Last Updated: April 20, 2020
The privacy of your data — and it is your data, not ours! — is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights to your data. We promise we never sell your data: never have, never will.
This policy applies to all products built and maintained by Code Rubik inc. That includes Polls for Pages, Surveys for Pages, Contests for Pages, Quizzes for Pages and their derivatives in other languages.
Promoters & participants
Two types of users may interact with the App: promoters and participants.
Promoters create and manage polls, quizzes and contests, gather answers or entries from participants and have control on such answers or entries.
Participants provide promoters with answers or entries for particular polls, quizzes or contests.
Promoters may collect personal information through the App. They commit to using personal information in accordance with applicable laws and regulations but we do not monitor promoters’ practices and take no responsibility for any use or disclosure of personal information by promoters.
Promoters may use personal information provided by participants in accordance with their own policies. As a participant, you should review any such available policy before submitting personal information using the App.
Promoters may offer polls, quizzes or contests without disclosing their identities. Participants should be aware that any personal information they provide through the App may be collected, exported and retained by promoters, even after a promoter’s account is deleted.
We do not monitor the use of personal information gathered through the App by promoters or third-parties. If you provide personal information to a promoter through the App, you do so at your own risk, we disclaim all responsibility for any personal information use or disclosure performed by a promoter or third-party.
Our role with respect to any such personal information collected is limited to holding said information for its use by promoters.
What we collect and why
Our guiding principle is to collect only what we need. Here’s what that means in practice:
Identity & access
When you sign up for one of our apps, we ask for your permission to fetch your name, profile picture and email address from your Facebook account. That's just so you can personalize your new account, and we can send you invoices, updates, or other essential information. We’ll never sell your personal info to third parties, and we won’t use your name or company in marketing statements without your permission, either.
When you pay for a Code Rubik app, we ask for your credit card and billing address. That's so we can charge you for service, calculate taxes due, and send you invoices. Your credit card is passed directly to our payment processor and doesn't ever go through our servers. We store a record of the payment transaction, including the last 4 digits of the credit card number and as-of billing address, for account history, invoicing, and billing support. We store your billing address to calculate any sales tax due in Canada, to detect fraudulent credit card transactions, and to print on your invoices.
We log all access to all accounts by full IP address so that we can always verify no unauthorized access has happened. We keep this login data for as long as your product account is active.
When you browse our website or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes like conversion rates and to test new designs. We sometimes track specific link clicks to help inform some design decisions. These web analytics data are tied to your IP address and user account if applicable and you are signed into our Services.
We do use persistent cookies to store certain preferences, make it easier for you to use our applications, and support some analytics. A cookie is a piece of text stored by your browser to help it remember your login information, site preferences, and more. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to see which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org.
When you write Code Rubik with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future.
When we access or share your information
Our default practice is to not access your information. The only times we’ll ever access or share your info are:
- To provide products or services you've requested. We do use some third-party services to run our applications and only to the extent necessary process some or all of your personal information via these third parties. You can see the list of third-party services we use in our apps. Having subprocessors means we are using technology to access your data. No human looks at your data for these purposes.
- To assist you with a question or support request. If you contact us and need help with your account, we might access it to help you resolve the issue.
- To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We have an obligation to protect the privacy and safety of both our customers and the people reporting issues to us. We do our best to balance those responsibilities throughout the process. If we do discover you are using our products for a restricted purpose, we will report the incident to the appropriate authorities.
- When required under applicable law. If the appropriate law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring we share data, we have to comply. Otherwise, we flat-out reject requests from local and federal law enforcement when they seek data. And unless we’re legally prevented from it, we’ll always inform you when such requests are made.
Your Rights With Respect to Your Information
At Code Rubik, we apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US. Code Rubik recognizes all of the rights granted in these regulations, except as limited by applicable law. These rights include:
- Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
- Right to Correction. You have the right to request correction of your personal information.
- Right to Erasure / “To be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, all of our service providers. Fulfillment of some data deletion requests may prevent you from using the service because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
- Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority. To identify your specific authority or find out more about this right, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en.
- Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: we never have and never will sell your personal data).
- Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
- Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
- Right to not be subject to Automated Decision-Making. You have the right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
- Right to Non-Discrimination. This right stems from the CCPA. We do and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights (such as the right “to be forgotten”) may, by virtue of your exercising those rights, prevent you from using our Services.
Many of these rights can be exercised by signing in and directly updating your account information. If you have questions about exercising these rights or need assistance, please contact us at firstname.lastname@example.org. To identify your specific authority to file a complaint or find out more about GDPR, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en.
How we secure your data
All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted. Most data are not encrypted while they live in our database (since it needs to be ready to send to you when you need it), but we go to great lengths to secure your data at rest.
Inactive and deleted data
In all of our applications, we give you the option to delete polls, contests and quizzes. You can also delete your account and all personal information from the Account page. The deleted data is kept in the database for up to 30 days. After that, the data is purged and permanently deleted.
If you delete your account, all the content you created and collected with the account is deleted as well. After a grace period of 30 days, all the data is permanently deleted.
We permanently delete all accounts and associated data that are on the free plan and have been inactive for 4 years or more.
Polls, contests or quizzes that have not been updated for 3 years ore more are automatically be closed. They can be re-opened at any time.
Location of Site and Data
Our products and web properties are hosted in the United States. If you are located in the European Union or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using our Site, participating in any of our services and/or providing us with your information, you consent to this transfer.
Changes & questions
We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will also announce them on our blog.