Subbu | Subbu Privacy Policy
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Last updated 05/01/ 2022

Coda Commerce Limited (a limited company with registration number 03874501 whose registered office is at Osbourne House, 143-145 Stanwell Road, Ashford, Middlesex, TW15 3QN.) (“us”, “our”, “we”, “Coda”) is a processor of personal data collected through the Subbu application (the “Application”). The Application has been developed to integrate retailers IT systems with their logistics providers.

Coda is committed to protecting and respecting privacy.

This privacy policy (the “Policy” or “Privacy Policy”) sets out the types of personal data we collect and use to provide the Application and how we may use that data.

1. Introduction

This Privacy Policy explains who we are, why and how we process personal data collected through use of the Application and, if you are the subject of any of the personal data concerned, what rights you have and how to get in touch with us if you need to.

Our Application enables retailers to pass information to logistics providers such as courier companies. We are not a data controller and only process your data on the instructions of data controllers. The data controller will generally be a retailer.

When personal data is supplied to us, we have legal obligations towards the data subject regarding the way we use that data. For ease of reading, we have divided this Policy into several sections:

1. Introduction
2. What information can we collect?
3. Special Category Data
4. How is your personal information collected?
5. How and why do we use and share your personal information?
6. For how long do we keep your personal information?
7. Security
8. Your Rights
9. Contact Details

It is important that you read this Policy together with any other privacy notice or fair processing notices that are provided by the retailer so that you are fully aware of how and why personal data is being used.

This Policy supplements other notices on our website and is not intended to override or replace them.

We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to let users of the Application know – for ease of reference the top of this Policy indicates the date on which it was last updated.

We may process personal data about children on behalf of data controller users of the Application.

2. What information can we collect?

What is personal data?

Where this Policy refers to ‘personal data’ it is referring to data about natural persons from which a specific individual could be identified – such as name and address.

By law, all organisations who process personal data in the UK are obliged to process personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the ‘Your Rights’ section of this Privacy Policy.

What types of data we collect through the Application

The personal data we collect from you may include:

• Identity Data which includes your name and gender.
• Contact Data which includes your e-mail address, billing address and delivery address.
• Transaction Data which includes details about payments from you and other details or services you have purchased from the retailer.

3. Special Category Data

We do not collect any special categories of personal data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

4. How is your personal information collected?

Direct interactions

If you contact us in relation to your personal data, we will process your personal data for the purposes of responding any requests and general communication.

Indirect interactions

When you purchase from a retailer and require delivery of goods, we process, store and use the personal data that you disclose to the retailer in order to enable delivery of the goods.

Third parties or publicly available sources

We partner with third parties who may collect personal data (including, for example, business partners, retailer customers and sub-contractors for technical support and delivery of the Application service) who may provide us with personal data.

How and why do we use/share your personal data?

Lawful basis for processing your information

We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:

● Where you have asked us a retailer customer to provide goods and they have a contract with us to process that data; and
● Where we need to comply with a legal or regulatory obligation.

Sharing your personal data

Depending on how we are processing your personal data we may share it in the following ways:

• we may share your personal data with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006; and
• with selected third parties to which we sub-contract to provide various services and/or aspects of the Application functionality, such as where we use third party plugins; and
• with further data processors of the retailer such as the courier companies.

We may also disclose your personal data to third parties in the following events:

• if we were to sell or buy any business or assets, in which case we might disclose your personal data to the prospective seller or buyer of such business or assets as part of that transaction;
• if Coda or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers and contacts 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 if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or

Change of purpose
We will only use your personal data for the purposes for which we have received it and on the instructions of the retailer (the data controller.)
5. For how long do we keep your personal data?

We will hold your personal information on our systems only for as long as required to provide our data processing services to the data controller and in accordance with our contractual obligations to the retailer (data controller.)

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate user data to manage traffic.

6. Security

Coda takes the protection of personal data very seriously. We have put in place technologically and organisationally appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know.

We have put in place procedures to deal with any suspected personal data breach and will notify the data controller and any applicable regulator of a breach where we are contractually and/or legally required to do so.

7. Your Rights

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance at (link to Contact Us page].
As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.

Right of Access
You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).

Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.

You can exercise this right at any time by writing to us by contacting us and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.

Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue processing it including storing it (you may have heard of this right described as the “right to be forgotten”).

Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is correct. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.

You can exercise this right at any time by contacting us and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

Your Right to Restrict Processing
You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.
Your Right to Portability
Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.
Your Right to object to processing
You may object to processing of your personal data but this may mean you may not be able to receive the goods or services from the data controller.
Your Right to stop receiving communications
We do not send communications to you except in response to your privacy enquiries.
Your Right to object to automated decision making and profiling
We do not make automated decisions or profile based on your personal data.
Withdraw consent, where consent is the lawful basis for processing
You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Exercising your rights
When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.
It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

8. Contact Details
If you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights set out above or if you think that the Privacy Policy has not been followed, please contact us by emailing at (link to Contact Us page).