Privacy Notice

Last updated: 30 October 2024

1. Scope and Application of Notice

1.1 Coda Netherlands Holding B.V. (“Coda Netherlands”) and/or its affiliates or subsidiaries, including its parent company Coda Payments Pte. Ltd (“Coda Singapore”)” (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 Notice (the “Notice”) 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 web store services (“Web Store Services”). This Notice applies to you if you reside or are located in the European Union / EEA or the United Kingdom. In the event of a conflict between this Notice and any other privacy notice on the Web Store, this Notice shall prevail to the extent necessary to resolve the conflict.  

1.2 “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) Merchant 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) Account passwords; and

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

1.3 We collect and process your Personal Data to enable you to purchase digital goods offered on https://store.fcm.ea.com/ (the “Web Store”).

1.4 We reserve the right to amend this Notice from time to time without any prior notice to you. Any amendments will be made available and published on our Web Store 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 Notice was last updated, set out above. We will notify you of any material changes by prominently posting a notice of such changes before they become effective or by sending you a notice directly via email. We recommend that you check this Notice periodically to review the latest version. To the extent permitted under applicable laws, your continued use of the Web Store Services after an amendment constitutes your acknowledgment of such changes.

2. Collection of Personal Data

2.1 We collect your Personal Data when you use the Web Store 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 Electronic Arts (“the Publisher”). 

2.2 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) when you sign up for our newsletter; and/or

(e) when you sign into Web Store 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.

2.3 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 Web Store Services and/or our Web Store. 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 Notice. You agree to our collection of such Transaction Data from you when you use the Web Store Services and/or our Web Store.

2.4 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.

2.5 We only process Personal Data if at least one of the following situations applies. 

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

(b) There is a legitimate interest on our part, or on the part of a third party, that justifies our processing of the Personal Data;

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

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

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

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 Coda Netherlands offers content distribution services in the EU/EEA and the United Kingdom through Web Store and sells the relevant codes to you. 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 (such as Zendesk, AWS, Google Analytics, Segment and Facebook (“Processors”), including our affiliates or subsidiaries, the Payment Channels, and the Publisher, for the purpose of providing you with the Web Store 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 Web Store Services;

(b) Analysing, improving or enhancing your use of the Web Store Services or user experience;

(c) Providing feedback on the digital goods offered on the Web Store;

(d) Processing and verifying your online transactions and payments on our Web Store; 

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

(f) Mitigating fraud;

(g) Protecting our legitimate interests;

(h) Enforcing our contractual rights; and 

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

‍     

3.2.3 Your Personal Data may also be shared for the purposes listed in clause 3.2.2 and 3.3.3 or for the purpose of content delivery, performance of audits and to comply with other compliance activities between Coda and the Publisher (Electronic Arts) whose content you are purchasing

3.2.4. Your Personal Data may also be shared for the purposes listed in clause 3.2.2 with  the Payment Channel that you have selected as your method of payment.

3.2.5. Your Personal Data may also be shared for the purposes listed in clause 3.2.2 and 3.3 with Coda Singapore and Processors. If you reside or are located in the European Union / EEA or the United Kingdom, you understand that Coda Netherlands acts as the controller of your Personal Data and that Coda Singapore is the processor carrying out the processing on behalf of Coda Netherlands.

3.3 Marketing and Promotional Campaigns

3.3.1 From time to time, we run marketing and promotional campaigns where we reward our users on our Web Store in a particular country, for or on behalf of the 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, other than as specified below. If you would like to opt out of receiving gifts and other prizes from our promotional events, please contact us.

3.3.2 Coda may carry out promotional campaigns in collaboration with Publishers, Payment Channels or other third parties. In such cases, if you sign up, we may share your name, email address and/or mobile number with them so that you can participate in these campaigns. If you would like to opt out of participating in these joint promotions, please contact us. 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 Web Store Services, or those conducted jointly, in partnership, or in connection with the Publisher, any 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. 

3.3.3 We may also share your personal data with the Publisher for the purposes of managing and serving promotions, offers or other online marketing to you on the Web Store Services, in their related products/services and on third party platforms, and to measure the effectiveness and distribution of advertising, including understanding who engages with the Web Store and/or their related products/services. 

   

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) Notifying you of matters relating to your transactions that may require your attention;

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

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

(d) 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 service providers for such purposes; 

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

(f) Notifying you of material changes to this Notice 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, the Publisher, 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 Web Store Services, us, or any of our users or the public from harm or illegal activities.

4. Your choices, rights and exceptions:

4.1. Your right to information: You acknowledge that this Notice provides you with information about the purposes, legal framework, interests, recipients or categories of recipients for which or with whom your Personal Data is shared, as well as about the transfer of Personal Data to a third country or international organization. You further acknowledge that, in addition to this information and in accordance with Coda's aim to ensure fair and transparent processing of your Personal Data, you have received additional information regarding the period for which your Personal Data will be retained and the existence of the rights granted to you and how you can exercise them. If we decide to process Personal Data for purposes other than those stated, all information relating to those new purposes will be communicated to you. 

4.2. Your right to delete your Personal Data and your right to withdraw your consent: You have the right to have your Personal Data deleted or withdraw your consent to its processing (where the processing we carry out is based on your consent). If you would like to have your Personal Data deleted or withdraw your consent, please contact us. However, please note that if your Personal Data is deleted or if you withdraw your consent for any of the purposes listed above, depending on the nature of your request, we may not be able to continue to provide the Web Store Services to you, or process and complete the transactions you wish to conduct on the Web Store. In addition, the exercise of the right to erasure is not possible when the retention of your Personal Data is necessary to comply with laws and regulations and in particular for the establishment, exercise or defence of legal rights and the withdrawal of consent will not affect previous transactions based on the consent you gave before the withdrawal, subject to compliance with the legal and regulatory obligations requiring data retention and which apply to us.

4.3. Your right to access and rectify your Personal Data: You have the right to access or update the Personal Data you have provided to us at any time, as well as to request us to correct it. If you would like to access the Personal Data we hold about you, or if you would like us to update or correct your Personal Data, please contact us. Depending on the nature of your request, we may charge you a reasonable administration fee, of which we will notify you as soon as reasonably possible.

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

4.5. Your right to object to data processing: You have the right to object to the processing of your Personal Data, including the right to object to marketing and promotional campaigns (as stated in Clause 3.3 above).

4.6. Your right to data portability: You have the right to request that the Personal Data you have provided be transferred to a third party, if the processing is based on consent or a contractual agreement and the processing is carried out by automated means.

4.7. Your right to lodge a complaint with a supervisory authority: If your request or concern is not resolved satisfactorily by us, you can contact the Dutch Data Protection Authority ("DPA”). The DPA can provide you with more information about your rights and our obligations with regard to your Personal Data and can handle any complaints you have about our processing of your Personal Data. You will find the contact details of the DPA here.

All rights mentioned above can be exercised by contacting us (see Clause 11 of this Notice).

5. Storage, Retention and Disposal of Data

Your Personal Data will be stored on AWS servers in Frankfurt, Germany. Please note, however, that in order to process orders and provide customer service/support, certain Personal Data will be transferred by our Processors to Singapore and other countries (see clause 7). 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.

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. Transfer of Data

7.1.1 Data Processor: To process orders or fulfil our contractual obligations, to provide customer service and support services, to store Personal Data and to analyse data, we use the following service providers:

(a) Zendesk, Inc. (“Zendesk"): Zendesk helps us provide customer service/support services to our users. Review their privacy policy, here;

(b) Amazon Web Services (“AWS"): AWS helps us store Personal Data. Review their privacy policy, here;

(c) Google Analytics van Google LLC. (“Google Analytics"): Google Analytics helps us perform statistical analyzes and data analyses. Review their privacy policy, here;

(d) Segment.io, Inc. (“Segment"): Segment helps us perform statistical analyzes and data analytics. Review their privacy policy, here; and 

(e) Facebook, Inc. (“Facebook"): Facebook helps us with marketing and providing leads based on your consent. Review their privacy policy, here.

Please note that these Processors may transfer your Personal Data to a location outside the EEA depending on their respective privacy policies. Therefore, we recommend that you read the privacy policy of each of these Processors to learn more about the privacy terms that apply to you.

7.2.2. International Data Transfer: Coda operates internationally. You therefore accept and understand that we may store your data in different countries depending on applicable data localisation regulations, or share your Personal Data with recipients (such as the Publisher, Payment Channels, or Coda affiliates/subsidiaries) who are located in countries other than the country in which your Personal Data was originally collected, in order to provide the Web Store Services to you, process and complete the transactions you wish to make on our Web Store, or for any other purposes set out in this Notice. 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 as well as the local data protection laws applicable in your jurisdiction.  

8. Collection of Statistical Data

8.1 We collect, and also allow third parties (including but not limited to Amazon Web Services, Facebook, and Google) to collect statistical information relating to your website use and online activities as you interact with our Web Store, 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 Web Store and the Web Store 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 Web Store 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 our services or content (including Publishers) or (iii) who help us analyze, improve or optimize our services; (iv) who wish to market their goods or services, which may be of interest to you; (v) who wish to improve their goods or services to be provided to you. 

     

9. Age Restrictions

9.1 We apply age restrictions to the Web Store Services to comply with applicable law.  Depending on your age and the legal requirements in your territory, you may not be able to access some or all of the Web Store Services.

10. Links to Other Web Sites

Our Web Store 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 Notice 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 Notice or applicable data protection laws, you may contact Coda’s     Data Protection Officer by submitting a request using this link .

11.2 For any other issues, please contact Coda at support.eu@codapayments.com or visit our Help Center