Welcome to COODY, Inc. ("COODY" "we," "us" or "our"). This Privacy Policy explains our policies and procedures pertaining to the collection, processing, storage and protection of potentially personally identifiable information in relation to our mobile services, and any other services we provide (collectively, our “Services”, “Service” or “DIGO”). By using our Services, you agree to the policies and procedures set forth in this Privacy Policy. You should review this Privacy Policy to understand our practices pertaining to personally identifiable information.
By using our Services, you understand and agree that we are providing a platform for you to post text, graphics, photos or other materials (collectively referred to as "Content"), to our Services and to share Content publicly. Please be advised that other users may search for, see, use, or share any of your Content that you make publicly available through our Services, consistent with the terms and conditions of this Privacy Policy and our Terms of Use.
Information We collect
1.1. Information you provide to us directly. This includes your username, password and entity related email address in connection with our registration process and the maintenance of your account with us which allows you to use our Services. Please be advised that we do not request or require that you provide us with your name, address, phone number or any additional identifying information in order to use our Services.
1.2. Content. Potential personally Identifying Information that you provide may also include the content, replies, conversations and images you post, publish or transmit when using our Services.
1.3. Location Information. We collect information about your location when you use our services, which helps us offer features like uploading contents, search results for things near you, and ads based on your general location. Your location can be determined with varying degrees of accuracy by your IP address, mobile or other device’s GPS, or other information you share with us, depending on your device settings.
1.4. Cookies. Like many websites, we may use cookies and similar technology for limited purposes such as, to help authenticate your access to our Services and prevent unauthorized parties from accessing your account.
1.5. Analytics Information. We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Services as part of a page request and other information that assists us in improving the Service. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user.
1.6. Usage details. When you access and use our Services, we may automatically collect certain details of your access to and use of our Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Services.
1.7. Device information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, mobile network information, and the device's telephone number.
1.8. Stored files. Our Services also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips.
1.9. Customer Support. We may collect information through your communications with our customer support team or other communications that you may send us and their contents.
How We Use Information
We also may use the Personal Information we obtain about you to:
How We Share Your Personal Information
We may disclose the Personal Information we collect about you as described below or otherwise disclosed to you at the time the data is collected, including with:
Service Providers: We engage certain trusted third parties to perform functions and provide services to us, including hosting and maintenance, error monitoring, debugging, performance monitoring, billing, customer relationship, database storage and management, and direct marketing campaigns. We may share your Personal Information with these third parties, but only to the extent necessary to perform these functions and provide such services. We also require these third parties to maintain the privacy and security of the Personal Information they process on our behalf.
Compliance with Laws and Law Enforcement: COODY cooperates with government and law enforcement officials or private parties to enforce and comply with the law. To the extent permitted under applicable law, we may disclose any information about you to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to, and defend against claims, for legal process (including subpoenas), to protect the property and rights of COODY or a third party, to protect COODY against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity, to protect the security or integrity of the Service and any equipment used to make the Service available, or to comply with the law.
Business Transfers: COODY may sell, transfer or otherwise share some or all of its assets, including Personal Information, in connection with a merger, acquisition, reorganization, sale of assets, or similar transaction, or in the event of insolvency or bankruptcy. You will have the opportunity to opt out of any such transfer if the new entity’s planned processing of your information differs materially from that set forth in this Privacy Policy.
Other Third Parties: We may share Personal Information with our headquarters and affiliates, and business partners to whom it is reasonably necessary or desirable for us to disclose your data for the purposes described in this Privacy Policy. We may also make certain non-Personal Information available to third parties for various purposes, including for business or marketing purposes or to assist third parties in understanding our users’ interest, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and functionality available through the Service.
How We Protect Your Personal Information
COODY is very concerned about safeguarding the confidentiality of your Personal Information. We employ administrative and electronic measures designed to appropriately protect your Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. Please be aware that no security measures are perfect or impenetrable. We cannot guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our administrative, physical, and electronic safeguards, subject to requirements under applicable law to ensure or warrant information security.
We will make any legally-required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored Personal Information to you via email or conspicuous posting on our Services in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system, and any other disclosures that may be required under applicable law.
We also take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.
Your Rights and Choices
Users of our Services may possess additional rights pertaining to processing and retention of personally identifiable information. If you are such a user and you request: 1) a copy of personal identifiable information, or; 2) correction or deletion of personal identifiable information, please contact us at [[email protected]]. Please be advised that the personal identifiable information in our possession is limited to the Content you have provided to us. We are unable to provide an entity related email address for a specific user because it is immediately encrypted upon registration. In addition, we do not discriminate against users of our Services based on whether they have exercised their rights under any privacy laws.
We are compliant with the requirements of the California Consumer Protection Act and do not sell or disclose for any business purpose any personally identifiable information.
Data Transfers
COODY is based in the Republic of Korea. Personal Information that we collect may be transferred to, and stored at, any of our affiliates, partners or service providers which may be inside or outside the European Economic Area (“EEA”) and Switzerland, including the Republic of Korea. By submitting your personal data, you agree to such transfers. Your Personal Information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information. When we transfer or disclose your Personal Information to other countries, we will protect that information as described in this Privacy Policy.
Policy Pertaining to Children
COODY does not knowingly collect or solicit any information from anyone under the age of consent established by the data protection law of their applicable country. COODY does not knowingly allow such persons to register for the Services. The Services are not directed to anyone under the age of consent established by the data protection law of their applicable country. In the event that we learn that we have collected personal information from anyone under the age of consent established by the data protection law of their applicable country, we will take all reasonable steps to erase such information as quickly as possible. If you believe that we may possess any information provided by or pertaining to a child, please contact us.
Changes to Our Privacy Policy
COODY may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice, modifications or updates as appropriate under the circumstances. Your continued use of our Services after any modification to this Privacy Policy will constitute your acceptance of such modification.
We welcome you to contact us if you have any concerns regarding our Privacy Policy and/or COODY’s processing of potential personally identifiable information. You may contact us at [[email protected]].
Effective: Sep 1, 2023.
Last Updated: Sep 1, 2023.