Privacy Policy

CodeSpeak Ltd

Company No. 16382179

Registered Office: Suite 505, Hamilton House, 1 Temple Avenue, London, EC4Y 0HA, United Kingdom

Effective Date: 3 March 2026

1. Introduction

1.1 Important information and who we are

Welcome to CodeSpeak Ltd's Privacy and Data Protection Policy ("Privacy Policy").

At CodeSpeak Ltd ("we", "us", or "our") we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation ("GDPR"), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. It also tells you about your privacy rights and how the law protects you.

This Privacy Policy applies to individuals who use our services, applications, software, websites, APIs, and related offerings (collectively, the "Service"), including visitors and account holders, and to the Personal Data we process in connection with providing the Service.

1.2 Your Data Controller and Processor

CodeSpeak Ltd acts as Data Controller in relation to personal data collected through the Service and account registration processes.

Where users upload or process personal data within their own projects ("Project Data"), CodeSpeak acts as Data Processor on behalf of the relevant user. The user remains the Data Controller for such Project Data.

Where we act as Data Processor, we process personal data only on the documented instructions of the relevant user and implement appropriate technical and organisational measures to protect such data in accordance with UK GDPR.

We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email to info@codespeak.dev or by post to Suite 505, Hamilton House, 1 Temple Avenue, London, EC4Y 0HA, United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

We ensure that all persons authorised to process personal data on our behalf are subject to appropriate confidentiality obligations and that we implement appropriate technical and organisational measures to protect personal data in accordance with UK GDPR.

2.1 Types of data / Privacy policy scope

"Personal Data" means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.

Contact Data: This is data relating to your addresses, email addresses, phone numbers.

Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.

Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.

Customer Support Data: This includes feedback and survey responses.

Usage Data: Information about how you use the Service.

Project Data: This includes program and library code, binaries, files, text, configurations, datasets, prompts, outputs and other content that you create, upload, store or share when using the Service. Project Data may contain Personal Data or content protected by intellectual property rights.

Together, Personal Data and Project Data constitute "Customer Data" as defined in our Terms of Service.

We also collect, use and share Aggregated Data such as project creation trends, the number of builds published, feature adoption rates, deployment frequency, and anonymised performance benchmarks across projects. This data is used to improve the Service and inform product development. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.

We do not intentionally collect Special Categories of Personal Data through the Service or account registration processes. Users should avoid uploading Special Categories of Personal Data in Project Data. Where users choose to upload such data, they are responsible for ensuring they have a lawful basis to do so, and we will process such data only on their instructions as Data Processor.

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

"Consent": Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or 'opt in' to a service.

"Contractual Obligations": We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.

"Legal Compliance": We're required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.

"Legitimate Interest": We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

3. How We Use Your Personal Data

3.1 Our data uses

We will only use your Personal Data when the law allows us to.

3.2 Marketing and content updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3 Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

3.4 User-Generated Project Data

You retain ownership of any intellectual property rights you have in your Project Data. The licence you grant to CodeSpeak in relation to Customer Data, including Project Data, is set out in our Terms of Service (Section 6).

You are responsible for ensuring that any content you upload does not infringe the rights of third parties and complies with applicable laws. We may use automated and manual review tools to help enforce our Terms of Service and remove content that violates our policies or legal obligations.

We process Project Data in accordance with this Privacy Policy and applicable data protection laws. We do not claim ownership of your Project Data but may create aggregated, anonymised insights derived from it for product development and improvement.

4. Your Rights and How You Are Protected by Us

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

Right to be informed. You have a right to be informed about our purposes for processing your personal data, how long we store it for, and who it will be shared with. We have provided this information to you in this policy.

Right of access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (also known as a "data subject access request"). See section 4.5 below for more details on how you can make a data subject access request.

Right to rectification. You have a right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Right to erasure. You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Right to object. You can object to the processing of personal data we hold about you. This effectively allows you to stop or prevent us from processing your personal data. Note that this is not an absolute right and it only applies in certain circumstances, for example:

Right to restrict processing. You have the right to request the restriction or suppression of their personal data. Note that this is not an absolute right and it only applies in certain circumstances:

Right to data portability. You have the right to request the transfer of your personal data to you or to a third party. If you make such a request, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

These rights apply to personal data we process as Data Controller. Where we act as Data Processor for Project Data, requests relating to such data should be directed to the relevant user (as Data Controller). If we receive a request relating to Project Data, we may refer the request to the relevant user and provide reasonable technical assistance to enable them to respond where required.

If you wish to make a request under any of these rights, please contact us at info@codespeak.dev.

4.2 Your control over CodeSpeak Ltd's use of your Personal Data

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

You will need to contact us if you would like to delete your account.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to info@codespeak.dev.

4.3 How CodeSpeak Ltd protects customers' Personal Data

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including adopting a secure protocol and encrypting our databases. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of CodeSpeak Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

4.4 Opting out of marketing promotions

You can ask us to stop sending you marketing messages at any time by clicking the "Unsubscribe" button in the email.

When you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

4.5 How to request your data and the process for obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

5. Your Data and Third Parties

5.1 Sharing your data with third parties

We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors or affiliates, subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions.

We may also share Personal Data with interested parties in the event that CodeSpeak Ltd anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.

If CodeSpeak Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

6. How Long We Retain Your Data

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

7. International Transfer of Data

We may store and process your personal data in the United Kingdom and in other countries where we, our group companies, and our service providers operate. Where personal data is transferred or made accessible outside the United Kingdom, including to countries that do not have a data protection law equivalent to UK standards, we will ensure appropriate safeguards are in place in accordance with UK GDPR requirements. These safeguards may include adequacy decisions issued by the UK Government, the UK Addendum to Standard Contractual Clauses, International Data Transfer Agreements, Binding Corporate Rules or other approved transfer mechanisms. Personal data will remain subject to the protections of this policy and applicable data protection law regardless of where it is processed.

8. Notification of Changes and Acceptance of Policy

We keep our Privacy Policy under review and will place any updates here. This version is dated 3 March 2026.

By continuing to use the Service, you acknowledge that you have read and understood this Privacy Policy.

9. Interpretation

All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. You are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website, etc.).

Our staff are not authorised to contract on behalf of CodeSpeak Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a CodeSpeak Ltd address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any CodeSpeak Ltd rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the CodeSpeak Ltd legal department.

10. Terms of Use

Please also see our Terms of Service which set out the terms, disclaimers, and limitations of liability governing your use of CodeSpeak Ltd.