Privacy Policy

‍Last updated: March 22,2022

1. Scope and Application of Policy

1.1. Coda Payments Pte. Ltd. (“Coda Singapore”) and/or its affiliates or subsidiaries (collectively referred to as “Coda”, “Agency”, “we”, “us”, or “our”) only collect and process personal data from you where it is necessary for us to do so or where it is relevant to our dealings with you. This Privacy Policy (the “Policy”) sets out our privacy practices in respect of the collection, processing, use, disclosure, transfer, retention, storage, and disposal of your Personal Data when we provide you with our Codalink services (“Services”). In the event of any conflict between this Policy and any other privacy policy on our Platform (i.e., Coda’s mobile platform, server or database applications, or websites at Codapayments.com, Codapay.com and Codashop.com), this Policy shall control to the extent necessary to resolve the conflict.

1.2. When you accept this Policy, you agree to the collection, processing, use, disclosure, transfer, retention or storage, and disposal of your Personal Data in the manner described in this Policy.

1.3. “Personal Data” shall refer to your personal information as an individual, whether true or not, from which you can be identified either by itself, or together with other information to which we have or are likely to have access. The Personal Data that we collect and process may include:

(a) Media partner name created by you which may include your first name and/or last name;

(b) Email address;

(c) Mobile number (or MSISDN);

(d) Physical/Postal address details such as street, address line, ZIP/PIN code, city, state, country;

(e) Cookies and/or statistical/analytical data, such as your browsing behaviour, to the extent that you may be identified through these;

(f) Documentation that may help us to verify the accuracy of the information you have provided, such as proof of identity;

(g) Your social media links or public profiles which includes the handles of and links to your accounts on social-media and content-sharing platforms (such as Facebook, Twitter, Instagram, Snap, YouTube, Vimeo, and Pinterest) and any personal information that may be visible thereon, which you may provide to us in the course of customer support dealings; and

(h) Any other personal information that you may provide to us in the course of using the Services.    

1.4. The collection and processing of your Personal Data enable you to make use of our Services.

1.5. We reserve the right to amend this Policy from time to time. Any amendments will be made available and published on our Platform and will take effect on the effective date stipulated herein above. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated set out herein above. In relation to any material changes, we will notify you either, by prominently posting a notice of such changes before they take effect or by directly sending you a notification via email. We recommend that you check this Policy periodically to review the latest version. To the extent permitted under applicable law, your continued use of the Services after an amendment constitutes your acknowledgement and acceptance of such changes.

2. Collection of Personal Data

2.1. When you use the Services or communicate with us, we collect your Personal Data. In these instances, you may provide your Personal Data to us directly, or it may be shared with us by our partner affiliate i.e., Impact Tech, Inc. (“Impact”) through the use of its platform currently located at www.impact.com by you (“Impact’s Platform”), our publisher partners (“Advertisers”), pursuant to your consent given to these parties.

2.2. We also collect transaction information, such as the transaction amount, date of transaction, information about the digital content promoted (“Transaction Data”), in order to pursue our legitimate interests and to abide by our contractual obligation as per our General Terms and Conditions. In most cases, these are not considered as Personal Data since your identity will not be apparent from them. However, to the extent that your identity may be determined from the Transaction Data, they will be considered as Personal Data under Section 1.3 and processed as Personal Data under this Policy. You agree to our collection of such Transaction Data from you when you use the Services.

2.3 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 that you provide to us.

3. Storage of your Personal Data

We store your Personal Data in AWS servers located in Frankfurt, Germany for the EMEA region, N. California for the US region and APAC for the APAC region. However, please note that in order to fulfill our contractual obligations and to provide customer service/support, certain Personal Data is transferred to Singapore as well as other countries by our Processors (For detailed information please refer to Section 8 and 10).  

4. Legal Basis of our Processing

4.1. We process Personal Data only if at least one of the following applies:

(a) You have given consent to the processing of your Personal Data;

(b) The existence of our legitimate interest, or that of a third party, which justifies that we process the Personal Data;

(c) The performance of a contract between you and us requires that we process the Personal Data; and/or

(d) We are required to comply with legal and regulatory obligations, which require the processing of the Personal Data concerned.

4.2. We have set out a table below to help you understand the legal basis for collecting each of the Personal Data:

5. Use and Disclosure of Personal Data

5.1. Your Personal Data shall be processed for the following purposes:

(a) To register you as our media partner and to facilitate your relationship with the Advertisers pursuant to your use of our Services;

(b) To manage our relationship with you, including handling any complaints or queries and notifying you about changes to our General Terms and Conditions and/or this Policy;

(c) Enforcing our contractual rights;

(d) To use data analytics to improve our Services, products/services, marketing, customer relationships and experiences;

(e) To make suggestions and recommendations to you about new proposals, opportunities, upcoming campaigns, and other news (including information about products and services offered by us and the Advertisers);

(f) To protect us, our customers, and our Services from fraud and theft;

(g) Providing you with information which you have requested from us;

(h) Managing or complying with our internal security or risk management mechanisms; and

(i) Other permitted uses and disclosures such as conducting statistical analysis or market and customer research.

5.2. Coda may use the Personal Data collected from you and share it with third parties such as Zendesk, AWS, Google Analytics and Segment (“Processors”), including our affiliates, Impact, the Advertisers, for the purpose of providing you with the Services, or where it is a necessary part of doing business with you.

5.3. For the foregoing purposes, your Personal Data will be shared between Coda Singapore and the following:

(a) The Advertisers;      

(b) Impact; and

(c) Coda affiliates and Processors.

5.4 You understand and accept that we may also disclose your Personal Data to our affiliates, the Advertisers, or other parties as permitted or required by applicable law, such as government authorities or regulators, or other necessary persons, for the following purposes:

(a) 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

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

6. Your choices, rights and exceptions

6.1. Your right of information: You acknowledge that this Policy provides you with information about the purposes, legal framework, interests, recipients or categories of recipients with whom your Personal Data is shared, and the Personal Data transfer to a third country or international organization. In addition to this information and with the aim of ensuring fair and transparent processing of your Personal Data, you further acknowledge that you have received additional information concerning the period for which your Personal Data will be kept and the existence of the rights which are granted to you and how you can exercise them. If we decide to process Personal Data for purposes other than those indicated, all information relating to those new purposes will be communicated to you.

6.2. Your right to erasure of your Personal Data and your right to withdraw your consent: You have the right to have your Personal Data removed or withdraw consent (when processing we carry out is based on your consent) to the processing thereof. If you wish to have your Personal Data erased, or want to withdraw your consent, please contact us. However, please note that if your Personal Data is removed or you withdraw your consent for any of the purposes stated above, depending on the nature of your request, we may not be in a position to continue providing the Services to you. Additionally, the exercise of right to erasure will not be possible when the retention of your Personal Data is necessary for compliance with laws and regulations and in particular for the establishment, exercise or defense of legal claims and withdrawal of consent will have no impact on the previous transactions based on the consent you gave before the withdrawal, subject to compliance with the statutory and regulatory obligations which requires data retention to which we are subject.

6.3. Your right of access to and rectification of your Personal Data: You have the right to access, update, or request correction of the Personal Data that you have 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 or correct your Personal Data, you may contact us. Depending on the nature of your request, we may charge a reasonable administration fee, of which we will inform you as soon as reasonably practicable.

6.4. EEA, UK, Switzerland residents’ privacy rights: If you are a resident of EEA, UK or Switzerland, please note that you have certain rights with respect to your Personal Data under the GDPR and other applicable local data protection legislation. This Section 6.4 supplements the information contained in this Policy.

6.4.1 Your right to restriction of processing: You may request restriction of processing of your Personal Data in the cases provided for by applicable law and regulations.

6.4.2 Your right to object to data processing: You have the right to object to the processing of Personal Data concerning you.

6.4.3 Your right to data portability: You have the right to request that your provided Personal Data be moved to a third party, if the processing is based on consent or contract and the processing is carried out by automated means.

6.4.4 Your right to lodge a complaint with a supervisory authority: If your request or concern is not satisfactorily resolved by us, you may approach the Dutch Data Protection Authority (“Dutch DPA”). The Dutch DPA can provide further information about your rights and our obligations in relation to your Personal Data, as well as deal with any complaints that you have about our processing of your Personal Data. Please refer to the Dutch DPA contact details here.

6.5. California residents’ privacy rights: If you are a California resident, please note that you have certain rights with respect to your Personal Data under the California Consumer Privacy Act (“CCPA”). This Section 6.5 supplements the information contained in this Policy.

6.5.1. Categories, sources, purposes, and recipients of the Personal Data we collect: Please note that we collect the categories of Personal Data described in Section 1.3 of this Policy. The sources from which we collect Personal Data, and the purposes for which we collect and process it, are described in Sections 2 and 5, respectively. We have disclosed for business purposes each of the categories of Personal Data with the categories of third parties as described in Section 5.

6.5.2. Sale of Personal Data: Please note that we do not sell your Personal Data. By ‘sell’ we mean that we do not share your Personal Data with third parties in exchange for valuable consideration. However, we disclose your Personal Data to our third parties as described in Section 5 of this Policy.

6.5.3. As a resident of California you have the right to (i) know what personal information we collect, use, disclose and sell; (ii) request deletion of your Personal Data, subject to certain exceptions; (iii) request information about the Personal Data we have sold or disclosed to third parties for business purposes, in the preceding 12 months; (iv) opt out from the sale of your Personal Data, if applicable; and (v) not be discriminated against for exercising your rights under the CCPA.

To exercise your rights described above, please contact us. We will contact you to request for additional information which we need in order to verify your identity and if we are unable to verify your identity then we will deny your request. Please note that you may designate an authorized agent to make requests on your behalf for exercising your rights under the CCPA. However, before accepting any request from your agent, we will require your agent to provide us with proof that you have authorized the agent to act on your behalf and we may need you to verify your identity directly with us.

6.5.4. California Do Not Track disclosures: Do Not Track (“DNT”) is an internet browser setting which allows you to avoid having your online actions monitored. Currently, Impact’s Platform doesn’t support such a setting since there are no agreed-upon standards for DNT signals and no guidelines on how to deal with DNT requests. Therefore, Impact will be unable to act on any requests we receive regarding DNT. However, we will process all your other requests as described in this Policy.

All the rights enumerated above can be exercised by contacting us (please refer to Section 13 of this Policy).

7. Retention and Disposal of Personal Data

Your Personal Data will be retained for as long as is necessary to fulfil or complete the purpose for which it was collected and until it is no longer necessary for any other legal or business purposes. Thereafter, we dispose of your Personal Data in a manner that prevents further access or processing, including but not limited to deletion or irreversible anonymization. ​

8. Data Processors

8.1. For fulfilling our contractual obligations, providing customer support/services, storage of Personal Data and for data analytics we use the following service providers:

(a) Zendesk, Inc. (“Zendesk”): Zendesk helps us in providing customer support/services to our users. Please refer to their privacy policy here;

(b) Amazon Web Services (“AWS”): AWS helps us in storage of Personal Data. Please refer to their privacy policy here;

(c) Google Analytics by Google LLC. (“Google Analytics”): Google Analytics helps us in performing statistical/data analysis. Please refer to their privacy policy here; and

(d) Segment.io, Inc. (“Segment”): Segment helps us in performing statistical/data analysis. Please refer to their privacy policy here;.

Please note that these Processors may transfer your Personal Data to a location outside of EEA, UK, Switzerland, US or other countries depending on their respective privacy policies. Therefore, we recommend you to read each of the privacy policies to learn about the privacy terms applicable to you.

9. Security

9.1. Coda makes reasonable efforts to safeguard Personal Data in our possession or under our control, in order to protect against loss, misuse, modification, unauthorised or accidental access or disclosure, alteration, or destruction. Unfortunately, no data transmission or storage over the internet can be guaranteed as totally secure. Nonetheless, we have adopted and currently practice administrative, organizational, technical, and physical security measures to protect your Personal Data to the best of our reasonable capacity, including but not limited to the following:

(a) Limiting Personal Data access to authorized and/or necessary personnel;

(b) Implementing technical solutions to ensure information security;

(c) Continuous monitoring and review of Personal Data protection measures; and

(d) Other security measures as may be required by the laws and regulations applicable in the country where you are located.

10. International Transfer of Personal Data

10.1. As we operate internationally, your Personal Data may be stored and processed in a country outside of the European Economic Area (“EEA”), UK, Switzerland, US or other countries where we have operations depending on applicable data localisation regulations, or share your Personal Data with recipients (such as the Advertisers, Processors, Impact or Coda affiliates/subsidiaries) who are located in countries other than the country in which your Personal Data was originally collected. You therefore accept and understand that we may share your Personal Data with recipients who are located in countries other than the country in which your Personal Data was originally collected in order to provide the Services to you, to facilitate your relationship with the Advertisers, or for any other purposes set out in this Policy.

10.2. In such circumstances, we take steps to ensure that overseas recipients shall provide a standard of protection to the Personal Data transferred that is comparable to the protection under the EU General Data Protection Regulations (“GDPR”), the CCPA as well as the local data protection laws applicable in your jurisdiction. We will take all steps reasonably necessary to ensure that your Personal Data is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, and/or by using standard contractual clauses, where applicable and that it is treated securely and in accordance with this Policy.

11. Collection of Statistical Data

11.1. Impact may collect statistical information relating to your website use and online activities as you interact with Impact’s Platform, using “cookies” and similar technologies. Such statistical information is anonymous in nature and does not identify who you are. This includes page visits, access times and dates, and browser type. This information is collected for analysis and evaluation to help in improving Impact’s Platform and our Services. Please refer to Impact’s Privacy Policy for a detailed overview on their privacy practices and cookies collection. Please note that Coda does not collect any statistical information/cookies from you.

11.2. “Cookies” are a feature on your Internet browser which store small amounts of data on your computer when you visit a website. They allow Impact to recognise a particular device or browser so that Impact can personalize and curate content to your preferences and make our Services and Impact’s 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.

12. Use by Minors​

Our Services and our Platform are not directed to persons under the age of majority in your country (a “minor”) and we do not and will not knowingly collect or solicit Personal Data from any minor. In the event we learn that we have inadvertently collected Personal Data from a minor, we will delete that information as quickly as possible. If you believe that we might have any information from or about a minor, please contact us.

13. Contact Us

To contact us on any aspect of this Policy or your Personal Data, including but not limited to withdrawing consent, requesting access to your Personal Data, requesting an update or correction to your Personal Data, or exercising any of your rights under this Policy or applicable data protection laws, you may contact our Data Protection Officer at dpo@codapayments.com.