PRIVACY POLICY

This Privacy Policy explains how Shopmatic collects, uses and discloses information about you (including your Personal Data) in connection with your access to the Platform and/or use of our Services.

Just like the Terms of Service, this Privacy Policy constitutes a binding and enforceable legal contract between you and Shopmatic Pte. Ltd. and its Affiliates – so please read them carefully. By accessing the Platform and/or using the Services, you agree that we may collect, use, store, transmit and disclose your information (including Personal Data) in accordance with this Privacy Policy, as amended from time to time. If you do not agree to any of the terms of this Privacy Policy, please do not access and/or use the Platform or the Services, do not create an Account or Buyer Account, do not opt-in when this option is offered to you and do not otherwise submit any Personal Data to this website or User Websites.

Unless otherwise defined herein, the terms used in this Privacy Policy have the same meaning as in our Terms of Service.

1. Collection of Personal Data

• 1.1 When you create an Account / Buyer Account with Shopmatic, use our Services or otherwise provide us with information about you, we may collect certain personally identifiable information that can be used to contact or identify you (your Personal Data). Personal Data may include your email address, name, phone number, mailing / residential address, and other types of personally identifiable information.
• 1.2 When you browse through our Platform and/or User Websites (and not create an Account), you generally do so anonymously, but please see Clause 4 (Log Data) and Clause 5 (Cookies) below for more details about these and similar technologies used by Shopmatic.
• 1.3 If you are a Buyer, we may collect information (including Personal Data) about you when you create a Buyer Account and/or use our Services through a User Website. The information you provide in these situations may be shared with Users in connection with our Services so they can operate their business, complete a transaction, fulfil orders, screen orders for fraud and contact you with new products and offers that may be of interest to you. As a Buyer, if you do not agree to Shopmatic or Users having access to your Personal Data, please refrain from creating a Buyer Account or purchasing from a User Website powered by Shopmatic.
• 1.4 Please ensure that all Personal Data you submit to us is complete, accurate, true and correct, otherwise we may not be able to provide you with our Services. If you are a Buyer, sellers may not be able to fulfil your order / deliver the User Product(s) you wish to buy through their User Website unless you provide complete, accurate, true and correct information about yourself (which may include Personal Information).
• 1.5 You may access and update the Personal Data submitted to us at any time as described below (see Clause 15).

2. Use and Disclosure of Personal Data

• 2.1 The Personal Data that we collect from you may also be used by or shared with third parties (including our Business Partners, Affiliates and other Third-Party Service providers) for the following purposes:

• Legal Bases	Purpose
  Provide, improve and develop our Platform to improve the business and users’ experiences, and where it is necessary for the adequate performance of the Terms of Service	(a) to provide and operate the Services and/or access to the Platform; (b) to manage and administer your Account / Buyer Account and our relationship with you; (c) to process and complete transactions and send you related information including purchase confirmations and invoices; (d) to send transactional messages including responding to your questions, comments, questions or requests, providing customer service and support, and sending you technical notices, updates, security alerts and support and administrative messages; (e) to notify you of any changes to the Platform or our Services that may affect you; (f) to resolve disputes, debt collection and troubleshoot issues; (g) to entities or businesses that we plan to merge with or be acquired by;
  Create and maintain a trusted and safer environment, complying with law. responding to legal requests, protecting our rights, ensuring compliance with Terms of Service, facilitating collection of tax, prevention of fraud and illegal activities	(h) to investigate and prevent fraudulent transactions, unauthorised access to the Platform and/or use of the Services and other illegal activities; (i) to comply with the applicable laws and regulations;
  Provide, personalize, measure and improve our advertising and marketing, analysing our communications	(j) to process and deliver contest or sweepstakes entries and rewards; (k) to monitor and analyse trends, usage and activities in connection with the Services; (l) to personalise the Services, including by providing content, features or advertisements that match your interests or preferences; (m) to send certain marketing and/or promotional materials about our Services, features, surveys, newsletters, offers, promotions, contests, events, updates and other news about Shopmatic, which you may opt out of receiving in accordance with Clause 6 below; (n) to conduct market research, understand and analyse customer behaviour, preferences and demographics to enable us, our Business Partners, Affiliates and Third-Party Service providers to determine the products and services that may be relevant to your profile; (o) to enable our Business Partners, Affiliates and Third-Party Service providers to contact you regarding their products, services, offers and events that may be of interest to you, as applicable; or
  Improve user experience through updates/upgrades	(p) to migrate all users to a re-branded or co-branded platform or due to update/upgrade of Platform version.

• 2.2 Depending on the circumstance, we may rely on your consent or the fact that the processing is necessary to fulfil a contract with you, protect your vital interests or those of other persons, or to comply with law. We may also process your Personal Data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations.
• 2.3 You acknowledge and agree that our Privacy Policy and each such third-parties privacy policy govern such activities. Third parties may use your Personal Data for other purposes with your consent.
• 2.4 Shopmatic may share or transfer your Personal Data in connection with or during negotiations of any merger, sale of company assets, financing or acquisition of all or a portion of its business to another company. You will have the opportunity to opt out of such transfer if the new entity’s planned processing of your Personal Data differs materially from that set forth in this Privacy Policy.
• 2.5 Shopmatic will not sell, share or disclose Personal Data with third parties except as described in this Privacy Policy.

3. Information about other Individuals

• 3.1 If you give us information on behalf of someone else, you warrant that the other person has appointed you to act on his or her behalf and has agreed that you can:
  (a) give consent on his or her behalf to the collection, use and processing of his or her information (including any Personal Data);
  (b) receive on his or her behalf any data protection notices; and
  (c) give consent to the transfer of his or her Personal Data abroad.

4. Log Data

• 4.1 We may also collect information that your browser sends whenever you visit our Platform (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browse type, browser version, the pages that you visit, the time and date of your visit, the time spent on those pages and other statistics.
• 4.2 In addition, we may use Third-Party Services such as Google Analytics that collect, monitor and analyse this type of information in order to increase our Services’ functionality. These Third-Party Service providers have their own privacy policies addressing how they use such information and each such privacy policy shall also apply to the information (including Personal Data) collected from you.

5. Cookies

• 5.1 Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.
• 5.2 We use “Cookies” to collect information to:
  (a) improve and customize our Services and your experience;
  (b) allow you to access the Platform or use the Services without re-entering your username or password or to generally remember your preferences; and
  (c) to count visits and understand which areas and features of the Platform and/or Services are most popular.
• 5.3 You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. You may have the option to change your browser settings to choose how we can collect some of this information.

6. Opting out of Marketing Communications

• 6.1 We may use your Personal Data to offer or otherwise contact you with newsletters, marketing, commercial and promotional materials, surveys and researches, invitations to events, webinars and other initiatives, and other information about our Services and certain User Products that may be of interest to you.
• 6.2 You may opt out of receiving any, or all, of these marketing or promotional communications from us by following the unsubscribe link or instructions provided in any email we send or by emailing our Privacy Officer at privacy@goshopmatic.com.
• 6.3 Although opt-out requests are usually processed immediately, please allow up to fourteen (14) days for removal requests to be processed. Please note that even after you have opted out from receiving marketing messages from Shopmatic, you will continue to receive information about transactions that occur on your Account (where applicable).

7. Compliance with Laws

• 7.1 We will disclose your Personal Data where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Services.
• 7.2 We cooperate with government and law enforcement authorities or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement authorities or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims, legal process (including subpoenas), to protect the property and rights of Shopmatic or third parties, the safety of the public or any person, to prevent or stop any illegal, unethical or legally actionable activity.

8. Credit Checking

• 8.1 We may use and disclose to our Affiliates and relevant Third-Party Service providers the information you provide (including Personal Data) and/or information about the activities occurred in your Account to make credit decisions about you (to the extent applicable to your use of the Services), for fraud prevention and money laundering purposes. If you provide false or inaccurate information and we suspect of any fraudulent activity, we will record this and if the situation warrants it, we may have to lodge a police report.

9. Security

• 9.1 Shopmatic uses the industry standard 128-bit SSL (secure sockets layer) encryption technology when you provide us with your financial details.
• 9.2 Shopmatic hosts Personal Data with hosting service providers in numerous countries around the world. The servers on which Personal Data is stored are kept in a controlled environment.
• 9.3 The security of your Personal Data is important to us, but do remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot however guarantee the security or integrity of any Personal Data transferred from you or to you via the Internet.

10. International Transfer

• 10.1 Your information, including Personal Data, may be transferred to, and maintained on, computers located outside of your jurisdiction of residence where the data protection laws may differ than those from your jurisdiction.
• 10.2 If you are located outside Singapore and choose to provide information to us, please note that we transfer the information, including Personal Data, to Singapore and process it there. However, where we are required to transfer your Personal Data to our Affiliates or third parties located overseas for data processing purposes, Shopmatic takes steps to ensure that the receiving jurisdiction has in place a standard of protection accorded to Personal Data that is comparable to the protection provided by us.
• 10.3 Your consent to this Privacy Policy followed by your submission of such Personal Data represents your agreement to that transfer.

11. Links to other Sitess

• 11.1 Our Platform may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.
• 11.2 We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services you may access via or through the Platform and/or the Services.

12. Monitoring

• 12.1 We may monitor and record communications with you (such as telephone conversations, meetings, social media and emails) for the purpose of quality assurance, training, fraud prevention and compliance.

13. Changes to this Privacy Policy

• 13.1 We may amend, modify or otherwise update our Privacy Policy from time to time at our sole discretion, without prior notification. You are advised to review this Privacy Policy periodically for any changes.
• 13.2 Changes to this Privacy Policy are effective when they are posted on the Platform.
• 13.3 Your continued use of the Services constitutes acceptance of any updates or changes to the Privacy Policy as Shopmatic may make and post from time to time. If you disagree with any changes to this Privacy Policy, do not access this Platform and/or the Services.

14. Updating your Personal Data

• 14.1 You can update your Personal Data at any time by accessing your Account or Buyer Account dashboard, as the case may be.
• 14.2 We take steps to share updates to your Personal Data with third parties with whom we have shared your Personal Data if your Personal Data is still necessary for the above stated purposes.

15. Accessing your Personal Data

• 15.1 If you would like to view the Personal Data we have on you or inquire about the ways in which your Personal Data has been or may have been used or disclosed by us with, please contact our Privacy Officer at privacy@goshopmatic.com. We will respond to your request within thirty (30) days.
• 15.2 We reserve the right to charge a reasonable administrative fee for retrieving your Personal Data records from our systems. If you wish to exercise this right, you should:
  (a) put your request in writing;
  (b) include proof of your identity and address (e.g., a copy of your driving licence or passport, and a recent utility bill); and
  (c) specify the Personal Data you want to access.
• 15.3 You have the right to require us to correct any inaccuracies in your Personal Data free of charge. If you wish to exercise this right, you should:
  (a) put your request in writing;
  (b) provide us with enough information to identify you (e.g., username, registration details, etc.); and
  (c) specify the information that is incorrect and what it should be replaced with.

16. Retention of Personal Data

• 16.1 We will retain your information (including Personal Data) for as long as your Account / Buyer Account is active or as reasonably useful for commercial purposes or as necessary to comply with our legal obligations under any applicable laws or resolve disputes and enforce our agreements.
• 16.2 You can delete your Account / Buyer Account following the appropriate process detailed in our Terms of Service if you no longer want us to have your Personal Data. However, we highlight that you are required to offset any outstanding Fees before deleting your Account.

17. Contact Us

• 17.1 If you have any questions relating to your Personal Data or about this Privacy Policy, please contact our Privacy Officer at privacy@goshopmatic.com.

18. Governing Law

• 18.1 This Privacy Policy shall be governed in all respects by the laws of Singapore. You agree to submit any disputes arising out or in connection with this Privacy Policy to the exclusive jurisdiction of Singapore.