Codem Inc. — EU Privacy Notice Supplement
This EU Privacy Notice Supplement ("EU Supplement") applies if you are located in the European Economic Area ("EEA") and supplements the general Codem Privacy Policy, which continues to apply to you. Where this EU Supplement and the general Policy conflict, this EU Supplement controls for EEA visitors.
1. Data Controller
For the purposes of the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR"), the data controller is:
- Codem Inc., 347 Green Street #6, San Francisco, CA 94133, USA
Codem does not currently maintain an establishment in the EEA. Where required by Article 27 GDPR, Codem will appoint an EU representative and publish their contact details here; until then, EEA data subjects may direct requests to contact us
2. Legal Bases for Processing
We rely on the following legal bases under Article 6 GDPR:
- Consent — for optional cookies, analytics, and marketing communications you opt into
- Legitimate interests — to operate and secure the Site, respond to inquiries, and conduct basic analytics, balanced against your rights and interests
- Contract — to take steps at your request before entering into an agreement, or to perform a contract with you or your employer
- Legal obligation — where processing is required to comply with the law
You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
3. International Data Transfers
Codem operates from the United States, Singapore, and India. Where we transfer personal information out of the EEA, we rely on the European Commission's Standard Contractual Clauses ("SCCs") with our processors, or another lawful transfer mechanism recognized under Chapter V GDPR, and we take supplementary measures as needed to ensure your information receives an essentially equivalent level of protection.
4. Your Rights Under the GDPR
Subject to the conditions and exceptions in the GDPR, you have the right to:
- Access the personal information we hold about you
- Rectify inaccurate or incomplete information
- Erase your personal information ("right to be forgotten"), in certain circumstances
- Restrict our processing of your information
- Object to processing, including for direct marketing or based on legitimate interests
- Receive a copy of your information in a structured, commonly used, machine-readable format (data portability)
- Withdraw consent at any time, where processing is based on consent
- Lodge a complaint with your local data protection supervisory authority
To exercise these rights, contact us. We may need to verify your identity before fulfilling a request, and we will respond within one month as required by Article 12 GDPR (extendable by two further months for complex requests).
5. Automated Decision-Making
Codem does not use your personal information to make decisions about you based solely on automated processing, including profiling, that produce legal or similarly significant effects.
6. Complaints
You have the right to lodge a complaint with the supervisory authority in your EU member state of residence, place of work, or the place of the alleged infringement. A list of EU supervisory authorities is available from the European Data Protection Board at edpb.europa.eu.
7. Contact
For any question about this EU Supplement or to exercise your rights, contact us
