Last updated: 28 November 2022

1. Scope and Application of Policy

1.1. Coda Payments Pte. Ltd. (“Coda Singapore”) and its affiliates (collectively referred to as “Coda” and “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 services (“Coda Services”) and shall apply if you are residing in New Zealand. In the event of any conflict between this Policy and any other privacy policy on our Platform, 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 below.

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) Your first name and last name;

(b) Email address;

(c) Mobile number (or MSISDN);

(d) Publisher affiliation and/or IP address;

(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, and any personal information that may be visible thereon, which you may provide to us in the course of customer support dealings;

(h) Details in your curriculum vitae or resume, which you may provide to us in the course of applying for job openings;

(i) Account passwords that you may create; and

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

1.4. This Policy only applies to Personal Data which is in our possession or under our control.

1.5. We collect and process your Personal Data to enable you to make purchases from us, your mobile network operator, or the relevant third-party payment channel operator (the “Payment Channels”), or a merchant or publisher of digital products (the “Publishers”) via Coda’s mobile platform, server or database applications, or websites at and (the “Platform”).

1.6. We reserve the right to amend this Policy from time to time without any prior notice to you. Any amendments will be made available and published on our Platform and will take effect on the effective date below. You may determine if any revision has taken place by referring to the date that this Policy was last updated, set out below. 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 Coda Services after an amendment constitutes your acknowledgement and acceptance of such changes.

2. Collection of Personal Data

2.1. We collect your Personal Data when you use the Coda Services or communicate with us. In these instances, you may provide your Personal Data to us directly, or it may be shared with us by our affiliates or subsidiaries, the Payment Channels, or the Publishers, pursuant to your consent given to these third parties.

2.2. Personal Data collected from third parties. Where reasonable and practicable to do so, we will collect your Personal Data only from you. However, in some circumstances we may be provided with Personal Data by third parties (as mentioned in Section 2.1). In such a case we will take reasonable steps to ensure that you are made aware of the Personal Data provided to us by the third party.

2.3. You may also submit Personal Data to us via other methods, including:

(a) in response to our communications;

(b) through social media or online forums;

(c) through participation in an offer, program or promotion conducted by us;

(d) while applying to any job opportunity via the "Careers" page on or;

(e) when you sign up for our newsletter;

(f) when you fill in the Partnerships and Marketing enquiry form on our website; and/or

(g) When you sign into Coda Services with a social login or your credentials from a third party platform (for example, Facebook, Gmail). We collect the Personal Data that you have agreed to share via the social media site or third party platform in question.

2.4. We also collect transaction information, such as purchase amount, date of purchase, information about the digital content, goods and/or services that you are purchasing (“Transaction Data”), in order to pursue our legitimate interests and to abide by our contractual obligation to provide you access to the Coda Services and/or our Platform. 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 and processed as Personal Data under this Policy. You agree to our collection of such Transaction Data from you when you use the Coda Services and/or our Platform.

2.5. 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. Use and Disclosure of Personal Data

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

(a) Transaction processing and content delivery;

(b) Marketing and promotional campaigns; and

(c) Other permitted uses and disclosures.

3.2. Transaction Processing and Content Delivery

3.2.1. As a payment channel aggregator, online distributor of digital content, and provider of related services, Coda will use your Personal Data and share it with third parties, including our affiliates or subsidiaries, the Payment Channels, and Publishers, for the purpose of providing you with the Coda Services, or where it is a necessary part of doing business with you.

3.2.2. In particular, your Personal Data may be processed for the following:

(a) Facilitating your use of the Coda Services;

(b) Processing and verifying your online transactions and payments on our Platform;

(c) Resolving any disputes in relation to your transaction;

(d) Mitigating fraud;

(e) Protecting our legitimate interests;

(f) Enforcing our contractual rights; and

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

3.2.3. Your Personal Data may also be shared for the above purposes between Coda and:

(a) The Publisher from whom you are purchasing content; and

(b) The Payment Channel that you have selected as your method of payment.

3.3. Marketing and Promotional Campaigns

3.3.1. From time to time, we run marketing and promotional campaigns where we reward our users for being top spenders on our Platform in a particular country, for a particular Publisher, or in other various categories. To this end, we may analyse your Transaction Data and use your Personal Data to contact you, in order to award you with the prizes offered for such promotional campaigns, which typically would be free Publisher or Payment Channel credits, or other free gifts. These promotional campaigns are conducted by Coda, and your Personal Data will not be shared with any third party for such purposes. If you would like to opt out of receiving gifts and other prizes from our promotional events, please contact us.

3.3.2. If you opt in to receiving marketing and promotional communications, we may use your Personal Data to notify you about marketing and promotional campaigns relating to any of the Coda Services, or those conducted jointly, in partnership, or in connection with any Publishers, Payment Channels, or third parties, and we may share your name, email address, and/or mobile number with them for this purpose. If you would like to opt out of receiving marketing and promotional communications or having your Personal Data disclosed for this purpose, please contact us. You may also opt-out of any such marketing and promotional emails by clicking the unsubscribe button provided in that email.

3.4. Other Permitted Uses and Disclosures

3.4.1. You accept that we may also use your Personal Data for the following purposes:

(a) Maintaining and securing any user accounts that you may have with Coda;

(b) Notifying you of matters relating to your account or your transactions that may require your attention;

(c) Processing service requests, resolving concerns, and responding to queries or feedback that you may communicate to us;

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

(e) Conducting statistical analysis or market and customer research, including surveys to ensure customer satisfaction.Please note that we may share your Personal Data with our third party serviceproviders for such purposes;

(f) Improving your experiences with our customer care services; and

(g) Notifying you of material changes to this Policy or to our Terms and Conditions as may be necessary.

3.4.2. You understand and accept that we may also disclose your Personal Data to our affiliates or subsidiaries, Publishers, Payment Channels, 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 (iii) protect the security or integrity of the Coda Services, us, or any of our users or the public from harm or illegal activities.

4. Your choices, rights and exceptions

4.1. You have the right to have your Personal Data removed or withdraw consent to its processing, where we are processing your Personal Data solely on the basis of your consent. If you wish to have your Personal Data removed, or do not wish to have your Personal Data used or processed for the purposes above, 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 Coda Services to you, or process and complete the transactions you wish to make on our Platform.

4.2. 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.

5. 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. ​

6. Security

Coda makes reasonable efforts to safeguard your Personal Data, 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.

7. International Transfer of Personal Data

7.1. Coda operates internationally. You therefore accept and understand that we may store and process your Personal Data outside New Zealand where we have operations, or share your Personal Data with recipients (such as the Publishers, Payment Channels, or Coda affiliates/subsidiaries) who are located in countries outside of New Zealand, in order to provide the Coda Services to you, process and complete the transactions you wish to make on our Platform, or for any other purposes set out in this Policy.

7.2. In such circumstances, we take steps to ensure that any Personal Data transferred in accordance with Section 7 of the Policy shall be provided a standard of protection that is comparable to the protection under the New Zealand Privacy Act 2020 as well as any relevant amendments, rules, regulations, guidelines etc. for New Zealand.

8. Collection of Statistical Data

8.1. We collect, and also allow third parties (including but not limited to Amazon Web Services, Zendesk, Facebook, Segment 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. They include 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 Coda Services.

8.2. “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.

8.3. 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.

9. Use by Minors

9.1. Coda Services and our Platform are not directed to persons under the age of 18 (“minors”) 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.

10. Links to Other Websites

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 respective 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.

11. Contact Us

11.1. To contact us on any aspect of this Policy or your Personal Data, including but not limited to withdrawing consent, opting out of receiving gifts and prizes, opting out of receiving marketing and promotional communications, 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 by submitting a request using this link.

11.2. For any other issues, please visit our Help Center.

12. Data Protection Officer

Name: Kedar Deshpande
Data Protection Officer
Email address:

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