A. COLLECTION OF INFORMATION
The personal information that we may collect about you broadly falls into the following categories:
Information you provide to us
If you are a representative or employee of any Buyer or Seller or a sole trader Buyer or Seller:
• You will be asked to provide specific contact information that is necessary for the registering for a Platform account on behalf of a Buyer or Seller, including name, address, phone number, email address, job title, and department;
• You will be asked to provide certain identifying information, tax registration and/or related information about your business, such as your company name, business type, and industry, corporate registration details, and information about your business license;
• If you are a Seller, we will also ask you to provide details about the goods and products that you intend to sell via the Platform and details about your sales/transactions on BrandsPal.com;
• If you are a Buyer, we will also ask you to provide details or preferences about the goods and products that you may be interested in buying via the Platform and any details or preferences relevant to your purchases;
• If you are successfully certified by BrandsPal as a blogger or an influencer, in addition to the information mentioned above, we may also collect your live stream videos, your social media account names and profile photos, and posts or comments made by other users of the Platform;
• In connection with the facilitation of transactions, purchases and payments over the Platform, you will be asked to provide certain payment information. This might include bank account numbers, billing and delivery information, credit/debit card numbers, expiration dates and security code and tracking information from cheques or money orders to facilitate the sale and purchase as well as the settlement of purchase price of the products or services transacted on or procured through the Platform;
• We will process any information provided to us in connection with disputes or to support complaints in connection with the Platform or goods and/or services purchased via the Platform. Please note, Buyers and/or Sellers may submit complaints regarding the products and services on the Platform and/or disputes between the Buyers and Sellers to the Platform and under such circumstances, we will process data provided to us by Buyers and/or Sellers that is relevant to the disputes or complaints submitted. This may include health data of end-users (which may include minors as applicable) of products purchased on the Platform to the extent relevant to the disputes or complaints that are being reviewed by the Platform and to the extent that the individual(s) has provided their explicit consent to their data being shared with us for the purposes of handling the complaints and/or settling the disputes.
• Information you submit to the Platform for publication may be made publicly available on the Platform and therefore accessible by any internet user. You should exercise caution when deciding what information, you submit to us for publication.
Information that we collect automatically
• If you contact us (such as via our customer services department chat service, telephone or email), we may record a copy of your correspondence and may ask for additional information to verify your identity.
• We will collect contact details and other information of users from publicly available sources for the purposes of verifying the users and performing due diligence on the users.
• We will collect details of user activities, transactions and interactions on the Platform including information relating to the types and specifications of the products and services purchased, pricing and delivery information, dispute and complaint records, communications between users and any information disclosed in any discussion forum.
• From time to time, we may also collect information about the existing and prospective users, during or in connection with trade shows, industry events and/or other functions. Including representative contact names, addresses, phone numbers, fax numbers and email addresses.
• If you visit our Platform, we will automatically collect certain information from your device. In some countries, including countries in the European Economic Area, this information may be considered as personal information under applicable data protection laws. Specifically, this information may include IP addresses, device type, unique device identification numbers, browser type, broad geographic location (e.g. country or city-level location), browsing patterns and details of how you have interacted with our Platform and the goods and services available on it. In addition, we gather statistical information about the Platform and visitors to the Platform including, browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors. Collecting this information enables us to better understand the visitors who come to our Platform, where they come from, and what content is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Platform.
Information that we receive from third parties
• We may receive personal information about you from social media platforms if you choose to register for a Platform account via a social media account. Exactly what information we receive will depend on your privacy settings with the applicable platform, but it would typically include basic public profile information such as:
o Your user name or nickname
o Your profile picture
o Company name
o Contact details
We may receive personal information about you from third parties that are engaged by us to assist with providing verification services and conducting suitable money laundering and KYC (know-your-customer) checks on users. This may include your name, email address, company details and contact information.
• If you choose to participate in reviewing or rating products and/or services on BrandsPal.com, we may receive personal information about you from third parties that work with us to conduct reviews into our services and/or rate us.
B. USE OF PERSONAL INFORMATION
We collect and use your personal information for the following purposes:
• verifying your identity and conducting security, KYC (know-your-customer) and anti-money laundering diligence and background checks in order to set up user accounts;
• setting up / administering user accounts, including providing log-in IDs and developing a Platform profile;
• providing users with customer service support; responding to queries, feedback, and managing claims and/or disputes;
• facilitating communication between Buyers and Sellers via the Platform, processing transactions and settlement between Buyers and Sellers made over the Platform, assessing fund withdrawal requests from Sellers;
• providing logistics and warehousing services (including, without limitation, customs clearance declarations via the Platform);
• facilitating customs clearance declarations / applications via the Platform;
• assessing and monitoring account security and transaction risks of users of BrandsPal.com, detecting and preventing fraud, money laundering and other security incidents;
• personalizing our marketing and communications with you based on your browsing records, and your order history;
• performing research or statistical analysis in order to improve the content and layout of the Platform, and to improve the product offerings and services on BrandsPal.com, including, for example, using anonymized data for machine learning purposes;
• identifying, developing and marketing and advertising products and services that we believe you will value, including across browsers and devices, in accordance with applicable laws. Cookies or other similar technologies may be used to provide you with advertising based upon your browsing activities and interests. Where we are required by applicable law, we will seek your consent prior to sending you communications for marketing purposes;
• if you are a Buyer, we will share details of the last viewed products on the Platform to enable Sellers to contact you with details of products and/or services that might interest you. You can opt not to share this information with Sellers via the Buyer Privacy Settings
We may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.
C. DISCLOSURE OR SHARING OF PERSONAL INFORMATION
We may disclose (or provide access to) personal information to the following categories of recipients:
• Other Platform Users where necessary in connection with the facilitation of purchases and communications made between you and the other users.
our business partners (for example, in order for them to provide you with discounts or offers that may interest you);
o credit risk assessment providers to conduct risk assessment on Sellers to determine whether a Seller can be permitted to make a fund withdrawal;
o logistics partners for providing delivery services for Buyers, including return and exchange of products, and warehousing services for Sellers;
o custom agents for customs clearances purposes;
o customer service providers to provide after-sale services;
o risk control service providers to assess the security of users’ accounts and transaction risks; and
o third party rating / reviewing service providers to carry out reviews of our services with customers if you choose to participate in reviewing or rating BrandsPal and/or services;
• To our professional advisers, law enforcement agencies, insurers, government and regulatory and other organizations where we believe it is necessary to comply with applicable laws or to exercise, establish or defend our legal rights or protect your vital interests or those of any other person, we may also disclose and transfer your personal information or as otherwise required or permitted by applicable laws.
• To any other person with your consent to the disclosure.
We retain your personal information as long as we have an ongoing legitimate business need to do so for example to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.