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POLICIES

Privacy Notice

1. Background

CodecaX Inc. and our affiliates (CodecaX or We), value your privacy. This Privacy Notice explains our privacy policy and the Personal Data we gather, use, disclose, and transfer. It also outlines the options you have and the rights you have in connection to your Personal Data.

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In this Privacy Notice, by Personal Data we mean any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

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Our privacy procedures outlined in this Privacy Notice are based on the OECD Guidelines on the Protection of Privacy and Transborder Flows, the EU General Data Protection Regulation 2016/679; the APEC Privacy Framework; and the APEC Cross Border Privacy Rules.

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2. Justification to process Personal Data

These are the legal grounds on which we process your Personal Data:

 

Legal obligations: We may use your Personal Data to comply with applicable laws and regulations, to establish or exercise our legal rights, or for other similar purposes, for instance, for the sake of legal claims, compliance or regulations.

 

Legitimate Interest: We may use your Personal Data as necessary to fulfill our legitimate business interests (provided this is not overridden by the legal rights of relevant individuals). Specifically, to manage, create, and enhance our products and services; to assist our customers and sales activities; to protect our workers and assets; to disseminate data that enhances our products and services; and to maintain compliance with applicable laws and regulations.

 

Compliance with agreements: We may use your Personal Data in order to enter into or comply with legal agreements with you or your organization, such as to provide and administer our products and services and to enable our customers to use our products, services, and supporting tools.

 

Consent: In some circumstances we may process your Personal Data with your consent. Specifically, in certain jurisdictions we may be required by law to obtain your consent for certain sales and marketing activities, online data collection tools, or surveys. In such case you may withdraw your consent at any time by modifying your communication preferences, unsubscribing from CodecaX communications, or contacting the CodecaX Privacy Unit.

 

3. Collection and use of Personal Data

We only collect Personal Data when there is a legal justification as described in paragraph 2. above. Your Personal Data is collected and handled depending on your relationship with CodecaX:

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Online data collection tools:  these are used to collect data about users' online activities to make our websites, mobile applications, products, and services easier to use; improving marketing and advertising campaigns; for gathering statistics to improve the functionality of our website, mobile applications, products, and services; and enhancing user experience and delivering content that is relevant to their interests.

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CodecaX's products and services: contact data, login data, and interactions with our digital assets and content are used for the following primary purposes: account creation and management, contract formation and performance with you or your organization, management and fulfillment of orders, deployment and delivery of products and services, tools to activate licenses, conducting quality checks, and provision of support.

 

CodecaX Business Purposes: sales and marketing campaigns; advertising; developing and delivering targeted ads and offers.

Partner and supplier programs: contact data to manage connections with partners and suppliers or engaging customers and offering products and services.

 

Clients, business partners, and suppliers: to provide and manage training and education programs.

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Security and authentication measures: contact and identification data for the purposes of protecting CodecaX's intellectual property, trade secrets, digital and data assets; and preventing unauthorized access to Personal Data.

 

Surveys: contact data, login credentials, comments, and feedback for the primary purposes of connecting with partners and suppliers and conducting customer engagement and satisfaction surveys.

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4. Disclosure of Personal Data

Except as otherwise specified in this Privacy Notice, CodecaX will not sell, rent, or lease Personal Data to third parties. Your Personal Data may be disclosed or shared in the following ways:

 

Sharing data with CodecaX affiliates: The headquarters of CodecaX is in the USA. In accordance with the manner in which we utilize your Personal Data, CodecaX may share your Personal Data as necessary throughout CodecaX affiliates.

 

Business partners: Personal Data may be shared with CodecaX's business partners in order to support the sale and distribution of CodecaX's products and services. Partners are contractually required to protect the confidentiality and security of Personal Data collected from CodecaX and to use it only for the aforementioned purposes, unless otherwise approved by you or by applicable laws and regulations.

 

Third parties: CodecaX employs suppliers and service providers to manage or support corporate operations, supply goods, services, and customer solutions, and assist with marketing and sales communication initiatives. For the purpose of assisting and facilitating our use of your Personal Data, such third parties may collect and process your Personal Data with the necessary authorization from CodecaX. According to the terms of their contracts, suppliers and service providers processing data on behalf of CodecaX must keep it confidential, secure, and use it exclusively to carry out the services they are providing to CodecaX.

 

Legal disclosure requirements: Disclosure of your Personal Data may be required in the following circumstances: (i) to respond to legally valid data requests from law enforcement or government agencies; (ii) comply with a court order, subpoena, or other legal process; or (iii) enforce or otherwise protect the rights and property of CodecaX or its affiliates.

 

5. International sharing of Personal Data

International Personal Data transfers: CodecaX may transfer your Personal Data to CodecaX affiliates. There is sometimes a possibility that the recipients are situated in countries that do not provide the same degree of data protection as your country. CodecaX shall ensure that any transferred Personal Data is sufficiently protected in accordance with applicable data protection legislation. Where required by local law, we will seek your permission before transferring your Personal Data.

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International Transfers of Personal Data to third parties: sometimes it is necessary for transfers of Personal Data to third parties located in countries that do not provide an adequate level of data protection. In such cases CodecaX will implement appropriate safeguards, such as using appropriate data protection contract clauses with the recipient. Please contact the CodecaX Privacy Unit if you would like further information regarding the applicable safeguards.

 

6. Automatic Data Collection Tools

CodecaX Automatic Data Collection Tools: The CodecaX web site and applications use cookies, web beacons, device identifiers, IP addresses, and other similar technologies (collectively, Automatic Data Collection Tools) to provide and secure the CodecaX web site and applications, remember log-in details, collect statistics to optimize functionality, track user preferences, collect data on user activity in response to email communications and related to white papers, documents, and other assets made available through our web site. Some of these Automatic Data Collection Tools are required for the provision of the CodecaX website and applications, while others are used to comprehend, customize, and enhance the CodecaX website and applications.

 

Third-Party Automatic Data Collection Tools: CodecaX also permits third-party advertising companies to use Automatic Data Collection Tools on our website and applications in order to comprehend how you interact with our website and applications, to optimize our advertisements and marketing, and to serve you with advertisements tailored to your interests on other websites or applications you may visit or use.

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When you fill out a web form on our website to subscribe to a service, receive a white paper, or seek data about CodecaX's goods and services, your contact data may be stored in a cookie on your device. This data is then accessed on subsequent visits to the CodecaX website allowing us to track and record the sites you have visited and the links you have clicked in order to improve the personalization of your online experience and future CodecaX communications.

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If you choose to receive marketing emails or newsletters from CodecaX, we may use web beacons and personalized URLs embedded within these communications to track whether you have opened these messages and clicked on any links contained within them. This enables CodecaX to better customize future communications and limit them to topics of interest.

 

7. Safeguarding your Personal Data

CodecaX employs reasonable and appropriate physical, technological, and administrative safeguards to secure the Personal Data we collect and handle against loss, misuse, unauthorized access, and disclosure, based on industry standards and best practices.

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When collecting or transferring Personal Data, we employ a number of additional security technologies and procedures to protect your Personal Data from unauthorized access, use, or disclosure. The Personal Data you supply is saved on computer systems secured in restricted-access facilities. Access to your Personal Data is restricted to CodecaX employees and approved third parties who need to know that Personal Data to process it on our behalf and are bound by stringent confidentiality obligations.

 

8. Your rights regarding your Personal Data

Depending on the data protection laws to which you are subject, you may be able to:

  • Request confirmation of the processing of your data, access or request copies of your Personal Data that CodecaX processes;

  • Learn about the entities with which CodecaX has shared your Personal Data;

  • Correct your Personal Data if it is inaccurate or incomplete;

  • Delete or anonymize your Personal Data, unless an exemption applies, for example, we may be required by law to retain your Personal Data;

  • Request restrictions on certain uses and disclosures of your sensitive Personal Data;

  • Restrict the processing of your Personal Data for example, if you contest the accuracy of your Personal Data, you may request that we restrict the processing of your Personal Data for the period of time necessary for us to verify the accuracy of your Personal Data; or

  • Object to the processing of your Personal Data. If you are in the EU, for example, you may object to direct marketing, including the profiling of your Personal Data for direct marketing, or to the processing of your Personal Data when we have a legitimate purpose in doing so.

 

These rights may be limited in certain circumstances, such as where CodecaX is required by law or has a legitimate interest in processing your Personal Data, or when CodecaX can lawfully apply an exemption to the exercise of a right.

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To see and modify the Personal Data you supplied directly to CodecaX please write to the CPU at the e-mail address listed below. If you believe that the processing of your Personal Data by CodecaX violates applicable data privacy laws, you may have the right to file a complaint in the country in which you reside, work, or believe a violation of data protection rules occurred.

 

9. Period of time we keep Personal Data

We keep Personal Data for the period of any contractual relationship and, to the extent permitted by applicable laws, for as long as is required to fulfill the purposes outlined in this Privacy Notice, to manage our business and to defend CodecaX against all legal claims. When we no longer require Personal Data, we will delete it from our systems or take steps to anonymize it, unless we are required to keep it for a longer period of time to comply with legal or regulatory requirements.

 

10. Communication and preference management

CodecaX may send you notifications regarding our new products and services, or information that complements our products and services. If you or your business have purchased our products or services, you may receive notifications, software updates, or responses to your support requests. If you elect to receive CodecaX messages, you may additionally opt to get particular newsletters and publications.

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You can modify your communication preferences by:

 

Online: Submitting your email address and specifying or modifying your preferences;

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Unsubscribe from correspondence: If you no longer wish to receive CodecaX communications, you can unsubscribe using the unsubscribe link in each email correspondence;

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Contacting the CPU: Send the CPU an e-mail with your name, contact information and a description of the CodecaX messages you no longer wish to receive.

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Please note that these options do not apply to messages on the administration of orders, contracts, support, product safety alerts, and other administrative and transactional notices whose primary aim is not promotional.

 

11. Communications over personal data issues

You can contact Mr. Sett Hlaing, the CodecaX General Counsel and Head of the CodecaX Privacy Unit (CPU), with any questions about our collection and use of Personal Data, or your communication preferences by writing to him at sett.hlaing@CodecaX.com

 

12. Non-CodecaX websites, platforms and networks

The CodecaX website or CodecaX services may include connections to third-party products, services, or websites for your convenience or information. In addition, we may provide social media features that enable you to interact with CodecaX and other users of CodecaX products and services on various social media platforms and networks. CodecaX has no control over third-party websites, platforms, or networks or their privacy policies, and we neither endorse nor make any representations regarding them. This Privacy Notice is not applicable to the Personal Data you choose to provide to, or that is collected or shared by, these third parties. Before allowing a website, platform, or network to collect and use your Personal Data, we strongly advise you to study their privacy policy.

 

13. Changes to this Privacy Notice

Any changes to this Privacy Notice will be published on the CodecaX website.

 

14. Effective Date

This Privacy Notice is effective as of January 1, 2023.

 

Copyright, CodecaX Inc © 2023. All rights reserved.

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