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© 2019 Coda Payments Pte. Ltd.

PRIVACY POLICY

Coda Payments Pte. Ltd. and/or its subsidiaries (hereafter referred to as “Coda”, “we”, “us” and “our”) only collects personal data from you where it is necessary for us to do so or where it is relevant to our dealings with you.

 

This policy sets out our privacy practices in respect of personal data we collect through the provision of our services (“Coda Services”) that enables you to make purchases from us, your mobile network operator, the relevant payment channel operator, or a merchant (collectively shall be referred to as “Merchants”) via our mobile platform, server or database applications, or websites at Codapay.com and Codashop.com (“Platform”), and only applies to an individual’s personal data which is in our possession or under our control.

 

We reserve the right to amend this policy from time to time without any prior notice. Any amendments will be made available and published on our Platform and will take effect on the effective date stipulated below. You may determine if any such revision has taken place by referring to the date on which this policy was last updated set out below. We recommend that you check this policy periodically to review the latest version. Your continued use of our Coda Services constitutes your acknowledgement and acceptance of such changes.

 

Effective date  : 28 August 2019

Last updated   : 28 August 2019

 

Collection of Personal Data

 

When you use our Coda Services or communicate with us, we will collect certain personal data about you, whether true or not, from which you can be identified either on its own, or together with other information to which we have or are likely to have access (“Personal Data”). Such Personal Data, including your name, email address, mobile number (or MSISDN), Merchant affiliation and/or IP address, may be provided to us directly by you or shared with us by our affiliates, third party payment channel providers (“Payment Channels”) and Merchants pursuant to your consent given to these third parties.

 

You may also choose to submit Personal Data to us via other methods, including (i) in response to our communications; (ii) through social media or online forums; and/or (iii) through participation in an offer, program or promotion conducted by us.

 

We will also collect transaction information such as purchase amount, date of purchase, shopping behaviour or pattern, and information about the digital content, goods and/or services that you are purchasing.

 

You consent to allow us to collect such data about you from you when you use Coda Services and/or our Platform.

 

You must provide us with information which is accurate and not misleading. In this connection, we reserve the right to request for documentation to verify the information provided to us by you.

 

Use and Disclosure of Personal Data

 

Transaction Processing and Content Delivery

 

As a payment channel aggregator, online distributor of digital content, and provider of related services, the Personal Data we collect from you will be used and/or shared with third parties, including our affiliates, Payment Channels and Merchants, for the purpose of providing you with our Coda Services or where it is a necessary part of doing business with you. This includes, (i) facilitating your use of our Coda Services; (ii) processing and verifying your online transactions and payments on our Platform; (iii) resolving any disputes in relation to your transaction; (iv) mitigating fraud and abuse; (v) enforcing our contractual rights;; and (viii) providing you with information which you have requested from us.

Marketing and Promotional Campaigns

From time to time, we run promotional campaigns where we reward our users for being top spenders on our Platform in a particular country, for a particular merchant, or in other various categories. To this end, we may analyse transaction information collected from your purchase transactions, and may use your Personal Data to contact you for the purpose of awarding you with the prizes offered for such promotional campaigns, which typically would be free Merchant or Payment Channel credits, or other free gifts. These promotional campaigns are conducted by Coda, and your Personal Data will not be shared with our third-party partners for such purposes. 
 


Other Permitted Use and Disclosures

You accept that we may disclose your Personal Data to our affiliates, Merchants, Payment Channels or other parties as permitted or required by applicable law, such as:

 

(i) for or in connection with the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture, or dissolution of all or a portion of our business; or

 

(ii) if we believe that disclosure is reasonably necessary to (a) comply with any applicable law, regulation, legal process, or governmental request; (b) assist in any investigations or proceedings; and (c) protect the security or integrity of our Coda Services, us, our users or the public from harm or illegal activities.

Your choices, rights and exceptions

 

If you do not wish to have your Personal Data used in this manner or for any other specific purpose, please contact us accordingly. Please note that if you withdraw your consent to our use and/or disclosure of your Personal Data for any of the purposes stated above, depending on the nature of your objection, we may not be in a position to continue to provide our services to you, or process and complete the purchase transaction you wish to make on our Platform.

Access and Correction

You may access and update your Personal Data provided to us at any time. If you would like to access the Personal Data that we have on file about you or request that we update your Personal Data, you may contact us at our email address below. We may charge a reasonable administration fee for retrieving your Personal Data, of which we will inform you as soon as reasonably practicable.

Retention of Data

Your Personal Data will be retained for as long as the purpose for which it was collected remains and until it is no longer necessary for any other legal or business purposes.

Security

Coda makes reasonable efforts to safeguard your Personal Data in our possession or under our control to protect against loss, misuse, unauthorised access or alteration. Unfortunately, no data transmission or storage over the Internet can be guaranteed as totally secure.

International Transfer of Data

 

As we operate internationally, your Personal Data may be stored and processed in a country where we have operations, where our Merchants are located, or where our Payment Channels are located. As abovementioned, we may share your Personal Data with recipients who are located in countries other than the country in which the Personal Data was originally collected, in order to provide our services to you, process and complete the purchase transaction you wish to make on our Platform, or for any other purposes set out in this policy. In such circumstances, we shall take steps to ensure these overseas organisations shall provide a standard of protection to the Personal Data so transferred that is comparable to the protection under the Personal Data Protection Act in Singapore.  

 

Collection of Statistical Data

We collect and also allow third parties (including but not limited to Facebook and Google) to collect statistical information relating to your website use and online activities as you interact with our Platform, using “cookies” and similar technologies. Such statistical information is anonymous in nature and do not identify who you are. They include browsing behaviour, page visits, access times and dates, and browser type. This information is collected for analysis and evaluation to help us improve our Platform and Coda Services.

 

Your Internet browser has a feature called "cookies" which stores small amounts of data on your computer when you visit a website, and they allow us to recognise a particular device or browser so that we can personalise and curate content to your preferences and make our services and Platform more useful to you. “Cookies” do not tell us who you are unless you specifically give us personally identifiable information. You may be able to manage and delete “cookies” by selecting certain options on your browser.

 

Such statistical data may be shared with our third party partners who: (i) we advertise with; (ii) help us deliver or optimize our services; (iii) wish to market their goods or services which may be of interest to you; or (iv) wish to improve their goods or services to be provided to you. 

Use by Minors

Coda Services are not directed to children. If you are under 18 years old, you may use Coda Services and/or our Platform only with the supervision of a parent or guardian. 

Links to Other Web Sites

Our Platform may contain links to other websites which are not maintained by us. Therefore, when visiting these third party websites, you should read their privacy policies which will apply to your use of their websites. We are not responsible for the content, use or privacy practices of these websites. 

 

Contact Us

To contact us on any aspect of this policy or your Personal Data, including access to your Personal Data or request to update your Personal Data, you may contact our Data Protection Officer at dpo@codapayments.com.