Codashop Global Series (CGS) App Privacy Policy
Last updated: 26 September 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 “CGS Privacy 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 Codashop Global Series (“CGS'') App. In the event of any conflict between this CGS Privacy 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 CGS Privacy Policy shall control to the extent necessary to resolve the conflict.
1.2. When you accept this CGS Privacy 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 CGS Privacy 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) Email address, mobile number, username/display name and password when you register for a CGS account;
(b) Profile information such as profile cover photo, profile picture, followers & following users’ list, personal bio, topics/games titles you’re interested in and games played by you;
(c) Cookies and/or statistical/analytical data, such as your browsing behaviour, to the extent that you may be identified through these;
(d) Documentation that may help us to verify the accuracy of the information you have provided, such as proof of identity; and
(e) Any other personal information that you may provide to us in the course of using the CGS App.
1.4. The collection and processing of your Personal Data enable you to make use of our CGS App.
1.5. We reserve the right to amend this CGS Privacy 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 CGS Privacy 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 CGS Privacy Policy periodically to review the latest version. To the extent permitted under applicable law, your continued use of the CGS App after an amendment constitutes your acknowledgement and acceptance of such changes.
2. Collection of Personal Data
2.1. When you use the CGS App such as register for and set up an account or communicate with us, we collect your Personal Data. In these instances, you may provide your Personal Data to us directly. We get your Personal Data from seeing how you use our CGS App, from cookies and other technology.
2.2. 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 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:
- To register you as a user of our CGS App;
- 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 CGS Privacy Policy;
- Enforcing our contractual rights;
- To use data analytics to improve our CGS App, products/services, marketing, customer relationships and experiences;
- To make suggestions and recommendations to you about new tournaments, upcoming campaigns, and other news;
- Providing you with information which you have requested from us;
- Managing or complying with our internal security or risk management mechanisms; and
- 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 other users of our CGS App, our affiliates for the purpose of providing you with the CGS App, 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) Coda affiliates;
(b) Other users; and
(c) Processors.
5.4 You understand and accept that we may also disclose your Personal Data to our affiliates, 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 CGS App, 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 CGS Privacy 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 CGS App 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.
7. Retention and Disposal of Personal Data
Your Personal Data will be retained for as long as is necessary to fulfill 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
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 your country 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
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 different countries where we have operations depending on applicable data localisation regulations, or share your Personal Data with recipients (such as the Processors, 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 CGS App to you, or for any other purposes set out in this CGS Privacy 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 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 CGS Privacy Policy.
11. Collection of Statistical Data
11.1. 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 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 us improve our Platform and the CGS App. Please refer to our Cookie Policy for a detailed overview.
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 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.
11.3. Your statistical data may be shared with our third-party partners: (i) with whom we advertise; (ii) who help us deliver or optimize our services; (iii) who wish to market their goods or services, which may be of interest to you; or (iv) who wish to improve their goods or services to be provided to you..
12. Use by Minors
Our CGS App 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. Other Websites and Services
We are not responsible for the practices employed by any websites or services linked to or from our Service, including the information or content contained within them. Please remember that when you use a link to go from our Service to another website or service, our CGS Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party's own rules and policies.
14. Contact Us
To contact us on any aspect of this CGS Privacy 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 CGS Privacy Policy or applicable data protection laws, you may contact our Data Protection Officer at dpo@codapayments.com.
