Codabrasoft LLC

Privacy Policy

We are committed to respecting your data privacy and providing transparency about our data practices. This Privacy Policy (this "Privacy Policy") explains how Codabrasoft LLC ("Company," "we," or "us") collects, stores, uses, transfers, and discloses Personal Data from our users ("you") in connection with the Company’s mobile application and related services (collectively, the "App"). We reserve the right to modify this Privacy Policy at any time. If we make any material changes, we will notify you via email (sent to the address you provided when registering), through the App, or by presenting you with a new version of this Privacy Policy for your acceptance, especially if we introduce new processing activities or collect additional Personal Data from you. Your continued use of the App after the effective date of an updated Privacy Policy indicates your acceptance of the changes. In some cases, you may be required to explicitly accept changes to the Privacy Policy in order to continue using the App. We encourage you to periodically review our website for the latest information on our data privacy practices. If you do not agree to the terms of the Privacy Policy, please discontinue using the App, exit immediately, and delete it.

1. Personal Data and Information We Collect About You

We collect the following Personal Data and information from you:

Contact Information: Name, email address, mailing address, phone number.
Preferences Information: Product or content interests, communication or marketing preferences.
Usage Activity: Information about how you interact with us, such as purchase history, content viewed, and areas of our site visited.
Fitness, Health, or Medical Information: Prescription information, weight, height, symptoms, nutrition, water consumption.
Device and Usage Information: Information specific to your mobile device (e.g., make, model, operating system, advertising identifier, etc.); details about your use of features, functions, or notifications; and signal strength related to WiFi or Bluetooth functionality, temperature, battery level, and similar technical data.
Location Information: Information that allows us to periodically determine your location, including relative location to third-party merchant locations.
Demographic Information: Age, gender.
Mobile Device Information: Mobile device ID (similar to a website IP address), device type, mobile service carrier.

We may collect this Personal Data and information even if you are not logged into the application. For iOS users: You can adjust your iOS mobile device settings to prevent our collection of Location Information by disabling the location services feature. For Android users: You can adjust your Android mobile device settings to prevent our collection of Location Information by disabling Bluetooth and Location services.

You also have the option to permit us to import data from third-party services such as Apple HealthKit and Google Fit into the App. This imported data may include sports activities, weight, calories burned, heart rate, number of steps, distance traveled, and other health-related information. Granting us access to third-party information can enhance your experience with the App, and we will handle any third-party data in full accordance with this Privacy Policy.

If the information in this section is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose. However, if this information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection laws, it will be referred to as "Personal Data" in this Privacy Policy. We use pseudonymization for certain types of Personal Data. Please note that the provisions of Section 3 do not apply to pseudonymized Personal Data.

By installing the App and creating a profile (or by explicitly accepting this Privacy Policy and consenting to the processing of your Personal Data), you explicitly consent to the following:

We may store and process the Personal Data you provide through the use of the App and during the account creation process solely to provide services to you, improve our service features, and fulfill other purposes outlined in Section 2 of this Privacy Policy. These services may include sending you information and reminders through the App or to the email address you provided.
The Personal Data you provide to us through the account creation process or use of the App includes data such as your account details (e.g., name and email address) and health data (e.g., body measurements, physical activity, etc.). Depending on the data you provide, it may also include information about your general health (e.g., weight, body temperature, etc.).
We will not transmit any of your Personal Data to third parties, except when necessary to provide the service to you (e.g., technical service providers) or when we have obtained your explicit consent.

2. How We Use Your Personal Data and Information

We may use your information, including your Personal Data, and by accepting this Privacy Policy, you provide us with your explicit consent for the following purposes:

To analyze, operate, maintain, and improve the App and marketing activities, and to add new features and services to the App.
To assess your needs and determine suitable products or services.
To send product updates or warranty information.
To respond to your comments, questions, and requests, and to provide customer service.
To send you push notifications, both internal and external. If you do not wish to receive these notifications, you can manage your preferences either through your device or the App settings, depending on your device type. You can also contact us at [email protected].
To send you marketing communications.
To improve our App and marketing efforts, conduct research and analysis, including for scientific and academic research purposes.
For any other purposes disclosed to you at the time we collect Personal Data or any other purposes indicated in this Privacy Policy.

Choice/Opt-Out: You may opt out of receiving our newsletter or marketing emails by following the unsubscribe instructions included in each newsletter or marketing email, or you can contact us at [email protected].

Social Networks: We enable you to create a profile and share information such as messages, photos, and videos with others within your network. We cannot control the actions of others with whom you may choose to share your pages and information. Additionally, we cannot guarantee that the content you post on our App will not be viewed by others outside your network.

Any information (including Personal Data) you share in any online community area or online discussion is by design open to the public and is not private unless provided otherwise in the App settings. You should think carefully before posting any Personal Data in any public forum. What you post can be seen, disclosed to, or collected by third parties and may be used by others in ways we cannot control or predict, including contacting you for unauthorized purposes. As with any public forum on any site, the information you post may also show up in third-party search engines.

If you mistakenly post Personal Data in our community areas and would like it removed, you can send us an email to request that we remove it. In some cases, we may not be able to remove your Personal Data, e.g., for technical reasons.

Information Obtained from Third Parties: Unless prohibited under applicable law in certain jurisdictions, we purchase marketing data about our customers from third parties and combine it with Personal Data we already have about you to create more tailored advertising and products. Such data never includes any of your personal data considered &qout;sensitive&qout; or falling under the category of &qout;special categories of personal data&qout; under applicable law. We will only use that information for the specific reason for which it was provided to us. By accepting this Privacy Policy, you provide your consent for such processing activities.

3. Your Rights

You can modify, correct, erase, and update your Personal Data in the App account settings or, if that is not possible, by writing to us at [email protected]. You have the right to access your Personal Data entered into the App and inquire about the type of Personal Data we have about you. You can do this through the app settings or by writing to [email protected].

Individuals residing in European Union countries have statutory rights concerning their personal data under the General Data Protection Regulation (GDPR). Subject to legal exemptions, you may request access to your Personal Data (including in a structured and portable form) and seek to update, delete, or correct it.

Rectification of Personal Data and Restriction of Processing: You are responsible for ensuring the accuracy of the Personal Data you submit to the App. Inaccurate information may affect your experience when using the App, websites, tools, and our ability to contact you as described in this Privacy Policy. If you believe your Personal Data is inaccurate, you have the right to contact us to correct it by emailing [email protected]. You also have the right to request a restriction of processing your Personal Data if you contest its accuracy and require time for verification.
Access to Your Personal Data and Data Portability: The App allows you to access and update your Personal Data through its settings. You also have the right to request details of whether we hold your Personal Data, access it (including in a structured and portable form), and request updates via your app settings or by emailing [email protected].
Erasure of Your Personal Data: If you believe your Personal Data is no longer necessary for the purposes for which it was collected, if you have withdrawn your consent, objected to its processing, or if the processing otherwise does not comply with GDPR, you have the right to request its erasure. To do so, contact us at [email protected]. Please note that deleting some Personal Data may impact your ability to use the App and its features. The erasure process may require some time due to technical reasons.
Right to Object to Processing: You can object to the processing of your Personal Data and request that we stop processing it by contacting us at [email protected]. Please note that removing certain Personal Data may affect your ability to use the App and its features.
Notification Requirements: We commit to notifying you within a reasonable timeframe and, where required, notifying your data protection authority within 72 hours of any personal data breaches related to the App.
Data Protection Authorities: Under GDPR, you have the right to:
- Restrict our use of your Personal Data.
- Lodge a complaint with your local data protection authority regarding any activities you believe do not comply with GDPR.

Additional Information
If your request for access, erasure, objection, or any other rights is unclear, we may engage you in a dialogue to better understand your request and locate the necessary information. If clarification is not possible, we reserve the right to refuse your request.

Following GDPR provisions, we may require proof of identity (e.g., ID or other documentation) to verify your rights, particularly for special categories of Personal Data, such as health data. This ensures the rights of third parties are not violated and that the request is made by the actual Personal Data subject or their authorized representative.

4. Sharing Your Personal Data and Information

We will share your Personal Data and information with third parties only in the ways that are described in this Privacy Policy.

We may disclose your Personal Data:

as required by law, such as to comply with a subpoena or similar legal process.
when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
if we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
to any other third party with your prior explicit consent to do so.

We share the information we collect with third-party business partners who commit to comply with applicable laws concerning their usage of your Personal Data (for example, GDPR for EU residents). Our third-party business partners may share your Personal Data with their own third-party business partners, granted they have appropriate data protection safeguards in place, and use the information either for themselves or on behalf of their own business partners to:

Operate and improve their services.
Provide you with advertisements and information for products and services in this app or on other apps or websites based on variables such as your location, and assess your level of engagement with them.
Carry out other purposes that are disclosed to you and to which you consent.

Depending on the service you use, we may share some of your Personal Data and information with third-party business partners who perform analytical and other tasks for us (in some jurisdictions such parties may qualify as a ‘processor’ under applicable laws). These are the third-party services with whom, among others, we may share some of your Personal Data and information:

Appsflyer
Appsflyer is a mobile marketing platform. We may share certain non-identifiable information about you and some Personal Data (but never any data related to health) in order to carry out marketing activities and provide you with better and more targeted services. Learn more about Appsflyer: https://www.appsflyer.com.
MoPub
MoPub is a subsidiary of Twitter, Inc. and a monetization platform. We may share non-identifiable information about you and some Personal Data (but never any data related to health) in order to carry out marketing and ad activities. Learn more about MoPub: https://www.mopub.com.
Facebook
We use Facebook as our advertising partner to display advertising in our App or to manage our advertising on other sites. Normally, Facebook collects only non-personally identifiable information about your activities on this App and other apps to provide you with targeted advertising based upon your interests. Learn more about Facebook advertising policy: https://m.facebook.com/ads/ad_choices.
Fabric
We use Fabric, an analytics company and a Google subsidiary, to better understand your use of the App. For example, Fabric may use device identifiers that are stored on your mobile device and allow us to analyze your use of the App in order to improve our App features. Read more about Fabric here: https://get.fabric.io.
Crashlytics
Crashlytics, a Google business division, provides us with a crash reporting solution that we use to track when the App crashes or works improperly on your device. Crashlytics may collect certain device identifiers to understand on which devices and under what circumstances the App does not work or crashes. See more about Crashlytics here: https://try.crashlytics.com/reports/.
Appsee
Appsee is a mobile app analytics platform that provides us with tools to track and optimize the UX in the App through the use of some device identifiers. See more here: https://www.appsee.com.
Flurry
Flurry is a Yahoo! subsidiary and analytical platform that we use to analyze different use trends in our App. We may share certain non-identifiable information about you and some Personal Data (but never any data related to health) with Flurry. See more: https://developer.yahoo.com/flurry/legal-privacy/tos.html.
Zendesk
We use Zendesk as an intermediary for user support services. Zendesk may collect some of your Personal Data (like contact information) to connect us with you.
Twitter
We use Twitter as our advertising partner to display advertising on Twitter. Normally, Twitter collects only non-personally identifiable information about your activities on this App and other apps to provide you with targeted advertising based upon your interests.
Firebase
Firebase is an analytics product from Google, Inc. that allows us to track crashes of the App, monitor events in the App, and provide us with stats regarding the use of the App. Firebase may collect certain device identifiers to understand on which devices and under what circumstances particular incidents and events happen. See more on Firebase: https://firebase.google.com.

Our third-party partners are either EU-based or certified under the EU-US Privacy Shield Framework, ensuring that European data protection requirements are met. The privacy policies of these services can be found on their respective websites. Be informed that some third-party service providers may have their servers located in the United States.

BY USING THE APP, YOU CONSENT THAT WE MAY USE COOKIES AND THIRD-PARTY SERVICES AND COLLECT YOUR USAGE (INCLUDING FOR PROCESSING BY THIRD-PARTY SERVICE PROVIDERS) AND SOME PERSONAL DATA UNDER A UNIQUE IDENTIFIER, FOR THE PURPOSES OF TRACKING, ANALYSIS, AND IMPROVEMENT OF THE APP. BY USING OUR SERVICE, YOU EXPLICITLY CONSENT TO THE USE AND PROCESSING OF YOUR DATA COLLECTED AS DESCRIBED ABOVE.

Aggregated Information: We may also share aggregated, anonymized, or de-identified information, which cannot reasonably be used to identify you. For example, we may share general age demographic information and aggregate statistics about certain activities or symptoms from data collected to help identify patterns across users. This information may be included in articles, blog posts, and scientific publications.

5.Data Security

The security of your Personal Data is a top priority for us. When you provide sensitive Personal Data or data categorized as &qout;special&qout; under applicable laws, we encrypt its transmission using Secure Socket Layer (SSL) technology. We adhere to generally accepted industry standards to protect the Personal Data you submit, both during transmission and after it is received.

To safeguard your Personal Data, we implement the following security measures:

Pseudonymization and tokenization of certain categories of your Personal Data.
Data integrity protection to ensure accuracy and reliability.
Encryption of your Personal Data, both in transit and at rest.
Systematic vulnerability scanning and penetration testing to identify and address potential risks.
Organizational and legal measures:
Employees have varying levels of access to your Personal Data, with only those responsible for data management granted access.
Access is restricted to purposes necessary for the App's operation.
Strict accountability is imposed on employees for any unauthorized disclosures, access, alterations, destruction, or misuse of your Personal Data.
Regular data protection impact assessments to ensure adherence to principles such as &qout;privacy by design&qout; and &qout;privacy by default,&qout; as well as other internationally recognized data protection standards.

We commit to conducting privacy audits in cases of mergers or takeovers of the Company.

Please note that while we strive to use the most robust security measures available, no method of transmission or electronic storage is entirely secure. Therefore, we cannot guarantee absolute security. If you have questions about security on our App, please contact us at [email protected].

6. Retention and Storage of Your Personal Data

We will retain your Personal Data for as long as the application remains installed on your mobile device or as necessary to provide you with our services. If you uninstall the application, we will delete your Personal Data, except for copies needed to comply with legal obligations, resolve disputes, or enforce our agreements.

If you wish to cancel your account or request that we stop using your information to provide services, please contact us at [email protected].

Your Personal Data is transferred, processed, and stored on servers located in the European Union (Germany).

7. Children's Privacy

We are committed to protecting the privacy of children. The App is not intended for use by children, and we do not knowingly collect Personal Data from individuals under the age of 16. If we become aware that someone under 16 is using the App, we will take the necessary steps to delete their information and/or account.

If you become aware of anyone under 16 using the App, please notify us at [email protected], and we will promptly address the issue.

8. Data Protection Officer

To contact our Data Protection Officer, please email [email protected].

9. Contacting Us

If you have any questions or concerns about your privacy, the provisions of this Privacy Policy, or your rights, you may contact us at:

Yury Zhalnerkevich
Codabrasoft LLC
68 Harrison Ave, Ste 601
Boston, MA 02111
Email: [email protected]
General inquiries: [email protected]