Privacy Policy

  1. Overview

CODE ONE INC is committed to maintaining the accuracy and security of your personal information. This statement (“Privacy Policy”) explains what types of personal information we may collect about you in the course of our business or the operation of this website, why it is collected, how we use your personal information and when we might transfer your personal information to a third party. It also explains the rights you have to request that we provide you with a copy of the personal information we maintain about you; that we correct the personal information we maintain about you; and, other legal rights you have concerning the personal information we maintain about you.

This Privacy Policy is effective on May 22, 2020. It replaces all other privacy policies that we have issued.  We reserve the right to amend this Privacy Policy at any time and for any reason.   Amendments will be retroactive to January 1, 2020.

In this Privacy Policy the term:

  1. “Individual” means a living natural person, and includes all actual and potential customers of CODE ONE INC, end users of CODE ONE INC products, users of our websites and others about whom we collect, use, store and transfer personal information. Individual does not include our employees, prospective employees and contractors for whom we have a separate privacy policy. We also use “you” or “your” in this Privacy Policy to refer to Individuals.

“CODE ONE INC” means CODE ONE INC, Code One, Inc, SG Products, LLC, and all of its subsidiaries and affiliates, except those which maintain their own privacy policies. CODE ONE INC is also referred to as “we”, “us” and “our”.  “H2One” and “CodeOne” are classification 5 hand sanitizer trademarks that have been filed by Code One, Inc. with the USPTO.  

If you live in the European Economic Area (“EEA”), the State of California, USA or the State of Nevada, USA, you may have additional rights concerning the personal information we maintain about you. 

This Privacy Policy describes a broad range of data processing activities. It is built upon current law, fair information practice principles and best practices.

  1. CODE ONE INC is a Wyoming Limited Company Headquartered in the United States.  

CODE ONE INC is headquartered in Naples, Florida, U.S.A. Your personal information may be transferred to CODE ONE INC locations and to third parties located in the United States and other countries or territories which do not offer the same level of data protection as the country in which you reside. Regardless of the country in which your PI is collected, processed or stored, we will process your PI in accordance with this Privacy Policy.

  1. What is Personal Information?

Personal information (“PI”) means any information that (i) directly and clearly identifies an Individual (for example, your name) or (ii) can be used in combination with other information to reasonably identify an Individual (for example, your gender, age or work address).

  1. What is Sensitive Personal Information?

Sensitive personal information (“Sensitive Information”) is a subset of PI that is more sensitive in nature than PI. It reveals race, religion, national origin, political opinions, union membership, sexual preferences, sexual orientation, genetic data and biometric data.

  1. What PI Do We Collect?

We may collect, store and use different types of PI about you. The types of PI may include:

  • First and last name, home address, business name and address, internet protocol address, email address and business and mobile telephone numbers;
  • Signature, account number and password and credit card number;
  • The amount of time during which you have had an account with CODE ONE INC;
  • Gender, date of birth and marital status; and;
  • Browsing time, cookies information, website history and social media account identifier.

While it is unusual for us to do so, we may sometimes collect Sensitive Information in limited instances.

  1. Do We Collect the PI of Children?

No. CODE ONE INC does not knowingly acquire or retain PI about children under the age of eighteen and will delete such information if collected or processed in error.

  1. Who Gives Your PI to Us?

We collect your PI from you when you: Interact with us using one of our websites before and after becoming a customer or end user; Ask us to provide our products or services to you, and you give us your PI with your request; Communicate with us by telephone, email, one of our websites or hard copy correspondence; Visit one of our websites which include cookies and similar technologies. (See, Section 8 below regarding our use of cookies.); or, Reply to one of our promotions, request a product sample, enter a sweepstakes or contest or subscribe to promotions from us, including by email.

If you fail to provide your PI to us when requested, we may not be able to perform all our legal and contractual obligations or carry out all activities such as providing you with marketing materials. We will make it clear if and when this situation arises and what the consequences of not providing your PI will be.

We also collect your PI from third party parties such as:

  • Those who provide your PI to us so that we can contact you with information about CODE ONE INC products and services; and, our distributors and marketing representatives.
  1. Cookies

CODE ONE INC uses different types of cookies and similar technologies on its websites. Some of those technologies collect your PI. See, our Cookie Policy.

  1. On What Legal Basis Does CODE ONE INC Collect and Process Your PI?

There are a number of reasons why CODE ONE INC collects and processes your PI. Those reasons include:

  • You have given us consent. The consent can be in writing. Or it can be verbal;
  • We must process your PI in order to perform a contract between you and CODE ONE INC;
  • Processing is needed for CODE ONE INC to comply with a legal obligation. For example, CODE ONE INC needs certain PI to enable us to process your purchase order; and,
  • Other reasons allowed by law.
  1. How Do We Use the PI We Maintain About You?

CODE ONE INC uses your PI to:

  • Manage all aspects of our relationship with you. This includes sending you promotional materials, fulfilling product orders, delivering services, communicating with you on pricing and discounts and scheduling dispenser installations;
  • Respond to your questions;
  • Determine how our websites are being used;
  • Improve website content; and,
  • Provide you with targeted information.
  1. Aggregate Data

In some instances, CODE ONE INC may use your information in combination with information belonging to other Individuals. In this process, we use various methods to remove the identifying portions of any PI from your information before combining it with the information of other Individuals. The output of this process is aggregate data, which is incapable of identifying you or any other Individual.  We use this aggregate data for several reasons, including making improvements to our products and services and how we deliver them to you.

  1. Does CODE ONE INC Share Your PI with Third Parties?

CODE ONE INC does not sell your PI to third parties for monetary payment.

CODE ONE INC may transfer your PI to third parties where CODE ONE INC does not receive a monetary payment. Example of these transfers include:

  • When you request us do to so, or provide your consent to us to do so;
  • To Service Providers. A “Service Provider” is a company or person which processes your PI for a CODE ONE INC business purpose under a written contract between CODE ONE INC and the Service •Provider. Examples of a business purpose are processing product orders, fulfilling sample requests and providing promotional services; and,
  • To our distributor partners and marketing representatives to assist in their sales efforts.

CODE ONE INC will also provide your PI to a third party in following situations:

  • If CODE ONE INC sells a business, your PI may be sent to the buyer of that business. If CODE ONE INC buys a business, it may acquire the PI of customers and prospective customers of that business;
  • When required by law or by order of a court or other government agency;
  • When CODE ONE INC determines it is needed or desirable to protect our safety and the safety of our employees and others;
  • When the PI we transfer is available to the public in government records; and,
  • When we seek the advice of professional advisors such as attorneys and accountants.
  1. Your Rights Regarding Your PI

You have the right to be informed about why CODE ONE INC collects your PI and how CODE ONE INC uses your PI. This Privacy Policy provides you with that information.

You also have the rights described in A. – H. below. To exercise any of these rights, please contact:

  • If you are an individual who lives in any other part of the world, including the United States, use this link to send your request; or,

Contact us at 1 800-804-0250.

When you contact CODE ONE INC to exercise any of the rights you have, as described below, we may request information from you to enable us to confirm your identity. We will use reasonable means to confirm that the Individual making the request is you. If we cannot verify that the Individual making the request is you, CODE ONE INC may deny the request.


There will be no charge to request and receive your PI. If CODE ONE INC cannot provide you with access to your PI, we will inform you of the permissible reasons why we may not do so.

In addition, CODE ONE INC may not always be able to fulfill your request to your satisfaction. In some cases, CODE ONE INC may be prohibited by law, agreement or legitimate interest to fully comply with your request. When those situations arise, CODE ONE INC will inform you of why we are unable to fulfill your request.

You have the following rights:

  1. Access

Upon request, we will provide you with access to the PI we have collected about you.

  1. Correction (also known as Rectification)

CODE ONE INC attempts to be sure that your PI in our possession is accurate, current and complete. If you believe that the PI CODE ONE INC has collected and is storing about you is incorrect, incomplete or outdated, you may request the revision or correction of that PI.

  1. Deletion (also known as the ‘Right to be Forgotten’)

You may request that we delete the PI which CODE ONE INC maintains about you. CODE ONE INC may retain your PI for as long as we believe it is necessary to fulfill the purposes for which the PI was collected.

There are instances where applicable law allows or requires us to refuse to delete your PI. In the event that we cannot delete your PI, we will inform you of the reasons why.

  1. Restrict Processing

You may request that CODE ONE INC restricts processing your PI under certain circumstances, including if you believe the PI is not accurate.

  1. Portability

You have the right, if possible given CODE ONE INC’s then current automated systems and data architecture, to receive from CODE ONE INC your PI in machine readable format.

  1. Objection

You have the right in limited circumstances to object to CODE ONE INC processing your PI.

  1. Automated Processing

You have the right to ask us to stop using your PI for automated processing such as profiling.

  1. Withdraw Consent

Where CODE ONE INC collects and processes your PI based on your consent, you have the right to withdraw consent.

  1. Lodge a Complaint

You also have a right to file a complaint with the appropriate government agency if you believe CODE ONE INC has not complied with this Privacy Policy or has violated the law.

  1. Retention of your PI

We will retain your PI for as long as necessary to fulfil the purposes for which it was collected, and to allow us to satisfy any legal, accounting and reporting requirements.

  1. Security of Collected Information

We are committed to protecting the security of the PI we collect from you. CODE ONE INC uses reasonable physical, technical and administrative safeguards to help protect the information from destruction, loss and unauthorized or inappropriate access or use.

  1. Who Can I Contact about My Rights Under this Privacy Policy?

Use the contact information located in Section 13 above. The contact point differs depending on the country in which you reside.

  1. Changes to this Privacy Policy

The effective date of this Privacy Policy is January 1, 2021.

We may change this Privacy Policy at any time. A revised version of this Privacy Policy will be available on our website.

  1. Contact Information 

Questions about the Privacy Policy should be sent to us at

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