PRIVACY POLICY
At Coders Master, we understand that your privacy is important to you and that you care about how your personal data is used. We will only collect and use personal data in ways described here and in a way that is consistent with our obligations and your rights under applicable local law. This Privacy Policy sets out the basis on which we may collect, use or otherwise process personal data through our website https://codersmaster.com/(Site), downloadable software, mobile applications, desktop applications, content, features, functions and/or through any other services provided by us and on which a link to this Privacy Policy is displayed, and/or all other communications with you by written or oral means such as email, chat or phone (collectively the “ Services ”) when you use our Services and the options you have associated with that personal data.
Please note that this Privacy Policy is directed to our potential, current and former customers. If you are, were or may be a potential employee of Codersmaster, your personal information will be used in connection with your employment in accordance with our separate policy, which is available at security@codersmaster.com.
We use your personal data to provide and improve our Services. Your acceptance of this Privacy Policy is deemed to occur upon your first use of our website and any Service.
Who we are
CODERS MASTER LLC, a corporation registered in St. Vincent & Grenadines under registration number 3742 LLC and has our registered office at Suite 305, Griffith Corporate Centre, Beachmont, Kingstown, SVG (hereinafter “ Codersmaster ” or “ Company ”). Codersmaster is the controller and responsible for the personal information you disclose to us to make use of our Services.
Codersmaster has partners and affiliated entities around the world, so when we mention “Codersmaster”, “Codersmaster Affiliates”, “Company”, “we” or “us” in this Privacy Policy, we are referring to the relevant partner or affiliated company responsible for collecting and/or processing your personal data when you use the Services. Codersmaster respects your privacy and therefore all companies within Codersmaster Affiliates are committed to protecting your data, which it collects and/or has access to.
DATA COLLECTION AND PROCESSING
We collect, process, store and transfer different types of personal data about you for various purposes in order to be able to provide and improve our Service to you. Depending on your use of the Service, we may collect some or all of the personal data set out below, as follows. Please also see the Cookies Section for more information about our use of Cookies and similar Technologies.
Identity data include name, surname and patronymic (if available), date of birth, gender, passport, identity document, driver number and copy of photo.
Contact details include billing address, email address and phone numbers.
Technical Data include internet protocol (IP) address, your login data, browser type and version, time zone and location setting, browser plug-in type and versions, operating system and platform, and other technology on the devices you use. uses to access the Site and use of cookies stored on your device.
Usage Data includes information about how you use the Site, products and Services, and IP history.Os dados no KYC (Conheça seu cliente) incluem informações de documentos de identidade, incluindo cópias de contas de serviços públicos com data recente, carteira de identidade, passaporte e/ou carteira de motorista, números de identificação fiscal (TIN).
Location Data include details about your actual location when interacting with our Site (for example, a set of parameters that determine the regional settings of your interface, i.e. country of residence, time zone and interface language)
Audio data include full voice recordings of calls you receive from or make to us.
Aggregated Data include statistical or demographic data for any purpose. Such data may be derived from your data, but may not be considered personal data by law as it will not directly or indirectly reveal your identity. An example of such Aggregated Data may be that we aggregate your Usage Data to calculate the percentage of users accessing a specific website feature and/or service/product preference. Notwithstanding the foregoing, if Codersmaster combines Aggregated Data with data in a way that the final result can in any way identify the data subject, Codersmaster will treat such combined data as data that will be processed in accordance with the provisions contained herein. (the above collectively referred to as “ personal data ”).
We may obtain information about you during direct interactions with us. You may provide us with your personal information (including personal identifiers, financial information, government identifiers, and professional or employment data) by filling out forms such as our account application, contacting us about our Services, or responding to our marketing activities. We may also obtain information about you from our affiliates, suppliers and other third parties.
We may also obtain personal information about you from publicly available sources and from companies we do business with, such as investigative and consumer reporting agencies that we use to conduct background checks, verify your identity, creditworthiness, and Know Your Customer requirements ( “KYC”). Additionally, your interactions with third parties linked to our Services, your interactions with our social media sites, advertising campaigns, and other information from publicly available sources such as public websites may also provide us with personal information. Please be aware that third-party websites and social media sites are governed by their own privacy policies, separate from ours.
CHILDREN
Our Website is not intended for children and we do not knowingly collect data relating to children. As we do not allow users under the age of 18 to use our services, we need to obtain your date of birth to confirm Customers' age verifications.
PROCESSING OF YOUR DATA
Codersmaster may process your personal data for any of the following reasons:
• To perform the contract with you,
• To comply with its legal and regulatory obligations, including, without limitation,
• To carry out compliance checks, such as verifying your identity and helping detect fraudulent or malicious activity on our website or services,
• To maintain our accounts and records,
• To manage our business needs, such as monitoring, analyzing and improving the Services and the performance and functionality of the Site,
• Comply with all applicable laws and regulations;
• For the purposes of safeguarding our legitimate interests and your interests and fundamental rights do not override those interests; and/or
• Other reasons.
DATA RETENTION
We will not keep your personal data for longer than necessary, considering the reason(s) for which it was first collected in accordance with this Privacy Policy.
To comply with applicable legal, regulatory, tax and accounting requirements, we keep your personal data for a minimum period of 5 years from the date on which our business relationship ends. We may retain your information for a longer period when we deem it appropriate for any reason and/or when we need the information to comply with regulatory or legal requirements or when we need it for our legitimate business purposes, such as responding to inquiries or complaints, combating fraud and financial crime and respond to requests from regulators.
At the end of the personal data retention period, the personal data will be erased by irreversible destruction and we will also inform all third parties to which the personal data have been transferred about such erasure and request them to implement similar actions.
DATA SECURITY
We protect your data by adhering to industry standard regulations on data protection, categorizing it into data types (e.g. technical data, personal data, cookie data, etc.) while applying relevant safeguards and due diligence procedures. Therefore, we apply appropriate technical and organizational controls to protect your data, including secure computer systems that adopt least privilege access to prevent unauthorized access, disclosure, modification or destruction of personal data. All printed documents are locked in a secure cabinet and destroyed when no longer required.
Encryption of your data in transit. Encryption provides a high level of security and privacy for your personal data. When personal data is provided when using our Services, we use strong encryption technologies (such as Transport Layer Security) to protect personal data during transmission from your devices to our servers.
To provide additional trust and security, we use digital EV (Extended Validation) Certificates issued by trusted Certificate Authorities. You can see the 'Green Bar' in supported browser versions, which confirms that all personal data transmitted is secure.
Protecting your personal data in our infrastructure. We prioritize developing Services that are secure by default. By default, our Services are designed with strict security requirements in mind before we even begin development. This is key to ensuring the protection and privacy of all personal data that our Services handle and store once the service or new feature is released.
To protect personal data, we use pseudonymization, which allows most of our Services to operate without using your real data. Instead, our Services use an untraceable system ID to identify you.
Codersmaster is always vigilant about the security of personal data stored in our infrastructure. That is why we locate all of our equipment used to process your personal data in secure, proprietary data centers. Network access to this equipment is isolated from the Internet. We use network segmentation to isolate Services that require different levels of security from each other. Furthermore, we restrict logical access to personal data to our employees on a “need to know” basis. Therefore, only those personnel who truly need access to personal data for the purpose of providing you with our best Service will have access to it.
Threat Protection. Codersmaster is highly informed about modern threats to personal data security and privacy, and we are well prepared to combat them. All events occurring in our infrastructure are continuously monitored, analyzed and responded to, which allows us to ensure adequate protection of your personal data, keeping it safe from threats, vulnerabilities and the effects of malware.
In the event of a failure that affects the accessibility of your personal data, we have personal data backup and recovery procedures in place that will help us restore your personal data in a short time. To further ensure fast recovery, we have high availability mode enabled for most of the critical databases, which allows us to minimize downtime
Employee awareness of data security . Our employees may handle your personal data in order to provide you with the first-class Service. To ensure the security and confidentiality of your personal data, we monitor all actions of employees with access to your personal data on our systems and grant access strictly on a “need to know” basis: only employees who need access will be granted it. We conduct regular training sessions to ensure that each employee understands the principles that Codersmaster follows to achieve robust data security and privacy.If you choose not to provide your personal information . In the context of our business relationship, we may need to collect data by law or under the terms of a contract we have with you. Without this data, we are not in a position in principle to enter into or perform a contract with you. If you choose not to provide us with this data, this may delay or prevent us from fulfilling our obligations. It may also mean that we are unable to perform the Services.To what extent we carry out automated decision-making and profiling . When establishing and performing a business relationship, we generally do not use automated decision-making. If we use this procedure in individual cases, we will inform you about this separately. In some cases, we may proceed with profiling to evaluate certain personal aspects. We will inform you accordingly if we carry out any profiling. In general, any data collection that is optional would be made clear at the point of collection.
DATA COLLECTION
We use different methods to collect data from and about you, including:
Direct Interactions. You will provide us with your Identity, Contact and Financial Data online through the Website and/or by completing and completing online forms and/or by corresponding with us by email or otherwise.
We need to collect the above data so that we can (i) provide our services efficiently, (ii) comply with our ongoing legal and regulatory obligations, including, among other things, (a) prevent fraud and money laundering and/or (b) conduct suitability assessment and property testing.
If you do not provide the data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Services). In this case, we may have to cancel a Service you have with us, but we will notify you if this is the case at the time.
It is important that the data we hold about you is accurate and current. Please keep us informed if your data changes during your relationship with us.
Automated Technologies or Interactions. When you use our Services, your device automatically transmits its technical characteristics to us. Locale (a set of parameters that determine the regional settings of your interface, namely country of residence, time zone and interface language) is used for the purpose of providing you with the best possible service within our platform.
The use of information about IP address, cookie files, information about browser and operating system used, date and time of access to the website and addresses of requested pages allows us to provide you with optimal operation in our web application, mobile and/or desktop versions of our application and monitor your behavior for the purpose of improving the efficiency and usability of our Services.
We use web analytics tools to monitor the performance of our website and the source of user marketing through cookies in order to optimize our marketing costs and provide users with a better experience.
You may at any time request that we refrain from such transmissions (to the extent this is possible and subject to any of our legal obligations) by sending your request to the DPO using our details in OUR CONTACT DETAILS below using the registered email address that you have disclosed and registered with us. We will comply with your request within 30 business days.
COOKIES
A cookie is a small amount of data, which often includes a unique identifier, that is sent to your computer or device’s browser from a website’s computer and is stored on your device’s hard drive to track your use of the website. A website can send its own cookie to your browser if your browser’s preferences allow it, but to protect your privacy, your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites. First-party cookies are those placed directly by us and are used only by us. We use cookies to facilitate and improve your experience on our website and to provide and improve our products and services. We have carefully chosen these cookies and take steps to ensure that your privacy and personal data are always protected and respected.
When using our Website, you may also receive certain third-party cookies on your computer or device. Third-party cookies are those placed by websites, services and/or parties other than us. For more details, please see the table below. All Cookies used by and on our Website are used in accordance with applicable legislation on the use of cookies
Our Website uses analytics services, which are a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how our Website is used. This in turn enables us to improve our Website and the Services offered through it. You do not have to allow us to use these Cookies, however, whilst our use of them does not pose any risk to your privacy or the safe use of our Website, it does enable us to continually improve our Website, making it a better and more useful experience for you.
You will be required to provide consent to Cookies by acknowledging the privacy and cookie policies during your account registration. By giving your consent to the placement of Cookies, you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placement of Cookies; however, certain features of our Website may not function fully or as intended.
You can choose to delete cookies from your computer or device at any time, however you may lose any information that enables you to access our Website more quickly and efficiently, including, but not limited to, login and personalisation settings. It is recommended that you keep your internet browser and operating system up to date and that you consult the help and guidance provided by your internet browser developer and the manufacturer of your computer or device if you are unsure about how to adjust your privacy settings.
You can instruct your browser to enable or disable cookies, refuse all cookies or indicate when a cookie is being sent. Please note that by doing this you may not be able to use all the functions provided by our Website and/or Services to the fullest.
We use the following cookies:
Strictly Necessary Cookies
These are cookies that are necessary for the operation of Our Website. They include, for example, cookies that enable you to log into secure areas of Our Website.
Analytics and performance cookies
We use third-party analytics providers, such as Google Analytics, to collect information about the use of our services and to enable us to improve how those services work, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies.
They are used to recognise you when you return to Our Site. This enables Us to personalise our content for you and remember your preferences (for example, your choice of language or region).
Targeting Cookies
We use third-party targeting tools such as LinkedIn Insights and ad tags. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.
DATA DISCLOSURE
We strive to maintain discretion in relation to customer-related issues and assessments of which we become aware. We may disclose data relating to you only if (i) we consider it necessary and/or are legally obliged to do so; (ii) if necessary when you expressly instruct us to process a transaction or any other service and (iii) it is necessary for the provision of our services under our contractual relationship and/or (iv) protection of our legitimate interests, in accordance with the provisions of applicable local laws and applicable local legislation, as amended from time to time.
The following are some examples of where and how your information may be transferred, but please note that this is not an exhaustive list and that due to ongoing changes in our IT and operational infrastructure, this may change at any time:
• We may share your data among Codersmaster Affiliates on a confidential basis in order to provide you with our Services.
• We may have to share your personal data with third party service providers, processing data on our behalf, who help us with our business operations. When your personal data is shared with third parties, we will take reasonable steps to ensure that your personal data is treated safely, securely and in accordance with your rights, our obligations and the third party’s obligations under the law. Your personal data is shared with third party organisations/entities, including but not limited to:
1. Service providers . We may share your personal data with our trusted third party service providers, who, on our behalf, operate, maintain and/or support our IT systems and IT infrastructure, our websites, manage our payment solutions, perform statistical analysis, marketing and advertising purposes, send newsletters, provide customer support and perform other important services for us, including maintaining any legal obligations we may have. We will store and process your data following industry best practices and security. Some of this processing takes place at our offices and data centres in Amsterdam and Frankfurt.
2. Regulatory and state authorities . The Company will make such disclosure only if required by the Company by applicable law, regulation or court order and to the minimum extent required.
3. Other disclosures . Non-affiliated companies that may assist us with, for example, processing transactions, conducting research and development, or providing escrow services. In addition to where you have consented to the disclosure of the data or where the disclosure is necessary to achieve the purpose(s) for which it was collected, the data may also be disclosed in special situations where we have reason to believe that it is necessary to identify, contact or bring legal action against anyone who is damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users, or anyone else that could be harmed by such activities, or otherwise where necessary for the establishment, exercise or defense of legal claims.
4. International Transfers. We process data both inside and outside the EEA and countries deemed by the European Union to have adequate safeguards to protect personal data. These countries are recognized by the EU as having adequate safeguards for the rights and freedoms of individuals and redress processes by which data subjects can exercise their rights.
5. Marketing. To send you marketing communications which we believe may be of interest to you;
6. Consent. Any other party where we have first obtained your prior consent.
If you would like more information about any of the data transfers mentioned above, please contact us using the registered email address which you have disclosed to us through the contact points listed in the OUR CONTACT DETAILS section.
ACCESS AND CHOICE
1. We may provide features through the Services that allow you to correct, update, or change your personal information. You may also email customer support (see the “Contact Us” section below) and we will honor that request to the extent required by law. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions you began prior to requesting a change or deletion. There may also be residual information that will remain in our databases and other records, which will not be removed.
2. If you decide at any time that you no longer wish to receive marketing emails from us, please follow the “unsubscribe” instructions provided in such emails or through your account. Please note that you cannot opt out of receiving administrative emails, such as regulatory, billing, or service notices.
CONTACT US
Codersmaster processes your personal data only in accordance with this Privacy Policy and in accordance with this Privacy Policy, while meeting the highest possible data protection standards and as such we treat data protection complaints very seriously. Therefore, should you have any reservations or complaints about how we process your personal data, you can contact us at the following address:
Full name of legal entity:
CODERS MASTER LLC
Email address:
security@codersmaster.com
To enable us to process your request, please contact us using the registered email address that you have disclosed and registered with us. We may require you to provide us with proof of your identity, such as providing us with a copy of a valid form of identification. This is to ensure that we adequately protect the personal data we hold from unauthorised access requests and comply with our security obligations.
If you have any questions or would like further details about how we use your data, please contact us using the contact details above and we will be happy to provide further details..
CHANGES TO THIS PRIVACY POLICY
We may provide links to third party websites on our Site. These linked websites are not under our control and we therefore cannot accept responsibility or liability for the conduct of any third party linked to our websites, including, without limitation, the collection or disclosure of your data. Before disclosing your data to any other website, we recommend that you review the terms and conditions of use of that website and its privacy policies.
CHANGES TO THIS PRIVACY POLICY
This Privacy Policy was last updated in February 2024.
We have the right, at our discretion, to amend this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects the protection of personal data and to ensure that the information contained herein provides relevant and adequate information about our collection and processing of your data.
In the event of any changes, the revised Privacy Policy will be published on our website. The changes will become effective as soon as the revised version is made available on our website above. We therefore recommend that you check the website regularly to stay up to date. Your comments and feedback are always welcome. You can contact us at any time via the contact points listed in the OUR CONTACT DETAILS Section.