Privacy policy for

Effective on January 1, 2021

Personal Data Controller

Face Code Ltd. (“the Company”) is the personal data controller and is, in accordance with the legislation on personal data applicable in Slovenia, responsible for any personal data submitted by You on (“the Website”). The terms of this Privacy Policy may be updated from time to time; You shall therefore read this Privacy Policy regularly. Any amendments of the Privacy Policy will be published on the Website.

You will find information about how to contact us under the heading “Contact Details” below.

This privacy policy describes:

  • the information we collect through our websites and apps;
  • how we use this information;
  • with whom we share it; and
  • and how we protect it.

This privacy policy also provides you with information about:

  • how you can request to access, stop the collection of, or delete your personal information (information that can be used to locate or identify you);
  • how to opt-out of the use of your personal information in our measurement products and datasets; and
  • where to go if you have questions about our privacy practices.

Collection and use of personal data

Collection upon registration of an account on the Website

In order to use the services offered on the Website, You are obliged to register an account. The account shall only be accessed and managed by the account holder and such employees at the Company who are authorized to administer the accounts. The account holder is able to update or amend the submitted personal data and to delete the account at any time. Should the requested information not be provided we are not able to provide the services offered on the Website to You.

Personal data that we collect

When You create an account on the Company’s Website You provide Your e-mail address. We also store the status of Your specific accounts i.e. Keep or Delete etc. Moreover, we collect Diagnostic Reports and other troubleshooting, bug, and crash reporting information from customers to help determine problems with the Website.

Purpose and use of data

The personal data submitted by You on the Website is aimed to provide The Company with the necessary information to administer and offer the services to the users and show users a list of accounts created with a specific email. We gather statistical information for the purpose of improving our services.

Information about your interaction with our website and apps including for example, technical details about the devices you use with our Service (such as IP address or other device identifier), usage information and statistics about your interaction with our websites, the URLs of our web pages that you visit, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, and other information about how you use our Service.

We store your contact information, i.e. email address, to be able to provide support and to communicate with You about other information such as product updates and announcements. You can choose to stop receiving communications from us, except regarding certain important notifications such as account security alerts.

To be able to detect and determine problems with our services we collect Diagnostic Reports and other troubleshooting information such as bug and crash reporting data from our users. Copies of Diagnostic Reports and other information transmitted to us is used to enhance and improve our Services and to provide support for our users.

How we collect this information

We collect information from you in several ways:

  • you directly provide us with some information
  • you authorize us to collect other types of information, and
  • we automatically collect certain types of information.

How We Use Collected Information

Information you provide us: We use the information that you provide us to:

  • bring you our email management service,
  • allow you to create and manage your account with us,
  • contact you about updates to and offers connected with the Service,
  • provide you with customer service and technical support, and
  • provide you with important notices about the Service.

Information you authorize us to collect: When we access your email account, we use this access to:

  • perform the functions of the Service, such as unsubscribing you from unwanted subscriptions and creating a “roll-up” of other subscriptions and/or transactions;
  • authenticate you as part of our security processes;
  • develop and offer new services; and
  • tailor content as part of our Service such as in our roll-up summaries

Legal ground for the processing

The legal ground used for processing Your personal data is dependent upon type of data, why it is collected and how we use it. Before submitting any personal data on the Website, You must provide Your consent to The Company to process and manage Your personal data for the purposes specified in this Policy. By using the Website, You consent to The Company’s use and disclosure of such personal data in compliance with this Policy. You have the right to withdraw Your consent to the processing at any given time. This does not, however, affect the legality of processing Your information prior to withdrawal. To withdraw Your consent simply send us an email stating that You withdraw Your consent to us processing Your information further.

When communicating with You about The Company product updates and other announcements or when we use Your data for troubleshooting, for a statistical purpose or for improving our services including developing new features we rely on the legal ground of our legitimate business interests. These legitimate business interests include evaluating the performance of our services and improving our infrastructure for the benefit of our users. This we do at the same time as we apply proper safeguards for Your Privacy and Your rights.

Disclosure of personal data

We have both policy and technological safeguards to prevent the unauthorized disclosure of information. However, we do reserve the right to disclose any information we have if compelled to do so by a court of law with competent jurisdiction or if necessary, to prevent criminal activity or damage to life or property. In such an event we will disclose requested personal data to the authorities. If permitted by the order issued by the court, we will notify You of such a request and whether or not we have complied. The Company may, in good faith, share personal data if we believe such disclosure is necessary to comply with the law or other contractual provisions of these terms or to enforce the terms or where such disclosure is expressly permitted under the terms. 

Where necessary in order for us to provide our services to You we use external suppliers (Processors) to help us with statistics and troubleshooting. These suppliers may process Personal Data and sometimes require limited access to Personal Data. We are committed to Your privacy why we limit such access and only share information that is necessary for suppliers to carry out their work. We make sure that our suppliers provide sufficient safeguards to protect Your Data in accordance with this Privacy Policy and the GDPR. We will never disclose Your data to a third party for commercial use.

Information you provide us: When you register for the Service, you provide us with basic contact information, such as name and email address. You may also provide us with information when you interact with us, such as:

  • when you sign up for email alerts,
  • subscribe to receive information,
  • complete a survey, or
  • seek customer support.

From time to time we will request additional information from you so that we can provide you with a specific offer, function, or feature.

Information that we automatically collect. We may automatically collect information about the way that you use or interact with our Service.

Here are some of the types of automated data collection that occur when you use our sites:

Web Browsers: When you visit one of our websites, your browser automatically sends us your internet protocol (“IP”) address so that the web pages you request can be sent to your computer or device. We use your IP address to determine additional information, such as whether the computer or device has ever been used to visit our site before, which site features were used most often, and how much time was spent on a page.

Cookies: We automatically collect information through “cookies,” which are text files placed on your device’s hard drive when you visit websites. Cookies can enhance your online experience by saving your preferences while you are visiting a particular site. We use cookies to help us manage and understand how you use our website. For example, we use cookies for authentication purposes, to measure session activity on the site, and to determine which areas and features of the site are the most popular. If you wish to disable cookies, you can do so by adjusting the settings for the browser that you use. If you do choose to disable cookies through your browser, you will not be able to take full advantage of all our site features.

Web beacons and Log Files: We may use “web beacons” (also known as internet tags, pixel tags, tracking pixels, and clear GIFs) on pages of our websites. These web beacons allow third parties to collect information such as the IP address of the device, the URL of the web page, the time the page was viewed, the type of browser used, and any additional information in cookies that may have been set by the third party. The information is typically collected in log files, which generally track traffic on our websites. We use web beacons to manage the content we present and for analytical purposes (such as understanding our users, and how they interact with our site, and assisting us in managing and improving our site and Service). We do not attempt to identify individual users through this information.

Do Not Track Browser Signals. At this time, our Service does not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions. However, you may be able to change your privacy preferences regarding the use of cookies and similar technologies through your browser, as described above.

Please note that if there are features of our Services that are provided by third parties, those parties also may use automated means of data collection that are subject to those third parties’ privacy notices and policies.

Storage period

The personal data is stored for as long as You have an account and deleted directly after inactivation of the account unless the data is required for a specific reason such as legal obligations or that The Company has agreed with You to store the personal data for a certain longer period of time. The Company reserves the right to delete personal data earlier if the Company deems appropriate.


The Company strives to provide a secure environment on the Website by limiting the access to Your account to only the account holder. The Company cannot guarantee that unauthorized persons do not gain access to the personal data in the account.

Transfers outside the EU/EEAS

Our servers are provided by our vendors in the United States and transfers to those servers are based on an adequacy decision in accordance with article 45 of the GDPR and they are certified under the EU-US Privacy Shield. When we use other third-party vendors for providing and improving our services which are located outside the EU/EEAS we make sure that they are subject to an adequacy decision or that appropriate safeguards are implemented and that Your rights are enforceable and that effective legal remedies are available for You, in accordance with article 46 of the GDPR.

Your rights

Under the GDPR You have the right to:

  • Request information about the Personal Data we hold related to You free of charge. You also have a right to request a withdrawal of the record. A request for a withdrawal of record shall be made in writing and must be personally signed by You. The request shall be sent by regular mail to the address indicated under Contact Details. It is thus insufficient to send the request by e-mail. You have the right to receive one copy of the record free of charge. For additional copies, we may charge a fee to cover the administrative costs.
  • Request rectification of inaccurate personal data concerning You and request incomplete data to be completed.
  • Request erasure of personal data concerning You. The Company has the obligation to erase Your personal data without undue delay if one of the grounds of article 17 GDPR applies for example if the personal data no longer is necessary for the purposes for which they were collected or otherwise processed.
  • Request restriction of the processing of personal data concerning You if one of the grounds in Article 18 GDPR applies for example if the processing is unlawful.
  • Object to further processing of personal data concerning You for direct marketing purposes. You also have the right to object to the further processing of personal data concerning You that occurs on basis of our legitimate interests or the public interest.
  • Data portability which means that The Company will, during certain circumstances, send the personal data concerning You in a machine-readable format if the transfer is technically possible. You can then without hindrance from The Company transmit those data to another controller.
  • Withdraw your consent to processing. This does not however affect the legality of processing Your information prior to withdrawal. To withdraw Your consent simply send us an email stating that You withdraw your consent to us processing Your information further.
  • Hand in a complaint to the relevant national data protection authority. 
  • Restrictions to Your rights may apply in accordance with article 23 of the GDPR.


A ‘cookie’ is a small text file sent from The Company’s server to Your browser. The cookie cannot identify You personally. It can only recognize the browser that is installed on Your computer and that is used to access The Company’s Website. Different cookies are sent to different computers if You access the Website from different computers. Cookies are required for the system to function correctly and safely, for example when You log in to Your account. Cookies are also used to measure the data traffic in the system and for statistical reasons.

There are two types of cookies, one type is called session cookies, and the other is called permanent cookies. A session cookie is sent between Your computer and The Company’s server in order for the system to work properly during Your visit on the Website. A session cookie disappears when the browser is closed and is thus not stored on the computer. A permanent cookie is stored in Your computer and allows The Company’s systems to recognize Your computer’s IP address and web browser the next time You log in. The Company’s system uses both session cookies and permanent cookies. You can decline The Company’s system to store cookies on Your computer by editing a setting on the browser. Such settings may imply that certain functions on the Website will not function properly or be available.

In order to retain aggregated statistics to be able to analyze, enhance and improve the functionality of our Services we use Google Analytics. For more information about Google Analytics and Privacy please follow this link: You can disable cookies for Google Analytics by following this link: