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Privacy Policy

Last modified: February 20, 2026

About Codal

Codal Inc is headquartered in Illinois with its principal offices located at 433 West Van Buren Street, Suite 205, Chicago, IL 60607 (“Codal”, “we”, “us”, or “our”). Communications regarding this Privacy Policy must be (i) sent via email to legal@codal.com; or (ii) sent in writing to the aforementioned postal address.

Intro to our Privacy Policy

This Privacy Policy, as a means to comply transparency requirements set out in data privacy laws and regulations, sets out all necessary information, including but not limited to: the basis on which Codal and its subsidiaries collect and process information that can be used to distinguish or trace an individual's identity, either alone or when combined with other information that is linked or linkable to a specific individual (“Personally Identifiable Information`” or “PII”), what Personally Identifiable Information is collected or used, retention periods, as well as who Personally Identifiable Information may be shared with. Collectively referred to as ("Privacy Information”).

By visiting Codal's website, using Codal's services or by some other interaction which results in you providing any Personally Identifiable Information to us, you accept and agree to the terms of this Privacy Policy.

Codal shall use your Personally Identifiable Information in compliance with all applicable laws and regulations relating to data protection and privacy.

What information we collect or use

Personally Identifiable Information, in most cases, is provided to us directly by you. Codal may also collect and process Personally Identifiable Information indirectly. If it is not disproportionate or prejudicial, Codal shall contact you to let you know that we are processing your Personally Identifiable Information.

Why Codal collects or uses information

Codal may collect or process your Personally Identifiable Information under any of the following lawful bases:

  1. Consent;

  2. Contract;

  3. Legal obligation; or

  4. Legitimate interests.

Codal may collect or process your Personally Identifiable Information, pursuant to the above legal bases, for any of the following purposes:

  • For the provision of services;

  • For the efficient handling of business transactions;

  • For the effective operation Codal customer accounts;

  • For service updates or direct marketing purposes (Codal shall comply immediately with any request to discontinue processing PII in connection with marketing purposes);

  • For recruitment purposes; or

  • For compliance with our duties under applicable law and regulations.

How long we keep information

Personally Identifiable Information is retained in accordance with applicable laws and regulations. Such retention periods are reviewed to ensure ongoing compliance with applicable laws and regulations and in order to comply with storage limitation, data minimisation and other such data handling best practices.

Who we share information with

Codal may share Personally Identifiable Information with third parties, service providers or companies/ individuals where necessary to achieve the above purposes.

Subject to the nature of your Personally Identifiable Information collection or use, Codal may share the same with:

  1. Third party companies or individuals who: (i) assist or facilitate the performance of our services, (ii) facilitate or assist with the effective delivery of services; or (iii) analyse our services to adjust and/ or improve the same;

  2. Third party companies or individuals that Codal is legally obligated to provide your Personally Identifiable Information to;

  3. Third party companies or individuals that Codal is legally obligated to disclose information, documents, materials or otherwise to and such disclosure may necessarily contain your Personally Identifiable Information; or

  4. Third party companies or individuals who perform services for Codal which are necessary for the operation of our business.

Codal shall not sell or share your Personally Identifiable Information with any third parties for the purposes of direct marketing unless provided with active and informed consent.

Sharing information outside of the UK, EEA, Canada or USA

Any transfer of your personal information to entities in other countries shall be subject to appropriate safeguards, adequacy regulations or exception(s). Such instances may include where Codal transfers Personally Identifiable Information (i) between our subsidiaries; (ii) to our suppliers; or (iii) other third parties.

In such circumstances, Codal is responsible for complying with any applicable transfer rules.

Cookies

Cookies are small text files that are placed on your computer or other device by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Codal implements cookies on its website as follows:

  • Strictly necessary cookies: these essential cookies are required for the operation of our website.

  • Analytical cookies: analytical cookies allow us to recognise, count, measure the number and how users navigate Codal's website to improve performance.
  • Functionality cookies: functional cookies are used to recognise you when you return to our website. In doing so, Codal is able to remember preferences and personalize content.

Your data protection rights

By law you may have certain rights with regard to any Personally Identifiable Information collected or used by Codal. These may include:

  • Right to be informed:

    • You may have the right to be informed about the collection and use of your PII.

  • Right of access or know:

    • You may have the right to access and receive a copy of your PII, and other supplementary information.

  • Right to ratification or correct:

    • You may have the right to have inaccurate PII rectified, or completed if it is incomplete.

  • Right to erasure or delete:

    • You may have a right to have PII erased.

  • Right to restrict processing:

    • You may have the right to request the restriction or suppression of your PII

  • Right to data portability:

    • You may have the right to data portability allowing you to obtain and reuse your PII for your own purposes across different services.

  • Right to object:

    • You may have the right to object to the processing of your PII in certain circumstances.

  • Rights related to automated decision making including profiling:

    • Such rights relate to: automated individual decision-making (making a decision solely by automated means without any human involvement); and

    • profiling (automated processing of PII to evaluate certain things about an individual). Profiling can be part of an automated decision-making process.

  • Right to opt-out of sale or sharing:

    • You may have the right to request that businesses stop selling or sharing your personal information (“opt-out”), including via a user-enabled global privacy control.

Further information on your rights as a data subject may be obtained from your national or state data protection regulator.

Any exercise of the above rights should be made by either (i) emailing us at legal@codal.com; or (ii) sending written notice to Codal's physical address provided at the top of this Privacy Policy.

Non-adult privacy

Codal does not knowingly collect Personally Identifiable Information of any person under the age of eighteen (18). Personally Identifiable Information of persons under the age of eighteen (18) shall be subject to automatic erasure upon discovery.

Last updated

Codal may update this Privacy Policy from time to time. Any changes to this Privacy Policy will cause the date provided below to be modified and for such changes to be effective from the date posted on this page.

February 20, 2026