1. Introduction and Scope
This Privacy Policy explains how Coder Holding Corporation, a Delaware corporation (together with its affiliates, “Coderhouse,” “we,” “us,” or “our”), collects, uses, discloses, and otherwise processes personal information about individuals located in the United States who visit www.coderhouse.com (the “Site”), use the learning platform at https://app.coderhouse.com/, enroll in our courses, subscribe to CoderPro Membership, or otherwise interact with us online (collectively, the “Services”).
This Privacy Policy forms part of, and should be read together with, our Terms and Conditions (the “Terms”). Capitalized terms not defined in this Privacy Policy have the meanings given to them in the Terms. This Privacy Policy does not apply to personal information we process about Teachers, tutors, contractors, job applicants, or employees in those capacities, which is governed by separate notices.
The Services are not offered to residents of California, Connecticut, or Texas (the “Excluded States”), as provided in the Terms, and this Privacy Policy is not directed to residents of the Excluded States.
2. Personal Information We Collect
“Personal information” means information that identifies, relates to, describes, or is reasonably capable of being associated with you or your household. It does not include de-identified or aggregated information, or publicly available information as defined by applicable law. Depending on how you interact with the Services, we collect the following categories of personal information:
Category
Examples
Sources
Identifiers and contact information
First and last name, email address, phone number, username, account ID, IP address, and device or online identifiers.
You; automatically from your device; our affiliates
Account and registration information
Password (stored in hashed form), country and state of residence, confirmation that you meet the minimum age requirement, communication preferences.
You
Commercial and transaction information
Courses and plans purchased, prices, discounts and coupons, installments, refunds, credit balances, subscription status, and billing address or ZIP code. Full payment card numbers are collected and processed directly by our payment processors; we receive only limited information such as card type, last four digits, and expiration date.
You; payment processors
Education and learning information
Cohort, attendance, content progress, quizzes, pre-submissions, Final Project and other submissions (“Student Work”), grades, feedback, ranking points, certificates, and interactions with Ticher (AI).
You; generated through your use of the platform; Teachers and Academic Staff
Audio, visual, and similar information
Profile photo; your image, voice, and chat messages when you participate in live online classes [and, if classes are recorded, the recordings]; recordings of support calls, if any.
You; videoconferencing providers
Communications and feedback
Messages sent through the chat widget or by email, survey responses, class ratings, testimonials you choose to submit, and community posts.
You
Internet and electronic network activity
Browsing and click activity on the Site and platform, pages viewed, referring URLs, time spent, device and browser type, operating system, and approximate location derived from IP address, collected through cookies, pixels, and similar technologies.
Automatically from your device; analytics and advertising partners
Professional information
[Current occupation, professional profile links, or résumé, if you provide them, for example in connection with career-related content.]
You
Inferences
Inferences about your learning preferences and interest in our products, drawn from the information above.
Generated by us
Sensitive personal information. The only sensitive personal information we collect is your account login credentials (username and password), which we use solely to provide secure access to your account. We do not request government-issued identification numbers, precise geolocation, health information, or biometric identifiers, and we ask that you do not submit such information through the Services.
3. How We Use Personal Information
We use personal information for the following purposes:
Providing the Services: creating and managing accounts; processing enrollments, payments, installments, refunds, and credit balances; delivering live and asynchronous classes; and issuing certificates.
Academic evaluation: tracking attendance and progress; grading pre-submissions and Final Projects through Ticher (AI) and Academic Staff review; conducting academic integrity checks; administering the ranking system; and maintaining academic records.
Subscriptions: administering CoderPro Membership, including automatic renewals, renewal and price-change notices, and cancellations.
Customer support and communications: responding to requests and sending transactional and service-related messages.
Marketing: sending information about our own courses, promotions, and events, subject to your choices described in Section 7, and measuring the effectiveness of our advertising.
Improving the Services: analyzing usage, developing new content and features, and improving our evaluation tools, including by using de-identified or aggregated information.
Security and fraud prevention: protecting the Services, our users, and Coderhouse; detecting and preventing fraud, payment abuse, and unauthorized account access; and verifying eligibility, including state of residence and age.
Legal and compliance purposes: complying with legal obligations, including tax and accounting requirements; enforcing the Terms; and establishing, exercising, or defending legal claims.
Other purposes disclosed to you at the time of collection or with your consent.
4. Artificial Intelligence and Automated Processing
Ticher (AI), our virtual assistance tool, processes your questions and Student Work to provide automated, guidance-oriented feedback based on course content. Pre-submissions and Final Projects are evaluated through a correction process that may combine artificial intelligence tools with review, validation, and/or supplementation by our Academic Staff. Decisions about approval of the Final Project and the issuance of certificates are not made solely by automated means, and you may request a review of any grade by our Academic Staff through the platform’s support channel, as provided in the Terms.
We do not use your conversations with Ticher (AI), or your Student Work, to train artificial intelligence models, whether our own or those of third parties. We may use third-party artificial intelligence service providers to operate Ticher (AI); these providers act solely on our behalf, and we contractually prohibit them from using your personal information, your conversations, or your Student Work to train their own models.
5. How We Disclose Personal Information
We disclose personal information to the following categories of recipients:
Affiliates: companies in the Coderhouse group, including Coderhouse S.R.L. (Argentina), which provide technology, content, academic, customer support, and administrative services on our behalf.
Service providers: vendors that process personal information on our behalf and under contractual restrictions, such as hosting and cloud providers, payment processors, videoconferencing platforms, email and messaging providers, customer relationship management and support tools, analytics providers, and artificial intelligence providers.
Teachers, tutors, and Academic Staff: to the extent necessary to deliver classes, provide feedback, and evaluate Student Work.
Other students: your name, profile photo, and contributions may be visible to other members of your cohort in live classes, chats, and community spaces[, and your position may be displayed in the Featured Ranking].
Advertising and analytics partners: third parties that place cookies, pixels, and similar technologies on the Site to measure and deliver advertising, as described in Section 6.
Legal and safety: government authorities, courts, or other parties when we believe disclosure is required by law or legal process, or necessary to protect the rights, property, or safety of Coderhouse, our users, or others.
Corporate transactions: a buyer, successor, or other party in connection with an actual or proposed merger, acquisition, financing, reorganization, or sale of all or part of our business or assets, subject to customary confidentiality protections.
With your consent or at your direction: for example, when you ask us to share your certificate with a third party.
Sales, sharing, and targeted advertising. We do not sell personal information for monetary consideration. However, our use of third-party advertising cookies and pixels may constitute a “sale” or “sharing” of personal information, or “targeted advertising,” under certain state laws. The table below describes the categories of personal information we disclosed in the preceding twelve (12) months:
Category
Disclosed for a business purpose to
Sold, shared, or used for targeted advertising
Identifiers and contact information
Affiliates; service providers; Teachers and Academic Staff; legal and safety recipients
Yes (online identifiers, to advertising partners)
Account and registration information
Affiliates; service providers
No
Commercial and transaction information
Affiliates; service providers (including payment processors)
No
Education and learning information
Affiliates; service providers; Teachers and Academic Staff
No
Audio, visual, and similar information
Affiliates; service providers; Teachers; other students in your cohort
No
Communications and feedback
Affiliates; service providers
No
Internet and electronic network activity
Affiliates; service providers; analytics providers
Yes (to advertising partners)
Professional information
Affiliates; service providers
No
Inferences
Affiliates; service providers
No
Sensitive personal information (login credentials)
Service providers, solely to provide secure access
No
We do not sell or share personal information, or use it for targeted advertising, when we have actual knowledge that the individual is under sixteen (16) years of age. We do not use or disclose sensitive personal information for purposes other than those permitted by applicable law without your consent.
6. Cookies and Similar Technologies
We and our partners use cookies, pixels, software development kits, and similar technologies to operate the Services, remember your preferences, analyze usage, and deliver and measure advertising. These technologies fall into the following types: (a) strictly necessary, required for the Site and platform to function, including authentication and security; (b) functional, which remember your choices; (c) analytics, which help us understand how the Services are used; and (d) advertising, which allow us and our partners to show you relevant Coderhouse advertising on other sites and measure its effectiveness. [A current list of the cookies and third-party technologies we use is available in our cookie preference center.]
Your choices. You can manage non-essential cookies through the “Your Privacy Choices” link on the Site and through your browser settings. Blocking some cookies may affect the functionality of the Services. You may also opt out of interest-based advertising from participating companies at www.aboutads.info/choices and www.networkadvertising.org/choices.
Opt-out preference signals. We treat a Global Privacy Control (GPC) signal sent by your browser as a valid request to opt out of the sale and sharing of your personal information and of targeted advertising for that browser and, if you are logged in, for your account. Do Not Track: because there is no common industry standard for “Do Not Track” signals, we do not respond to them, except to the extent that we honor GPC signals as described above.
7. Your Choices About Communications
Email marketing: you may unsubscribe at any time by using the link included in each marketing email or by updating your preferences in your account. We will continue to send you transactional and service-related messages, such as enrollment confirmations, class reminders, and subscription notices.
Text messages: we send marketing text messages only with your prior express written consent, which is not a condition of any purchase. You may opt out at any time by replying STOP. Message and data rates may apply.
Account information: you may review and update certain account information at any time through your account settings on the platform.
8. Your Privacy Rights
Depending on your state of residence, you may have some or all of the following rights with respect to your personal information, subject to exceptions under applicable law:
Access / right to know: to confirm whether we process your personal information and to obtain information about, and a copy of, the personal information we hold about you.
Correction: to correct inaccurate personal information.
Deletion: to request deletion of personal information we have collected from or about you.
Portability: to obtain your personal information in a portable and, to the extent technically feasible, readily usable format.
Opt out: of the sale or sharing of your personal information, of targeted advertising, and of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
List of third parties: where provided by applicable law, to obtain a list of the specific third parties to which we have disclosed personal information.
Non-discrimination: we will not discriminate against you for exercising any of these rights.
Although not all state privacy laws apply to Coderhouse, we will honor the requests described above from residents of any U.S. state in which the Services are offered, subject to verification and to the exceptions available under applicable law.
How to Submit a Request
You may submit a request by: (a) completing our online form by emailing [email protected]; (b) using the “Your Privacy Choices” link on the Site (for opt-out requests); or (c) emailing us at [email protected]. Please include your name, the email address associated with your account, your state of residence, and the right you wish to exercise.
Verification. To protect your personal information, we will verify your identity before responding to requests to access, correct, or delete information, generally by matching information you provide with information in our records and, where you have an account, by requiring you to log in or to confirm the request from the email address associated with your account. Opt-out requests do not require verification, but we may deny a request we reasonably believe is fraudulent.
Authorized agents. Where permitted by applicable law, you may designate an authorized agent to submit a request on your behalf. We may require the agent to provide written, signed permission from you and may require you to verify your identity directly with us.
Response timing. We will respond to verified requests within forty-five (45) days of receipt. Where reasonably necessary, we may extend this period by an additional forty-five (45) days, in which case we will notify you of the extension and the reason for it.
Appeals. If we decline to take action on your request, you may appeal our decision by emailing [email protected] with the subject line “Privacy Request Appeal” within a reasonable period after receiving our response. We will inform you in writing of any action taken or not taken in response to your appeal, and the reasons for our decision, within the period required by applicable law. If your appeal is denied, you may contact the Attorney General of your state of residence.
9. Data Retention
We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to provide the Services, comply with our legal, tax, and accounting obligations, resolve disputes, and enforce our agreements. The criteria we use include the nature of the information, the duration of your relationship with us, and applicable legal requirements. Our general retention periods are:
Category of information
Retention period
Account and registration information
While your account is active and for three (3) years after your last activity, unless you request earlier deletion.
Commercial and transaction information
Seven (7) years after the relevant transaction, to meet tax and accounting requirements.
Grades, attendance, and certificates
Ten (10) years after the end of the course, to allow verification of certificates and academic records.
Student Work and Ticher (AI) interactions
Two (2) years after the end of the course.
Class recordings, if any
Twelve (12) months after the end of the cohort.
Communications and support records
Three (3) years after the last interaction.
Marketing preferences and opt-out records
For as long as necessary to honor your choices.
Cookie and analytics data
Up to thirteen (13) months, unless a shorter period is set by the relevant technology.
When we no longer need personal information, we delete or de-identify it. We may retain information for longer periods where required by law or needed to establish, exercise, or defend legal claims.
10. Data Security
We implement reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, and destruction, including encryption in transit, access controls, and contractual obligations for our service providers. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your password confidential. If we become aware of a security breach affecting your personal information, we will notify you and the relevant authorities as required by applicable law.
11. International Data Transfers
Coderhouse is based in the United States and operates through affiliates in other countries. Your personal information may be transferred to, processed, and stored in the United States, Argentina, [Brazil, Mexico,] and other countries where our affiliates and service providers operate. The data protection laws of those countries may differ from those of your state of residence. When we transfer personal information, we take steps designed to ensure that it receives an appropriate level of protection, including contractual commitments with our affiliates and service providers.
12. Children and Minors
The Services are intended for individuals who are at least eighteen (18) years of age, or the age of majority in their state of residence if higher. We do not knowingly collect personal information from children under the age of thirteen (13), and we do not accept the enrollment of minors. If we learn that we have collected personal information from a child under thirteen (13), or from a minor in violation of the Terms, we will delete it. If you believe that we may have collected such information, please contact us at [email protected].
13. Third-Party Sites and Services
The Services may contain links to, or integrations with, third-party websites and services, such as videoconferencing platforms, payment processors, and social media networks. This Privacy Policy does not apply to those third parties, whose privacy practices are governed by their own policies. Information you post in public or shared areas of the Services, such as community spaces or class chats, may be viewed by other users.
14. Nevada Residents
We do not sell covered information, as defined under Chapter 603A of the Nevada Revised Statutes. Nevada residents may nevertheless submit a request to opt out of any future sale by contacting us at [email protected].
15. Accessibility
We are committed to making this Privacy Policy accessible to individuals with disabilities. To request this Privacy Policy in an alternative format, please contact us at [email protected].
16. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. We will post the updated version on the Site with a new “Last Updated” date and, if we make material changes, we will notify registered users by email or through the platform before the changes take effect. Where required by applicable law, we will obtain your consent before using previously collected personal information in a materially different manner than disclosed at the time of collection.
17. Contact Us
If you have questions about this Privacy Policy or our privacy practices, please contact us at:
Coder Holding Corporation — Attn: Privacy c/o Harvard Business Services, Inc., 16192 Coastal Highway, Lewes, Delaware 19958, USA Email: [email protected]
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