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CodeB Privacy Policy


ALOAHA Limited / CodeB and its affiliated companies and subsidiaries (“we / us”) respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Privacy Policy”).

This Privacy Policy (together with our terms of use and any other documents referred to in it) describes the type of information that we collect from you through the use of our products and/or services (“Products”), or the use of this website (our “Website”), how that information may be used or disclosed by us and the safeguards we use to protect it.

This Privacy Policy does not apply to information collected on any third-party site or by any third-party application that may link to or be accessible from the Website or any of the Products. ALOAHA encourages you to review the privacy statements of other websites and applications to understand their information practices.

Please read the following carefully to understand our policies and practices regarding your information and how we will treat it. By using or accessing our Website or the Products, you agree to the collection, use and disclosure of information in accordance with this Privacy Policy. This Privacy Policy may change from time to time and your continued use of the Website or the Products is deemed to be acceptance of such changes, so please check the Privacy Policy periodically for updates.

Information you provide to us

We collect and use personal information that you voluntarily provide to us on our Website or through the use of the Products including but not limited to your name, address, email address, telephone number or financial information, in the following circumstances:

  • Accounts – when you register for an account or subscribe to use the Products or our Website.

  • Support – when you request support, services or information about the Products or our Website.

  • Contests and Promotions – when you participate in a contest, promotion or survey sponsored by us.

  • Correspondence – if you contact us we will collect the personal information contained within your correspondence (including e-mail addresses).

  • Transactions and Orders – when you carry out transactions through our Website or purchase the Products including on a trial basis or any upgrades.

If you choose not to provide the personal information we request, you can still visit most areas of the Website, but you may be unable to access certain options, offers and services that involve interaction. You have the final decision on whether to proceed with any activity that requests personal information.

Information we may collect

We may automatically collect statistical or aggregate non-personal information about your interaction with our Website or the Products.

Aggregate information is information that we collect about a group or category of products, services or customers that is not personally identifiable. This may include usage information about your computer, laptop, tablet, mobile phone or other electronic device and your activity using the Products or our Website. We may collect information including the internet protocol (IP) addresses, browser type, internet service provider (ISP), pages that you access, referring/exit pages, operating system, resources that you access, date/time stamp and other interactions with our Website or the Products. This information can assist us in analysing trends, providing statistical information and improving our Website and Products.

If we link or associate any information gathered with personal information we treat the combined information as personal information. Otherwise we use and disclose information collected solely by passive means in aggregate form or in a non-personally identifiable form. We may collect, use and disclose non-personal information for any purpose. Where, according to local law, IP addresses and the like are considered personal information, then we treat it as such.



Like the vast majority of website providers, we use various common internet technologies, such as cookies and web beacons, to collect details about your interactions with our Website and Products. We only collect aggregate information, such as, for example, traffic data, logs and other communication data, whether this is required for our own contractual purposes or otherwise.

Cookies – Cookies are small files stored on the browser or the hard drive of your computer. Use of cookies help us to improve our Website and Products and to deliver a better and more personalized service by enabling us to: estimate our audience size and usage patterns, store information about your preferences, allowing us to customize our Website according to your individual interests, speed up your searches and recognize you when you return to our Website. If you register with us or if you continue to use our Website and/or Products, you agree to our use of cookies.

Web Beacons – Web beacons also known as pixel tags are electronic images, contained on a website that permit us to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). Web beacons are not used to access your personal information on the Website and are only used to compile aggregated statistics concerning use of the Website.

Web Analytics – We also collect some information (ourselves or using third party services) using web analytic tools to help us continuously improve our Website and the Products. We use third-party services that use tracking technologies to track non-personally identifiable information about interactions on our Website and Products in the aggregate to capture usage and volume statistics. This information is used to monitor and analyse the use of our Website and/or the Products, to increase our services functionality and for the technical administration.

Third Party Advertising Technologies – In addition to our use of technologies as described herein, we may use third party vendors such as Google to perform display advertising or remarketing services to display advertising on our Website or manage our advertising on other sites. These services can help us tailor advertising that we think may be of interest to you based on your use of our Website and/or Products and to otherwise collect and use data about your use of our Website and/or Products. Third-party vendors may use cookies and web beacons to collect non-personal information about your activities on our Website and other websites to provide you with targeted ads.

As always we respect your privacy and do not collect any personally identifiable information through the use of Google or any other third party services. Any information collected is used only for remarketing purposes and will not be used by third-party marketing vendors for any other purpose.

How we use the information


We use information that we collect about you or that you provide to us, including any personal information, in the following ways:

  • To administer, operate, maintain and improve the Products, services and our Website.

  • To provide you with information, newsletters and Products or services that you request from us.

  • To notify you about any changes or provide you with support.

  • To carry out our obligations, process and enforce our rights arising from any contracts entered into between you and us such as communications related to payments and changes to our terms, conditions and policies.

  • To allow you to purchase and download Products and participate in interactive features of our services, when you choose to do so.

  • For billing and accounting purposes.

  • For internal purposes such as performing research and analysis and to provide anonymous reporting internally or externally.

  • For marketing and promotional purposes so as to provide you with information about Products or services we think you might like. You may opt-out of receiving these communications by following the steps described below.

  • For any other purposes that we may disclose to you at the point at which we request your personal information and pursuant to your consent.

  • To prevent or take action against activities that are or may be in violation of the Product end-user license agreement, the Website Terms of Use or applicable law.

Once you have registered for the Products we reserve the right to send you certain communications relating to the Products, such as service announcements and administrative messages that are considered part of the Product.

Disclosure of your information


We do not sell or rent your personal information to third parties. Except as described in this Privacy Policy we will not disclose your personal information that we collect from the Products or our Website to third parties without your consent. We may disclose personal information that you provide to us when necessary to the following third parties:

  • To a member of our group – holding company and its subsidiaries and affiliates. This information helps us make your customer experience more seamless and efficient by allowing us to improve our marketing efforts to better target customer needs, streamline our processes and consolidate our backend business systems.

  • Direct or indirect contractors and service providers we occasionally use to support our business as may be required for example, to fulfil orders, conduct billing/credit card processing, provide you with services or perform statistical analysis of the Products and our Website. Those service providers will be permitted to obtain only the personal information they need to deliver the service in accordance with our policies under confidentiality agreements and not for their own purposes.

  • Authorised partners, distributors and resellers to fulfil any terms under your licensing and service relationship with us and to provide you with local technical and customer support

  • In the event (whether perspective or actual) of a merger, acquisition, or any form of sale of some or all of ALOAHA’s assets, in which case personal information held by us about you and our customers will be among the assets transferred to the (prospective) buyer.

  • Comply with a law, court order or other legal obligation.

  • Enforce or apply our terms of use or terms of license or sale and other agreements.

  • Protect the rights, property, or safety of ALOAHA, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.


We may disclose your non-private, aggregated or otherwise non-personal information that doesn’t identify you, to our partners or other third parties about how our customers, collectively, use our Website and the Products but we do not sell or share any information at the individual level.

Your choices and opt-out


We strive to provide you with choices regarding the information you provide to us. You may elect to opt out of receiving direct marketing or market research information. We have created mechanisms to provide you with the following control over your information:

Cookies – You can refuse to accept cookies by activating the appropriate setting on your browser. Please be aware that restricting the use of cookies may impact on the functionality of our Website and you may be unable to access certain parts of our Website. More information can be found in our Cookie Policy.

Promotional Offers from Third Parties – If you do not wish us to share your personal information with affiliated third parties for promotional purposes, you can opt-out by checking the relevant box located on the applicable registration form on which we collect your data. You can also always opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an e-mail stating your request to

Promotional Offers from ALOAHA. If you do not wish to have your e-mail address used for promotional purposes by ALOAHA, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always opt-out of receiving e-mail information from us other than the e-mail informing you of the completion of user registration, correction of user data, or change of password by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an e-mail stating your request to If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions.

Personalized Advertising. If you do not want us to use personal information that we gather to allow third parties to personalize advertisements we display to you, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always adjust your user advertising preferences accordingly in your account profile by checking or unchecking the relevant boxes or by sending us an e-mail stating your request to

Unsubscribing In each and every marketing or promotional email that we send to you, there is an ‘unsubscribe’ hyperlink, which you may you use if you wish to ‘opt out’ of and stop receiving email communications from us. The hyperlink will direct you to our website, where upon entering the email address that you no longer wish to receive ALOAHA emails, one last confirmation email shall then be sent to the email address you designate. Merely confirm that you do indeed wish to stop ALOAHA email’s being sent to you and that email address shall automatically be unsubscribed.

Alternatively, you may email ALOAHA at with your request, stating ‘Unsubscribe’ in the header and what email addresses you wish not to receive ALOAHA emails and within a reasonable period, we shall ensure that such email addresses are unsubscribed and shall no longer receive any communications from us.

These choices do not apply to the receipt of mandatory communications related to the Products that are considered part of the Product which you may receive periodically unless you cancel the Product. Please be aware that you may not opt out of receiving this information. If you opt-out of receiving commercial e-mail from us, it may take up to ten business days for us to process your opt-out request, and you may receive commercial e-mail from us during that period.

You should review this Privacy Policy carefully, because if you do not agree with our practices, your ultimate choice is not to use the Website or the applicable Product. Remember, by using any part of the Website, you accept and agree to our privacy practices. If we update this Privacy Policy, your continued use of the Website and Products (following the posting of the revised Privacy Policy) means that you accept and agree to the terms of the revised Privacy Policy.

User Contributions


You are responsible for any content, including personal information, that you contribute to be posted, published or displayed on the Website, or transmit to other users of the Website (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to other users of the Website at your own risk. Although we limit access to certain pages, you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions; therefore, we cannot guarantee who will view or use your User Contributions. We are not responsible for circumvention by third parties of any privacy settings or security measures contained on the Website. You understand and acknowledge that, even after removal, copies of your User Contributions may remain viewable in cached and archived pages, or may have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by this Privacy Policy and our Website Terms of Use and known or suspected violations should be reported to

Accessing and correcting your personal information


You can review, update, correct or delete your personal information by logging into the Website and visiting your account profile page and making changes. If you have forgotten your password, once you have tried to register and failed, you can click on the “Forgot your password?” link to reach a page on which you can submit your e-mail address. Your user name and password then will be e-mailed to you. Alternatively, you can also contact us at if you wish to exercise these rights. While we will strive to accommodate your requests, we may reject requests which risk the privacy of others, are unreasonable or repetitive, require disproportionate technical effort (such as developing new systems or fundamentally changing an existing business practice), or would be extremely impractical. Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort.

If you request that we delete your account we will do so within a reasonable period of time, but we may need to retain some of your personal information in order to satisfy our legal obligations, or where we reasonably believe that we have a legitimate reason to do so.

Where we store your personal data


The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside of the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfillment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

With respect to data transfers from the EEA to the United States or to other countries outside the EEA, we have taken steps to ensure adequate protection for such data transfers in accordance with European data protection legislation. We have entered into appropriate data transfer agreements based on the standard contractual clauses approved by the European Commission to provide adequate protection for data transfers between ALOAHA entities outside the EEA, as necessary.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Children under the age of 13


Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, please do not register on the Website, make any purchases through the Website or send any information about yourself to us. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at

Your EU Privacy Rights

If you are a user located in the EU/EEA/UK, you have the following rights regarding your Personal Information:

  • Right of access: You may ask us to confirm whether we process your Personal Information and, if so, to provide you with a copy of that Personal Information (along with certain other details).

  • Right to rectification: If the Personal Information we hold about you is inaccurate or incomplete, you are entitled to ask for rectification or completion.

  • Right to erasure: You may ask us to delete or remove your Personal Information in some circumstances, e.g., if you believe we no longer need it or if you withdraw your consent (where applicable). If you completely delete all such Personal Information, then your account may become deactivated.

  • Right to restrict processing: You may ask us to restrict the processing of your Personal Information in some circumstances, e.g., if you object to us processing it.

  • Right to data portability: You have the right to obtain Personal Information you have provided to us in a structured, commonly used and machine-readable format for reuse under certain circumstances.

  • Right to object: You may ask us at any time to stop processing your Personal Information, and we will do so under appropriate circumstances, if we (1) rely on legitimate interests to process your Personal Information, except if we can demonstrate compelling legal grounds for the processing, or (2) process your Personal Information for direct marketing.

  • Rights in relation to automated decision-making and profiling: You have the right not to be subject to a decision when it is based solely on automated processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

  • Right to withdraw consent: If we rely on your consent as legal basis for processing your Personal Information, you have the right to withdraw that consent at any time.

Your California privacy rights


California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please send an e-mail to

Changes to our Privacy Policy


It is our policy to post any changes we make to our Privacy Policy on this page. It is your responsibility to check this page from time to time to check for any change. Your continued use of the Website or our Products shall be deemed to be your consent to such changes.

The date the Privacy Policy was last revised is identified at the top of the page.

Contact information


To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Corporate address

Aloaha Limited
45, Triq Gio Felice Inglott
PBK 1131, Pembroke
Malta, Europe


Telephone: +49 541 3859 4554

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