Privacy Policy

Registration

In order to use CodeREADr Website and Web Services, you must first complete the online registration form and create a username and password. During registration, you are required to give contact information such as your name and email address. We use this information to contact you about the services on our site in which you have expressed interest.

We also collect personally identifiable information from our users at several different points on our CodeREADr Web Service. We do not sell individual information about our visitors. We will not disclose the individual information provided to us online unless you specifically authorize it, it is required by law, or disclosure is necessary to protect the safety of customers, employees or property.

Payment Information

If you purchase a product or service from us, we request certain personally identifiable information from you on our online order form. You must provide contact information (such as name, email and billing address) and financial information (such as credit card information).

We use a third-party payment processor for all credit card transactions, including charges and refunds. We do not store any credit card information other than encrypted reference data, specifically the last four digits of the credit card number and its expiration date. We store this reference data so you can recognize the card you have on file. We will remove reference data promptly on request.

Communications from this Site

Email: We do not send unsolicited email. We may use email to communicate with our customers, to respond to visitors’ emails, to confirm orders placed online, and to send information that a visitor has requested.

Service-Related Announcements: We will send you service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

Legal Disclaimer: We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process.

Choice/Opt-Out

If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by electing to ‘unsubscribe’.

Log Files

We automatically gather usage and interaction information for the API, the Web Services, and the Application, and store it in log files and our database. This information may include customer identification and communication information, such as Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamps, clickstream data, communications to and from our Products and any user actions. We use this information to track usage, analyze trends, to administer the site and support our customers.

Device ID

When the CodeREADr Web Service is used together with the CodeREADr Barcode Scanner Mobile Application, the device ID of Authorized Users is passed from the application to our servers to facilitate service functionality and track usage for billing purposes. The device ID does not include personally identifiable information and is treated as the Confidential Information of Registered Users.

Cookies

CodeREADr Web Services also uses “cookies” which are small text files that are stored on a user’s computer for record-keeping purposes. When you use our site we send information, a cookie, to your computer and it is stored there. When you return to our site, your computer sends a cookie back to us to allow our server to recognize your computer and any settings you created on our site. The cookie restores those settings so you do not have to enter the same information every time you visit. The fact that our server recognizes your computer when it retrieves cookies does not mean that we are actually acquiring information about you.  For details on the cookies we use please review our Cookie Policy.

Links to Other Sites

This website may contain links to other sites that are not owned by us. This privacy statement applies only to information collected by the CodeREADr Web Service.

Third-Party Service Integration

We allow you to integrate our Web Services with third-party cloud services (e.g. Dropbox, QuickBase, etc.) for specified tasks and we allow you upload files via FTP/SFTP to your own or third-party servers. To enable that you need to provide your access credentials. Those credentials are encrypted on our server.  They are only used for the specified task(s) you enable and they can be edited and/or removed at any time.

## Our Role: Controller vs. Processor

CodeREADr acts as the Controller of personal information relating to our own website visitors, registered account holders (admins), and business contacts — for example, the contact and payment information described above. Where a Client’s own end users submit information through a Client’s configured instance of the CodeREADr app or Web Service (for example, scan data, form responses, or identity information collected on the Client’s behalf), CodeREADr acts solely as a Processor on the Client’s instructions, and the Client is the Controller responsible for that data. If you are such an end user and wish to exercise a privacy right over that data, please contact the organization that issued you access to the app (your Client), rather than CodeREADr directly, as we are required to refer such requests to them.

## Legal Basis for Processing

Where the GDPR or a similar law applies, we rely on the following legal bases for the purposes described in this Policy:

## Data Retention

We retain personal information only as long as necessary for the purposes described in this Policy. In general: account and registration data is retained for the duration of your account plus a reasonable period thereafter to comply with legal and accounting obligations; payment reference data (the last four digits and expiration date of a card on file) is retained until you request its removal; log files and usage data are retained in accordance with our Data Destruction Policy; and backups are retained for 30 days. Client Data processed by CodeREADr as a Processor is retained and deleted in accordance with the applicable Data Processing Addendum.

Changing Personal Information

You may access, correct, update, change, delete or deactivate the information you have provided to us by making the appropriate changes on the Account page.

Your Rights. Depending on your location, you may have the following rights regarding your personal information: the right to access the personal information we hold about you; the right to rectification of inaccurate or incomplete information; the right to erasure (“right to be forgotten”); the right to restrict or object to our processing of your information; the right to data portability (receiving your data in a structured, commonly used format); the right to withdraw consent at any time where processing is based on consent; and the right to lodge a complaint with your local data protection supervisory authority. You may exercise these rights by using our request form or by emailing our Data Protection Officer at dpo@codereadr.com. We will respond in accordance with applicable law, and may need to verify your identity before fulfilling a request. Data Subjects (or any other person whose personal data we Process) can request access or removal of their personal data from their data Controller. For most Data Subjects, we are just the data Processor. EU/UK/Swiss Representative. CodeREADr Inc. is established in the United States and does not maintain an establishment in the European Union, European Economic Area, Switzerland, or United Kingdom. Personal Data relating to EEA, UK, and Swiss data subjects processed through the CodeREADr Cloud Service consists primarily of business contact information and application usage/log data; CodeREADr contractually prohibits Clients from using the Service to process special categories of data (Article 9 GDPR) or data relating to criminal convictions or offenses (Article 10 GDPR) absent a separate written agreement. On this basis, CodeREADr does not process personal data on a large scale, nor on a scale likely to present a high risk to the rights and freedoms of data subjects, and relies on the derogation in Article 27(2)(a) GDPR (and the equivalent provision of the UK GDPR) from the requirement to appoint an EU/UK representative. Data subjects with EU/UK/Swiss data protection inquiries may contact our Data Protection Officer at dpo@codereadr.com.

Any person wishing exercise their rights under the provisions of the EU General Data Protection Regulation can do so by filling out this request form.

Security

## Your Privacy Rights Under California and Other US State Laws

If you are a California resident, you have rights under the California Consumer Privacy Act (as amended by the CPRA) to request access to, deletion of, or correction of personal information we hold about you, and to know the categories of personal information collected, the business purpose for collecting it, and any third parties with whom it has been shared. We do not sell or share personal information for cross-context behavioral advertising. Residents of Virginia, Colorado, Connecticut, and other US states with comprehensive privacy laws have similar rights under their respective laws.

These rights apply to personal information CodeREADr processes as a Controller — primarily information about our own website visitors, customers, and business contacts. Where CodeREADr processes personal information as a Processor on behalf of a Client (for example, data your organization’s end users submit through the CodeREADr app), the request should be directed to that Client, who is the Controller responsible for it.

You may exercise these rights by emailing dpo@codereadr.com or using our request form. We will not discriminate against you for exercising any privacy right.

Artificial Intelligence. We do not use Client Data or other personal information collected through the CodeREADr Website, Web Services, or Barcode Scanner Mobile Application to train artificial intelligence or machine learning models, whether our own or a third party’s.

The security of your personal information is important to us. When you enter sensitive information, such as credit card information, on our registration or order forms, we encrypt that information using secret socket layer technology (SSL/TLS). We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

Changes to this Privacy Statement

We will post any material changes to this privacy statement here and any other places we deem appropriate at least 30 days before such changes become effective. We reserve the right to modify this privacy statement at any time, so please review it frequently.

Contact Us

If you have any questions concerning our privacy policy, please contact our Data Protection Officer at dpo@codereadr.com. If necessary you may call us at +1.617.279.0040 or send a letter to CodeREADr Inc., Attn. CodeREADr DPO, 100 Summer St Suite 1600, Boston, MA 02110 USA