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Privacy Policy

Privacy Policy of Codenga

1. General


At Codenga, we care about your personal data, so we have prepared this Privacy Policy to explain how we collect, use and share it.

This Privacy Policy (“Privacy Policy”) details the personal data ES Investments (“Codenga”, “we”, “us” or “our”) receives about you, how we process it and your rights and obligations in relation to your personal data. ES Investments, Przemysłowa 27, 33-100 Tarnów, Poland is the data controller for the purposes of the General Data Protection Regulation (“GDPR”) and any relevant local legislation (“Data Protection Laws”).


2. Information we collect

Codenga collects information from you directly, automatically through its Services, and from third parties. Each collection mechanism is described in more detail in this Privacy Policy.

2.1 Information you provide

In order to use all parts of the Services you need to provide us the following information:

  • - Your Email address
  • - Your First name
  • - Your Last Name
  • - Your Country


We will not store or collect your payment card credentials. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy.


Optionally you can provide us the following information:

  • - Profile picture (Avatar)
  • - Your Bio
  • - The URL of your website
  • - Links to your social media profiles

2.2 Automatically Collected Information

If you use the Services, we process Data that your browser communicates to our servers. We collect the following Data, which is necessary for us in order to display the Service correctly and guarantee the necessary stability and safety:

  • - IP address;
  • - date and time stamp;
  • - time difference to GMT;
  • - requested site;
  • - access status/HTTP status code;
  • - transmitted data volume;
  • - site from which the request was sent;
  • - browser;
  • - operating system and interface; and
  • - language and version of the browser software.

2.3 Cookies

The Services may use cookies. A cookie is a small text file that is stored on your device through your browser. The cookies used by our Services include both first party and third party cookies. First party cookies allow us to collect analytics data, remember your settings, and perform other useful functions that help simplify your user experience. Third party cookies are used by third parties for advertising, retargeting, analytics, and tracking.

You can disable the cookies by entering the corresponding settings in your browser software (e.g. in Internet Explorer, Mozilla Firefox, Opera, or Safari). However, in this case you may have limited access to the Services.



We use the Information for the following purposes:

  • - to provide and improve our Services;
  • - to manage customer relations and customer support;
  • - to communicate with you;
  • - to advertise our own products;
  • - to conduct research and development of the Services;
  • - to maintain the security of the Services;
  • - to prevent the abuse of the Services;
  • - to comply with our legal obligations;
  • - to protect our legitimate business interests and legal rights


4. Third party sharing

4.1 Third party sharing

We disclose Information:

  • - to contractors, service providers, and other third parties we use to support our Services, including advertising service providers, analytics service providers and payment processing service providers;
  • - to fulfill any purpose for which you provide it;
  • - for any other purpose disclosed to you when you provide the information; or
  • - with your consent.

We may also disclose your information:

  • - to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  • - to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets;
  • - if we believe disclosure is necessary or appropriate to protect our rights, property, or interests.

4.2 List of third party services

Here is the list of third party service providers that we use:

  • - Facebook Inc., 1601 South California Ave, Palo Alto, CA 94304, USA (“Facebook”);
  • - Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”);
  • - Hotjar Ltd, Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian's STJ 3141, Malta, Europe;
  • - PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal L-2449, Luxembourg;

4.3 Third country sharing

Some of the third parties are based in the United States. Therefore, Data is transferred to third parties in third countries, all of which adhere to the EU-US privacy shield (see for more information).

4.4 Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:


5. Bases for Processing

The legal bases for our processing activities include:

  • - Your consent (Article 6(1)(a) General Data Protection Regulation);
  • - Codenga exercising its rights and performing its obligations in connection with entering into or performing under any contract it makes with you (Article 6(1)(b) General Data Protection Regulation);
  • - Compliance with our legal obligations (Article 6(1)(c) General Data Protection Regulation);
  • - Legitimate interests that are not overridden by your interests or your fundamental rights and freedoms (Article 6(1)(f) General Data Protection Regulation).


6. Data Retention

We only store Information for as long as is needed to fulfil our contractual or legal obligations or any other permissible purpose for which we have collected it, including to detect and prevent fraud or security incidents. When the applicable retention period has expired, we take measures to permanently delete the information or anonymize it.

6.1 Deleting your data

Your Data will be deleted if you (a) revoke your consent to the storage (b) Data is not needed to fulfill the user contract concerning the Services anymore, or (c) the storage is or becomes legally impermissible. A deletion request does not affect Data, if the storage is legally necessary, for example for accounting purposes.


7. Security

We use commercially reasonable administrative, physical, and technical measures to safeguard your information and help protect it from unauthorized access. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us by contacting us as detailed in the “Contact Us” section.


8. Your Rights

We would like to make sure you are fully aware of all of your data protection rights. You are entitled to the following:

The right to access – You have the right to request us for copies of your personal data.

The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.

The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions

The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you would like to exercise any of these rights, please contact us at our email:


9. Privacy policies of other websites


The Codenga website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.


10. Changes to our privacy policy

We keep this privacy policy under regular review and we place any updates on this web page. This privacy policy was last updated on 07 June 2021.


11. Contact Us

If you have any questions about Codenga’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at:


Or write to us at:

ES Investments

Przemysłowa 27

33-100 Tarnów, Poland