Privacy Policy

Last updated: September 14, 2026

Ethics Code LLC (“Ethics Code,” “we,” “our,” or “us”) helps U.S. companies scale engineering capacity with distributed senior talent. This Privacy Policy explains how we process personal data from visitors to https://ethicscode.ai (the “Site”) and people who contact us or subscribe to our communications.

If you are a California resident, see Section 14.

Table of contents

  1. 1. Scope
  2. 2. Personal data we collect
  3. 3. How we use personal data
  4. 4. Disclosures of personal data
  5. 5. International data transfer
  6. 6. Legal basis
  7. 7. Cookies and similar technologies
  8. 8. Security
  9. 9. How long we retain personal data
  10. 10. Your rights as a data subject
  11. 11. Your privacy choices
  12. 12. Personal data of minors
  13. 13. External links
  14. 14. California notice
  15. 15. Changes to this policy
  16. 16. Contact us

1. Scope

This Policy describes how we process personal data as a controller when you use the Site, submit a Discovery Call request, use the Site assistant, or join our mailing list. When we process personal data on behalf of a business customer under a services agreement, that contract and the customer’s privacy notice apply to that processing.

This Policy does not apply to employee or job-applicant records, except where those people use the Site as visitors. We may provide additional notices for a specific event, form, or campaign.

2. Personal data we collect

The data we collect depends on how you interact with us. We may collect data from you, automatically from your device, and from service providers that help us operate the Site.

Data you provide

  • Discovery Call and contact forms. Name, work email, company, role, area of interest, and the message you send. Submissions may be forwarded to a webhook or inbox we configure to handle inquiries.
  • Email and other messages. If you write to privacy@ethicscode.ai or build@ethicscode.ai, we keep the content of that correspondence and your contact details.
  • Newsletter signup. Email address and your consent records (including that you asked to receive Ethics Code communications and agreed to this Policy). When HubSpot (or another email platform) is connected, that provider stores the subscription on our behalf.
  • Site assistant. The questions and follow-ups you type into the hero chat. Those messages are sent to our language-model provider so we can reply from Ethics Code site content. Do not submit secrets, health data, or other sensitive information in the chat.

Data collected automatically

  • Device and log data. IP address (used in part to limit abuse of our APIs), browser type, approximate general location derived from IP, pages requested, and timestamps.
  • Usage. How you move through the Site (for example, pages viewed). We do not currently load advertising pixels or a third-party analytics tag on the Site. If we enable analytics later, we will update this Policy and, where required, collect consent first.

Data we do not seek

We do not ask for government ID numbers, payment card data, or precise geolocation on this Site. We do not knowingly collect sensitive personal information as defined under the CCPA through these public forms.

3. How we use personal data

  • Services and support. Operate the Site, answer inquiries, schedule Discovery Calls, and deliver professional services under a separate agreement.
  • Communications. Reply to you and, if you opt in, send news, insights, and event invitations. You can unsubscribe at any time.
  • The Site assistant. Generate answers from published Ethics Code content. Chat transcripts are used to provide the reply and to protect the service (rate limits, abuse).
  • Security and integrity. Detect spam, automated abuse, and unauthorized access.
  • Legal. Comply with law, enforce our terms, and establish, exercise, or defend legal claims.
  • Improvement. Understand how the Site is used so we can fix issues and improve content. We do not use chat or form data to train public foundation models.

4. Disclosures of personal data

We do not sell personal data for money. We may disclose data to:

  • Service providers (processors). Hosting (currently Google Cloud Run), email and CRM tools (HubSpot when connected), transactional or marketing email, the language-model provider for the Site assistant (Groq), and similar vendors bound to use data only on our instructions.
  • Professional advisors such as lawyers or accountants, when needed.
  • Legal and safety. If required by law, regulation, legal process, or to protect Ethics Code, our clients, or others.
  • Business transfers. In connection with a merger, financing, or sale of assets, with appropriate safeguards.

We may use aggregated or de-identified information that can no longer reasonably identify you.

5. International data transfer

Ethics Code is organized in the United States and works with teams in the Dominican Republic. The Site is hosted on cloud infrastructure that may process data in the United States, the European Union, or other regions where our providers operate. Language-model and CRM providers may also process data outside your country.

Where a transfer is restricted by law, we rely on appropriate safeguards (such as standard contractual clauses or the provider’s certified transfer mechanism) and on the necessity of the transfer to provide the Site or respond to you.

Where GDPR or similar laws apply, we process personal data on these grounds:

  • Contract / steps prior to contract — to respond to a Discovery Call or services inquiry.
  • Consent — newsletter signup and any non-essential cookies we may add later.
  • Legitimate interests — to operate, secure, and improve the Site, and to prevent abuse, in a way that does not override your rights.
  • Legal obligation — when the law requires us to keep or disclose records.

7. Cookies and similar technologies

The Site uses cookies or similar storage that are needed to run the Site (for example, security and load balancing). We do not currently use advertising cookies. See our Cookie Policy and Cookie Preferences for more detail.

Browser “Do Not Track” is not a consistent standard; we do not respond to DNT. If we later use cookies that would constitute a “sale” or “share” under California law, we will honor a Global Privacy Control (GPC) signal for that browser where required.

8. Security

We use reasonable administrative, technical, and organizational measures (HTTPS, access controls, vendor contracts). No transmission over the internet is completely secure. You use the Site and provide personal data at your own risk.

9. How long we retain personal data

We keep personal data only as long as needed for the purposes in this Policy, including:

  • Inquiry and sales records for as long as we need them to follow up and keep a business file
  • Newsletter contacts until you unsubscribe or we delete the list record
  • Chat and API logs used for rate limiting, typically for a short operational window
  • Longer where required for legal, tax, dispute, or security reasons

10. Your rights as a data subject

Depending on where you live, you may have the right to access, correct, delete, port, restrict, or object to certain processing, and to withdraw consent. To exercise these rights, email privacy@ethicscode.ai. We may need to verify your identity before we respond. You may also complain to your local data-protection authority. We encourage you to contact us first so we can try to resolve the issue.

11. Your privacy choices

  • Marketing email. Use the unsubscribe link in any newsletter, or email privacy@ethicscode.ai. We may still send service messages about an inquiry you opened.
  • Forms and chat. You can choose not to submit personal data; some features will not work without it.
  • Cookies. You can block cookies in your browser. Strictly necessary cookies may still be set. Manage categories on Cookie Preferences.

12. Personal data of minors

The Site is a general-audience business site. It is not directed to children, and we do not knowingly collect personal data from anyone under 16. If you believe we have collected such data, contact privacy@ethicscode.ai and we will delete it.

The Site may link to LinkedIn, Instagram, YouTube, or other third-party sites. Their privacy practices govern those destinations. Review their policies before you provide them data.

14. California notice

This section is for California residents under the CCPA (as amended). “Personal Information” has the meaning given in that law. It does not cover information that is publicly available or otherwise exempt.

In the past 12 months we may have collected the following categories, from you or automatically from your device, to operate the Site and respond to you:

  • Identifiers (name, email, IP address, online identifiers)
  • Professional or employment-related information (company, role)
  • Commercial information related to services you inquire about
  • Internet or electronic activity (Site interactions, chat messages you send)

We disclose these categories to service providers (hosting, email/CRM, AI assistant) and, if required, to government or legal recipients. We do not sell Personal Information for money. We do not currently share Personal Information for cross-context behavioral advertising. We do not use or disclose sensitive Personal Information in a way that would trigger the CCPA “limit the use” right on this Site. We do not have actual knowledge of selling or sharing Personal Information of consumers under 16.

You may request to know, delete, or correct Personal Information, and you have a right to non-discrimination for exercising CCPA rights. Email privacy@ethicscode.ai. We will verify your request using information we already hold. You may use an authorized agent; we may require proof of authorization and may contact you directly to confirm.

15. Changes to this policy

We will post updates on this page and change the “Last updated” date. If a change is material, we may also provide a notice on the Site. Continued use of the Site after an update means the revised Policy applies.

16. Contact us

For questions about this Policy or how we process personal data:

Ethics Code LLC
HQ: 110 East Broward Blvd., Suite 1759, Fort Lauderdale, Florida 33301
LATAM Regional: Suite WP 104, Las Américas Highway, Km. 27 ½, La Caleta, Boca Chica, Santo Domingo Este Province, Dominican Republic
Email: privacy@ethicscode.ai
Website: https://ethicscode.ai

Ethics Code serves the U.S. market from Fort Lauderdale, Florida. Our delivery and team hub is Santo Domingo, Dominican Republic. For a formal privacy request, write to 110 East Broward Blvd., Suite 1759, Fort Lauderdale, Florida 33301 or Suite WP 104, Las Américas Highway, Km. 27 ½, La Caleta, Boca Chica, Santo Domingo Este Province, Dominican Republic, or email privacy@ethicscode.ai.