parties.

We may also use the information and data we collect (including Your Information) to improve and enhance the Services (including, without limitation, the Platform) (in whole or in part) and for other development, diagnostic, and corrective purposes in connection with the Services (including, without limitation, the Platform), our technology, and/or our other product or service offerings.

We may use the information we collect to fulfill any other purpose for which you provide it. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders.

We may also use Your Information in other ways. To the extent required by applicable law, we will provide notice at the time of collection and obtain your consent.

How We Share Or Disclose Your Information

We may disclose or share your personal information to:

• Any service providers who assist us in providing the Services (e.g., technical agents and payment processing vendors).
• Companies that help us market and advertise to you.
• Other subcontractors.
• Our affiliates, representatives, employees, agents, and consultants.

If you give us permission, we may share your personally identifiable information with third parties who may send you marketing and promotional information. In any transaction involving credit card information, your credit card company will be provided with relevant information about us, services purchased, cost, and other information necessary to process the transaction.

We may disclose your personal information if permitted or required by law, or where we reasonably believe such action is necessary to protect or defend our interests or the interests of our employees, users, or business partners. This includes protecting, establishing, or exercising our legal rights, defending against legal claims, or when we believe in good faith that such disclosure is necessary to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, threats to our property, suspected fraud, or violation of our terms and conditions.

We may disclose or share the information we collect, including Your Information, to fulfill the purpose for which you provide it.

The Services may track usage statistics collected through the Services, and we may internally analyze this data for trends and statistics. Such information will be maintained, used, and disclosed internally to us and our affiliates. We may freely share anonymous user information with others, such as clients, advertisers, sponsors, and business partners.

Please note that this section is not exhaustive and that we may, to the extent permitted by applicable law, disclose the information we collect to third parties at any time, for any lawful purpose, without notice or compensation to you.

When we disclose the information we collect to third parties, such information will become permanently subject to the information use and sharing practices of the third party, and the third party will not be restricted by this Privacy Policy with respect to its use and further sharing of such information. Furthermore, these third parties may further disclose, share and use this information. By submitting information (including Your Information) to us, you expressly consent to such disclosure and use of such information. If you do not want this information (including Your Information) shared as described above, then you should not provide us with such information.

Other Disclosures by Us:

Aggregation and De-Personalization. We may use and disclose any de-identified information for any lawful purpose, including for any commercial purpose. De-identified Information means information that does not identify you, including any identifiable information de-identified by either combining it with information about others, for example, by aggregating Your Information with information about other persons, or by removing characteristics, such as your name, that make the information personally identifiable to you.

Business Transfers. We may disclose, lease, sell, assign, or transfer the information we collect (including Your Information) to third parties in connection with a Business Transfer. A “Business Transfer” means a sale, acquisition, merger, consolidation, reorganization, change in control, bankruptcy, or other corporate change involving us, even if the Business Transfer is only being contemplated and regardless of whether the Business Transfer relates to a part of or our whole business. Nothing in this Privacy Policy is intended to interfere with our ability to transfer all or part of our business, equity, or assets (including our Services) to an affiliate or independent third party at any time, for any lawful purpose, without notice or compensation to you.

International Data Transfers

You agree that all personal information submitted to or collected via or by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your personal information may be accessible to law enforcement or other authorities pursuant to a lawful request.

Third Party Sites and Services

The Services may contain links to other websites and other websites may reference or link to our Services. These other domains and websites are not controlled by us, and we do not endorse or make any representations about third-party websites, services, or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

In addition, third parties may directly gather user information from users of our Services through automated means such as cookies. This Privacy Policy does not cover how third parties gather and use such data.

Choices About How We Use and Disclose Your Information

Email Offers: If we send you a marketing e-mail, it will include instructions on how to opt out of receiving these e-mails in the future. We will process your request within a reasonable time after receipt. Please note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding us, and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our terms and conditions or this Privacy Policy).

Accessing and Correcting Your Information: You can review and change your personal information by logging into the Services and visiting your account profile page or you may send us an email at legal@codecomply.ai to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Data Retention

We retain the personal information we collect as described in this privacy policy for as long as you use our services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, comply with applicable laws, and for our other business purposes.

Security

We use certain technical, administrative, and organizational security measures to keep Your Information safe. However, despite our efforts, please be aware that methods of transmission and electronic storage are not completely secure. We cannot guarantee the privacy or security of Your Information, as third parties may unlawfully intercept or access transmissions or electronic storage. Further, to the extent permitted by law, we are not responsible for circumvention of any privacy settings or security measures of our Services. Therefore, you use our Services at your own risk, you should not expect that Your Information will always remain private, and we do not guarantee the performance or adequacy of our security measures. In the event that an unauthorized third party compromises our security measures, to the extent permitted by law, we will not be responsible for any damages, directly or indirectly, caused by an unauthorized third party’s ability to view, use or disseminate Your Information.

Children’s Data

The Services are not directed to children under 18 years of age, and we do not knowingly collect personal information from children under 18 years of age. If you learn that your child has provided us with personal information without your consent, you may alert us at legal@codecomply.ai. If we learn that we have collected any personal information from children under 18 years of age, we will promptly take steps to delete such information.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. We will comply with all such laws that apply to us and with respect to our collection, use and/or disclosure of Your Information.

Contact Us

If you have any questions, suggestions or complaints regarding our use or disclosure of the information we collect from you or wish to contact us to make a request regarding such information (including Your Information), please contact us at legal@codecomply.ai.

Changes To This Privacy Policy

We may amend this Privacy Policy at any time and from time to time. Amendments will take effect immediately upon us posting the updated Privacy Policy on our Services. Accordingly, you are encouraged to revisit this Privacy Policy from time to time in order to review any changes that we have made. The date on which this Privacy Policy was last updated will be noted immediately above this Privacy Policy.