Updated January 1, 2025

Welcome to our website. This Privacy Statement describes the types of information that Social Code, LLC dba Code3 (“we” or “us”) collects from and about you on www.Code3.com (the “Site”).

The Site provides information about our company and our software, mobile applications and related services and collects minimal information about Site visitors. This Privacy Statement is for informational purposes only and describes how we generally collect and use information. When you interact with us through the Site, we may collect information from you, as further described below.

Code3 provides various data analytics and marketing services to corporate customers (our “Customers”) and is generally a processor, and not a controller, of personal information. To the extent one of our Customers discloses Personal Information of California consumers or households to Code3, Code3 may be considered a “service provider” under California law. Code3 does not intentionally collect identifiable personal information directly from website visitors.

Your privacy is important to us. This Privacy Statement sets forth our policy with respect to the collection, use and disclosure of information that is collected on our Site. By using the Site, you agree to the data collection, use, disclosure and storage practices described in this Privacy Statement.

We collect information about you in a range of forms, including personal information, when you choose to provide it to us. Personal information (or personal data) means information about an individual from which that person can be identified. It does not include personal information where the identity has been removed (anonymous personal information). This may include when you contact us with inquiries or otherwise contact us. We do not collect personal information directly from individual consumers.

If you are visiting this Site on behalf of one of our Customers, please see the “Authorized Users” section below.

CODE3 DOES NOT SELL YOUR INFORMATION TO THIRD PARTIES

Information You Provide to Us

We do not intentionally collect personal information from visitors to the Site. If you use a third party service to link to us or communicate with us (such as a social network or third party video chat), we may receive certain information about you from the third party based on your registration and privacy settings on those third party services.

Information Collected From Other Sources

We may obtain information about you from other sources, including social networks that you use to connect with us. This information may include name, user name, demographic information, updated address or contact information, interests, and publicly-observed data, such as from social media and online activity.

Information Obtained from Third Parties

If we receive personal information about you from or on behalf of our Customers, we will only use that information for the specific reason for which it was provided to us.

Information Use

We may use the information we collect from and about you on our Site to:

  • Assess the needs of your business to determine suitable products;
  • Send you requested product or service information;
  • Respond to customer service requests;
  • (With your consent), send you a newsletter and marketing communications;
  • Respond to your questions and concerns;
  • Improve the content and functionality of our Web site and marketing efforts;
  • Conduct research and analysis;
  • Display content based upon your interests;
  • Comply with applicable laws, including to respond to requests from public and government authorities;
  • Enforce this Privacy Statement;
  • Protect our rights, privacy, safety or property, and/or that of you or others.
  • Develop new programs, products or services
  • Protect the security or integrity of the Services and our business; and
  • As described to you at the point of data collection or in our Agreement with our Customer.

Information Sharing

We may share the information we collect from and about you:

  1. with third parties that we believe may provide promotional materials, and goods and services that may be of interest to you;
  2. with our Service Providers, if the disclosure will enable them to perform a business, professional or technical support function for us, including as part of our agreement with our Customers;
  3. as necessary if we believe that there has been a violation of this Privacy Statement, our Terms of Use [link], of our rights or the rights of any third party;
  4. when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
  5. to respond to judicial process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, national security or law enforcement, as permitted by law, or otherwise as required by law; and
  6. as described to you at the point of collection or in our Agreement with a Customer.

If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Information We Automatically Collect and cookie policy

As is true of most web sites, we automatically gather information about your computer such as your IP address, browser type, referring/exit pages, and operating system.

We may use cookies, web beacons, pixel tags, log files, or other technologies to automatically collect certain information when you use our Services or interact with our emails and online or mobile advertisements. For example, we may automatically collect certain non-personal information from you such as your mobile device identifier or MAC address, browser type, operating system, device model, software version, Internet Protocol (“IP”) address, mobile or ISP carrier information, and the domain name from which you accessed the Services. We also may collect information about your use of the Services including the date and time you access the Services, the areas or pages of the Services that you visit, the amount of time you spend using the Services, the number of times you return, whether you open forward or click-through emails and ads, and other usage data.

We may also use third-party tools or services, such as Google Analytics, to assist us with analyzing and improving the Site. These third parties are not permitted to use the information collected on our behalf except to help use conduct and improve our business.

As a service provider, we may use certain tracking technologies to assist our Customers in collecting information about your online activities and across third-party websites or other online services (behavioral tracking). Specific inquiries about online advertisements, including on social media, should be directed at our Customers.

7. Tracking Options and California Do Not Track Disclosures. You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Services or take full advantage of all of our offerings. Check the “Help” menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences. To learn more about the use of cookies or other technologies to deliver more relevant advertising and your choices about not having this information used by certain Service Providers (defined below), please click here. On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising. Note that our systems may not recognize Do Not Track headers or requests from some or all browsers.

8. Combination of Information

We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Site, as well as information collected offline or from third party sources to help us tailor our communications to you and to improve our services.

We do not sell your personal information to third parties.

9. We may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through the Services in a manner that is consistent with this Privacy Statement.

10. If you do not want us to share your personal information as set forth in this Privacy Statement, contact us at privacy@Code3.com.

Third Parties

We may contract with third parties to perform functions related to the Site and services we provide to our Customers. These third parties will have access to your personal information needed to perform their business functions, but may not use or share that personal information for other purposes. These companies are authorized to use your personal information only as necessary to provide these services to us and/or to support the services we provide to our Customers.

CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS

Graham Holdings Company and its affiliates (“the Company”) respect the privacy of your personal information and take our related compliance and regulatory obligations seriously. This California Privacy Statement (“Statement”) describes the categories and uses of the Personal Information (as defined below) of Company employees, independent contractors and job applicants who reside in California (collectively “California Workers”) as required by the California Consumer Privacy Act (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”). The term “California Workers” includes current and former job applicants, independent contractors, temporary staff, interns, company officers, directors, emergency contacts, and benefits recipients in addition to employees solely for the purpose of this Statement.

The Company receives Personal Information, including Sensitive Personal Information, from and about you during the course of interviewing, hiring and employing or engaging you. We also may collect Personal Information about your related family members, dependents and beneficiaries in connection with benefits processing or obtaining emergency contacts. “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

The Company collects, uses, and discloses this sensitive personal information only as necessary to perform the services reasonably expected by an employee, and for business purposes permissible for sensitive personal information under the CCPA and CPRA.

The Company does not sell or share California Workers’ Personal Information, including Sensitive Personal Information, including that of individuals under age 16.

Categories of Personal Information Collected

(Some information may overlap categories)

Examples

Identifiers.

 A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, photograph, or other similar identifiers.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

 A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, or other financial information, medical information, or health insurance information.
Protected classification characteristics under California or federal law Age (40 years or older), race, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.
Internet or other similar network activity Email sent or received on the Company network or on your Company computer, browsing history, search history, and information on your interaction with a website, application, or advertisement while operating on the Company network, IT systems access data, including data about the use of Company equipment, electronic communications systems, and property, such as computers.
Geolocation data Internet protocol address, which may indicate general location.
Sensory data Photos, videos, voicemail, and meeting recordings
Professional or employment-related information Job title, business site, supervisor, work schedule and status, compensation information, benefit information, training and development information, employment duration, current or past job history or performance evaluations, certification information, special competencies or work accomplishments and other relevant information, education history, professional licensing, information regarding financial conflicts of interests, information about conduct or investigations, if any.
Inferences drawn from other personal information Profile reflecting a person’s preferences, characteristics, predispositions, behavior, attitudes, and aptitudes.
Sensitive Information Social Security Number, driver’s license number, state identification card number, or passport number; racial or ethnic origin; religious or philosophical beliefs; personal information collected and analyzed concerning the California Worker’s health; sex life or sexual orientation.

 

Purposes for Processing Your Personal Information

The processing of your Personal Information enables the Company to perform its role as an employer and/or for the purposes of engaging you, including fulfilling its legal obligations under applicable laws and as necessary in connection with the Company’s performance of its employment and/or other worker obligations. Without this information, it would not be possible for the Company to manage the workforce and meet applicable legal obligations. The Company processes certain Personal Information for its business interests, including, but not limited to, the following:

  1. applicant recruiting and employee on-boarding;
  2. payroll administration and independent contractor payment processing;
  3. pension administration;
  4. health administration and health insurance benefits;
  5. life insurance benefits and other benefits, such as online legal services
  6. expense reimbursement and management;
  7. contacting others in the event of an emergency;
  8. making information available on the intranet and to facilitate communication between and among the Company workforce;
  9. administration and management of your access to information technology systems;
  10. time entry and leave management;
  11. training, appraisal, and development, such as personality and aptitude tests (e.g., DiSC and Strengths Finder), performance records and disciplinary records;
  12. employee and staff surveys;
  13. equal opportunities monitoring;
  14. any Company benefit administration, including equity-related plans and benefits;
  15. conducting security screenings and managing personnel security and safety;
  16. performing internal reporting functions and complying with corporate financial responsibilities;
  17. for public relations purposes and in connection with the performance of your duties (e.g., the Company may send your contact information to customers and potential customers as part of the sales process so they can contact you); and
  18. to comply with applicable laws and legal obligations, including without limitation:

 

    • to maintain the ethics hotline;
    • to respond to governmental inquiries or requests from public authorities;
    • to comply with valid legal process or discovery obligations;
    • to protect the rights, privacy, safety or property of the Company, its workers or the public if such a disclosure is proportionate in the individual case;
    • to permit the Company to pursue available remedies or limit the damages that the Company may sustain;
    • to respond to an emergency; and/or
    • to comply with applicable regulations, policies and procedures.

19. and to fulfill or meet the reason for which the Personal Information is provided.

In some cases, The Company uses the services of suppliers (e.g., benefits providers). As a result, your personal information will be provided to suppliers engaged by The Company that need access to it to provide the services for which they have been engaged.

We disclose the personal information to the following categories of persons:

  • Service providers and contractors that process personal information on our behalf pursuant to a written contract.
  • To law enforcement and other third parties to address legal obligations.
  • To third parties at your direction to fulfill requests by you or with your consent.
  • To third parties in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition.

We retain each category of personal information, including sensitive personal information, in accordance with our Graham Holdings Company Records Retention Policy for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to administer benefit plans, comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

Your Rights

The CPRA provides California residents with specific rights regarding their personal information. This section describes those rights. We do not discriminate against California Workers who exercise any of their rights described in this Privacy Notice.

Request to Access Your Personal Information (Right to Know)

You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your personal information over the past 12 months.

As part of our verification process of your request we ensure reasonable measures are in place to detect fraudulent requests and prevent unauthorized access to your personal information. We are required to verify your identity, and the identity of your authorized agent, if the request is submitted via an agent by associating the information provided in the request to any personal information previously collected by us or use a third-party identity verification service.

Once we confirm your verifiable request, we will disclose to you, consistent with your request:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • Specific pieces of personal information we collected about you, if requested.

Requests to Delete Your Personal Information (Right to Request Deletion)

You have the right to request that we delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless doing so violates federal or state law, or prevents us from providing obligatory services to you.

If we deny your deletion request, we will notify you in writing of the reason.

Requests to Correct Your Personal Information (Right to Request Correction)

You have the right to request that we correct any of your personal information that we have collected from you. If you have an active account, you may be asked to “self-serve” the request. Otherwise, once we receive and confirm your verifiable request, we will correct (and direct our service providers to correct) your personal information in our records.

Submitting a Request

To exercise the rights described above, you can contact us by submitting your request to your HR department or through the California Privacy Policy contact methods for your business.

Only you or your authorized agent may make a verifiable request related to your personal information. If you use an authorized agent to submit a request on your behalf, we may require that you (1) provide the authorized agent written permission to do so, and (2) provide a copy of the authorization or provide a copy of a power of attorney that complies with California Probate Code sections 4000 to 4465 so that we can verify the identity of the authorized agent.

In verifying requests, we employ reasonable measures to detect fraudulent requests and prevent unauthorized access to your personal information. To meet our obligations, we are required to verify your identity, and the identity of your authorized agent, if the request is submitted via an agent, by associating the information provided in your request to personal information previously collected by us.

If we suspect fraudulent or malicious activity on or from the password-protected account, we may decline a request or request that you provide further verifying information.

You may only make a verifiable request twice within a 12-month period. The verifiable request must:

  • Provide sufficient information that allows us to verify you are the person about whom we collected personal information and, if applicable, provide necessary documentation about your authorized agent.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Responding to Requests

Upon receiving your request to know or a request to delete, we will process your request or notify you if the request requires an extension or will be denied. If we only comply with your response in part, we will explain the reasons why. We attempt to process requests within 45 days after receipt. If we require additional time beyond 45 days, we will inform you of the reason and the extension period.

If you have any questions about this Privacy Policy or our information-handling practices, please contact us by email as follows: privacy@ghco.com.