PRIVACY POLICY

This privacy policy was last updated on 1 September 2023.

Your privacy is important to us. This Privacy Policy (“Policy”) explains how CODROK, uses, discloses, and retains your information when you visit or use our website (our “services”), including the use of personal information in connection with interest-based advertising. It also describes the controls we provide you with to manage your personal information within our services and your data subject rights (such as your right to object to certain types of processing we carry out). Please read through the following before providing us with any of your personal data. When you provide CODROK with your personal data, you consent to CODROK’s collection, use, disclosure, and retention of your personal data in accordance with this Privacy Policy and as otherwise permitted by law.

What Personal Data do we collect

The types of personal data we collect from you include:

Account Information:

When you create or manage an account with CODROK, and/or sign up for a loyalty program, we collect the following information from you:

• Name
• Email address
• Gender
• Nationality
• Date and month of birth
• Contact information
• Password/ Answers you provide to security questions
• Mailing and shipping address

Purchase Information:

When you purchase products or services from our store, as part of the buying and selling process, we collect the following information from you, or your friends and family who wish to ship a product (including gift cards) to you:

• Name
• Email address
• Credit card and payment information
• Mailing and shipping address
• Contact information
• Marketing preferences and any other information you provide
• Please note that we retain your purchase history from CODROKwebsites

Online Activity information:

When you use our website we collect (including through cookies and similar trackers) the IP address you use, information so we can single out your device and information about you, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access. We collect information on the products you click to view through our emails. Our partners may also collect similar information, including with respect to your activities on other sites. Among other things, this helps us analyze, improve, and secure our online services, as well as support our advertising and marketing efforts

Marketing information:

When you register, or subscribe for our newsletters or promotions, or participate in our promotions, sweepstakes, contests, or surveys, and/or fill in any forms on our websites, we collect the following information that is needed for your participation:

• Name
• Contact information
• Date of birth
• Email address
• Marketing preferences
• Any other personal information you choose to provide to us

Feedback Information:

When you submit a review for any item on the CODROK websites, we collect the following information from you:

• Name
• Gender
• Photographs you upload or any other personal particulars you voluntarily provide

Support Information:

When you submit any questions or feedback to us, or contact or correspond with us in any way, we collect the following information from you:

• Name
• Email address
• Contact information
• Any other personal information you choose to provide to us

Information from third-party partners:

We may collect your email address via cookies and pixels on the website through the use of trusted third-party partners. These partners may combine your email information with other information they have access to such as mailing address so that we may serve relevant marketing offers to you via direct mail.We will indicate if the collection and provision of certain categories of personal data is mandatory. For any such categories, we may not be able to provide you with access to the certain features of our website or order any products if you do not provide us with the required information.

We may also obtain information about you from our third-party partners to allow us to successfully fulfil any orders placed by you or your friends and family. This information includes, but is not limited to:

• Name
• Mailing and Shipping Address(es)
• Contact information
• Any other information required for us to fulfil these orders

An example of us obtaining information about you from our third-party partners includes when you purchase a product through a third-party platform, such as Facebook or Instagram, and the third-party platform sends us your name, contact information and transaction information but not your payment card details.

Occasionally, we may require more information for contractual or legal reasons. We will inform you when such information is required, how to provide them, and any implications should you fail to comply with our request.

How CODROK uses your personal information

We may use and disclose your Personal Data for the following purposes:

To provide our services

• To establish and maintain your user account and/or loyalty program on our sites, including tracking your orders, purchase history, and shipments and sending you reminders of items left in your shopping cart and/or providing you with product notifications;
• To improve our services and business, including in response to trends, patterns, feedback, and sentiments expressed on social media or directly to us;
• To process your order for our products or services, process or collect your payment for the order;
• To process your returns or refunds in accordance with our Terms and Conditions;
• To understand your needs and interests, and personalise your experience with the Service and our communications such as by using your location information to determine your language preferences or display accurate date and time information; and
• To provide support for the Service, respond to your requests, questions and feedback, evaluate your satisfaction with the Service and to otherwise administer our relationship with you.
• To provide you with supporting services and functions related to your user account;
• To monitor and enforce compliance with our Terms and Conditions, including dispute resolution; and
• To comply with (i) internal risk controls, (ii) the terms of our access to payment processing, financial or banking services such as credit card disputes, fraud, billing errors, or (iii) any applicable law

Marketing and Advertising

• To send you marketing communications and ads in relation to our sales, products, services and promotions, including promotional mail together with your order;
• To deliver advertisements which are related to our products and services which may be of interest to you on our websites and/or social media platforms;
• To process your participation in our promotions, lucky draws, initiatives or any request for additional Personal Data such as customer surveys;
• To process your participation in our loyalty programs;
• To promote our products and services on our websites;
• To improve your customer experience across all touchpoints and training our customer experience team, such as by recording and monitoring phone calls; and
• For any specific purpose in relation to a particular product or service, which we may separately notify you on the product or service page

Research and Development

We may use your Personal Data for research and development purposes, including to analyse and improve the Service and our business. As part of these activities, we may create aggregated, de identified or other anonymous data from personal information we collect. We make personal information into deidentified or anonymous data by removing information that makes the data personally identifiable to you. We may use this deidentified or anonymous data and share it with third parties for our lawful business purposes, including to analyse and improve the Service and promote our business.

Others

We may also use your Personal Data (a) for other purposes which are reasonably related to the Purposes and where we have obtained and maintain related consent, the Additional Purposes; or (b) in circumstances where such use does not require consent under Applicable Laws.

How CODROK shares your personal information

In order to provide the above services to you, we may share your personal data with the following entities:

• Companies involved in running our website, getting your purchases to you, such as payment service providers, warehouses, order packers, and delivery companies;
• Companies involved in running our loyalty program (if you participate in the program);
• Professional service providers, such as marketing agencies, and 3rd party platform providers, who help us to run our business;
• Companies approved by you, such as social media sites (if you choose to link your account to us); and
• Law enforcement and fraud prevention agencies or anybody required by law.

In addition, through our Services, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioural advertising. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our thirdparty service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.

We may also disclose or transfer personal data as otherwise permitted or required by law, including for compliance with regulations on anti-money laundering and countering the financing of terrorism.

We may disclose your information to a third party in connection with a proposed or actual business transaction, such as a corporate reorganisation, merger or acquisition, or the sale of some or all of our business or assets (including in connection with a bankruptcy proceeding) We will require that the information recipient agree to protect the privacy of your information in a manner that is consistent with this Policy. This could include all of your information relevant to the business being acquired.

Website Cookies

Some of the information that we collect will not personally identify you but will instead track your use of our website so that we can better understand how our website is used by end users and in turn enhance and improve your experience in using our website. This information can be obtained through the use of cookies. Cookies are a small data file transferred to your device that recognises and identifies your device and allows your device to 'remember' information from our website for future use. We may collect technical information from your web browser or mobile device or your use of our services through a web browser or mobile device, for example, location data and certain characteristics of, and performance data about your device, carrier/operating system including device and connection type and IP address. Unless you have elected to remain anonymous through your device and/or the web browser, the above mentioned information may be collected and used by us automatically through your use of our website. Additionally, we may share non-personally identifiable information with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising. You have a number of options to control or limit how we and our partners use cookies and similar technologies, including for advertising.

• Although most browsers and devices accept cookies by default, their settings usually allow you to clear or decline cookies. If you disable cookies, however, some of the features of our website may not function properly.
• To prevent your data from being used by Google Analytics, you can install Google’s opt-out browser add-on by visiting https://tools.google.com/dlpage/gaoptout.
• To opt out of ads on Facebook, Pinterest, or Google that are targeted to your interests, use your Facebook, Pinterest, or Google Ads settings.
• If you are using your mobile device, check your mobile device for settings that control ads based on your interactions with the applications on your device. For example, on your iOS device, enable the “Limit Ad Tracking” setting, and on your Android device, enable the “Opt out of Ads Personalization” setting.

Our websites do not respond to Do Not Track signals because we do not track our users over time and across third-party websites to provide targeted advertising. However, we believe that you should have a choice regarding interest-based ads served by our partners, which is why we outline the options available to you above.

Links To Third Party Websites

The website may contain links to other third party websites and microsites, whose privacy practices may differ from those of ours. If you submit personal data to any of those sites, your personal data is not subject to this Privacy Policy. We are not responsible for the security or privacy of any information collected of such websites and microsites.

We encourage you to review the privacy policy of any website you visit. By clicking on or activating such links and leaving our website, we can no longer exercise control over any personal data which you give to any other entity after leaving our website. Any access to such other third party websites is therefore entirely at your own risk.

Accessing And Correcting Your Personal Data

You may review and correct your personal data by signing into your user account and selecting 'Update Profile' or equivalent, or by contacting us at CODROK. We will only disclose personal data to the individual who registered his/her personal data with our website, and only after confirming the identity of the registered party. Please allow fourteen (14) working days for your request to be processed. In relation to any request for access to any personal data, we reserve the right to charge a nominal fee for the processing of this request in accordance with applicable local legislation.

Deletion of your account with us will not automatically delete the personal data held about you. If you would like to request that we delete all personal data together with the deletion of your account, please follow the steps under Request for Deletion of Personal Data.

Opting-Out

You have certain choices about your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us at CODROK. Please allow thirty (30) working days for your request to be processed.

Even if you opt out, we may still collect and use non- personal information regarding your activities on our Services and for other legal purposes as described above.

If you would like to unsubscribe from our newsletter, or opt-out of our loyalty program detailed instructions are provided at the bottom of all emails sent out. If you would like to unsubscribe from any of our other mailing lists, please write to us at CODROK. Please allow thirty (30) working days for your request to be processed.

Request for Deletion of Personal Data

You have the right to request that we delete any of your personal data that we collected from you and retained, with certain exceptions. If you would like to withdraw your consent for the collection, use and/or disclosure of any of your personal data, please write to us at CODROK. We will process such a request within a reasonable time and it may take up to thirty (30) days for this to be reflected in our systems. Once this is complete, we will no longer retain, use and/or disclose your personal data, except for compliance, regulatory or other legal purposes. Our ability to comply with your deletion request is subject to any applicable legal or other requirement to maintain certain records of your personal data. In that regard, please note that the deletion of your personal data from our database will result in us not being able to provide you with the products or services that you have requested from us.

Retention of Personal Data

Unless you have exercised your right to withdraw your consent, we will retain your Personal Data for as long as it is necessary for our legitimate business purposes, as well as our legal and financial obligations.

When your personal data in our possession is no longer required for the purpose it was collected for, or any of our legitimate business or legal purposes, we will exercise measures to ensure that your personal data is either destroyed or anonymised.

Security

We take reasonable precautions to protect your information and process it securely. Such measures include, but are not limited to passwords, firewalls, and other standardised industry practices. Where you have chosen a password to access our website, you are responsible for keeping your password confidential. Do not share your password with anyone. However, no method of transmission over the internet, or electronic storage, is 100% secure and we cannot be held liable for any loss you may suffer for unauthorised access or loss of any data provided to our website. Nevertheless, we strive to protect the security of your information, and are constantly reviewing and enhancing our information security measures. We may, but are not obliged to, post a notice on our website if a security breach occurs, or send an email to you at the email address you have provided to us in these circumstances.

Transfer

The personal data you provide to us may be transferred to and stored with a cloud service provider with servers that are located in various jurisdictions. In addition, some of the entities to which your personal data may be disclosed or transferred under "Personal Data" above may be located outside your home jurisdiction. Some of these countries may not have the same or substantially similar privacy laws than those of your home jurisdiction. We have taken appropriate safeguards to require that your personal information will remain protected and require our third party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.

Amendments

We reserve the right to amend this Privacy Policy at any time. The Effective Date stated below indicates the last time this Privacy Policy was materially revised. Any changes we may make to this Privacy Policy in the future will be posted on our website. You are encouraged to review this page periodically to see any updates or changes to our Privacy Policy.

Contact Us

All other questions on our use of your personal data should be addressed to our Data Protection Officer, whom you may contact at CODROK.