Legal

Privacy Policy

Last updated: 24 July 2026 · Effective: 24 July 2026

This policy explains what personal data Acode LLC collects when you use CATMANAGER, why we collect it, who we share it with, and what rights you have over it.

Data controller
Legal entity
Acode LLC
Registered address
Pushkin Street 46, 0010 Yerevan, Armenia
Registration number
999.110.1596752
Tax number (TIN)
02952249
Privacy contact
[email protected]
Phone
+374 55782705
Contents
  1. What we collect
  2. Why we use it and our legal basis
  3. Payment data
  4. Who we share data with
  5. International transfers
  6. How long we keep data
  7. Your rights
  8. Cookies and local storage
  9. Security
  10. Children
  11. Changes to this policy
  12. Contact and complaints

1. What we collect

Account data

The name, email address, and company details you give us when registering, plus a securely hashed password. We never store passwords in readable form.

Catalogue data you upload

The product category records you import or create — device names, brands, types, SKUs, identifiers, notes and enrichment results. This is business data. It is not normally personal data, but if you choose to include personal information in free-text fields, we process it on your behalf.

Usage and technical data

Basic records generated when you use the Service: sign-in times, actions recorded in the change log (which user created, edited or deleted a record and when), IP address, browser type and error diagnostics.

Correspondence

Emails and support messages you send us, and our replies.

Billing data

Order records, invoice references and subscription status received from our payment provider. See section 3 — we do not receive or store your full card details.

2. Why we use it and our legal basis

PurposeData usedLegal basis
Providing and operating the ServiceAccount, catalogue, usagePerformance of a contract
Authenticating users and securing accountsAccount, technicalPerformance of a contract; legitimate interests
Maintaining an audit trail of changesAccount, usageLegitimate interests in accountability and data integrity
Taking payment and managing subscriptionsAccount, billingPerformance of a contract
Providing supportAccount, correspondence, technicalPerformance of a contract; legitimate interests
Fixing faults and improving reliabilityTechnical, usageLegitimate interests in a functioning service
Service notices about outages, changes or billingAccountPerformance of a contract; legal obligation
Meeting accounting and tax obligationsBillingLegal obligation
Preventing fraud and abuseTechnical, usage, billingLegitimate interests; legal obligation

Where we rely on legitimate interests, we have considered whether those interests are overridden by your rights, and we have concluded they are not. You can object to this processing at any time — see section 7.

We do not sell personal data. We do not use your data to train AI models, and we do not use it for advertising or profiling.

3. Payment data

Payments are processed by Paddle.com Market Limited, which acts as merchant of record for all orders. Paddle collects and processes your payment details directly as an independent controller for that purpose. Acode LLC does not receive or store your card number, CVV or full payment credentials.

We receive from Paddle only the information needed to run your subscription: your name, billing email, country, subscription tier and status, and transaction references. Paddle's handling of your data is governed by its own Privacy Notice.

4. Who we share data with

We share data only with providers that help us run the Service, and only to the extent needed. Each is bound by contract to protect it and to process it solely on our instructions (except Paddle, which acts as its own controller for payment processing).

Category of recipientPurposeData involved
Payment provider (Paddle.com Market Limited, UK)Payments, invoicing, tax, merchant of recordBilling and contact data
Database providerHosting of catalogue and account recordsAccount, catalogue, usage
Web and application hosting providerRunning the ServiceTechnical and application data
Automation providerRunning background enrichment jobsCatalogue records sent for enrichment
SEO data providerSupplying search volume estimatesDevice and category names only
AI providerClassifying release year and model tierDevice and category names only

Only product and category names are sent to the SEO data and AI providers. Account holder details are not sent to them.

A current list naming each sub-processor is available on request from [email protected]. We will give notice before adding a new sub-processor that processes personal data on our behalf.

We may also disclose data where required by law, court order or a competent authority, or where necessary to establish, exercise or defend legal claims. If our business is transferred or reorganised, data may pass to the acquiring entity, and we will notify you before that happens.

5. International transfers

Acode LLC is established in Armenia. Our providers operate in the European Economic Area, the United Kingdom and the United States. Transferring data from the EEA or UK therefore involves an international transfer.

Where we transfer personal data outside the EEA or UK, we rely on an appropriate safeguard, normally the European Commission's Standard Contractual Clauses (with the UK Addendum where relevant), or an adequacy decision where one applies. You can request a copy of the safeguards in place by emailing [email protected].

6. How long we keep data

You can ask us to delete your account data sooner. We will comply unless we are legally required to keep it, in which case we will tell you why.

7. Your rights

Depending on where you live, and in particular if you are in the EEA or UK under the GDPR, you have the right to:

To exercise any of these, email [email protected]. We will respond within 30 days. There is no charge unless a request is manifestly unfounded or excessive. We may ask you to confirm your identity before acting.

You can also export your catalogue data yourself at any time using the CSV export function in the Service.

8. Cookies and local storage

CATMANAGER uses only what it needs to function. We do not use advertising cookies, third-party trackers or cross-site analytics.

These are strictly necessary for the Service to work, so no consent banner is required for them. Clearing your browser storage will sign you out and reset your interface preferences.

Paddle may set its own cookies during checkout; those are governed by Paddle's privacy notice.

9. Security

We take reasonable technical and organisational measures to protect your data, including:

No system is completely secure. If a personal data breach occurs that is likely to result in a risk to your rights, we will notify the relevant supervisory authority within 72 hours where required, and inform you without undue delay where the risk is high.

10. Children

CATMANAGER is a business tool and is not directed at children. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with personal data, contact us and we will delete it.

11. Changes to this policy

We may update this policy to reflect changes to the Service, our providers or the law. The "last updated" date at the top will always show the current version. For material changes we will notify account holders by email at least 30 days before they take effect.

12. Contact and complaints

For any privacy question or request, contact:

Acode LLC
Pushkin Street 46, 0010 Yerevan, Armenia
Email: [email protected]
Phone: +374 55782705

If you are in the EEA or UK and you are not satisfied with our response, you have the right to lodge a complaint with your local data protection supervisory authority. We would appreciate the chance to address your concern first.