1 Who we are
CODASMS (codasms.com) is operated by [EKRPT Networking Labs Ltd., RC [number], registered address, Nigeria], the data controller for the personal data described here. Contact our privacy team at [privacy@codasms.com]. [Lawyer: add an EU/UK representative and/or DPO if required by GDPR Art. 27.]
2 Data we collect
| Category | Examples |
|---|---|
| Account | Email address, password (hashed), account settings, referral code used. |
| Transactions | Balance ledger, top-ups, purchases, refunds, loyalty points. Payments are processed by PayPal/Cryptomus — we receive a confirmation and transaction ID, not your full card or wallet details. |
| Service usage | Orders placed (service, country, status), and verification codes received on a number you ordered, shown in your account. |
| Technical | IP address, device/browser type, and similar log data, used for security and fraud prevention. |
| Analytics & marketing | Only with your consent via the cookie banner — see our Cookie Policy. |
3 How we use your data
- Provide the Service — issue numbers, deliver codes, maintain your balance.
- Process payments and prevent duplicate or fraudulent credits.
- Operate referral, affiliate, and loyalty programs.
- Secure the Service, detect abuse, and meet legal obligations.
- Communicate with you about your account and support requests.
- With consent, measure usage and send marketing.
4 Legal bases (GDPR/NDPR)
We rely on: contract (to provide the Service you sign up for); legitimate interests (security, fraud prevention, service improvement); consent (analytics and marketing cookies, marketing email); and legal obligation (record-keeping, lawful requests). You can withdraw consent at any time. [Lawyer to confirm bases per processing activity.]
6 International transfers
Because we serve customers globally and use international processors, your data may be processed outside your country, including outside Nigeria and the EEA/UK. Where required, transfers are protected by appropriate safeguards such as standard contractual clauses. [Lawyer to confirm transfer mechanism and list processor locations.]
7 Retention
We keep account and transaction records for as long as your account is active and for a period afterward to meet legal, tax, and fraud-prevention obligations. Received verification codes are retained only as long as needed to display them to you and are then deleted or anonymised on our standard schedule. [Lawyer/ops to set exact retention periods.]
8 Your rights
Subject to applicable law, you may request to access, correct, delete, restrict, or port your data, and to object to certain processing or withdraw consent. To exercise any right, contact [privacy@codasms.com]. You also have the right to complain to your data-protection authority — in Nigeria, the [Nigeria Data Protection Commission]; in the EU/UK, your local authority.
10 Security
We use technical and organisational measures to protect your data, including encryption in transit, hashed passwords, server-side handling of payment and supplier keys, and access controls. No system is perfectly secure, but we work to protect your information and to notify you and regulators of breaches where the law requires.
11 Children
The Service is for users 18 and older. We do not knowingly collect data from children. If you believe a child has used the Service, contact us and we will take appropriate action.
12 Changes
We may update this policy. Material changes will be posted here with a new "last updated" date and, where appropriate, notified in-account.
13 Contact
Privacy questions or requests: [privacy@codasms.com]. Controller: [EKRPT Networking Labs Ltd., address, RC number].