(Effective as of March 20, 2021)
Table of Contents
A.COLLECTION OF INFORMATION.
- Information That You Provide to Us
- Information That We Collect Automatically
- Information That We Receive From Third Parties
B.USE OF PERSONAL DATA.
C.DISCLOSURE OF PERSONAL DATA.
E.RIGHTS REGARDING PERSONAL DATA.
J.VISITORS FROM THE EUROPEAN UNION
- Legal Basis for Data Processing.
- International Transfers of personal information.
- Your Rights.
A.COLLECTION OF INFORMATION
The personal information that we collect broadly falls into the following categories:
Information That You Provide To Us:
If you are a Buyer, we will ask you to provide:
- contact informationincluding: name; address; phone number; email address;
- purchase and/or payment informationincluding: credit card or similar payment information that you intend to purchase with; billing and delivery address;
- information about your purchasesincluding: the goods purchased and how many;
- information about and/or to support complaintsmade in connection with the Platform or goods and/or services purchased via the Platform;
- ID (such as a passport)for identification verification in certain circumstances, when you apply for after-sales services.
If you are a Seller (i.e. an employee or representative of a Seller or a sole trader Seller (we’ll refer to you as a Seller)), we will ask you to provide:
- information about the Seller’s business(if applicable) including corporate registration, business licences (if applicable), tax or similar information;
- details about the goods and products that the Seller intends to sellvia the Platform;
- purchase and/or payment informationincluding bank account or other payment information that the Seller intends to be paid by.
If you attend one of our industry events or other functions, contact details such as user name, address, phone number, fax number and email address.
If you are a certified blogger / influencer for Kamoer, we may also ask you to provide us with your contact information and social media accounts / blog information.
If you choose to provide us with any additional information, such as in response to questionnaires for market research / analytics. This may include marital status, nationality, gender, date and/or year of birth, annual income, monthly spending and user preferences. If you prefer not to provide such information, the use of our services and products will not be affected.
Information That We Collect Automatically:
If you are a Buyer or Seller or prospective Buyer or Seller we will automatically collect:
- A copy of any correspondence with us,including any verification information we ask for, if you contact us for any reason (such as our customer service department chat service, telephone or email).
- Details of transactions and communications over the Platform,including the types and specifications of the goods sold and purchased, pricing and delivery information, any dispute records, communications between Buyers and Sellers over the Platform and any information disclosed in any discussion forum.
- Details of Platform buying and browsing activities, for these purposes we will automatically collect information from your device. In some jurisdictions, including countries in the European Economic Area and the UK, this information may be considered as personal information under applicable data protection laws. Specifically this collected 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 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. Some of this information may be collected using cookies and similar tracking technology, as explained further under the section E “COOKIES” below. Where we are required by applicable law, we will seek your prior consent to the collection of information using cookies and similar tracking technologies. We also may derive or collect inferences about you based on your buying and browsing activity information and other information we have collected about you.
If you are successfully certified by Kamoer as a blogger or an influencer, we may also collect your social media account handles and posts / comments made in relation to the Platform.
We may collect information about the people or accounts with whom you share content or interact and contact information if you choose to upload or import it from a device (such as an address book). Information That We Receive From Third Parties:
If you are a Buyer or Seller 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 would typically include basic public profile information such as:
- Your social media user name, nickname or username
- Your social media profile picture
- Company name (if applicable).
- Third parties that are engaged by us to provide verification services,such as conducting suitable money laundering, fraud and “Know Your Customer” checks on Buyers and Sellers. This may include your name, email address, company details and contact information.
B.USE OF PERSONAL DATA
We collect and use your personal information for the following purposes:
- verifying Platform account registrations,including conducting fraud, security, “Know Your Customer” and anti-money laundering checks in order to approve your Seller account;
- verifying your eligibilityas a Platform blogger or influencer;
- setting up / administering Buyer and Seller accounts, including providing log-in IDs and setting up payment / transaction accounts;
- providing customer service support, such as responding to your queries, feedback and managing claims and/or disputes;
- providing/supporting general Platform services,facilitating communication between Buyers and Sellers, processing transactions and payments, assessing advance withdrawal requests from Sellers and providing logistics and delivery services;
- supporting Buyer and/or Seller clearance declarations / applicationswhere made via the Platform;
- providing relevant membership benefits,including birthday rewards, membership offers and coupons, anniversary awards, exclusive member prices;
- verifying your identity and purchases in connection with product warranty or other after-sales claims;
- assessing and monitoring account security and transaction risksof Buyers and Sellers, such as detecting and preventing fraud, money laundering and other security incidents;
- sending and serving tailored marketing and advertising that we believe will be of interest to youbased on the ways in which you use the Platform, your browsing records, and order history;
- conducting research and analyticsto ensure the security of our Platform, to improve the content and layout of the Platform, and to improve our product offerings and services;
- Help you find people you may know who are also using Kamoer
- Cookies or other similar technologies may be used to provide you with advertising based upon your browsing activities and interests (see section E. COOKIES below for more information).
We may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you if and where this is permitted by applicable data protection laws.
C.DISCLOSURE OR SHARING OF PERSONAL DATA
We disclose/share personal information with the following categories of recipients:
- Other Platform Buyers and/or Sellerswhere necessary to support purchases and communications made between you. If you are a Buyer, Sellers that you purchase from will also control personal information about you relevant to or connected with your Platform purchases and communications with them. Please refer to Seller Privacy Policies for information about how they will process your information.
- our business partners(for example, in order for them to provide you with discounts or offers that may interest Buyers or prospective Buyers) where you have consented to receiving such information from them if required by applicable data protection laws;
- credit risk assessment providersto conduct risk assessment on Sellers to determine whether a Seller can be permitted to make an advance withdrawal;
- logistics partnersfor providing delivery services for Buyers and Sellers, including return and exchange of products, and warehousing services for Sellers;
- customs agentsfor customs clearances purposes, where applicable to support Buyers and Sellers with international sales/purchases;
- cloud computing or other hosting service providersto provide cloud storage services;
- warranty service providersto provide product warranty services where requested by a Buyer or Seller;
- customer service support providersto provide after-sale services or other customer service support;
- risk control service providersto assess the security of Buyer and Seller accounts and transaction risks; and
- third party rating / reviewing service providersto carry out reviews of our services with customers if you choose to participate in reviewing or rating Platform products and/or services;
- To our professional advisers, law enforcement agencies, insurers, government and regulatory and other organisationswhere 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; or as otherwise required or permitted by applicable laws.
- To any other person with your consent to the disclosure.
We will retain your personal information for as long as we have an ongoing legitimate business need to do so, to provide services or products to you, as required or permitted by applicable laws. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise 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 itfrom any further processing until deletion is possible. How long your data is kept for will also depend on how you use our website (for example if you are logged in as a member or you are visiting our website as a guest) and what the information you provide to us is used for. For example, if you are a registered member, certain data will be retained for a length of time following termination or deletion of your account, in order to comply with applicable laws or in case of disputes. In other instances, the period of retention may be determined according to your activity on the Platform or to comply with a specific arbitration period/resolve a dispute.
E.RIGHTS REGARDING PERSONAL DATA
Under applicable laws, you may have rights of access to personal information held by us and other rights. If you are a Visitor from the European Union, please refer to section J. VISITORS FROM THE EUROPEAN UNION below for more information. If you are a Visitor from California, please refer to section K. VISITORS FROM CALIFORNIA below.
What are cookies?
A cookie is a string of information that is sent to your browser and stored on your computer’s or mobile device’s hard drive. If you do not de-activate or erase the cookie, each time you use the same browser or device to access the Platform, our web servers will be notified of your visit to the Platform and, in turn, we may have knowledge of your visit and the pattern of your usage.
Cookies set by the site or app owner (in this case, Kamoer) are called “first party cookies”. Cookies set by third parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognize your device both when it visits the website in question and also when it visits certain other websites.
Cookies are also categorized as “session cookies” (which are erased once you close the browser or shut down the device) and “persistent cookies” (which remain even after closing the browser or shutting down the device/application and which are activated each time you visit the Platform). Session cookies use encrypted data to authenticate you. Persistent cookies do not store account numbers or passwords. We use both session cookies and persistent cookies.
We use first and third party cookies for several reasons.
Some cookies are required for technical and/or security reasons in order for our Platform to operate, and we refer to these as “essential” or “strictly necessary” cookies. First party cookies are mainly served to enable basic functionality on our Platform; including web analytics cookies that help us understand how users use our web pages and how we can improve their use. For example we use essential or strictly necessary cookies to enable us to remember goods added to your shopping basket and to recognize you when you sign into your account.
We also use social media cookies. You may register for Platform membership and “share” Platform content through social media such as Facebook and Twitter. Sometimes we embed videos from websites like YouTube. These websites have their own privacy policies which govern their use of information, which you can find on the respective websites.