Privacy Policy

The data privacy and data protection of all customers and partners is of utmost importance to us.

CODA are committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

WHAT INFORMATION IS HELD?

  • Information you consent to provide CODA that is required to carry out our obligations arising from any contracts entered between you and us, or potential contracts that may be in liaison between you and us.
  • Information that you consent to provide by filling in forms on our website, or as part of any direct marketing or sales activities. This includes and is not limited to personal information about you such as your name, telephone contact number, geographical address/location, email address and interests.
    Note: Clear consent information is supplied at point of collection to provide information on the use of data.
  • If you contact us in writing, we may keep a copy of your correspondence or communication.
  • Details of your visits to our website and the resources that you access.
  • If you have provided us with the personal data of another person, there is a clear requirement imposed by CODA for you to confirm that he/she consents to the processing of his/her personal data and that you have informed him/her of our identity as a Data Controller and the nature of the processing taking place.

HOW WILL THE DATA BE USED?

Performance of a contract – We use information held about you to carry out our obligations arising from any contracts entered between you and CODA; and to notify you about changes to our services.

LEGITIMATE INTERESTS

We use information held about you to provide you with information and/or services that you request from us or which we feel may interest you if relevant to the products or services currently being supplied as part of a contract with CODA, or in relation to a previous contract with CODA.

CONSENT (DIRECT MARKETING)

We use information held about you to provide you with information on services that you request from us, or which we feel may interest you where you have consented to be contacted for such purposes. Where consent has been provided, it is a recognised right of the Data Subject that this consent can also be withdrawn.

CONSENT (WEBSITE)

To ensure that content from our website is presented in the most effective manner for you and your device. We will not share your data with third parties for other marketing purposes unless we have your express consent to do so.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be updated on our website.

YOUR RIGHTS RELATING TO PERSONAL DATA

You have the right to ask us to cease processing your personal data for marketing purposes. We will seek consent (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your data to any third party for such purposes.

You can also exercise your right to prevent such processing by contacting us.

GDPR gives you the right to access information held about you and your right of access can be exercised at any time. CODA operate both a ‘data subjects rights procedure’ and a ‘subject access rights procedure’ to ensure that all rights exercised by data subjects relating to personal data are managed appropriately.

From time to time, our website may contain links to and from our strategic partners, partner network(s), and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.

RETENTION OF YOUR INFORMATION

We take appropriate measures to ensure that any information collected from you is kept secure and kept only for so long as is necessary for the purpose for which such information is used.

If any of your personal data changes, or if you have any questions about how we use data which relates to you, please contact us.

We may disclose your personal information to any member of our group, which means our subsidiaries, strategic partner(s) or strategic sponsor(s) our ultimate holding company and its subsidiaries as defined in section 1159 of the UK Companies Act 2006.

As part of our GDPR compliance obligations, we are duty bound to check when personal data may be shared with third parties to ensure that they apply the same or greater controls in terms of data protection. The use of non-disclosure agreements form part of our third-party data sharing controls.

We may disclose your personal information to third parties:-

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets
  • If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about our customers will be one of the transferred assets
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce or apply other agreements
  • To protect the rights, property or safety of CODA, our customers or others.

CODA has assessed the risk where personal information may be transferred outside the EEA. As part of our own due diligence, we have identified that personal data held for and by CODA resides in the EU. CODA will continue to monitor this and, should a requirement for data to be transferred outside of the EU in future, CODA will implement controls and safeguards to ensure that equal to or greater data protection measures are enforced, and records retained to evidence this.

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