Prohibited Content Policy

1.1 This Prohibited Content Policy (this “Policy”) details the types of Content (defined herein) which are prohibited from being offered for sale or published on the Coda Platform (“Prohibited Content”).

1.2 This Policy applies to Content facilitated through all products, services, and activities offered by Coda to any person who uses the Coda Platform and/or Coda Services (as defined herein) (“you” or “your”).

1.3 This Policy is required to ensure that Content offered for sale or published on or via Coda Platform is compliant with relevant laws, regulations and Coda’s obligations to payment partners and third parties. Content is reviewed at various stages of our relationship with you, including during your onboarding process with Coda and periodically thereafter.

2.1 For the purposes of this Policy, the following definitions shall apply:

1. “Content” includes, but is not limited to, articles of digital content, virtual items, online game credits, codes and vouchers; encompassing any components contributing to gameplay experiences, in-app functionalities, or features within the application.
2. “Coda Platform” means a proprietary payment orchestration software platform known as “Codapay,” an online business-to-consumer distribution platform for digital content known as “Codashop,” and any distribution web store or interface owned, operated, and maintained by Coda and/or its distribution partners offering the content for sale to end-users.
3. “Coda Services” refers to the payment orchestration services or the sale and purchase of Content facilitated between Coda and you, including any related products and services.

2.2 Prohibited Content comprises General Prohibited Content and Specific Prohibited Content. General Prohibited Content applies to you in accordance with your agreement with Coda. In addition, if you make available Content in certain territories or with specific Coda’s third-party partners, the Specific Prohibited Content relevant to those territories and third-party partners will also apply to you.

2.3 Coda makes all reasonable efforts to ensure the Policy remains current and aligned with the requirements imposed on Coda by its partners and the applicable laws and regulations. Therefore, Coda reserves the right to update or modify this Policy at any time. It is your responsibility to regularly review the Policy and any changes made to it to ensure your ongoing compliance.  

3. All Content made available by you on Coda Platform must and shall:

3.1 not be sold and may not be used for any illegal purpose (including, without limitation, money laundering), and the transmission and the offering of it must not be in breach of any rights of any third party (including, without limitation, privacy rights, intellectual property rights and other proprietary rights);

3.2 not, and may not, be considered pornographic (including child pornography) or sexually explicit in nature, or otherwise intended for adults only;

3.3 not be, or in connection with, tobacco, alcohol, weapons or ammunition, drugs or drugs paraphernalia, or any other illicit substances;

3.4 not be, or be in connection with, or contain references in support of, terrorism;

3.5 not be and may not be considered to be in connection with gambling, wagering, betting or participating in a lottery or game of chance where the game is played for money or money’s worth, or considered sports-book products or services, a binary option, an investment or financial trading product, or of a similar nature to the aforementioned subject matters;

3.6 not be, and shall not contain any, software virus, malware, spyware, or any other computer code, files, or programs that may interrupt, damage, or limit the functionality of any other computer software, hardware or telecommunications equipment;

3.7 not be and may not be considered libelous, illegal, unlawful, abusive, threatening, harmful, hateful or defamatory, nor insult or treat with disrespect or contempt, or damage any religion, respectful person or objects;

3.8 not cause insult, be offensive to or make disrespectful remark(s) against any country, nationality, religion, ethnic group, caste (and other protected groups), government, government official, gender, gender identity, disability or community;

3.9 not, inadvertently or otherwise, allow or facilitate any third party including end users, to collect, remit or withdraw payments, or cash out or convert into or in exchange for money or any other things of monetary value or equivalent to money;

3.10 not promote discrimination, bigotry, racism, sexism, homophobia or any form of intolerance towards a particular group;

3.11 not conflict with the public policy of the relevant territories in which you operate, nor cause public unrest or affect relationships between countries;

3.12 not contain content of disillusion, deceit, or otherwise which may deceive people, especially kids and youths, including manipulation of systems for personal or financial gain such as phishing schemes, sale or promotion of hacked, stolen, or unauthorized accounts, fraudulent game top-ups or fake virtual items;

3.13 not contain any misrepresentation, misinformation, misstatement(s) or untrue content;

3.14 not be prohibited, nor in connection with, prohibited products, services and/or digital content, as directed by Coda at its sole discretion from time to time;

3.15 not be any content that is designed to spam or harass users with unsolicited messages or contents; and/or

3.16 be in compliance with any and all applicable laws, rules or regulations of any relevant territories.

4. Codapay shall not be used to collect payment for:

4.1. physical goods;

4.2. apps, sites and/or subscription services that are provided through HTML5 (i.e. not through an app that the customer has downloaded) and/or for which the Content is delivered by SMS;

4.3. apps, sites and/or subscription services that facilitate or allow any withdrawal of value that is earned through gameplay using any mechanism (i.e. through an in-game feature or through private channels) and using any unit of value (i.e. money, prepaid mobile credits, gift cards, etc.); and/or

4.4. apps, sites and/or subscription services that allow players to purchase or accrue points that can be used to bid on items or prizes (e.g. raffle games).

5. Content aggregators. Codapay may be used by payment gateways, digital agencies, or other aggregators that are not themselves publishing the Content for which payments are collected through Coda Services, subject to the following requirements:

1. You must act as a merchant of record for the Content published or offered to users on your platforms or websites, including ensuring compliance with all applicable laws, regulations, and industry standards, unless Coda agrees otherwise.
2. You shall be solely accountable for the Content being monetised, including verifying its legitimacy, ownership, and adherence to relevant laws and policies.
3. You must ensure, at all times, during your agreement with Coda: (i) clear and transparent terms and conditions for end users governing the purchase and use of the Content including provisions related to transactions and user interactions, (ii) a detailed policy outlining content restrictions that align with this Policy, and (iii) a well-defined onboarding policy that defines the criteria and process for adding Content or partners to your platforms or websites.

6. Voucher codes/gift cards. Codapay may be used by platforms that sell digital or physical gift or voucher codes (e.g. Google Play Gift Cards or Codes, Steam Wallet Codes, etc.), subject to the following requirements:

1. You must ensure, at all times, during your agreement with Coda: (i) clear and transparent terms and conditions for end users governing the purchase and use of these digital codes, gift cards, or voucher codes including provisions related to transactions and user interactions, and any limitations on use, (ii) effective fraud prevention mechanisms to safeguard the purchase transaction, (iii) compliance with AML/CTF regulations, and (iv) clear policies on refund and chargeback, specifically for gift cards.

7. NFT sales and cryptocurrencies. Limited availability: subject to our review and approval. For more information please contact our sales team at partnerships@coda.co.

8. You are subject to the Specific Prohibited Content in addition to the General Prohibited Content. The restrictions listed may vary based on the territory, the type of Content being offered, and the requirements of Coda’s third-party partners, including payment channel partners.

9. Please contact partnerships@coda.co if you have any questions about the applicability of the restrictions in certain territories or if you would like to understand the requirements from Coda’s third-party partners for specific Content (where applicable).

10. Coda reserves the right to review and monitor your compliance with this Policy, including requesting any material and documentation to verify your compliance. Any violations of this Policy may result in immediate action for Coda, as deemed necessary, and are without prejudice to any other remedies or legal actions available to Coda.

11. This version of the Policy provides a summary to help you understand our Prohibited Content. Upon onboarding with Coda, you will be subject to the full version of this Policy, which will form part of your agreement with Coda.

If you have any questions or require further clarification regarding this Policy, please contact us at partnerships@coda.co.