Privacy Policy
This policy explains what personal data c0dename collects through c0dename.com and related enquiries, briefings and correspondence, why we collect it, who we share it with, how long we keep it, and what rights you have.
It covers only the website and pre-contract business contact. Data we process for customers under a signed agreement is governed by that agreement and its data processing terms, not by this policy.
1. Who we are
The controller of your personal data is c0dename ("we", "us").
Privacy questions and requests: hello@c0dename.com. We have not appointed a data protection officer; this address reaches the people responsible for data protection at c0dename.
2. Our approach
We collect the minimum data we need to answer a business enquiry and run a secure website. We do not run advertising, we do not sell data, and we do not build profiles of visitors. We treat the fact that you contacted us as confidential.
3. What we collect
Briefing requests. First name, last name, business email address, phone number, job title, company, country, and anything you write in the project description.
Correspondence and meetings. Your email address, the content of your messages and attachments, and notes of calls, briefings or meetings with you.
Verification and screening. To confirm that an enquiry is genuine and comes from an eligible organisation, and to meet sanctions and export control obligations, we may check your name, role, organisation and country against public sources, such as official registers, your organisation's website and professional profiles, and against official sanctions and restricted-party lists. We record the result.
Technical data. Our hosting and security providers automatically record IP address, approximate location derived from it, browser and device type, pages requested, referring page, and date and time of the request.
From others. If someone refers you to us or introduces you, we receive the contact details they share.
Briefings. We record a briefing or call only with the prior agreement of everyone taking part.
What is required. Fields marked as required on the enquiry form are needed for us to respond. If you do not provide them, we cannot process your enquiry. Everything else is optional. You are not under any legal or contractual obligation to give us personal data.
Please use your business contact details. Do not send us classified, operationally sensitive or special-category data (for example health, political opinions, religious beliefs or biometric data). If you do, we may delete it without processing it.
4. Why we use it and on what legal basis
| Purpose | Legal basis |
|---|---|
| Respond to your enquiry, assess fit, arrange and hold a briefing | Steps taken at your request before a possible contract; our legitimate interest in responding to business enquiries |
| Verify that an enquiry is genuine and that the organisation and intended end use are eligible | Legitimate interest in protecting our products, information and business from misuse |
| Screen against sanctions, export control and restricted-party lists, and keep records of screening | Legal obligation; legitimate interest in complying with sanctions and export control regimes that apply to us, our suppliers and our customers |
| Manage business relationships and follow up on your enquiry | Legitimate interest in running and developing our business |
| Send occasional updates about our products to business contacts | Legitimate interest, or your consent where the law requires it. You can opt out at any time |
| Operate, secure and protect the Site; detect and prevent abuse, fraud, intrusion and attacks | Legitimate interest in operating a secure website |
| Establish, exercise or defend legal claims; comply with legal and regulatory obligations and lawful requests | Legal obligation; legitimate interest |
Where we rely on legitimate interests, we have balanced them against your rights and freedoms. You can ask us for details of that assessment.
We may use AI-based tools, operated by our service providers under data processing agreements, to summarise, sort and route enquiries. A person reviews every enquiry before any decision about it. We do not allow your data to be used to train third-party AI models.
We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects.
5. Cookies and tracking
The Site uses only cookies and similar technologies that are strictly necessary for it to work and stay secure. We do not use advertising, cross-site tracking, session recording or analytics cookies, and we do not use third-party pixels. Because we do not track you across sites, browser "Do Not Track" and Global Privacy Control signals do not change how the Site behaves. If this changes, we will update this policy and ask for your consent first where the law requires it.
7. International transfers
Some of our service providers process data outside your country, including outside the European Economic Area, the United Kingdom and Ukraine. Where that happens, we rely on an adequacy decision or on Standard Contractual Clauses approved by the European Commission (with the UK Addendum where relevant), together with a transfer risk assessment and additional safeguards where needed. You can ask us for a copy of the relevant safeguards.
We never transfer personal data to, store it in, or allow access to it from the Russian Federation, the Republic of Belarus, or any country subject to comprehensive sanctions, and we do not use service providers owned or controlled from those countries.
8. How long we keep it
| Data | Retention |
|---|---|
| Enquiries and correspondence that do not lead to a contract | Up to 24 months after our last contact with you |
| Data relating to a signed contract | For the term of the contract and as long afterwards as the law or the contract requires |
| Sanctions and export control screening records | As long as the applicable law requires, typically up to 5 years |
| Opt-out records | As long as needed to respect your opt-out |
| Technical and security logs | Up to 30 days, or longer if needed to investigate a security incident |
When a period ends, we delete or irreversibly anonymise the data. We may keep data longer only where we need it to establish, exercise or defend a legal claim, and only for as long as that need lasts.
9. Security
We protect personal data with technical and organisational measures appropriate to the risk, including encryption in transit, access limited to people who need it, access logging, multi-factor authentication on our systems, and vetting of service providers.
Ordinary email is not a secure channel. If you need to share something sensitive, ask us first and we will agree a secure method.
No system is fully secure. If a breach is likely to put your rights at risk, we will notify you and the relevant authority as the law requires.
10. Your rights
Depending on where you live, you have the right to:
- access the personal data we hold about you and receive a copy;
- correct inaccurate or incomplete data;
- have your data deleted;
- restrict how we use it;
- object to processing based on legitimate interests, and object at any time to direct marketing;
- receive your data in a structured, machine-readable format and have it transmitted to another controller;
- withdraw consent at any time, where we rely on consent, without affecting earlier processing.
To use any of these rights, email hello@c0dename.com. We will respond within one month, which we may extend by up to two further months for complex or numerous requests, and we will tell you if we do. We may ask you to confirm your identity first, and we will not act on a request we cannot verify. An authorised agent may act for you if they provide proof of authority.
We may refuse a request, or part of it, where the law allows, for example where we must keep data to comply with a legal obligation, including sanctions and export control record-keeping, to establish, exercise or defend a legal claim, or where disclosure would reveal personal data of others or confidential information. We will tell you why.
We will not treat you less favourably for exercising your rights.
You also have the right to complain to a data protection authority: in Ukraine, the Ukrainian Parliament Commissioner for Human Rights; in the EU, the supervisory authority where you live or work; in the UK, the Information Commissioner's Office. We would appreciate the chance to address your concern first.
11. United States residents
In the past 12 months we have collected the categories of personal data described in section 3: identifiers and contact details, professional information, internet activity limited to the technical data described, and the content of your communications. We use them only for the purposes in section 4 and disclose them only as described in section 6. We do not sell or share personal data for cross-context behavioural advertising, and we do not use or disclose sensitive personal information. Depending on your state, you may have the rights described in section 10, and you can use them the same way.
12. Information about other people
If you give us personal data about someone else, such as a colleague you copy into an email or name in an enquiry, you confirm that you are authorised to share it and that you have told that person about this policy, or that the law does not require you to. We use that data only for the purposes in section 4.
13. Children
The Site is for professionals acting in a business or official capacity. It is not directed at anyone under 18, and we do not knowingly collect personal data from them.
If you believe that someone under 18 has given us personal data, contact us at hello@c0dename.com. We will delete the data without undue delay and will not use it for any purpose. We may ask anyone who contacts us to confirm that they are 18 or over.
14. Third-party sites and platforms
The Site links to third-party sites, including LinkedIn and UNITED24. When you follow a link, you leave the Site, and the third party's own privacy policy applies. We do not control those sites and are not responsible for their content or how they handle your data. Read their policies before you share anything with them.
LinkedIn. If you follow or interact with our LinkedIn page, LinkedIn processes your data under its own privacy policy. LinkedIn may give us aggregated, non-identifying statistics about visits to our page. Where it does, LinkedIn and we may be joint controllers for that statistical processing, and LinkedIn has primary responsibility for it, including for responding to your rights requests. You can still contact us about it.
No embedded content. The Site does not embed third-party content, social media plugins, maps or videos that would let those third parties collect data about your visit. If we add any, we will update this policy first and load such content only with your consent where the law requires it.
15. Changes to this policy
We review this policy at least once a year and whenever we change how we process personal data.
We will post every new version on this page and update the dates at the top. Minor changes, such as clarifications or corrections that do not affect your rights, take effect when posted.
If a change is material, for example a new purpose, a new category of data, a new type of recipient, or a reduction of your rights, we will announce it on the Site before it takes effect. Where we have your email address and the change affects data we already hold about you, we will also tell you by email. Where the change requires your consent, we will ask for it and will not apply the change to you until you give it.
Previous versions of this policy are available on request from hello@c0dename.com.
16. Language and interpretation
This policy is written in English. Any translation is for convenience only. If a translation conflicts with the English version, the English version prevails.
Headings are for convenience and do not affect meaning. "Including" means including without limitation. This policy is a notice about how we process personal data. It is not a contract and does not create contractual rights or obligations, except where the law provides otherwise.
17. Contact and complaints
For any question, request or complaint about this policy or how we handle your personal data, email hello@c0dename.com with "Privacy" in the subject line.
To help us respond quickly, include:
- your name and the email address you used when contacting us;
- what your request is about, such as access, correction, deletion or objection;
- any detail that helps us find the relevant data, such as the date you submitted an enquiry.
We aim to acknowledge every privacy request within five working days and to respond in full within the time limits in section 10. Responding is free of charge, unless a request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse it, and we will explain why.
If you are not satisfied with our response, you can complain to the data protection authority listed in section 10.