Privacy policy

Hertzogovina OÜ (hereinafter – "Codyfight") values the privacy of visitors to Codyfight’s websites. To ensure transparency, this Privacy Policy describes Codyfight’s information handling practices when you access content Codyfight owns or operates on the websites located at, or any other websites, pages, features, or content Codyfight owns or operates (collectively, the "Website(s)"). Acknowledge yourself with this Privacy Policy carefully. If you have any questions about this Privacy Policy, please contact Codyfight at [email protected].

1. Acceptance of Privacy Policy

By accessing and using the Website, you signify acceptance of the terms of this Privacy Policy. Where Codyfight requires your consent to process your personal information, Codyfight will ask for your consent to the collection, use, and disclosure of your personal information as described further below. If you do not agree with any aspect of this Privacy Policy, you should immediately discontinue access or use of the Website.

2. Changes to Privacy Policy

Codyfight reserves the right to modify this Privacy Policy at any time, and when required by law, Codyfight will notify you of changes to this Privacy Policy. If Codyfight makes any material changes, Codyfight will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Website prior to the change becoming effective.

3. Information about Codyfight Ltd.

Hertzogovina OÜ is a private limited company incorporated in Estonia with company number 16352304 and whose registered office is Papiniidu tn 5 Pärnu, Pärnu Pärnumaa 80042. Codyfight will be developing Codyfight project as described on the Website: and Whitepaper.

4. Personal information collected

Codyfight collects personal information to contact you and to allow you to participate in Codyfight’s Project. When Codyfight requires certain personal information from users it is because Codyfight is required by law to collect this information or it is relevant for specified purposes. Any information you provide to Codyfight that is not required is voluntary. You are free to choose whether to provide Codyfight with the types of personal information requested, but Codyfight may not be able to serve you as effectively or offer you all of Codyfight’s services when you do choose not to share certain information with Codyfight. This Privacy Policy does not apply to anonymized data, as it cannot be used to identify you. For example, Codyfight collects personal information which is required for Codyfight‘s KYC/AML services provider to verify your identity. Codyfight also collects personal information when you use or request information about Codyfight Project, subscribe to marketing communications, request support, complete surveys, etc. Codyfight may also collect personal information from your offline, for example when you contact Codyfight’s customer support. Codyfight collects the following types of information:

4.1. Personal Identification Information:

Full name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email.

4.2. Formal Identification Information:

Tax ID number, passport number, national identity card details, photograph identification cards.

4.3. Financial Information:

Bank account information, payment card primary account number (PAN), transaction history, trading data, and/or tax identification.

4.4. Online Identifiers:

Geo location/tracking details, browser fingerprint, OS, browser name and version, and/or personal IP addresses.


Survey responses, the information provided to our support team, public social networking posts, authentication data, security questions, user ID, click-stream data, and other data collected via cookies and similar technologies.

5. How your personal information is used

Codyfight’s primary purpose in collecting personal information is to provide you with the most accurate information about Codyfight’s Project and to make sure that any funds gathered during Project are legal and can be used to develop a great product for you. In general, Codyfight uses personal information to create, develop, operate, deliver, and improve Codyfight’s Website, content, and advertising, and for the prevention of anti-fraud. Codyfight may use this information in the following ways based on Codyfight’s contract with you:

5.1. To maintain legal and regulatory compliance:

to legally use the funds gathered during Project Codyfight is subject to laws and regulations requiring Codyfight to collect and use your personal identification information, formal identification information, transaction information, online identifiers, and/or usage data in certain ways. For example, Codyfight must identify and verify customers sending funds to Codyfight’s Project in order to comply with anti-money laundering and terrorist financing laws across jurisdictions. In addition, Codyfight uses third parties to verify your identity by comparing the personal information you provided against third-party databases and public records.

5.2. To provide you services:

Codyfight processes your personal information in order to provide services to you. For example, when you want to buy Codyfight tokens, Codyfight requires certain information such as your identification, contact information, and payment information. Codyfight cannot provide you with services without such information.

5.3. To provide Service communications:

Codyfight sends administrative information to you to keep you updated about Codyfight’s Project, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect you.

5.4. To provide customer service:

Codyfight processes your personal information when you contact Codyfight to resolve any questions, disputes, or troubleshoot problems. Codyfight may process your information in response to another customer’s request, as relevant. Without processing your personal information for such purposes, Codyfight cannot respond to your requests.

5.5. To ensure quality control:

Codyfight processes your personal information for quality control and staff training to make sure Codyfight continues to provide you with accurate information. If Codyfight does not process personal information for quality control purposes, you may experience issues on the Website. Codyfight basis for such processing is based on the necessity of performing Codyfight’s contractual obligations with you.

5.6. To ensure network and information security:

Codyfight processes your personal information in order to enhance security, monitor, and verify identity, combat spam or other malware or security risks, and comply with applicable security laws and regulations. Without processing your personal information, Codyfight may not be able to ensure the security of Codyfight’s Website and satisfy Codyfight’s legal obligations.

5.7. For research and development purposes:

Codyfight processes your personal information to better understand the way you use and interact with the Website. In addition, Codyfight uses such information to customize, measure, and improve the content and layout of the Website. Without such processing, Codyfight cannot ensure your continued enjoyment of the Website. Codyfight processes this personal information to satisfy Codyfight’s legitimate interests as described above.

5.8. To engage in marketing activities:

Based on your communication preferences, Codyfight may send you marketing communications to inform you about Codyfight’s events or Codyfight’s partner events; to deliver targeted marketing; and to provide you with promotional offers based on your communication preferences. Codyfight uses information about your usage of the Website and your contact information to provide marketing communications. You can opt out of Codyfight’s marketing communications at any time. Codyfight will not use your personal information for purposes other than those purposes Codyfight has disclosed to you, without your permission. From time to time Codyfight may request your permission to allow Codyfight to share your personal information with third parties. You may opt-out of having your personal information shared with third parties, or allowing Codyfight to use your personal information for any purpose that is incompatible with the purposes for which Codyfight originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your personal information, certain features or services may not be available to you.

6. Collection and use of information collected automatically

Codyfight receives and stores certain types of information automatically, such as whenever you interact with the Website. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, device ID, operating system version, web-browser software, and your Internet Protocol (IP) address/MAC address/device identifier. For example, Codyfight automatically receives and records information on Codyfight’s server logs from your browser, including how you came to and used the Services; your IP address; device type and unique device identification numbers, device event information (such as crashes, system activity, and hardware settings, browser type, browser language, the date and time of your request and referral URL), broad geographic location (e.g. country or city-level location) and other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser. Codyfight may also collect information about how your device has interacted with the Website, including pages accessed and links clicked. Codyfight may use identifiers to recognize you when you arrive at the Website via an external link, such as a link appearing on a third-party Website.

7. Information sharing with third parties

Codyfight allows your personal information to be accessed only by those who really need to in order to perform their tasks and duties and to share with third parties who have a legitimate purpose for accessing it. Codyfight will never sell or rent your personal information. Codyfight will only share your information in the following circumstances:


Codyfight shares your information with third-party identity verification services in order to prevent fraud. This allows Codyfight to confirm your identity by comparing the information you provide Codyfight to public records and other third-party databases. These service providers may create derivative data based on your personal information that can be used solely in connection with the provision of identity verification and fraud prevention services.


Codyfight may share your information with service providers under contract who help with parts of Codyfight’s Project such as marketing and technology services. Codyfight’s contracts require these service providers to only use your information in connection with the services they perform for Codyfight and prohibit them from selling your information to anyone else.


Codyfight shares your information with financial institutions with which Codyfight partners to process payments you have authorized.


Codyfight may share your information with law enforcement, officials, or other third parties when Codyfight is compelled to do so by a subpoena, court order, or similar legal procedure, or when Codyfight believes in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate any violations. Please note that any third parties you interact with may have their privacy policies, and Codyfight is not responsible for their operations, including, but not limited to, their information practices. Information collected by third parties, who may include such things as contact details or location data, is governed by their privacy practices. Codyfight encourages you to learn about the privacy practices of those third parties.

8. How Codyfight protects and stores personal information

Codyfight understands how important your privacy is, which is why Codyfight maintains (and requires its service providers to maintain) appropriate physical, technical, and administrative safeguards to protect the security and confidentiality of the personal information you entrust to Codyfight. However, Codyfight cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your personal information. When registering with the Website, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third parties, and to immediately notify Codyfight if you become aware of any unauthorized access to or use of your account. Furthermore, Codyfight cannot ensure or warrant the security or confidentiality of the information you transmit to Codyfight or receive from Codyfight by Internet or wireless connection, including email, phone, or SMS, since Codyfight has no way of protecting that information once it leaves and until it reaches Codyfight. If you have reason to believe that your data is no longer secure, please contact Codyfight e at the email address, mailing address, or telephone number listed at the end of this Privacy Policy.

9. Retention of personal information

Codyfight will only retain your personal information for as long as necessary to fulfill the purposes for which Codyfight collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about Codyfight’s typical retention periods for different aspects of your personal information are described below.


Contact Information such as your name, email address, and telephone number for marketing purposes is retained on an ongoing basis until you un-subscribe. Thereafter Codyfight will add your details to Codyfight’s suppression list indefinitely.


Content that you post on the Website such as support desk comments, photographs, videos, blog posts, and other content may be kept indefinitely after you close your account for audit and crime prevention purposes.


Recording of Codyfight’s telephone calls with you may be kept for a period of up to six years.


Information collected via technical means such as cookies, webpage counters, and other analytics tools is kept for a period of up to one year from the expiry of the cookie.

10. Children’s personal information

Codyfight does not knowingly request to collect personal information from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, Codyfight will require the user to close his or her account and will not allow the user to continue to participate in Project. Codyfight will also take steps to delete the information as soon as possible. Please notify Codyfight if you know of any individuals under the age of 18 participating in Codyfight’s Project so Codyfight can take action to prevent access to Project.

11. Individual Rights

When Codyfight receives an individual rights request via email Codyfight may take steps to verify your identity before complying with the request to protect your privacy and security:

11.1. Right to withdraw consent.

You have the right to withdraw your consent to the processing of your personal information collected on the basis of your consent at any time. Your withdrawal will not affect the lawfulness of data processing based on consent before your withdrawal.

11.2. Right of access to and rectification of your personal information

You have a right to request that Codyfight provide you a copy of your personal information held by Codyfight. This information will be provided without undue delay subject to some fee associated with the gathering of the information (as permitted by law) unless such provision adversely affects the rights and freedoms of others. You may also request Codyfight to rectify or update any of your personal information held by Codyfight that is inaccurate. Your right to access and rectification shall only be limited where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of persons other than you would be violated.

11.3. Right to erasure.

You have the right to request the erasure of your personal information that: (a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing that you previously consented, but later withdraw such consent; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for Codyfight’s processing. The above is subject to limitations by relevant data protection laws.

11.4. Right to data portability.

If Codyfight processes your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have Codyfight transfer your personal information directly to another "controller", where technically feasible, unless the exercise of this right adversely affects the rights and freedoms of others. A "controller" is a natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of your personal information.

11.5. Right to restriction of or processing.

You have the right to restrict or object to Codyfight processing your personal information where one of the following applies:


You contest the accuracy of your personal information that Codyfight processed. In such instances, Codyfight will restrict processing during the period necessary for Codyfight to verify the accuracy of your personal information.


The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead.


Codyfight no longer needs your personal information for the purposes of the processing, but it is required by you to establish exercise or defense of legal claims.


You have objected to processing, pending the verification of whether the legitimate grounds of Codyfight processing override your rights.

11.6. Right to lodge a complaint.

If you believe that Codyfight has infringed your rights, Codyfight encourages you to contact Codyfight first at [email protected] so that Codyfight can try to resolve the issue or dispute informally. You can also complain about Codyfight’s processing of your personal information to the relevant data protection authority. You can complain in the EU member state where you live or work, or in the place where the alleged breach of data protection law has taken place.


Your rights to personal information are not absolute. Access may be denied when:


Denial of access is required or authorized by law;


Granting access would have a negative impact on other's privacy;


To protect Codyfight’s rights and properties; and


Where the request is frivolous or vexatious.

12. Cookies

The Website may use a browser feature called a "cookie" to collect information anonymously and track user patterns on the Website. A cookie is a small text file containing a unique identification number that identifies a customer’s browser, but not the customer personally, each time that customer visits a website using cookies. Cookies tell Codyfight which pages of the Website are visited and how many people visited each one. This helps enhance visitors’ online experience. Cookies also serve to identify your computer so that your preferences can be saved for future visits, and Codyfight may work with third parties that use these cookies to help Codyfight. You have the right to decide whether to accept cookies. You can exercise your preferences in relation to cookies served on the Website. You can reset your browser to either refuse to accept all cookies or to notify you when you have received a cookie. However, if you refuse to accept cookies, you may not be able to use some of the features available on the Website. Codyfight uses Google Analytics to carry out statistical analysis of Website use, Website interactions and paths through the Website to evaluate and develop our Website. This is known as 'digital analytics'. Codyfight may also record certain information that You provide during a visit in Website or other process. This information allows Codyfight to understand individual behaviors and needs more accurately. For more information on how Google uses the data collected via this service, see here: To opt out of being tracked via Google Analytics, you can also use Google's opt-out browser add-on:

13. How to contact Codyfight

If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, you should first contact us at [email protected], or by writing to OU Codyfight at Papiniidu tn 5 Pärnu, Pärnu Pärnumaa 80042, Estonia. You can also complain about Codyfight’s processing of your personal information to the relevant data protection authority. You can complain in the EU member state where you live or work, or in the place where the alleged breach of data protection law has taken place.