Privacy Policy
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.
- 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
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
| Purpose | Data used | Legal basis |
|---|---|---|
| Providing and operating the Service | Account, catalogue, usage | Performance of a contract |
| Authenticating users and securing accounts | Account, technical | Performance of a contract; legitimate interests |
| Maintaining an audit trail of changes | Account, usage | Legitimate interests in accountability and data integrity |
| Taking payment and managing subscriptions | Account, billing | Performance of a contract |
| Providing support | Account, correspondence, technical | Performance of a contract; legitimate interests |
| Fixing faults and improving reliability | Technical, usage | Legitimate interests in a functioning service |
| Service notices about outages, changes or billing | Account | Performance of a contract; legal obligation |
| Meeting accounting and tax obligations | Billing | Legal obligation |
| Preventing fraud and abuse | Technical, usage, billing | Legitimate 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 recipient | Purpose | Data involved |
|---|---|---|
| Payment provider (Paddle.com Market Limited, UK) | Payments, invoicing, tax, merchant of record | Billing and contact data |
| Database provider | Hosting of catalogue and account records | Account, catalogue, usage |
| Web and application hosting provider | Running the Service | Technical and application data |
| Automation provider | Running background enrichment jobs | Catalogue records sent for enrichment |
| SEO data provider | Supplying search volume estimates | Device and category names only |
| AI provider | Classifying release year and model tier | Device 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
- Account and catalogue data — for as long as your subscription is active. After termination, we keep it for 30 days so you can export it, then delete or anonymise it.
- Change log entries — retained for the life of the account as an audit record, then deleted with the account.
- Billing and tax records — retained as required by applicable accounting and tax law, typically for up to seven years.
- Support correspondence — up to three years from the last message.
- Technical logs — normally up to 12 months.
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:
- Access the personal data we hold about you and receive a copy;
- Rectify data that is inaccurate or incomplete;
- Erase your data where there is no overriding reason for us to keep it;
- Restrict processing in certain circumstances;
- Port your data to another provider in a structured, machine-readable format;
- Object to processing based on legitimate interests;
- Withdraw consent where processing is based on consent, without affecting processing already carried out.
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.
- Session storage — keeps you signed in for the duration of your session. Sessions expire automatically after 8 hours.
- Local preferences — remembers interface settings such as filters, sort order and page size in your browser. This stays on your device and is not sent to us.
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:
- encrypted connections (HTTPS/TLS) for all traffic;
- passwords stored as salted hashes, never in plain text;
- API credentials held server-side and never exposed in the browser;
- role-based access control and time-limited sessions;
- access to production data restricted to personnel who need it.
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.