You're right that it's tough completely cover everything but a code of ethics isn't supposed to be a set of laws you follow to the letter but more a set of guid

You're right that it's tough completely cover everything but a code of ethics isn't supposed to be a set of laws you follow to the letter but more a set of guidelines for how you should try and act. I think almost everyone would agree that a quick, plain English, summary is more honest to customers than a giant legal document. If you have to leave out some technical details for space that isn't "lying to your customers" but intentionally trying to cover up what you're doing with customer data definitely is.