CodeSignal Privacy Policy

Last Updated October 9, 2020

BrainFights, Inc., a Delaware corporation doing business as CodeSignal, (“BrainFights”, “CodeSignal” or “we”) is committed to protecting your privacy. This Privacy Policy spells out how CodeSignal collects, secures, uses and discloses personal information about you, and how you can exercise your privacy rights. This Privacy Policy applies to the skills assessment platform services at app.codesignal.com (the “Services”) and the website at www.codesignal.com (the “Website”) which are owned and operated by CodeSignal. For purposes of this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual (e.g., name, email address, or phone number).

Remember that your use of our Services is at all times subject to the Terms of Use and the Master Subscription Agreement, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use or the Master Subscription Agreement. Note that the data controller of Personal Information collected through our Services is the CodeSignal customer who has purchased out Services and the data controller of Personal Information collected through our website is CodeSignal.

If you have any questions or concerns about our use of your Personal Information, please contact us at using the contact details provided below.

Services Privacy Policy

For the avoidance of doubt, this Services Privacy Policy does not apply to our customers, who manage the Personal Information they collect through our Services in accordance with their own privacy policies. CodeSignal processes the Personal Information that is stored in our Services as a data processor on behalf of our customers and in accordance with their instructions (as defined in our customer agreements). For example, if you are invited to take an assessment by a prospective employer that is one of our customers, your Personal Information will be automatically transferred to CodeSignal. However, the prospective employer is the data controller and you should contact that entity directly with any questions you may have regarding its privacy policies or data processing practices, and if you want to modify your Personal Information, restrict its processing, or delete it from our Services.

What information does CodeSignal collect or process?

CodeSignal processes certain Personal Information input or uploaded into our Services by our customers’ employees, customers’ authorized agency members, and prospective employees, including name and email address.

CodeSignal will use such Personal Information only as necessary to provide and deliver the Services to the customer, to prevent or address any service or technical issues, to respond to a customer’s support request, or for any other purpose provided for in the customer agreement, or in accordance with or as may be required by law.

CodeSignal collects Personal Information you voluntarily provide to CodeSignal (including CodeSignal’s service providers or other parties who collect it on CodeSignal’s behalf). For example, we collect Personal Information such as your name, email address, and third-party account credentials (such as your log-in credentials for Google or other third-party sites) when you register to use CodeSignal Services.

How does CodeSignal secure my information?

We take appropriate steps including technical and organizational measures to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Information, and to protect its loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Such measures include but not limited to:

  • the pseudonymization and encryption of Personal Information;
  • the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
  • the ability to restore the availability and access to Personal Information in a timely manner in the event of a physical or technical incident;
  • a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

How does CodeSignal use my personal information?

CodeSignal may access or use the Personal Information collected through the Services for a range of reasons, which may include:

  • To provide, operate, maintain and improve the Services;
  • To handle customer questions and support requests;
  • To manage CodeSignal’s platform, system administration and security;
  • To aggregate data about the usage of the Service to analyze trends and optimize customers’ experience;
  • To communicate directly with you, including sending technical alerts, reports, updates, security notifications and other Service-related communications;
  • To carry out research and development to improve our products and services;
  • To investigate and prevent fraud, unauthorized access or use of Services, breaches of terms and policies, and other wrongful behavior;
  • To carry out other legitimate business purposes, as well as other lawful purposes about which CodeSignal will notify you.

Will CodeSignal ever disclose my information?

We do not sell or otherwise disclose Personal Information we collect or process in our Services, except as described in this Services Privacy Policy or as we disclose to you at the time this information is collected. As described in more detail below, we may disclose your Personal Information:

  • with our customers who specifically invited you to be a part of their skills assessment processes. For example, if you are invited to take an assessment by a prospective employer that is one of our customers, your Personal Information can be shared with the particular customer of ours to ensure that they can match your result to your application. You may also directly manage the sharing preference of your certified assessment results at any time by updating the settings.
  • with our contracted service providers or third-party data sub-processors. We authorize these sub-processors to use the information only as necessary to assist CodeSignal in providing the Services (for example, to provide system administration and hosting services, support ticketing, or to help to enhance security). We require these sub-processors by contract to safeguard the privacy and security of any Personal Information that they process on our behalf;
  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, provided that we inform such third parties that they must use your Personal Information only for the purposes disclosed in this Services Privacy Policy; and
  • to any other person with your consent to do so.

Our customers may choose to integrate their CodeSignal accounts with other third party service providers.  While we try to choose integration partners that share our standards for privacy, their websites and services are outside of our control and are not covered by this Services Privacy Policy, and we are not responsible for their content, security, or privacy practices.

How long does CodeSignal retain my personal information?

We retain Personal Information we collect or process where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

Any Personal Information we process on behalf of our customers is retained in accordance with the timeframes set out in the relevant customer agreements.

What are my data protection rights?

You have the following data protection rights:

  • Right to withdraw consent. For any consent-based processing of your Personal Data, you have the right to withdraw your consent. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.
  • Right to rectification.  You may request to correct any of your Personal Data in our files.
  • Right to erasure.  In certain circumstances, you may have a right to the erasure of your Personal Data that we hold on you.
  • Right to restriction. You have the right to request that we restrict our processing of your Personal Data win certain circumstances.
  • Right to object to processing. You have the right to object to our processing at any time and as permitted by applicable law if we process your Personal Data on the legal bases of: consent; contract; or legitimate interests. We may continue to process your Personal Data if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
  • Right to lodge complaint. We commit to resolve complaints about our collection or use of your Personal Data. European Union and Swiss individuals with inquiries or complaints regarding our privacy policy should first contact CodeSignal at [email protected].

Please note that you should direct any requests related to the data protection rights described above to the CodeSignal customer who holds the relevant CodeSignal account. As a data processor of any Personal Information stored and processed on the Services, CodeSignal will not be able to respond directly to such requests and will refer any such requests to the relevant Customer.

Website Privacy Policy

What information does CodeSignal collect?

CodeSignal may collect the following information, including Personal Information from and about you:

From your interaction with Sales & Marketing: We receive and store any information you knowingly provide to us. For example, we collect Personal Information such as your name, company name, email address, and phone number when you request a demo of our Services or request sales information.

Cookies, Scripts and Related Technologies: When you visit our website, www.codesignal.com, we and our third-party service providers receive and record Personal Information that you may have provided and your digital signature, such as your IP address. The technologies we use to track your movements around our website include cookies, tracking scripts and pixels, and tagging technologies, which we may employ to understand your preferences, improve your experience on our website, etc. You can control the use of cookies at the individual browser level. If you want to learn more about cookies, or how to control, disable, or delete them, please visit http://www.aboutcookies.org for detailed guidance.

Collection of Data by Advertisers:  We may also use third parties to serve ads on our website or to manage our advertising on other sites.  Certain third-party partners may automatically collect information about your visits to this and other websites, your IP address, your ISP, the browser you use to visit our website (but not your name, address, e-mail address or telephone number).  They do this by using cookies, pixel tags or other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our website and the other sites tracked by these third parties.  This policy does not apply to, and we are not responsible for, cookies or pixel tags in third party ads, and we encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technologies. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here: http://www.aboutads.info/choices or http://www.networkadvertising.org.

How does CodeSignal secure my information?

We take appropriate steps including technical and organizational measures to ensure that your Personal Information is treated securely and in accordance with this Website Privacy Policy.  The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Information.

How does CodeSignal use my personal information?

We may use the information that we collect about you and from you, including Personal Information, for the following purposes:

  • To customize our website: We seek to improve your experience with our website.  As a result, we will analyze data we collect about your use of the website.
  • To communicate with you: If you request more information about our products, we will contact you using the information you provide us. We may also send you information about products and services that may be of interest to you, with your prior opt-in consent where required by applicable law.
  • To aggregate data:  We may anonymize and aggregate data collected through our website and to create statistics that may be used for any purpose, provided that such statistics do not identify any customers or individuals or contain any Personal Information. 

Will CodeSignal ever disclose my information?

We do not sell or otherwise disclose Personal Information we collect about you, except as described in this Website Privacy Policy or as we disclose to you at the time this information is collected. As described in more detail below, we may disclose your Personal Information:

  • with our partners and third-party service providers. We authorize these service providers to use or disclose the information only as necessary to perform services on behalf of CodeSignal (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website). We require these service providers by contract to safeguard the privacy and security of Personal Information that they process on our behalf;
  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, provided that we inform such third parties that they must use your Personal Information only for the purposes disclosed in this Website Privacy Policy; and
  • to any other person with your consent to the disclosure.

Our website may contain links to third-party websites or third-party applications (“apps”).  When you click on a link to any other website, app or location, you will leave our website and go to another site and another entity may collect Personal Information or anonymized data from you.  We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Website Privacy Policy do not apply to these outside websites, apps or content, or to any collection of your Personal Information after you click on links to such outside websites or apps.  We encourage you to read the privacy policies of every website you visit or app you use. The links to third party websites, apps or locations are for your convenience and do not signify our endorsement of such third parties or their products, apps, content or websites.

How long does CodeSignal retain my personal information?

We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

What are my data protection rights?

You have the following data protection rights:

  • Right to withdraw consent. For any consent-based processing of your Personal Data, you have the right to withdraw your consent. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.
  • Right to rectification.  You may request to correct any of your Personal Data in our files.
  • Right to erasure.  In certain circumstances, you may have a right to the erasure of your Personal Data that we hold on you.
  • Right to restriction. You have the right to request that we restrict our processing of your Personal Data in certain circumstances.
  • Right to object to processing. You have the right to object to our processing at any time and as permitted by applicable law if we process your Personal Data on the legal bases of: consent; contract; or legitimate interests. We may continue to process your Personal Data if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
  • Right to lodge complaint. We commit to resolve complaints about our collection or use of your Personal Data.  European Union and Swiss individuals with inquiries or complaints regarding our privacy policy should first contact BrainFights at [email protected].

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Children’s Privacy

As noted in the Terms of Use, we do not knowingly collect or solicit personal information from anyone under the age of 13 without parental consent, and no part of our website is directed to children under the age of 13. If you are under 13, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible and terminate the related account. If you believe that a child under 13 may have provided us personal information, please contact us at [email protected].

California Privacy Rights

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights concerning their personal information held by CodeSignal as described below.

Right to Know About Personal Information

You have the right to request that we disclose the specific pieces of personal information we have collected about you over the past 12 months as well as categories of third parties we have shared it with. You may submit a consumer request to know this information by emailing [email protected]In order to verify your request, we will ask you to provide your name, email address, and certain other pieces of identifying information. Once you have submitted this information and any necessary supporting documentation, we will confirm the information by reviewing it against our records.

Right to Request Deletion of Personal Information

You have the right to request the deletion of your personal information that we have collected about you. You may submit a consumer request to delete this information by emailing us at [email protected]In order to verify your request, we will ask you to provide your name, email address, and certain other pieces of identifying information. Once you have submitted this information and any necessary supporting documentation, we will confirm the information by reviewing it against our internal records and/or third-party databases.

Right to Non-Discrimination 

We do not and will not discriminate against you for exercising your privacy rights as granted by the CCPA. We do not sell personal information of any consumer including personal information of minors under 16 years of age.

Changes to Our Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on the app.codesignal.com page, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

Contact Information

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to [email protected] or at the mailing address below, and we will try to resolve your concerns.

CodeSignal
Attn: Data Protection Officer
201 California Street, Suite 1240
San Francisco, CA 94111