Privacy Policy
Your privacy is important to us. It is Codeless Consultant's policy to respect your privacy
and comply with any applicable law and regulation regarding any personal information
we may collect about you, including via our app, POB - Flashcard, and its associated
services.
Personal information is any information about you which can be used to identify you.
This includes information about you as a person (such as name, address, and date of
birth), your devices, payment details, and even information about how you use an app
or online service.
In the event our app contains links to third-party sites and services, please be aware that
those sites and services have their own privacy policies. After following a link to any
third-party content, you should read their posted privacy policy information about how
they collect and use personal information. This Privacy Policy does not apply to any of
your activities after you leave our app.
This policy is effective as of 11 February 2022.
Last updated: 11 February 2022
Information We Collect
Information we collect falls into one of two categories: “voluntarily provided”
information and “automatically collected” information.
“Voluntarily provided” information refers to any information you knowingly and
actively provide us when using our app and its associated services.
“Automatically collected” information refers to any information automatically sent by
your device in the course of accessing our app and its associated services.
Log Data
When you access our servers via our app, we may automatically log the standard data
provided by your device. It may include your device's Internet Protocol (IP) address,
your device type and version, your activity within the app, time and date, and other
details about your usage.
Additionally, when you encounter certain errors while using the app, we automatically
collect data about the error and the circumstances surrounding its occurrence. This data
may include technical details about your device, what you were trying to do when the
error happened, and other technical information relating to the problem. You may or
may not receive notice of such errors, even in the moment they occur, that they have
occurred, or what the nature of the error is.
Please be aware that while this information may not be personally identifying by itself,
it may be possible to combine it with other data to personally identify individual persons.
Device Data
Our app may access and collect data via your device's in-built tools, such as:
Your identity
Location data
Notifications
When you install the app or use your device’s tools within the app, we request
permission to access this information. The specific data we collect can depend on the
individual settings of your device and the permissions you grant when you install and
use the app.
Personal Information
We may ask for personal information — for example, when you submit content to us or
when you contact us — which may include one or more of the following:
Name
Email
User-Generated Content
We consider “user-generated content” to be materials (text, image and/or video content)
voluntarily supplied to us by our users for the purpose of publication on our platform,
website or re-publishing on our social media channels. All user-generated content is
associated with the account or email address used to submit the materials.
Please be aware that any content you submit for the purpose of publication will be public
after posting (and subsequent review or vetting process). Once published, it may be
accessible to third parties not covered under this privacy policy.
Legitimate Reasons for Processing Your Personal Information
We only collect and use your personal information when we have a legitimate reason
for doing so. In which instance, we only collect personal information that is reasonably
necessary to provide our services to you.
Collection and Use of Information
We may collect personal information from you when you do any of the following on
our website:
Register for an account
Use a mobile device or web browser to access our content
Contact us via email, social media, or on any similar technologies
When you mention us on social media
We may collect, hold, use, and disclose information for the following purposes, and
personal information will not be further processed in a manner that is incompatible with
these purposes:
to provide you with our app and platform's core features and services
to enable you to customize or personalize your experience of our website
for internal record keeping and administrative purposes
We may combine voluntarily provided and automatically collected personal information
with general information or research data we receive from other trusted sources. For
example, If you consent to us accessing your social media profiles, we may combine
information sourced from those profiles with information received from you directly to
provide you with an enhanced experience of our app and services.
Security of Your Personal Information
When we collect and process personal information, and while we retain this information,
we will protect it within commercially acceptable means to prevent loss and theft, as
well as unauthorized access, disclosure, copying, use, or modification.
Although we will do our best to protect the personal information you provide to us, we
advise that no method of electronic transmission or storage is 100% secure, and no one
can guarantee absolute data security.
You are responsible for selecting any password and its overall security strength,
ensuring the security of your own information within the bounds of our services. For
example, ensuring any passwords associated with accessing your personal information
and accounts are secure and confidential.
How Long We Keep Your Personal Information
We keep your personal information only for as long as we need to. This time period may
depend on what we are using your information for, in accordance with this privacy
policy. For example, if you have provided us with personal information as part of
creating an account with us, we may retain this information for the duration your account
exists on our system. If your personal information is no longer required for this purpose,
we will delete it or make it anonymous by removing all details that identify you.
However, if necessary, we may retain your personal information for our compliance
with a legal, accounting, or reporting obligation or for archiving purposes in the public
interest, scientific, or historical research purposes or statistical purposes.
Children’s Privacy
We do not aim any of our products or services directly at children under the age of 13,
and we do not knowingly collect personal information about children under 13.
Disclosure of Personal Information to Third Parties
We may disclose personal information to:
a parent, subsidiary, or affiliate of our company
third-party service providers for the purpose of enabling them to provide their
services, including (without limitation) IT service providers, data storage, hosting
and server providers, analytics, error loggers, debt collectors, maintenance or
problem-solving providers, professional advisors, and payment systems
operators
our employees, contractors, and/or related entities
our existing or potential agents or business partners
credit reporting agencies, courts, tribunals, and regulatory authorities, in the event
you fail to pay for goods or services we have provided to you
courts, tribunals, regulatory authorities, and law enforcement officers, as required
by law, in connection with any actual or prospective legal proceedings, or in order
to establish, exercise, or defend our legal rights
third parties, including agents or sub-contractors, who assist us in providing
information, products, services, or direct marketing to you
third parties to collect and process data
an entity that buys, or to which we transfer all or substantially all of our assets
and business
Third parties we currently use include:
OneSignal
AdMob
Transmitting data results via email
International Transfers of Personal Information
The personal information we collect is stored and/or processed in United States, or
where we or our partners, affiliates, and third-party providers maintain facilities.
The countries to which we store, process, or transfer your personal information may not
have the same data protection laws as the country in which you initially provided the
information. If we transfer your personal information to third parties in other countries:
(i) we will perform those transfers in accordance with the requirements of applicable
law; and (ii) we will protect the transferred personal information in accordance with this
privacy policy.
Your Rights and Controlling Your Personal Information
Your choice: By providing personal information to us, you understand we will collect,
hold, use, and disclose your personal information in accordance with this privacy policy.
You do not have to provide personal information to us, however, if you do not, it may
affect your use of our app or the products and/or services offered on or through it.
Information from third parties: If we receive personal information about you from a
third party, we will protect it as set out in this privacy policy. If you are a third party
providing personal information about somebody else, you represent and warrant that
you have such person’s consent to provide the personal information to us.
Marketing permission: If you have previously agreed to us using your personal
information for direct marketing purposes, you may change your mind at any time by
contacting us using the details below.
Access: You may request details of the personal information that we hold about you.
Correction: If you believe that any information we hold about you is inaccurate, out of
date, incomplete, irrelevant, or misleading, please contact us using the details provided
in this privacy policy. We will take reasonable steps to correct any information found to
be inaccurate, incomplete, misleading, or out of date.
Non-discrimination: We will not discriminate against you for exercising any of your
rights over your personal information. Unless your personal information is required to
provide you with a particular service or offer (for example serving particular content to
your device), we will not deny you goods or services and/or charge you different prices
or rates for goods or services, including through granting discounts or other benefits, or
imposing penalties, or provide you with a different level or quality of goods or services.
Notification of data breaches: We will comply with laws applicable to us in respect of
any data breach.
Complaints: If you believe that we have breached a relevant data protection law and
wish to make a complaint, please contact us using the details below and provide us with
full details of the alleged breach. We will promptly investigate your complaint and
respond to you, in writing, setting out the outcome of our investigation and the steps we
will take to deal with your complaint. You also have the right to contact a regulatory
body or data protection authority in relation to your complaint.
Unsubscribe: To unsubscribe from our email database or opt-out of communications
(including marketing communications), please contact us using the details provided in
this privacy policy, or opt-out using the opt-out facilities provided in the
communication. We may need to request specific information from you to help us
confirm your identity.
Business Transfers
If we or our assets are acquired, or in the unlikely event that we go out of business or
enter bankruptcy, we would include data, including your personal information, among
the assets transferred to any parties who acquire us. You acknowledge that such transfers
may occur, and that any parties who acquire us may, to the extent permitted by
applicable law, continue to use your personal information according to this policy,
which they will be required to assume as it is the basis for any ownership or use rights
we have over such information.
Limits of Our Policy
Our app may link to external sites that are not operated by us. Please be aware that we
have no control over the content and policies of those sites, and cannot accept
responsibility or liability for their respective privacy practices.
Changes to This Policy
At our discretion, we may change our privacy policy to reflect updates to our business
processes, current acceptable practices, or legislative or regulatory changes. If we decide
to change this privacy policy, we will post the changes here.
If the changes are significant, or if required by applicable law, we will contact you
(based on your selected preferences for communications from us) and all our registered
users with the new details and links to the updated or changed policy.
If required by law, we will get your permission or give you the opportunity to opt in to
or opt out of, as applicable, any new uses of your personal information.
Additional Disclosures for Australian Privacy Act Compliance (AU)
International Transfers of Personal Information
Where the disclosure of your personal information is solely subject to Australian privacy
laws, you acknowledge that some third parties may not be regulated by the Privacy Act
and the Australian Privacy Principles in the Privacy Act. You acknowledge that if any
such third party engages in any act or practice that contravenes the Australian Privacy
Principles, it would not be accountable under the Privacy Act, and you will not be able
to seek redress under the Privacy Act.
Additional Disclosures for General Data Protection Regulation (GDPR) Compliance
(EU)
Data Controller / Data Processor
The GDPR distinguishes between organisations that process personal information for
their own purposes (known as “data controllers”) and organizations that process
personal information on behalf of other organizations (known as “data processors”). We,
Codeless Consultant, located at the address provided in our Contact Us section, are a
Data Controller with respect to the personal information you provide to us.
Legal Bases for Processing Your Personal Information
We will only collect and use your personal information when we have a legal right to
do so. In which case, we will collect and use your personal information lawfully, fairly,
and in a transparent manner. If we seek your consent to process your personal
information, and you are under 16 years of age, we will seek your parent or legal
guardian’s consent to process your personal information for that specific purpose.
Our lawful bases depend on the services you use and how you use them. This means we
only collect and use your information on the following grounds:
Consent From You
Where you give us consent to collect and use your personal information for a specific
purpose. You may withdraw your consent at any time using the facilities we provide;
however this will not affect any use of your information that has already taken place.
When you contact us, you may consent to your name and email address being used so
we can respond to your enquiry. While you may request that we delete your contact
details at any time, we cannot recall any email we have already sent. If you have any
further enquiries about how to withdraw your consent, please feel free to enquire using
the details provided in the Contact Us section of this privacy policy.
Performance of a Contract or Transaction
Where you have entered into a contract or transaction with us, or in order to take
preparatory steps prior to our entering into a contract or transaction with you. For
example, we need technical information about your device in order to provide the
essential features of our app.
Our Legitimate Interests
Where we assess it is necessary for our legitimate interests, such as for us to provide,
operate, improve and communicate our services. For example, we collect technical
information about your device in order to improve and personalize your experience of
our app. We consider our legitimate interests to include research and development,
understanding our audience, marketing and promoting our services, measures taken to
operate our services efficiently, marketing analysis, and measures taken to protect our
legal rights and interests.
Compliance with Law
In some cases, we may have a legal obligation to use or keep your personal information.
Such cases may include (but are not limited to) court orders, criminal investigations,
government requests, and regulatory obligations. If you have any further enquiries about
how we retain personal information in order to comply with the law, please feel free to
enquire using the details provided in the Contact Us section of this privacy policy.
International Transfers Outside of the European Economic Area (EEA)
We will ensure that any transfer of personal information from countries in the European
Economic Area (EEA) to countries outside the EEA will be protected by appropriate
safeguards, for example by using standard data protection clauses approved by the
European Commission, or the use of binding corporate rules or other legally accepted
means.
Your Rights and Controlling Your Personal Information
Restrict: You have the right to request that we restrict the processing of your personal
information if (i) you are concerned about the accuracy of your personal information;
(ii) you believe your personal information has been unlawfully processed; (iii) you need
us to maintain the personal information solely for the purpose of a legal claim; or (iv)
we are in the process of considering your objection in relation to processing on the basis
of legitimate interests.
Objecting to processing: You have the right to object to processing of your personal
information that is based on our legitimate interests or public interest. If this is done, we
must provide compelling legitimate grounds for the processing which overrides your
interests, rights, and freedoms, in order to proceed with the processing of your personal
information.
Data portability: You may have the right to request a copy of the personal information
we hold about you. Where possible, we will provide this information in CSV format or
other easily readable machine format. You may also have the right to request that we
transfer this personal information to a third party.
Deletion: You may have a right to request that we delete the personal information we
hold about you at any time, and we will take reasonable steps to delete your personal
information from our current records. If you ask us to delete your personal information,
we will let you know how the deletion affects your use of our app, website or products
and services. There may be exceptions to this right for specific legal reasons which, if
applicable, we will set out for you in response to your request. If you terminate or delete
your account, we will delete your personal information within 14 days of the deletion of
your account. Please be aware that search engines and similar third parties may still
retain copies of your personal information that has been made public at least once, like
certain profile information and public comments, even after you have deleted the
information from our services or deactivated your account.
Additional Disclosures for California Compliance (US)
Under California Civil Code Section 1798.83, if you live in California and your business
relationship with us is mainly for personal, family, or household purposes, you may ask
us about the information we release to other organizations for their marketing purposes.
To make such a request, please contact us using the details provided in this privacy
policy with “Request for California privacy information” in the subject line. You may
make this type of request once every calendar year. We will email you a list of categories
of personal information we revealed to other organisations for their marketing purposes
in the last calendar year, along with their names and addresses. Not all personal
information shared in this way is covered by Section 1798.83 of the California Civil
Code.
Do Not Track
Some browsers have a “Do Not Track” feature that lets you tell websites that you do not
want to have your online activities tracked. At this time, we do not respond to browser
“Do Not Track” signals.
We adhere to the standards outlined in this privacy policy, ensuring we collect and
process personal information lawfully, fairly, transparently, and with legitimate, legal
reasons for doing so.
CCPA-permitted financial incentives
In accordance with your right to non-discrimination, we may offer you certain financial
incentives permitted by the CCPA that can result in different prices, rates, or quality
levels for the goods or services we provide.
Any CCPA-permitted financial incentive we offer will reasonably relate to the value of
your personal information, and we will provide written terms that describe clearly the
nature of such an offer. Participation in a financial incentive program requires your prior
opt-in consent, which you may revoke at any time.
California Notice of Collection
For more information on information we collect, including the sources we receive
information from, review the “Information We Collect” section. We collect and use
these categories of personal information for the business purposes described in the
“Collection and Use of Information” section, including to provide and manage our
Service.
Right to Know and Delete
If you are a California resident, you have rights to delete your personal information we
collected and know certain information about our data practices in the preceding 12
months. In particular, you have the right to request the following from us:
The categories of personal information we have collected about you;
The categories of sources from which the personal information was collected;
The categories of personal information about you we disclosed for a business
purpose or sold;
The categories of third parties to whom the personal information was disclosed
for a business purpose or sold;
The business or commercial purpose for collecting or selling the personal
information; and
The specific pieces of personal information we have collected about you.
To exercise any of these rights, please contact us using the details provided in this
privacy policy.
Shine the Light
If you are a California resident, in addition to the rights discussed above, you have the
right to request information from us regarding the manner in which we share certain
personal information as defined by California’s “Shine the Light” with third parties and
affiliates for their own direct marketing purposes.
To receive this information, send us a request using the contact details provided in this
privacy policy. Requests must include “California Privacy Rights Request” in the first
line of the description and include your name, street address, city, state, and ZIP code.
Contact Us
For any questions or concerns regarding your privacy, you may contact us using the
following details:
Jared Gibb
jared.gibb@gmail.com
