Privacy Policy

1. Who we are

CodeWink Labs LLC ("CodeWink Labs", "we", "us", "our") is a limited liability company organized under the laws of the State of Louisiana, United States. We are the data controller (and, in California terms, the "business") responsible for the personal data described in this policy. Contact: admin@codewinklabs.com.

2. What this policy covers

This policy applies to the website at codewinklabs.com and to email you send to the company. It does not cover our software products, which collect different data under their own policies:

• Panelogue (desktop app and getpanelogue.com): getpanelogue.com/privacy

When we publish a new product, its policy is linked here before the product ships.

3. Personal data we collect, and why

Server logs. Like nearly every website, our hosting provider records standard access logs when you load a page: your IP address, browser type and version, operating system, the pages requested, the referring page, and the date and time. We use these only to keep the site secure and working, and to diagnose problems. We do not use them to identify or profile you.

Email correspondence. If you write to us, we receive your email address, anything you choose to include, and the thread that follows. We use it to answer you, to follow up, and to keep a record of support and business conversations.

Nothing else. This site has no accounts, no forms, no newsletter signup, no comments, no analytics, no advertising, and no embedded third-party content. We do not buy data about you and we do not combine what we hold with data from other sources.

4. Cookies and tracking

codewinklabs.com sets no cookies and uses no local storage, pixels, fingerprinting, or third-party scripts. Fonts and images are served from our own domain. There is nothing to consent to and nothing to opt out of. Because we do not track visitors, we treat every browser as if it had sent a Global Privacy Control or Do Not Track signal.

5. Legal bases (EEA, UK, Switzerland)

Where the GDPR, UK GDPR, or Swiss FADP applies, we process server logs under our legitimate interest in the security and operation of the site (Art. 6(1)(f) GDPR). We process email correspondence under our legitimate interest in responding to you, or, where you are a customer or prospective customer, as necessary to perform or enter into a contract (Art. 6(1)(b)). We do not process special categories of data, and we do not make automated decisions with legal or similarly significant effects.

6. Who we share data with

• Our hosting provider, which stores the server logs described above and serves this site. It acts as our processor.
• Our email provider, which stores and transmits correspondence.
• Legal and safety recipients, if we are required to by law, subpoena, or court order, or if disclosure is necessary to protect our rights, your safety, or the safety of others.
• A successor, if CodeWink Labs is merged, acquired, or its assets are sold, in which case this policy continues to apply to the transferred data.

We do not sell personal data, we do not share it for cross-context behavioral advertising, and we have not done so in the preceding twelve months.

7. International transfers

CodeWink Labs is located in the United States and our providers process data on servers in the United States. If you visit from outside the US, including the EEA, UK, or Switzerland, the limited data described here is transferred to and processed in the US. Where a transfer mechanism is required, we rely on our providers' standard contractual clauses or equivalent safeguards.

8. Retention

• Server logs: retained by our hosting provider for its standard rolling period, then deleted automatically.
• Email: kept for as long as the conversation is useful to serve you, and for up to three years after the last message for record-keeping, unless the law requires longer or you ask us to delete it sooner.

9. Your rights

You can ask us to tell you what personal data we hold about you, to correct it, to delete it, to give you a copy in a portable format, to restrict or object to our processing of it, and to withdraw any consent you have given. We honor these requests from anyone, anywhere, not only where the law requires it.

EEA, UK, and Switzerland. You have the rights above under the GDPR, UK GDPR, and FADP, and the right to lodge a complaint with your local supervisory authority.

California and other US states. Under the CCPA/CPRA and similar laws in states such as Virginia, Colorado, Connecticut, Utah, Texas, and Oregon, you have the right to know what we collect and why, to access and delete it, to correct it, to opt out of sale, sharing, and targeted advertising (we do none of these), and not to be discriminated against for exercising your rights. The categories of personal information we collect are identifiers (IP address, email address) and internet activity (server logs), from you directly and from your browser, for the purposes in section 3.

To exercise any right, email admin@codewinklabs.com. We will confirm receipt and respond within 30 days, or sooner where the law requires. We may ask you to verify your identity by replying from the email address in question. An authorized agent may submit a request on your behalf with your written permission.

10. Children

This site and our products are not directed at children under 13, and we do not knowingly collect personal data from them. If you believe a child has provided us personal data, contact us and we will delete it.

11. Security

The site is served over HTTPS. We keep the data we hold to the minimum described here, restrict access to it, and use providers with their own security programs. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. Changes

When this policy changes materially, we will update the effective date at the top and, where we have a way to reach affected people, tell them directly. The current version is always at codewinklabs.com/privacy.html.

13. Contact

CodeWink Labs LLC, a Louisiana limited liability company. admin@codewinklabs.com. For Panelogue-specific privacy questions: support@getpanelogue.com.