Privacy Policy

1. Overview

COBOL Pro is committed to protecting your privacy and maintaining the confidentiality of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you use our services.

We adhere to international privacy standards including GDPR, CCPA, and other applicable regulatory frameworks.

2. Information We Collect

2.1 Personal Information

We collect information that identifies you personally, including:

• Name and contact information
• Email addresses and phone numbers
• Job title and company information
• Authentication credentials
• Payment and billing information

2.2 Technical Information

We collect information about your use of our services:

• IP addresses and device identifiers
• Browser type and version
• Operating system information
• Usage patterns and preferences
• Log files and error reports

2.3 COBOL System Data

Information from your COBOL systems for analysis:

• Source code structure (not content)
• System metadata and configurations
• Performance and usage metrics
• Dependency relationships
• Documentation artifacts

Data We Never Collect: Social Security numbers, financial account details, health records, biometric data, location tracking, or any data not explicitly required for service provision.

3. How We Use Your Information

We use your information for the following purposes:

• Service Provision - To provide, maintain, and improve our COBOL analysis and documentation services
• Communication - To communicate with you about our services, support, and important updates
• Customization - To personalize your experience and provide relevant content and recommendations
• Security - To protect our services and users from security threats and unauthorized access
• Legal Compliance - To comply with applicable laws, regulations, and legal processes
• Business Operations - To conduct our business operations, including analytics and service improvement

4. Information Sharing

We do not sell your personal information to third parties. We may share your information in the following circumstances:

• Service Providers - With trusted third-party service providers who assist us in operating our business
• Legal Requirements - When required by law, regulation, legal process, or governmental request
• Business Transfers - In connection with mergers, acquisitions, or other business transactions
• Consent - When you have given explicit consent for specific sharing purposes
• Protection - To protect our rights, property, safety, or that of our users or others

Absolute Prohibitions: No sale, licensing, or commercialization of client data. No use of proprietary code for AI training without explicit consent. No sharing with competitors, marketing partners, or data brokers.

5. Data Retention

We retain your information only as long as necessary to fulfill the purposes outlined in this policy:

• Account Information - Duration of account plus 7 years for business records
• Technical Logs - 90 days for operational logs, 1 year for security logs
• COBOL Analysis Data - Duration of service agreement plus 1 year
• Marketing Data - Until consent is withdrawn or 3 years of inactivity

6. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information:

• Access - Request access to your personal information we hold
• Correction - Request correction of inaccurate or incomplete information
• Deletion - Request deletion of your personal information
• Portability - Request transfer of your data to another service provider
• Restriction - Request restriction of processing of your personal information
• Objection - Object to processing of your personal information

7. Security Measures

We implement comprehensive security measures to protect your information:

• End-to-end encryption for data in transit and at rest
• Multi-factor authentication and access controls
• Regular security audits and penetration testing
• SOC 2 Type II and ISO 27001 compliance
• Employee security training and background checks
• Incident response and breach notification procedures

8. Cookies and Tracking

We use cookies and similar technologies to enhance your experience:

• Essential Cookies - Required for basic website functionality and security
• Analytics Cookies - Help us understand how you use our website to improve it
• Preference Cookies - Remember your settings and preferences
• Marketing Cookies - Used to deliver relevant advertisements and measure effectiveness

9. International Transfers

Your information may be transferred to and processed in countries other than your own with appropriate safeguards:

• Adequacy decisions by relevant data protection authorities
• Standard contractual clauses approved by the European Commission
• Certification under approved certification mechanisms
• Your explicit consent for specific transfers

10. Children's Privacy

Our services are designed exclusively for enterprise use and are not directed at individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware of such collection, we will delete the information immediately.

11. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes through our website or by email at least 30 days prior to implementation.

12. Contact Information

If you have questions about this Privacy Policy or our privacy practices, please contact us:

EU Supervisory Authority: If you are located in the European Union and have concerns about our data processing that cannot be resolved directly with us, you have the right to lodge a complaint with your local supervisory authority.

Lead Supervisory Authority: Irish Data Protection Commission (DPC), Email: info@dataprotection.ie, Phone: +353 (0)761 104 800