Codem Inc. — UK Privacy Notice Supplement
This UK Privacy Notice Supplement ("UK Supplement") applies if you are located in the United Kingdom and supplements the general Codem Privacy Policy, which continues to apply to you. Where this UK Supplement and the general Policy conflict, this UK Supplement controls for UK visitors.
1. Data Controller
For the purposes of the UK GDPR and the Data Protection Act 2018 (as amended by the Data (Use and Access) Act 2025), the data controller is:
- Codem Inc., 347 Green Street #6, San Francisco, CA 94133, USA
Codem does not currently maintain an establishment in the UK. Where required under Article 27 UK GDPR, Codem will appoint a UK representative and publish their contact details here; until then, UK data subjects may direct requests to contact us
2. Legal Bases for Processing
We rely on the following legal bases under Article 6 UK 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 UK, we rely on the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another lawful transfer mechanism recognized under UK data protection law, and we take supplementary measures as needed to ensure your information receives an appropriate level of protection.
4. Your Rights Under UK Data Protection Law
Subject to the conditions and exceptions in UK data protection law, 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 the UK Information Commissioner's Office (ICO)
To exercise these rights, contact us. We may need to verify your identity before fulfilling a request, and we will respond within the timeframe required by UK law.
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 Information Commissioner's Office (ICO). The ICO can be contacted at ico.org.uk, or by phone at 0303 123 1113, or by post at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom.
7. Contact
For any question about this UK Supplement or to exercise your rights, contact us
