This Privacy Policy concerns your use of the “CODI Platform” available at (www.codi.mobi). Your use constitutes acceptance of its terms and conditions, and it takes effect immediately upon your first use of the Platform/electronic application.
Data Operator (CODI Platform): Ads System Company, whose details are stated in the “First” section above.
Data Protection Officer: CODI Platform Management (info@codi.mobi).
We regard your privacy as a matter of great importance and are committed to responsible practices when handling data. This Privacy Policy forms an integral part of the Platform’s Terms & Conditions. If you do not agree to this Privacy Policy, you must stop using or accessing the Platform.
1. Legal Basis for Processing
The Company processes your Personal Data on one of the following bases, as applicable:
- Performance of the contract concluded with you or the Organization to which you belong, or taking pre-contractual measures.
- Your express consent, particularly in relation to marketing communications and advertising personalisation.
- Compliance with the requirements of the laws and regulations in force in the Kingdom.
- The Company’s legitimate interest in operating and securing the Platform and preventing fraud, without prejudicing the Data Subject’s rights.
You may withdraw your consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.
2. How We Collect Your Personal Data
- Personally identifying information that you provide when registering, together with information we obtain from the way you use the services offered by the Platform.
- If you download or use the mobile Platform, we may access details about your location and the location of your mobile phone, including your device’s unique identifier, after obtaining your permission through the device settings.
- Data you provide to us, or that we may collect from you, when you report any difficulty encountered while using the Platform.
- Data collected through correspondence records when you contact us.
- Details concerning the mobile phone, including, for example, your Internet Protocol address, operating system, and browser type, together with data concerning your general use of the internet, such as data stored on or accessed from your device, including cookies, conversion-tracking code, and web beacons, collectively referred to as “Cookies.”
- Your email address supplied to us by third parties who have confirmed that they obtained your consent to share it.
- We collect your personally identifying information only when you provide it to us. We may also collect information about transactions you conduct and additional information concerning your participation in Offers made available through the Platform.
- We also monitor Customer traffic patterns and use of the “application/Platform,” enabling us to improve the service we provide.
3. Data Retention Period
3-1 We retain your Personal Data for the period required by the nature of the transaction you conduct through the application/website and for the period necessary to achieve the purpose for which it was collected.
3-2 Once the purpose of processing has ended, the data shall be deleted or anonymised unless a legal obligation, regulatory requirement, or pending judicial claim requires retention. In that event, it shall be retained only for the legally prescribed period.
3-3 Some records may remain in system backups for a limited period after your account is deleted and shall be destroyed in accordance with our approved backup cycle.
4. Purposes for Which We Use Your Data
We undertake not to handle your data, whether for consideration or otherwise, for unauthorised or impermissible purposes with any other entity, unless required or permitted under applicable laws and regulations or with the prior written consent of the User to whom the information relates. We use your data for the following purposes:
- To create your account or profile.
- To enable you to use our services optimally and to consistently provide you with the best service.
- For internal business purposes, such as improving our services.
- To process data provided through our services, such as verifying that your email address or telephone number is active and valid for use.
- To personalise the content, recommendations, and advertisements provided by us and third parties, based on your separate, revocable consent.
- To contact you regarding service and operational communications and security alerts relating to your account.
- To share certain Customer data with Sellers registered in the application, including, without limitation, the geographic locations of points of sale, so the Customer can benefit from Offers and the Seller can follow the delivery process.
- To share your information for purposes disclosed when you provide it, with your consent and in accordance with this Privacy Policy.
- To deliver Offers to the specified person by identifying that person through the QR code containing the Customer information entered at registration, so the person may receive the goods based on the information specified on the Platform.
5. Sharing Your Personal Data with Third Parties
5-1 We may share data with third parties so they can provide you with certain services through the Platform. We shall require those third parties to take all measures necessary to preserve your data and to use it only in accordance with this Privacy Policy, under written data-processing agreements requiring a level of protection no lower than that established in this Policy.
5-2 We exercise due care in selecting and supervising data processors and bear our legal responsibility for their selection, without assuming responsibility for their unauthorised use outside the scope of our instructions.
5-3 This Policy applies only to data collected through the application. Although the Platform may sometimes provide links to third-party websites, this Privacy Policy does not apply to any other website you access through the Platform. We are not responsible for the content or practices of applications and websites operated by other parties and electronically linked within the CODI Platform.
5-4 Transfer of Data Outside the Kingdom: If it is necessary to transfer or process your data outside the Kingdom of Saudi Arabia, this shall be done in accordance with legally prescribed controls and conditions, after verifying the adequacy of the protection afforded by the recipient and obtaining any approval required from the competent authority.
6. Disclosure of Your Data
We may disclose your data to third parties in the following circumstances:
- To provide services available through the Platform.
- Where those third parties assist us in providing services to you or carry out certain functions on our behalf, including information-technology support, professional, or logistics services.
- In the event of a sale, merger, liquidation, transfer of ownership, or appointment of a receiver over the assets of Ads System Company or any of its subsidiaries, to any prospective purchaser of its business and its professional advisers.
- To comply with laws, a court order, or a decision of a competent regulatory authority, or where we consider disclosure necessary to protect, defend, and enforce our rights. This includes exchanging data with other companies and institutions for fraud prevention and reduction of credit risk.
- To execute any lawful request, we may disclose the User’s IP address, all data recorded on the registration page, and all activities undertaken by the User through the Platform/application, as determined by the request, decision, or judicial ruling directed to us.
To enable us to respond to requests from government authorities, summonses, or court orders, or to protect other Users or our systems, we reserve the right to disclose any data if we deem it necessary, including your User data, such as name, email address, address, and other data; usage history; and content submitted to the Platform/application, to the extent necessary to fulfil the purpose of the request.
7. Protection of Your Personal Data
7-1 We do not consider the internet the most secure means of transmitting data. We therefore make every effort to protect the Personal Data in our possession, although we cannot guarantee the security of data transmitted over the internet or through the application. We are fully aware of protection standards and take information-security measures to protect personally identifying information against breach or misuse. All data you provide is stored on secure servers.
7-2 Measures we apply include encryption of data in transit and at rest, need-based access controls, logging access operations, and periodic review of systems.
7-3 You agree that you are responsible for maintaining the confidentiality of your account information and for immediately informing the CODI Platform and/or Ads System Company of any unauthorised use of your account password or any other breach of your confidential information on the Platform.
7-4 The CODI Platform and/or Ads System Company shall not be responsible for any direct or indirect, moral or material loss incurred by you as a result of a third party’s disclosure of username or password information, unless the disclosure arose from our gross error or negligence or from our breach of our data-protection obligations.
8. Notification of Data-Breach Incidents
8-1 If an incident involving leakage, destruction, or unauthorised access to Personal Data occurs, the Company shall notify the competent authority and affected persons within the periods and in the manner prescribed by law.
8-2 The notification shall describe the incident, the nature of the affected data, the measures taken to limit its impact, and recommendations addressed to the Data Subject.
9. Rights of the Personal Data Subject
As a Data Subject, you may exercise the following rights in accordance with applicable laws:
- Right to be informed: to know the legal basis and purpose for collecting your data.
- Right of access: to request a copy of your Personal Data available to us.
- Right to rectification: to request correction or updating of inaccurate or incomplete data.
- Right to destruction: to request deletion of your data when it is no longer needed, unless there is a legal obligation to retain it.
- Right to withdraw consent: at any time in respect of processing based on consent.
- Right to object to and unsubscribe from direct marketing.
- Right to lodge a complaint with the competent data-protection authority in the Kingdom.
Requests may be submitted by email to info@codi.mobi and shall be answered within thirty (30) days of receipt.
10. Our Responsibility in Relation to Privacy
10-1 We are not responsible for theft or leakage of information resulting from transmission or reception errors or unauthorised acts by third parties outside our control, unless caused by our breach of our data-protection obligations or by our gross error or negligence.
10-2 You agree to receive our communications in all forms, including telephone calls, mobile messages, email, periodic newsletters, and notices and alerts announced on the “website” and “application,” in relation to service and operational communications. Marketing communications are subject to your separate consent under Clause (11).
10-3 You agree that all electronic transactions sent to you by us are legally binding and shall be treated in the same manner as written transactions.
10-4 We shall not use your information for any purpose other than completing the provision of services and the purposes stated in Clause (4) above. We do not rent or sell your private information and shall not disclose any information to any third party except in the circumstances stated in Clause (6) above.
11. Marketing Communications
11-1 We may occasionally send you information concerning Offers we make from time to time or services we may provide and believe may interest you when using the Platform, based on your express and separate consent.
11-2 You may unsubscribe from marketing communications at any time using the unsubscribe link included in the message, through your account settings, or by contacting us at info@codi.mobi, without affecting your continued receipt of necessary service and operational messages.
11-3 Third parties are not permitted to target you directly in their marketing activities relating to services they provide. If you receive an unsolicited marketing message, you must notify us immediately.
13. Privacy of Minors
13-1 The Platform is not directed to persons under eighteen years of age, and we do not knowingly collect their data.
13-2 If an Organization includes minors among its Organization Members, such as students, it is responsible for obtaining the consent of the minor’s guardian or lawful representative before adding them and confirms that it has obtained that consent.
13-3 If we discover that a minor’s data has been collected without the legally required consent, we shall destroy it as soon as possible.
14. Changes to the Privacy Policy
14-1 If this Privacy Policy is changed, we shall notify you or publish the change on the Platform and its affiliated applications and shall inform you of the changes where necessary, at least fifteen (15) days before material changes take effect.
14-2 Your continued use of the Platform after the effective date constitutes acceptance of the changes made to the Privacy Policy. If you do not accept amendments to the Privacy Policy, you must stop using the CODI Platform and close your account.
14-3 Please review the Privacy Policy published on the website from time to time to remain informed of its terms and updates.
14-4 The interpretation, implementation, and all aspects of the Privacy Policy are governed by the laws applicable in the Kingdom of Saudi Arabia and its judicial authorities, and the legal review notes — CODI Platform.