Privacy Policy

1. Data Controller

The entity responsible for processing your personal data is:

Company Name: CODIXERA LIMITED

Registration Number: 15712597

Address: Unit A, 82 James Carter Road, Mildenhall Industrial Estate, Suffolk, United Kingdom, IP28 7DE

Email: [email protected]

We determine how and why your personal data is processed and are responsible for its protection. Contact us with any questions regarding how your data is handled.

2. Methods of Data Collection

We collect personal data through:

• Direct Collection: data you provide when creating an account, contacting us, or using our top-up and bundle services.
• Automated Collection: data gathered through cookies and similar tracking technologies.
• Third-Party Sources: data received from service providers, regulators, or publicly available sources.

3. Categories of Personal Data We Process

We may collect and process the following categories of personal data:

• Contact Information: name, email, phone, address.
• Account Information: profile ID, password, settings.
• Identity Data: full name, date of birth, identification documents, where required for verification.
• Legal Data: information needed to comply with legal obligations (AML, KYC), where applicable.
• Transaction Data: top-up and bundle order history, recipient mobile number, billing information.
• Payment Information: Payments are handled by our authorised payment processor, FINTECH GLOBAL SOFTWARE LTD. We do not collect, process, or store your payment card details or other sensitive financial information. Payment data is collected and processed directly by the payment gateway in compliance with PCI-DSS standards.
• Communication Logs: emails, chats and call records with our support team.
• Marketing Data: your preferences for marketing communications and surveys.
• Technical Data: device information, IP address, cookies, usage statistics.
• Customer Support Information: details of enquiries and support interactions.

4. Mandatory and Optional Data

Some data is required for us to provide our top-up and bundle services (for example, the recipient mobile number and payment details); other data is optional and can be managed through your account or browser settings.

5. Legal Grounds for Processing

We process personal data on the following legal grounds:

Account Management: To set up and administer your user account so that you can access and use our services. (Legal Basis: Performance of a contract.)

Provision of Services: To deliver the top-up and bundle services you request, efficiently and in line with your needs. (Legal Basis: Performance of a contract.)

Identity Verification: To confirm your identity and secure your account, protecting against fraud and unauthorised access. (Legal Basis: Compliance with a legal obligation, Legitimate interests.)

Legal Compliance: To comply with applicable laws and regulations, including anti-money laundering (AML), counter-terrorist financing (CFT), know-your-customer (KYC) and related requirements where applicable. (Legal Basis: Compliance with a legal obligation, Performance of a public task.)

Order Fulfilment: To process and complete your top-up or bundle orders, including handling payment and delivering the recharge to the recipient mobile number. (Legal Basis: Performance of a contract.)

Transaction Management: To manage and support transactions, ensuring their accuracy, security and compliance with applicable standards. (Legal Basis: Performance of a contract, Legitimate interests.)

Risk Management: To assess, monitor and manage business risk, so that our services continue to run smoothly. (Legal Basis: Performance of a contract, Compliance with a legal obligation, Legitimate interests.)

Customer Communication: To engage with you about your account, provide support, and respond to enquiries. (Legal Basis: Performance of a contract, Legitimate interests.)

Marketing: To send marketing communications and tailored content, where you have given your consent. (Legal Basis: Consent, Legitimate interests.)

Fraud Prevention: To detect, prevent and respond to fraud and other unlawful activity, protecting both our services and your data. (Legal Basis: Compliance with a legal obligation, Legitimate interests.)

Security: To protect our systems and data from unauthorised access, maintaining their integrity and confidentiality. (Legal Basis: Performance of a contract, Compliance with a legal obligation, Legitimate interests.)

Technical Support: To diagnose and resolve technical issues and keep our services reliable. (Legal Basis: Performance of a contract.)

Service Improvement: To develop and improve our services based on feedback and usage patterns. (Legal Basis: Legitimate interests.)

Dispute Resolution: To manage and resolve legal claims or disputes, protecting our legal interests and meeting our legal obligations. (Legal Basis: Performance of a contract, Compliance with a legal obligation, Legitimate interests.)

6. Data Sharing

We may share your data with service providers who help us deliver our services — for example, payment processors and mobile top-up/recharge platform partners. We do not sell your personal data. Any sharing takes place in accordance with legal requirements and appropriate safeguards.

7. International Data Transfers

Your data may be transferred outside the UK or EU/EEA for processing. Where this occurs, we take appropriate measures to protect it, including the use of Standard Contractual Clauses or other approved legal mechanisms.

8. Data Retention

We retain your personal data only for as long as necessary for the purposes for which it was collected. Data connected to legal obligations may, for example, be retained for up to five years, or longer where required by law.

9. Data Security

We apply robust technical and organisational measures to protect your data, including encryption, secure storage, access controls and regular security assessments. We also work with trusted providers who maintain high security standards.

10. Your Data Subject Rights

You have the following rights regarding your personal data:

• Right to Access: request a copy of the data we hold about you.
• Right to Rectification: correct any inaccurate data.
• Right to Erasure: request deletion of your data, subject to legal exceptions.
• Right to Restrict Processing: limit how your data is processed.
• Right to Object: object to processing based on legitimate interests or for marketing purposes.
• Right to Data Portability: request your data in a machine-readable format and have it transferred to another service.
• Right to Withdraw Consent: withdraw consent for data processing, where applicable.

To exercise any of these rights, please contact us. We may need to verify your identity before processing your request.

11. Automated Decision-Making and Profiling

We do not use automated decision-making or profiling that produces legal or similarly significant effects on you.

12. Complaints

If you have concerns about how we handle your data, please contact us directly. If you remain unsatisfied with our response, you may lodge a complaint with the relevant supervisory authority. In England and Wales, this is the Information Commissioner's Office (ICO).

Contact details:

The Information Commissioner's Office (ICO)

Website: ico.org.uk/global/contact-us/

Data protection complaint mechanism: ico.org.uk/make-a-complaint/data-protection-complaints/

Tel: +0303 123 1113

13. Updates to This Privacy Policy

We may update this Privacy Policy to reflect changes in our data processing practices or in applicable law. The latest version will always be available on our website, and we will communicate any significant updates to you. We encourage you to review this Policy periodically.

14. Data of Minors

Our services are not intended for individuals under 18 years of age. We do not knowingly collect data from minors. If we become aware that we have inadvertently collected such data, we will take prompt steps to delete it.

15. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at [email protected].