1code Studio Privacy Policy
Last updated: 30 October 2026 · Version 1
This policy explains what personal information 1code collects when you use 1code Studio and its apps, why we collect it, who helps us handle it, where it goes, how long we keep it and what you can do about it. 1CODE X LTD, a company in the United Kingdom, is responsible for your information wherever you live. You sign in with 1code ID, not a password. Your content is yours: we keep it to give you the service, and we do not sell it, advertise with it or use it to train AI. If you connect your own AI agent, it can do only what you allow, sensitive actions wait for your approval on your phone, and you can read everything it did for a year. The first part of this policy applies to everyone. The country sections after it add only what is different or extra where you live.
Who we are
1code Studio is one website, 1code.studio. It shows the country section for the country you give in your account. 1code.co.za is the South African door to the same website, and 1code.uk the UK door.
1CODE X LTD is a company registered in England and Wales, company number 12828341, at 2 Centurion Way, Credenhill, Hereford HR4 7FF, United Kingdom. It operates 1code ID and 1code Mail for everyone, runs 1code Studio, and publishes the 1code phone app on Google Play. It decides what personal information is collected and why. That makes it the controller of your information (the "responsible party" in South African law), wherever you live.
1code X (Pty) Ltd is a company registered in South Africa, registration number 2025/981275/07, at 2 The Circus St, Three Rivers, Vereeniging 1935, South Africa. People who live in South Africa contract with it for everything they use and buy on 1code, and it bills them in rand through Paystack. It uses 1CODE X LTD to run 1code, including 1code ID and 1code Mail, for them. It handles the information it needs for this on behalf of 1CODE X LTD and under its rules.
Everyone outside South Africa contracts with, and is billed by, 1CODE X LTD, through Stripe.
Our team works from South Africa.
In this policy, "1code", "we" and "us" mean 1CODE X LTD, and for contracts and billing in South Africa also 1code X (Pty) Ltd. "You" means the person using 1code.
This policy applies to all of 1code: Docs, Sheets, Slides, Pdf, Drive, Mail, Channels, Rooms, Calendar, Project, Store, Books, 1code ID and the 1code phone app. It also covers the 1code connector and the developer API.
When you are in charge of the information
Sometimes you, not we, decide what happens to other people's information. Then you are the controller (or responsible party) and we handle that information for you, only on your instructions. Our Terms of Service contain the data processing agreement for this, under Article 28 of the GDPR and the UK GDPR and section 21 of South Africa's POPIA.
This applies to:
- Company mailboxes. Addresses like name@company.1code.email belong to the company. The company can see and close them.
- Your audience in Rooms. The people who sign up for, join or pay for your presentations, meetings and rooms, and the people who watch what you share.
- Your shoppers in Store. The people who buy from your online store or fill in forms on your website.
- Your clients in Books. The people and businesses you send invoices to.
- Your workspace. The people you invite and the content they add, where you run the workspace for your organisation.
If you are in someone else's audience, mailbox, store or client list and have a question about your information, ask them first. If they do not answer, write to us and we will help.
What we collect
We collect only what each app needs to work. Here it is, app by app.
Your 1code account and 1code ID
You sign in to every 1code app with 1code ID. There is no password. In the 1code phone app, you sign in with your phone and your fingerprint or face. On the web, you may get a one-time code by email, or a request to approve the sign-in on your phone.
- Account: a username you choose. An email address only if you add one, kept only once you verify it. Your language, time zone and country, if you give them.
- Your phone: the public half of the key your phone creates, the certificate we issue for it (serial number and dates), the type of phone, what protects the key, and a device name you can set. The private key never leaves your phone.
- Sign-in approvals: which app or website asked, when, the identifier we released for you, and what you agreed to share.
- Recovery: the people you choose as key holders, the invitations you send, and any recovery requests with who confirmed them and when.
- Security and activity records: the time, device and action for sign-ins and important changes, such as adding a phone or starting a recovery.
- Identity checks for other businesses: if a business asks you to prove who you are, you can photograph an identity document. The images go to that business's verification service, which is named on screen first. 1code ID keeps no copy.
We never receive your fingerprint or face. See "The 1code phone app" below.
Docs, Sheets, Slides, Pdf, Drive and Project
- Your content: documents, sheets, decks, PDFs, videos, recordings, pictures, notes, boards and Kanbans, with their titles, folders, comments, checklists, due dates and earlier versions.
- Sharing: who you share with and what they may do.
- Storage use: how much room your files take.
- Workspaces: your workspaces, their members and their roles, and your settings.
- Account: your 1code ID identifier, your name and your addresses.
- Your mail: messages you send and receive, attachments, drafts, scheduled and snoozed mail, labels, filters, signatures and templates.
- Address suggestions taken from your own mail, and your settings (time zone, language, region).
- Sender checks: the results of SPF, DKIM and DMARC checks on incoming mail, spam reports and the senders you block.
- A sending record for each message: when it was sent, from which address, how many recipients were inside and outside 1code, and whether it was delivered. For mail sent outside 1code, also the sender's 1code ID identifier. We do not keep recipient addresses in this record. We use it to stop abuse and to apply the sending limits in our Acceptable Use Policy.
- Contacts: the name and address of people who write to an address in a workspace, when the sender checks show the mail really came from them, and addresses members add by hand. Addresses on 1code.email write only inside 1code. Addresses on your own domain can write outside 1code only to these Contacts, or reply to an email someone sent them.
- Vacation replies: which senders got your automatic reply, so each gets it only once in a while.
- Companies: the company's name and subdomain, its people and roles, invitations (including the personal email an invitation is sent to), aliases, groups, shared-mailbox access and a log of admin actions.
- Keys for mail apps and AI agents: stored only as one-way fingerprints that cannot be turned back into the key.
- Imports: if you bring old mail across, read-only access to your Google or Microsoft account, stored encrypted and deleted when the import ends, or a mail file you upload, also deleted when the import ends.
- DMARC reports that other mail providers send us about mail using our domains. They include the addresses of sending servers.
Channels
- Your messages, replies and reactions, the files you share, the channels you belong to and who else is in them, and which messages have been read.
Rooms
- Sessions: the rooms you open, the names people type to join, when they joined and left, the chat and questions in the session, and a recording when the host records.
- Your audience: sign-ups (name, email and the answers to questions you set), which session they signed up for, and unsubscribes.
- Paid rooms: who paid, for what and when, and whether the payment went through. Card details go straight to our payment provider. We never see full card numbers.
- Viewing numbers: when someone watches a video you share, we count the view without storing anything on their device. We record the page it was watched on, which parts were played, and the country their connection appears to come from. No name or account is attached.
- Camera, microphone and screen: used only while you are in a meeting with them on, or while you record after pressing record. Everyone in a session is shown when it is being recorded. Live sound and video pass through our provider's real-time network. When a session is not recorded, any short pieces of it that passed through our storage are deleted within a day. When a presenter shows a web page to the room, the page passes through our servers and we keep nothing of it.
Calendar
- Your calendars and events (titles, times, places, notes, repeats and reminders), your settings, and the dates other 1code apps put there for you, such as due dates and scheduled rooms.
- Calendars you add by web address. We fetch them every few hours and show them to you.
- If you turn on a calendar's subscribe link, anyone with that link can see that calendar's events. Replace the link to stop the old one.
Store and free sites
- Your business: your name, email, phone number and business details.
- Identity checks before you can sell: you must pass identity checks (KYC) and add a payout account before you can sell. In South Africa we ask for an identity document, a company registration (CIPC) certificate where you trade as a company, a bank letter and proof of address. These are kept in private storage. Only you, our compliance staff and our payment provider, where it must check them, can see them.
- How identity documents are checked: to save you typing, an AI service working only on our instructions reads the documents and fills in the form fields (your name, ID number, company and bank details). Fixed rules then check those fields against each other. A person on our team reviews and approves every application, so no decision about selling is made by a computer alone.
- Your shoppers' orders: name, email, delivery address and what they ordered. You are in charge of this information (see above).
- Free sites at
<name>.1code.host: what you publish. Anyone can see a published site. We count visits from Cloudflare's own server records, without scripts or cookies in your visitors' browsers. If your site collects information from visitors, such as through a form, you are in charge of that information.
Books
- The invoices you create: your clients' names, contact details, billing addresses and tax numbers, what you sold, the amounts and whether they are paid. You are in charge of your clients' information (see above).
Domains
- If you buy a domain through us, we pass your name and contact details to the registrar (domains.co.za or Name.com) and the registry for that domain. Some of it may be published in public domain records where the registry's rules require it.
Billing
- Your plan, your invoices, your billing name and address, and whether each payment went through. Card and bank details go straight to Paystack (South Africa) or Stripe (everywhere else). We never see full card numbers.
When you contact us, give feedback or accept a policy
- Contact form: your name, email, company if you give one, your message, and the country your connection appears to come from.
- Feedback: what you post, the name shown with it, and your votes.
- Acceptance records: which version of each policy you accepted, the country you gave, and when. In 1code ID, also the network (IP) address and the browser or app you accepted from. In Store, also the network (IP) address.
Security records and connection data
- Records of sign-ins, failed attempts and changes to your account.
- The network address of a sign-in attempt, used to limit repeated attempts and forgotten within minutes.
- Our hosting provider sees connection details (IP address, browser, time) as it delivers and protects the service, and keeps them only briefly.
- Until you give your country, we use the country your connection appears to come from to choose which country section and prices to show. We do not store it, except where this policy says so.
Cookies and your browser
We set only what 1code needs to work:
- a sign-in cookie, for up to 30 days unless you sign out;
- a short cookie while you sign in, for up to 10 minutes;
- a cookie that holds the access a shared link gives you, for up to 12 hours;
- a marker that tells a page you are signed in;
- your theme, language and similar choices, kept in your browser.
These do not track you across other websites and are not shared with anyone. We have no advertising or analytics cookies and no tracking scripts from other companies. We count views of shared videos without storing anything on your device. The Cookie Policy (1code.studio/cookies) lists every cookie we use and everything our apps keep in your browser.
Where we get it from
Most of it comes from you. We also get information:
- from other people on 1code, when they share something with you, invite you, add you to a company or choose you as a key holder;
- from people who write to you, when their mail or messages reach your 1code address;
- from services and AI agents you connect, such as Google, Microsoft or Slack;
- from Paystack and Stripe: whether a payment or payout went through, and whether their checks on a seller are complete;
- from domain registrars and registries, about domains you buy through us;
- from other mail providers: sender checks, bounce notices and DMARC reports;
- from your phone and browser, as you use 1code (see "Security records and connection data" and "Cookies and your browser").
Do you have to give it to us?
You choose what you give us. Some things are needed for a service to work:
- An account needs a username and a phone with 1code ID. Without them we cannot give you an account.
- Paying for a plan or a domain needs billing details. Without them you cannot buy.
- Selling needs identity checks and a payout account. Without them you cannot sell.
- A domain needs true contact details, because the registry requires them.
Everything else, such as an email address, a display name or a connected service, is up to you. Leaving it out only means the feature that needs it will not work.
Why we use it
Some laws ask us to name a legal reason (a "lawful basis") for each use. These are ours.
| What we do | Our reason |
|---|---|
| Run your account, sign you in, keep and deliver your content, mail, rooms, calendar, store and invoices | To carry out our agreement with you |
| Bill you and take payment | To carry out our agreement with you |
| Register domains you buy through us, and pass your details to the registrar and registry | To carry out our agreement with you; the registry's rules |
| Send the phone notifications you turned on | To carry out our agreement with you |
| Keep tax and accounting records | The law requires it |
| Identity checks before you sell, and payout details | To carry out our agreement with you, and our legitimate interest in preventing fraud and money laundering and meeting our payment providers' requirements (they have their own legal duties to check sellers). A legal duty only where a law applies to us directly. |
| Security records, spam and malware checks, sending limits, scanning free sites, stopping abuse | Our legitimate interest, and yours, in keeping 1code safe |
| Keep the activity log of connected AI agents and apps | To carry out our agreement with you, and our legitimate interest, and yours, in being able to check what was done in your name |
| Viewing numbers for your videos | Your legitimate interest in knowing how your videos are watched, and ours in running the service |
| Answer the contact form and read feedback | Our legitimate interest in answering you and improving 1code; steps you ask for before an agreement |
| An optional email address, connected services and connected AI agents | Your choice, which you can withdraw at any time |
| Record which policy version you accepted | Our legitimate interest in showing what was agreed |
| Information about other people you put in your audience, mailboxes, store or invoices | Your instructions; you choose the reason |
| Disclose information to authorities | Only where the law requires it |
Where we rely on legitimate interests, we weigh them against your rights, and you can object (see "Your right to object" below). Where we rely on your choice (consent), you can withdraw it at any time. That does not undo what we did before you withdrew it.
What we do not do
- We do not sell or rent personal information.
- We do not show ads or use your information for advertising.
- We do not use your content to train AI, and we do not let our providers train on it.
- We do not add tracking scripts from other companies.
- We do not make decisions about you by computer alone that have legal or similarly serious effects. Automated checks may block a single message, file or page that matches known malware, phishing or child sexual abuse material. A person reviews every pause or removal, and you can always ask a person to look again.
- We do not send marketing or bulk email, and we do not let anyone send it through 1code. Emails to a Rooms audience are limited to confirmations, links and reminders, and 1code Studio has no way to connect an email-marketing service.
- People at 1code do not read your content, unless you ask us to (for support), we must look into abuse or a security problem, or the law requires it. Automated systems check mail for spam, fake senders and malware.
AI agents you connect, and the activity log
You can connect your own AI agent, such as Claude, ChatGPT or Gemini, to 1code. You do this through the 1code connector (MCP) or our developer API, using your own subscription or your own keys.
- Your AI account stays yours. We never ask for, store or pass on the sign-in details of your AI account.
- You choose what it can do. Nothing is connected until you connect it. You choose its access, for example read, draft or send. You can disconnect it at any time.
- What your AI provider receives. Your AI provider receives what you let your agent read, and handles it under its own terms. It is your provider, not ours, so its privacy policy applies to what it receives.
- Sensitive actions wait for you. When an agent asks to send something outside 1code, pay, publish something publicly, or delete something for good, we ask you to approve it on your phone first. This is on by default. Sending inside 1code and moving something to Trash do not ask by default. You can change each of these settings.
- The activity log. We keep a log of what each connected agent did, when, and what you approved or refused. You can read it at any time. We keep it for one year.
- Keys. The keys we issue for a connection are stored only as one-way fingerprints.
The same rules apply to apps that developers build on our API. An app gets only the access you approve, and you can remove it at any time.
Our own AI features
Where 1code itself offers an AI feature, it runs on our own API keys with our AI providers. It never uses your personal AI subscription. Our AI providers act only on our instructions and may not train on your information. We name them on request.
The 1code phone app
The 1code phone app is published on Google Play and operated by 1CODE X LTD, which is the controller of the information in it.
- Fingerprint and face. Your phone checks your fingerprint or face itself. The app asks only "is this the right person?" and receives yes or no. Your fingerprint and face never leave your phone. We never see or store them.
- Your key. The private key that approves your sign-ins is made on your phone, kept in its protected storage behind your fingerprint or face, and never leaves it.
- Notifications. If you allow notifications, we send them through Google Firebase Cloud Messaging. Google receives a token for your phone and the notification itself. A notification carries only what is needed to show it, such as a sender's name and the subject of new mail.
- Camera. Used only to scan codes (to pair a phone, approve a sign-in or confirm a recovery) and, if you choose, to photograph a document. Never in the background.
- Microphone and camera in meetings. Used only while you are in a meeting with them on.
- What the app does not touch. We do not read your address book, messages or photos. We see only the files you choose to share.
- Google Play. Google collects its own information when you download the app, under its own policies. An iPhone app is planned.
Services you connect
You can connect other services to 1code. Each one is your choice, and you can disconnect it at any time. Each handles your information under its own terms.
- Google Calendar (in Calendar). We read the list of your calendars and the events of the calendars you choose, and show them to you. If you ask, we keep your 1code events in one calendar named "1code Calendar" that we create in your Google account. We touch nothing else. Unlinking removes that calendar, ends our access and deletes what we hold.
- Google or Microsoft mail (to import old mail into Mail). Read-only, and only while the import runs.
- Slack (in Project). We keep your Slack workspace's name, the key Slack gives us (encrypted) and which Slack person is which 1code account. We read a Slack message only when you choose to make a card from it.
- Your AI agent. See above.
We keep the keys these services give us encrypted. We never sell what we receive from them, use it for advertising or train AI on it.
1CODE X LTD's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. The use of raw or derived user data received from Google Workspace APIs will adhere to the Google User Data Policy, including the Limited Use requirements.
Who processes it for us
These providers handle personal information for us, only on our instructions, under written data processing agreements.
| Provider | What for | Where |
|---|---|---|
| 1code X (Pty) Ltd | Our South African group company: billing South African customers, the phone app's store listing, and our team in South Africa | South Africa |
| Cloudflare, Inc. | Hosting, database, file storage, video conversion, live rooms, live sound and video, and receiving, routing and sending email | Stored in Western Europe; served from the location nearest each person |
| Resend | Sending email. It keeps a message and the address it went to for up to 30 days. | United States |
| Google Cloud (Key Management) | Holds the key that signs 1code ID's phone certificates | Johannesburg, South Africa |
| Google Firebase Cloud Messaging | Phone notifications | United States and worldwide |
| Paystack | Payments and payouts for South African customers | South Africa, and where Paystack processes |
| Stripe | Payments and payouts for customers outside South Africa | United States and Ireland |
| domains.co.za | Registering domains you buy through us | South Africa |
| Name.com | Registering domains you buy through us | United States |
| AI providers for our own AI features | See "Our own AI features" | We name them, and where they are, on request |
Paystack, Stripe, the domain registrars and registries also use some information for their own legal duties, such as fraud checks, anti-money-laundering checks and registry rules. For that use they decide what happens to it themselves, under their own privacy policies.
We also share information:
- with the people you share content with, and the services you connect;
- with the business you are dealing with, when you buy from a store or join a room;
- with authorities, only where the law requires it. We push back on requests that are not lawful, and we tell you unless the law forbids it.
We will tell business customers at least 30 days before we add or replace a provider that handles the information they put in our care.
Transfers between countries
Your information is stored in Western Europe. 1CODE X LTD is in the United Kingdom. Our team works from South Africa. Some providers are in the United States. So your information crosses borders. This is how we protect it:
| From | To | Why | Protection |
|---|---|---|---|
| United Kingdom | European Union | Storage in Western Europe | UK law recognises the European Economic Area as giving adequate protection |
| European Union | United Kingdom | We are a UK company | The EU recognises the United Kingdom as giving adequate protection |
| United Kingdom and European Union | South Africa | Our team works from there; Paystack, domains.co.za and Google Cloud Key Management are there | For our team and Google Cloud, the EU Standard Contractual Clauses (2021/914), with the UK Addendum to them. Paystack and domains.co.za act as our processors under their own terms |
| United Kingdom and European Union | United States | Cloudflare, Resend, Stripe, Google Firebase and Name.com | The EU–US Data Privacy Framework and its UK Extension, where the provider is certified to it; otherwise the EU Standard Contractual Clauses with the UK Addendum |
| South Africa | United Kingdom, European Union and United States | All of the above | Section 72 of POPIA: personal information leaves South Africa only where it allows, for example because the receiving country has an adequate law, or binding rules or a contract protect it (see "South Africa" below) |
You can ask us for a copy of these safeguards at privacy@1code.email. We may hide business details in it that are not about your information.
Transfers between 1CODE X LTD and 1code X (Pty) Ltd are covered by a data transfer agreement between the two companies: the EU Standard Contractual Clauses with the UK Addendum. to be confirmed — owner signs the intra-group transfer agreement
How long we keep it
We keep information only as long as we need it. When your account closes, we delete your data within 30 days, unless the law requires us to keep something longer.
| What | How long |
|---|---|
| Your 1code ID account | While it is open; removed within 30 days of deleting it |
| Retired or revoked phone certificates | 12 months, so revocation checks keep working |
| Security and activity records | 12 months |
| Recovery requests and confirmations | 12 months after they end |
| 1code ID sessions | A few hours |
| Sign-ins to the apps | Up to 30 days |
| Your files and content, including Channels messages, calendars, projects, store orders and invoices in Books | Until you delete them or your account closes |
| Anything in Trash, in every app, Mail included | 30 days, then deleted for good |
| While your account is open | |
| Closed Mail addresses | Never given to anyone else |
| Mail sending records, the sending log and DMARC reports | 13 months |
| Bounce notices | 30 days |
| Vacation-reply records | 30 days |
| Scrambled address used to limit 1code ID emails | 2 days |
| Resend's copy of a message it sent | Up to 30 days |
| Large-file download links in Mail | 30 days |
| One-time links to open an attachment | A day after they expire |
| A company's admin log | While the company's account is open |
| Workspace Contacts | While the workspace exists; a contact reported as spam is removed |
| Unrecorded live pieces of a session | Within a day |
| Chat, notes and attendance of an unrecorded meeting | 12 months after it ends |
| Recordings | Until the host deletes them |
| Your audience's sign-ups | Until you delete them or your account closes |
| Viewing numbers | While the video exists |
| Connected services (Google, Microsoft, Slack) | Until you disconnect them |
| Phone notification tokens | Until you turn notifications off, sign out on that phone or remove the app |
| Details of a domain you bought through us | While we manage the domain for you, and after that as long as the registry's rules require |
| AI agent activity log | One year |
| KYC documents | 5 years after your selling account closes, then deleted |
| Billing, invoices we issue, and tax records | 6 years after the end of the tax year they belong to in the United Kingdom, and 7 years in South Africa, as tax and company law requires |
| Acceptance records | While your account is open, and 6 years after it closes, the time within which a claim about the agreement can usually be brought |
| Contact-form messages | 12 months |
| Feedback | Until you or we delete it |
| Limits on repeated sign-in attempts | Minutes |
| Backups | Up to 30 days, so deleted data is gone from them after that |
We delete data on these schedules automatically.
Security
- Everything is encrypted on its way to and from us, and our storage provider encrypts it at rest.
- There are no passwords to steal. You sign in with your phone or a one-time code, and your phone's private key never leaves it.
- Keys that other services give us are kept encrypted. Keys we issue to apps and AI agents are kept only as one-way fingerprints.
- Private videos are served only through short-lived links.
- KYC documents are kept in private storage that is never public.
- Only people who need it for their work can reach systems holding your information.
- If a breach puts your information at risk, we tell you and the authorities your law requires, in the time it requires. If it affects information you put in our care, we tell you so you can tell the people concerned.
If you find a security problem, please tell us at privacy@1code.email.
Scanning and pausing
To keep people safe, we scan published free sites for phishing, malware, impersonation and other harm. We may pause an account, site or app that causes harm. When we do, we tell its owner why, unless the law or a safety risk stops us, and we tell people who use an app we pause that it is paused. A person reviews every pause or removal. If we pause something at once to stop harm in progress, a person reviews it straight after. Nothing with serious effects is decided by a computer alone.
Children
1code is for people aged 18 or over and is not designed for children. You must be 18 or over to have a 1code account. We do not knowingly collect children's information for an account. If we learn a child has an account, we delete it.
Rooms audiences who join without an account are not targeted at children. If you invite anyone under 18 to a room, you are responsible for having their parents' or school's consent. If you sell to children in your store, you are responsible for any consent their law requires.
If you think a child's information is in 1code without that consent, write to privacy@1code.email.
Your rights and how to use them
Wherever you live, you can ask us to:
- tell you whether we hold information about you, and give you a copy;
- correct it;
- delete it;
- give it to you, or to another service, in a common format;
- stop or limit using it, where the law allows;
- stop using it where we rely on legitimate interests;
- withdraw a choice you made, at any time;
- have a person look again at a decision made by computer, hear your view and let you challenge it.
Your right to object. Where we rely on legitimate interests, you can object at any time, for reasons about your own situation. We then stop, unless we have strong legitimate grounds that outweigh your interests, rights and freedoms, or we need the information to make or defend a legal claim.
You can also do much of this yourself: download your files, remove an optional email, remove a phone, disconnect a service or AI agent, and close your account.
How to ask. Write to privacy@1code.email. It is free. We may ask you to confirm it is you by approving on your phone with 1code ID. We answer within one month, or sooner where your law requires. If a request is complex, we may need longer, and we will tell you why within that month.
If your information is in a company mailbox, an audience, a store or an invoice, we may pass your request to the business in charge of it, and help them answer.
If we cannot do what you ask, we tell you why.
Complaints
Please tell us first at privacy@1code.email. We acknowledge a complaint within 30 days and tell you what we did about it.
You can also complain to a regulator at any time:
- United Kingdom: the Information Commissioner's Office.
- South Africa: the Information Regulator.
- European Union: the data protection authority where you live, work or where the problem happened.
- Elsewhere: your national data protection authority, where there is one.
Contact details are in the country sections below.
Changes to this policy
When we change this policy, we change the date and version at the top. We tell you by email or in 1code at least 30 days before a significant change applies. We keep a record of which version and which country section you accepted. Accepting this policy means you have been shown it. It is not consent, and we do not rely on it as consent. Where we need your consent, we ask for it separately.
This policy lives at 1code.studio/privacy.
Contact
1CODE X LTD, 2 Centurion Way, Credenhill, Hereford HR4 7FF, United Kingdom.
- Privacy, security, reports of abuse or illegal content, appeals and authorities: privacy@1code.email
- Help, billing and complaints: support@1code.studio
We have not appointed a data protection officer, because the law does not require one for what we do today.
By country
South Africa your region
This section adds what is different or extra if you live in South Africa.
The law. The Protection of Personal Information Act, 2013 (POPIA) applies to how we handle your information.
1code X (Pty) Ltd is itself responsible for the tax and accounting records it must keep in South Africa, such as invoices.
Who is responsible. 1CODE X LTD is the responsible party for your information, as for everyone. 1code X (Pty) Ltd contracts with you for everything you use and buy on 1code, bills you in rand, and uses 1CODE X LTD to run 1code for you. It handles what it needs for that for 1CODE X LTD. It keeps the accounting records South African tax law requires. Where you are in charge of other people's information (see "When you are in charge of the information"), we are your operator under section 21 of POPIA.
Information Officer. Our Information Officer is Thebe Phele, director of 1code X (Pty) Ltd and of 1CODE X LTD, reachable at privacy@1code.email. to be confirmed — registration with the Information Regulator, owner
UK law applies too. Because 1CODE X LTD is a UK company, the UK GDPR also protects your information. You have the rights in the United Kingdom section as well, and you can also complain to the ICO.
Our reasons. The reasons in "Why we use it" match section 11 of POPIA: your consent, carrying out our agreement with you, a legal duty, and legitimate interests. Your agreement is with 1code X (Pty) Ltd, and 1CODE X LTD provides the service under it. So where "Why we use it" says "our agreement with you", for you it means that agreement.
Laws that require some of it. The Tax Administration Act, 2011, the Value-Added Tax Act, 1991 and the Companies Act, 2008 require billing and accounting records to be kept.
Identity checks before selling. Store asks for KYC documents before you can sell and receive payouts. We use them to carry out our agreement with you, and for our legitimate interest in preventing fraud and money laundering and meeting our payment providers' requirements. We rely on a legal duty only where a law applies to us directly.
Your rights. You have the rights in POPIA, including to know what we hold (section 23), to have it corrected or deleted (section 24), to object (section 11(3)), and not to be subject to a decision made by computer alone (section 71). We do not send you direct marketing (section 69).
Records about you (PAIA). You can ask for records under the Promotion of Access to Information Act, 2000. Our PAIA manual is at 1code.co.za/paia.
Sending your information outside South Africa (section 72). Your information is stored in Western Europe, controlled from the United Kingdom, and some providers are in the United States. We send it there only because:
- the United Kingdom and the European Union have data protection laws that give protection substantially similar to POPIA's;
- our providers are bound by written agreements that give that same protection, including on passing the information on; and
- the transfer is needed to carry out our agreement with you.
Breaches. If a breach affects your information, we tell the Information Regulator and you as soon as reasonably possible, as section 22 of POPIA requires.
Children. POPIA treats anyone under 18 as a child. You must be 18 or over to have an account.
Complaints. Information Regulator (South Africa): inforegulator.org.za, enquiries@inforegulator.org.za or POPIAComplaints@inforegulator.org.za, 010 023 5200.
Consumer law. The Consumer Protection Act, 2008 and the Electronic Communications and Transactions Act, 2002 also protect you. Our Terms of Service set out the supplier details that ECTA requires.
United Kingdom
This section adds what is different or extra if you live in the United Kingdom.
The law. We are a UK company. The UK GDPR and the Data Protection Act 2018 govern everything we do with your information, wherever you live. The Privacy and Electronic Communications Regulations (PECR) govern cookies and electronic marketing.
Who is responsible. 1CODE X LTD is the controller. We do not need a UK representative. Our ICO registration (data protection fee) number is to be confirmed — ICO registration number, owner.
Our reasons. Carrying out our agreement with you (Article 6(1)(b)), legal duties (Article 6(1)(c)), legitimate interests (Article 6(1)(f)), and your consent (Article 6(1)(a)), as shown in "Why we use it". We do not process special category data, unless you choose to put it in your own content.
Your rights. You have the rights in Articles 15 to 22 of the UK GDPR: access, correction, deletion, restriction, portability, objection, and not being subject to a decision made by computer alone with legal or similarly serious effects. We answer within one month. For complex requests we may extend this by up to two more months, and we tell you within the first month.
Cookies (PECR). We use only cookies and browser storage that are strictly necessary for the service you asked for, or that keep your own choices. So we do not ask for consent. We count views of shared videos without storing anything on your device.
Marketing (PECR). We do not send you marketing email or texts. Messages about your account, your security or a change to our terms are not marketing.
Transfers. See "Transfers between countries". Transfers to South Africa use the UK Addendum to the EU Standard Contractual Clauses. Transfers to the United States use the UK Extension to the EU–US Data Privacy Framework where the provider is certified, and otherwise the UK Addendum.
Breaches. We tell the ICO within 72 hours of learning of a breach that puts people at risk, and we tell you without undue delay when the risk to you is high.
Children. 1code is for people aged 18 or over and is not designed for children. Rooms audiences who join without an account are not targeted at children. A host who invites anyone under 18 is responsible for having their parents' or school's consent.
Complaints. Information Commissioner's Office: ico.org.uk, 0303 123 1113, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
European Union
This section adds what is different or extra if you live in the European Union or the wider European Economic Area.
The law. The General Data Protection Regulation (GDPR) applies. Where we host what you publish or share, the Digital Services Act (DSA) also applies.
Who is responsible. 1CODE X LTD, in the United Kingdom, is the controller. We have no office in the EU.
Representative. We have not yet appointed a representative in the EU under Article 27 GDPR, or a legal representative under Article 13 of the Digital Services Act. We will appoint and name them before we market to people in the EU. Until then, write to privacy@1code.email.
Our reasons. The same as in the United Kingdom section, under Article 6 GDPR.
Your rights. You have the rights in Articles 15 to 22 GDPR, the same as listed in the United Kingdom section. We answer within one month.
Transfers. Your information is stored in the EU. The EU recognises the United Kingdom as giving adequate protection. Transfers to South Africa use the EU Standard Contractual Clauses (2021/914). Transfers to the United States use the EU–US Data Privacy Framework where the provider is certified, and otherwise the Standard Contractual Clauses.
Reports and decisions about content (DSA).
- Anyone can report content on 1code they believe is illegal, by writing to privacy@1code.email or using the report link where we show one. We use the reporter's name and email only to handle the report and tell them what we decided.
- If we remove, restrict or pause your content or account, we tell you why and how to challenge the decision.
- Our point of contact for users and authorities under the DSA is privacy@1code.email, in English.
- We show no ads, so no ads are ever targeted at you, whatever your age.
Business users (P2B). Where the EU or UK platform-to-business rules apply to a service (such as a future app marketplace), we follow them. If you sell through 1code Store, we do not use your shoppers' information for our own purposes, we do not give it to other sellers, and you can export it at any time.
Complaints. You can complain to the data protection authority in the EU country where you live, work, or where the problem happened. The list of authorities is at edpb.europa.eu.
Everywhere else
The policy above applies to you in full, wherever you are. If your country's law gives you more rights, you have those too. Where your law asks us to name a privacy officer, data protection contact or grievance officer, write to privacy@1code.email. If you are not happy with our answer, you can complain to your national data protection authority, where there is one.

