Privacy policy

This Privacy Policy applies to the websites https://kodjin.com/ and https://edenlab.io/.

EDENLAB OÜ (“we,” “us,” or “our”) is a custom software development company that provides you with access to and use of these websites https://kodjin.com/, https://edenlab.io/, their Services, Products, and Solutions.

This Privacy Policy describes how and why we might collect, store, use, and/or share (“process”) your information when you use our websites, Services, Products, and Solutions, such as when you:

• Visit our websites at https://kodjin.com/, https://edenlab.io/, or any website of ours that links to this Privacy Policy.
• Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you disagree with our policies and practices, please do not access or use our websites.

Summary of Key Points

This summary provides key points from our Privacy Policy, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for. You can also click here to go directly to our table of contents.
What personal information do we process? When you visit, use, or navigate our websites, we may process personal information depending on how you interact with us and our Services, Products, and Solutions.

Do we process any sensitive personal information?

We do not process sensitive personal information.

Do we receive any information from third parties?

Some information, such as your browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, and other technical information we receive from third parties, such as analytics tools. We don’t disclose or sell this information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our websites, and other technical information.

How do we process your information?

We process your information to provide, improve, and administer our Products, Services, and Solutions, communicate with you for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

What are your rights?

Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

1. What information do we collect?

The personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our Products, Services, and Solutions (such as your name, email address, and company name) when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information we collect depends on the context of your interactions with us, your choices, and the products and features you use. The personal information we collect may include the following:

• Name
• Email address
• Company name

Sensitive Information. We do not process sensitive information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our websites.

We automatically collect certain information when you visit, use, or navigate our websites, using our Products, Services, and Solutions. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our websites, and other technical information. This information is primarily needed to maintain the security and operation of our websites and for our internal analytics and reporting purposes.
We also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy: https://kodjin.com/cookie-policy/.

The information we collect includes the following:

• Log and Usage Data. Log and usage data is website-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our websites and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, settings, and information about your website activity.
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the websites. Depending on the device used, this data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data, such as information about your device’s location, which can be precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the websites. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt-out, you may not be able to use certain aspects of the websites.

Other than as required by law, Edenlab websites (https://kodjin.com/ and https://edenlab.io/) do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). EDENLAB OÜ will not collect any information about criminal convictions and offenses.

2. How do we process your information?

In Short: We process your information to provide, improve, and administer our websites, communicate with you for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our websites, including:

• We may process your information to provide you with the requested service.
• To respond to user inquiries. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

3. What legal bases do we rely on to process your personal information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person.

In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this Privacy Policy since we determine the means and/or purposes of the data processing we perform. This Privacy Policy does not apply to the personal information we process as a “data processor” on behalf of our customers. In those situations, the customer to whom we provide services and with whom we have entered into a data processing agreement is the “data controller” responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection, and prevention
• For business transactions, provided certain conditions are met
• If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession, and the collection is consistent with the purposes for which the information was produced
• If the information is publicly available and is specified by the regulations.

4. Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy: https://kodjin.com/cookie-policy/.

5. How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy unless a more extended retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the websites, you represent that you are at least 18. If you become aware of any data we may have collected from children under the age of 18, please contact us at [email protected]

7. What are your privacy rights?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv), if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?” below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK, and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent, depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?” below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. You can usually set your browser to remove and reject cookies if you prefer. If you choose to remove or reject cookies, this could affect certain features or services of our websites. For further information, please see our Cookie Policy: https://kodjin.com/cookie-policy/.

8. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference and not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

9. Do California residents have specific privacy rights?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

CCPA Privacy Policy

The California Code of Regulations defines a “resident” as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as “non-residents.”
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this Privacy Policy and our Cookie Policy: https://kodjin.com/cookie-policy/.

You may contact us by email at [email protected] or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” your personal information.
EDENLAB OÜ has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. EDENLAB OÜ will not sell personal information in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell your personal information to third parties;
• the categories of personal information that we sold or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
• the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your Privacy Rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine whether you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use the personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant or ask to restrict the processing of the information.
• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

To exercise these rights, you can contact us by email at [email protected] or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

10. Do we make updates to this policy?

In Short: Yes, we will update this Policy as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated date, and the updated version will be effective as soon as it is accessible. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

11. How can you contact us about this policy?

If you have questions or comments about this policy, you may email us at [email protected] or by post to:

EDENLAB O
Vesivärava str. 50-201
Tallinn, 10152
Estonia

12. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it.