Privacy Policy
Last Update: April 2023
At Code Inc., we respect your privacy and are committed to protecting it through our compliance with this policy. We have prepared this privacy policy to explain the manner in which we collect, use and disclose personal information through the Code Wallet (the “App”) and in our other interactions with you.
The Code App is a non-custodial wallet that allows users to access their Kin currency, and send and receive Kin. Users cannot purchase Kin within Code.
Table of Contents
Collection and Use of Information
How we collect and use personal information through the App and in our other interactions with you
We may collect personal information when you:
Create an account and use the App
Participate in our surveys
Sign up for marketing emails
Contact us with a comment, question or complaint
Creating an Account and Using the App: You will be asked to create an account before you can use the App. We collect and verify your phone number, and request access to your contacts. Code is presently invitation only and you must be invited by a current User to join. We use this information to authenticate your request for an account, and to create and administer your account. We will never ask you for your password or other credentials in any unsolicited communication (such as letters, phone calls or email messages). If you become aware of any unauthorized access to or use of your account, you are required to notify us immediately.
With your invitation, we collect the following information, some of which is Personal Information: Who invited you to join Code, your mobile phone number and your contact phone numbers. We do not collect or store contact names, images or metadata for you or your contacts. We use this information for account verification and enabling users to invite others, as well as internal business analysis and other internal business purposes.
Once your account is activated, we may collect certain limited information to create your profile, and information about your device’s registered locale and language preferences. We use information regarding your location to provide an up-to-date value of your Kin in relation to your local currency.
Finally, we collect and use certain information when you use the App, such as information about your Kin transactions (e.g. deposits and withdrawals, and records of Kin sent to or received from other Code users). We use this information to keep records of your transactions, and to update your Code Wallet.
Surveys: From time to time, we may offer you the opportunity to participate in one of our surveys. The information obtained through our surveys is used in an aggregated, de-identified form. We use this information to help us understand our users and to enhance our Website.
Contact Us: When you contact us with a comment, question or complaint through privacy@getcode.com, you may be asked for information that identifies you, such as your name and telephone number, along with additional information such as email address we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service and service offerings.
Sharing of Personal Information
We do not sell or disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law.
Service Providers: Your personal information will be transferred (or otherwise made available) to certain third parties that provide services on our behalf. We use service providers to provide services such as hosting the App, providing user authentication and verification services and offering opportunities to buy Kin. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers may be located in the U.S., Canada or other foreign jurisdictions.
Legal and Compliance: We and our Canadian, US and other foreign service providers may provide your personal information in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Code Inc. or as part of a corporate reorganization or other change in corporate control.
Information About Our App
In addition, when you install or use our App, we may collect and use the following additional information.
Usage Data: When you access and use the App, we may automatically collect certain details of your access to and use of the App, including information about the type of device hardware and operating system, unique device identifier, IP address, and language settings of your device. We also collect information about the date and time the App accesses our servers. We use this information to help us understand the activity on our App, to monitor and improve our App, and to tailor your in-App experience. In addition, we may use third party service providers to collect analytical information about your use of the App, such as the App features used and time spent on the App, to help us tailor your in-app experience, improve our products and the quality of our App, and to manage and analyze data in order to better understand our users.
Information about your Device: As with many applications, certain limited data is required for the App to function on your device. This data includes the type of device hardware and operating system, unique device identifier, IP address, language settings, and the date and time the App accesses our servers. We use this information to help us understand the activity on our App, to monitor and improve our App, and to tailor your in-App experience. In addition, we may use third party service providers to collect analytical information about your use of the App, such as the App features used and time spent on the App, to help us tailor your in-app experience, improve our products and the quality of our App, and to manage and analyze data in order to better understand our users.
Third Party Links: Our App may contain links to other websites that Code Inc. does not own or operate. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.
Safeguards And Retention
We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements. We have record retention processes designed to retain personal information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business requirements.
Access to Information
If we receive a request from an individual to access or update personal information we maintain on behalf of a customer, we will direct that individual to the relevant customer. We will assist our customers wherever possible in responding to individual access requests. Subject to applicable law, you have the right to access, update and correct inaccuracies in your personal information in our custody or control. You may request access, updating and corrections of inaccuracies in your personal information in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.
Updates to the Privacy Policy
We may update this privacy policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this privacy policy when it was most recently updated.
Contact Us
If you have any questions or comments about this privacy policy or the manner in which we or our service providers (including our service providers outside Canada) treat your personal information, or to request access to our collection of your personal information, please contact us at: