Effective Date: 23-APR-2026
1. Introduction
CODADA ("we", "our", "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit codada.com, whistleblower.codada.com, and related CODADA-operated domains and services (collectively, the "Site"). Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access or use the Site.
CODADA® is a registered trademark and is used under license by CODADA International LLC.
This Privacy Policy applies to CODADA-operated websites and domains, including general website use and the CODADA Conduct & Ethics Portal available at whistleblower.codada.com. Certain processing activities relating to the portal are described in the specific section below.
2. Information We Collect
We may collect information about you in a variety of ways. The information we may collect on the Site includes:
- Personal Data: Personally identifiable information, such as your name, email address, phone number, company details, and any messages or other information you voluntarily provide when you contact us, use our forms, or otherwise communicate with us.
- Derivative Data: Information our servers automatically collect when you access the Site, such as your IP address, browser type, device type, operating system, access times, referring pages, and the pages viewed directly before and after accessing the Site.
- Communications and Form Submissions: Information you provide when submitting inquiries, requests, appointment requests, or other messages through the Site.
- Portal Reports and Related Information: Information submitted through whistleblower.codada.com, including the content of reports, supporting documents, communications within the portal, and any identity or contact information voluntarily provided by the reporter. Reports may also contain information relating to other persons named in or connected to the report.
We do not sell or trade your personal information to third parties.
3. Use of Your Information
We may use information collected about you via the Site to:
- Respond to your inquiries, requests, and communications.
- Communicate with you regarding updates or other important information.
- Provide, operate, maintain, and improve the Site.
- Monitor and analyze usage and trends to improve user experience and security.
- Manage business communications and related activities.
- Prevent fraudulent activity, unauthorized access, misuse, and other unlawful activity.
- Protect our rights, property, systems, and business operations.
- Receive, review, assess, investigate, and follow up on reports submitted through the portal.
- Comply with legal, regulatory, compliance, and internal governance obligations.
4. Disclosure of Your Information
We may share information we have collected about you in certain situations. Your information may be disclosed as follows:
- By Law or to Protect Rights: If we believe the release of information about you is necessary to respond to legal process, comply with applicable law, investigate or remedy potential violations of our policies, or protect the rights, property, and safety of CODADA or others, we may disclose information as permitted or required by law.
- Service Providers: We may share information with third parties that perform services for us or on our behalf, including hosting, infrastructure, email, technical support, security, and similar operational services, subject to appropriate confidentiality and access controls.
- Professional Advisers: We may share information, where necessary, with legal advisers, accountants, auditors, or other professional advisers in connection with compliance, investigations, legal claims, or business protection.
- Portal Reports: Information submitted through the portal may be disclosed only to persons who need access for the purpose of reviewing, handling, investigating, or following up on a report, including authorized internal personnel and, where necessary, external advisers or competent authorities.
5. Security of Your Information
We use administrative, technical, and physical security measures designed to protect your personal information. These measures include access controls, restricted administrative access, and other safeguards appropriate to the nature of the information processed. While we take reasonable steps to protect the information you provide, no system or method of transmission over the internet can be guaranteed to be completely secure.
6. CODADA - Conduct & Ethics Portal
This section applies specifically to reports and related information submitted through whistleblower.codada.com.
6.1 Purpose of the Portal
The CODADA Conduct & Ethics Portal is provided to enable the confidential submission, receipt, review, and follow-up of reports relating to suspected misconduct, compliance concerns, ethical issues, or other matters that may appropriately be raised through the portal.
6.2 Categories of Data Processed
Data processed through the portal may include:
- Identity and contact details of the reporter, if voluntarily provided.
- The content of the report and any follow-up communications.
- Information relating to persons named in the report, including witnesses or other third parties.
- Documents and other files uploaded in support of a report.
- Technical and system data processed in connection with the operation, security, and administration of the portal.
6.3 Confidentiality and Access
Access to reports submitted through the portal is restricted to authorized persons with a legitimate need to access the information for review, handling, investigation, follow-up, compliance, or legal purposes. CODADA treats such reports as confidential, subject to applicable legal obligations and the need to conduct an appropriate review or investigation.
6.4 Anonymous Reporting
The portal may allow reports to be submitted without identifying the reporter. Where a reporter chooses not to disclose their identity, CODADA will process the report on the basis of the information made available through the portal and any follow-up communications that may be possible through the system.
6.5 Use and Disclosure of Portal Information
Information submitted through the portal will be used only for legitimate compliance, ethics, legal, governance, and related case-handling purposes. Such information may be disclosed, where necessary, to authorized internal personnel, legal advisers, investigators, professional advisers, or competent authorities, subject to appropriate confidentiality safeguards and applicable legal requirements.
6.6 Retention
Reports submitted through the portal and related information will be retained only for as long as reasonably necessary for the handling of the report, any resulting investigation, follow-up actions, legal or regulatory obligations, and the establishment, exercise, or defense of legal claims, after which such data will be deleted, anonymized, or otherwise handled in accordance with applicable requirements and internal retention practices.
6.7 Portal Infrastructure
The CODADA Conduct & Ethics Portal is operated using GlobaLeaks as part of CODADA's technical infrastructure. As with any online system, certain technical and server-side data may be processed as necessary for hosting, security, maintenance, and operation of the portal.
7. Legal Basis for Processing
Where required by applicable law, we process personal data only where there is an appropriate legal basis to do so. Depending on the nature of the data and the purpose of the processing, this may include processing that is necessary for our legitimate interests in operating, securing, and improving the Site and managing our business activities, processing that is necessary to comply with legal or regulatory obligations, processing that is necessary in connection with the establishment, exercise, or defense of legal claims, and processing based on consent where consent is required or has been provided. In connection with reports submitted through the portal, personal data may also be processed where necessary for the receipt, review, assessment, investigation, and follow-up of reports and for related compliance, governance, and legal purposes.
8. Your Rights
Subject to applicable law, you may have rights in relation to your personal data, including the right to request access to, correction of, or deletion of personal data, the right to restrict or object to certain processing, and the right to lodge a complaint with a competent authority. These rights may be limited where necessary to protect confidentiality, preserve the integrity of an investigation, comply with legal obligations, or protect the rights of others, including in connection with reports submitted through the portal.
9. International Transfers
Depending on the nature of the inquiry, report, service provider, hosting setup, or internal handling process, your information may be processed in jurisdictions other than your own. Where applicable, we will take reasonable steps to ensure that such processing remains subject to appropriate safeguards and confidentiality measures.
10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to our practices, systems, legal obligations, or operational requirements. We will notify users of material changes by updating the "Effective Date" of this Privacy Policy. You are encouraged to review this page periodically to remain informed of any updates.
11. Contact Us
If you have questions or comments about this Privacy Policy, please contact us at:
CODADA
Email: [email protected]
Phone: +60 11 1537 0788
Address:
Ilham Tower, Level 33,
No. 8, Jalan Binjai, Kuala Lumpur 50450 / Malaysia