1. INTRODUCTION
1.1 Welcome to the ASKOshop (individually and
collectively, "ASKOshop", "we", "us" or
"our"). ASKOshop takes its responsibilities under
applicable privacy laws and regulations ("Privacy Laws") seriously
and is committed to respecting the privacy rights and concerns of all Users of
our ASKOshop website and mobile application (the
"Platform") (we refer to the Platform and the services we provide as
described on our Platform collectively as the "Services"). Users
refers to a user who registers for an account with us for use of the Services,
including both buyers and sellers (individually and collectively, “Users”, “you”
or “your”). We recognize the importance of the personal data you have entrusted
to us and believe that it is our responsibility to properly manage, protect and
process your personal data. This Privacy Policy (“Privacy Policy” or “Policy”)
is designed to assist you in understanding how we collect, use, disclose and/or
process the personal data you have provided to us and/or we possess about you,
whether now or in the future, as well as to assist you in making an informed
decision before providing us with any of your personal data.
1.2 "Personal Data" or "personal
data" means data, whether true or not, about an individual who can be
identified from that data, or from that data and other information to which an
organisation has or is likely to have access. Common examples of personal data
could include name, identification number and contact information.
1.3 By using the Services, registering for an account
with us, visiting our Platform, or accessing the Services, you acknowledge and
agree that you accept the practices, requirements, and/or policies outlined in
this Privacy Policy, and you hereby consent to us collecting, using, disclosing
and/or processing your personal data as described herein.If you do not consent
to the processing of your personal data as described in this Privacy Policy,
please do not use our services or access our platform. If we change our Privacy
Policy, we will notify you including by posting those changes or the amended
Privacy Policy on our Platform. We reserve the right to amend this Privacy
Policy at any time. To the fullest extent permissible under applicable law,
your continued use of the Services or Platform, including placing of any
orders, shall constitute your acknowledgment and acceptance of the changes made
to this Privacy Policy.
1.4 This Policy applies in conjunction with other
notices, contractual clauses, consent clauses that apply in relation to the
collection, storage, use, disclosure and/or processing of your personal data by
us and is not intended to override those notices or clauses unless we state
expressly otherwise.
1.5 This Policy applies to both buyers and sellers who
use the Services except where expressly stated otherwise.
2. WHEN WILL ASKOshop COLLECT PERSONAL DATA?
2.1 We will/may collect personal data about you:
● when you register and/or use our Services or Platform,
or open an account with us;
● when you submit any form, including, but not limited
to, application forms or other forms relating to any of our products and
services, whether online or by way of a physical form;
● when you enter into any agreement or provide other
documentation or information in respect of your interactions with us, or
when you use our products and services;
● when you interact with us, such as via telephone calls
(which may be recorded), letters, fax, face-to-face meetings, social media
platforms and emails, including when you interact with our customer service
agents;
● when you use our electronic services, or interact with
us via our application or use services on our Platform. This includes, without
limitation, through cookies which we may deploy when you interact with our
application or website;
● when you grant permissions on your device to share
information with our application or Platform;
● when you link your ASKOshop account with
your social media or other external account or use other social media features,
in accordance with the provider’s policies;
● when you carry out transactions through our Services;
● when you provide us with feedback or complaints;
● when you register for a contest; or
● when you submit your personal data to us for any reason
● The above does not purport to be exhaustive and sets
out some common instances of when personal data about you may be collected.
3. WHAT PERSONAL DATA WILL ASKOshop COLLECT?
3.1 The personal data that ASKOshop may
collect includes but is not limited to:
● name;
● email address;
● date of birth;
● billing and/or delivery address;
● bank account and payment information;
● telephone number;
● gender;
● information sent by or associated with the device(s)
used to access our Services or Platform;
● information about your network and the people and
accounts you interact with;
● photographs or audio or video recordings;
● government issued identification or other information
required for our due diligence, know your customer, identity verification, or
fraud prevention purposes;
● marketing and communications data, such as your
preferences in receiving marketing from us and third parties, your
communication preferences and history of communications with us, our service
providers, and other third parties;
● usage and transaction data, including details about
your searches, orders, the advertising and content you interact with on the
Platform, and other products and services related to you;
● location data;
● any other information about the User when the User
signs up to use our Services or Platform, and when the User uses the Services
or Platform, as well as information related to how the User uses our Services
or Platform; and
aggregate data on content the User engages with.
3.2 You agree not to submit any information to us which
is inaccurate or misleading, and you agree to inform us of any inaccuracies or
changes to such information. We reserve the right at our sole discretion to
require further documentation to verify the information provided by you.
3.3 If you sign up to be a user of our Platform using
your social media account (“Social Media Account”), link your ASKOshop account
to your Social Media Account or use any ASKOshop social media
features, we may access information about you which you have voluntarily
provided to your Social Media Account provider in accordance with such
provider's policies, and we will manage and use any such personal data in
accordance with this Policy at all times.
3.4 If you do not want us to collect the aforementioned
information/personal data, you may opt out at any time by notifying our Data
Protection Officer in writing. Further information on opting out can be found
in the section below entitled "How can you withdraw consent, remove,
request access to or modify information you have provided to us?"
Note, however, that opting out or withdrawing your consent for us to collect,
use or process your personal data may affect your use of the Services and the
Platform. For example, opting out of the collection of location information
will cause its location-based features to be disabled.
4. COLLECTION OF OTHER DATA
4.1 As with most websites and mobile applications, your
device sends information which may include data about you that gets logged by a
web server when you browse our Platform. This typically includes without
limitation your device’s Internet Protocol (IP) address, computer/mobile device
operating system and browser type, type of mobile device, the characteristics
of the mobile device, the unique device identifier (UDID) or mobile equipment
identifier (MEID) for your mobile device, the address of a referring web site
(if any), the pages you visit on our website and mobile applications and the
times of visit, and sometimes a "cookie" (which can be disabled using
your browser preferences) to help the site remember your last visit. If you are
logged in, this information is associated with your personal account. The
information is also included in anonymous statistics to allow us to understand
how visitors use our site.
4.2 Our mobile applications may collect precise
information about the location of your mobile device using technologies such as
GPS, Wi-Fi, etc. We collect, use, disclose and/or process this information for
one or more Purposes including, without limitation, location-based services
that you request or to deliver relevant content to you based on your location
or to allow you to share your location to other Users as part of the services
under our mobile applications. For most mobile devices, you are able to withdraw
your permission for us to acquire this information on your location through
your device settings. If you have questions about how to disable your mobile
device's location services, please contact your mobile device service provider
or the device manufacturer.
4.3 As when you view pages on our website or mobile
application, when you watch content and advertising and access other software
on our Platform or through the Services, most of the same information is sent
to us (including, without limitation, IP Address, operating system, etc.); but,
instead of page views, your device sends us information on the content,
advertisement viewed and/or software installed by the Services and the Platform
and time.
5. COOKIES
5.1 We or our authorized service providers and
advertising partners may from time to time use "cookies" or other
features to allow us or third parties to collect or share information in
connection with your use of our Services or Platform. These features help us
improve our Platform and the Services we offer, help us offer new services and
features, and/or enable us and our advertising partners serve more relevant
content to you, including through remarketing. “Cookies” are identifiers that
are stored on your computer or mobile device that record data about computer or
device, how and when the Services or Platform are used or visited, by how many
people and other activity within our Platform. We may link cookie information
to personal data. Cookies also link to information regarding what items you
have selected for purchase and web pages you have viewed. This information is
used to keep track of your shopping cart, to deliver content specific to your
interests, to enable our third party advertising partners to serve
advertisements on sites across the internet, and to conduct data analysis and
to monitor usage of the Services.
5.2 You may refuse the use of cookies by selecting the
appropriate settings on your browser or device. However, please note that if
you do this you may not be able to use the full functionality of our Platform
or the Services.
6. HOW DO WE USE THE INFORMATION YOU PROVIDE US?
6.1 We may collect, use, disclose and/or process your
personal data for one or more of the following purposes:
● to consider and/or process your application/transaction
with us or your transactions or communications with third parties via the
Services;
● to manage, operate, provide and/or administer your use
of and/or access to our Services and our Platform (including, without
limitation, remembering your preference), as well as your relationship and user
account with us;
● to respond to, process, deal with or complete a
transaction and/or to fulfil your requests for certain products and services
and notify you of service issues and unusual account actions;
● to enforce our Terms of Service or any applicable end
user license agreements;
● to protect personal safety and the rights, property or
safety of others;
● for identification, verification, due diligence, or
know your customer purposes;
● to evaluate and make decisions relating to your credit
and risk profile and eligibility for credit products;
● to maintain and administer any software updates and/or
other updates and support that may be required from time to time to ensure the
smooth running of our Services;
● to deal with or facilitate customer service, carry out
your instructions, deal with or respond to any enquiries given by (or purported
to be given by) you or on your behalf;
● to contact you or communicate with you via voice call,
text message and/or fax message, email and/or postal mail or otherwise for the
purposes of administering and/or managing your relationship with us or your use
of our Services, such as but not limited to communicating administrative
information to you relating to our Services. You acknowledge and agree that
such communication by us could be by way of the mailing of correspondence,
documents or notices to you, which could involve disclosure of certain personal
data about you to bring about delivery of the same as well as on the external
cover of envelopes/mail packages;
● to allow other users to interact, connect with you or
see some of your activities on the Platform, including to inform you when
another User has sent you a private message, posted a comment for you on the
Platform or connected with you using the social features on the Platform;
● to conduct research, analysis and development
activities (including, but not limited to, data analytics, surveys, product and
service development and/or profiling), to analyse how you use our Services, to
recommend products and/or services relevant to your interests, to improve our
Services or products and/or to enhance your customer experience;
● to allow for audits and surveys to, among other things,
validate the size and composition of our target audience, and understand their
experience with ASKOshop’s Services;
● for marketing and advertising, and in this regard, to
send you by various mediums and modes of communication marketing and
promotional information and materials relating to products and/or services
(including, without limitation, products and/or services of third parties
whom ASKOshop may collaborate or tie up with) that ASKOshop (and/or
its affiliates or related corporations) may be selling, marketing or promoting,
whether such products or services exist now or are created in the future. You
can unsubscribe from receiving marketing information at any time by using the
unsubscribe function within the electronic marketing material. We may use your
contact information to send newsletters or marketing materials from us and from
our related companies;
● to respond to legal processes or to comply with or as
required by any applicable law, governmental or regulatory requirements of any
relevant jurisdiction or where we have a good faith belief that such disclosure
is necessary, including, without limitation, meeting the requirements to make
disclosure under the requirements of any law binding on ASKOshop or
on its related corporations or affiliates (including, where applicable, the
display of your name, contact details and company details);
● to produce statistics and research for internal and
statutory reporting and/or record-keeping requirements;
● to carry out due diligence or other screening
activities (including, without limitation, background checks) in accordance
with legal or regulatory obligations or our risk management procedures that may
be required by law or that may have been put in place by us;
● to audit our Services or ASKOshop's business;
● to prevent or investigate any actual or suspected
violations of our Terms of Service, fraud, unlawful activity, omission or
misconduct, whether relating to your use of our Services or any other matter
arising from your relationship with us;
● to respond to any threatened or actual claims asserted
against ASKOshop or other claim that any Content violates the rights
of third parties;
● to store, host, back up (whether for disaster recovery
or otherwise) of your personal data, whether within or outside of your
jurisdiction;
● to deal with and/or facilitate a business asset
transaction or a potential business asset transaction, where such transaction
involves ASKOshop as a participant or involves only a related
corporation or affiliate of ASKOshop as a participant or
involves ASKOshop and/or any one or more of ASKOshop's related
corporations or affiliates as participant(s), and there may be other third party
organisations who are participants in such transaction. A “business asset
transaction” refers to the purchase, sale, lease, merger, amalgamation or any
other acquisition, disposal or financing of an organisation or a portion of an
organisation or of any of the business or assets of an organisation; and/or any
other purposes which we notify you of at the time of obtaining your
consent.(collectively, the “Purposes”).
6.2 You acknowledge, consent and agree that Exit
Shop may access, preserve and disclose your Account information and
Content if required to do so by law or pursuant to an order of a court or by
any governmental or regulatory authority having jurisdiction over Exit
Shop or in a good faith belief that such access preservation or disclosure
is reasonably necessary to: (a) comply with legal process; (b) comply with a
request from any governmental or regulatory authority having jurisdiction
over ASKOshop; (c) enforce the ASKOshop Terms of Service or
this Privacy Policy; (d) respond to any threatened or actual claims asserted
against ASKOshop or other claim that any Content violates the rights
of third parties; (e) respond to your requests for customer service; or (f)
protect the rights, property or personal safety of ASKOshop, its users
and/or the public.
6.3 As the purposes for which we will/may collect, use,
disclose or process your personal data depend on the circumstances at hand,
such purpose may not appear above. However, we will notify you of such other
purpose at the time of obtaining your consent, unless processing of the
applicable data without your consent is permitted by the Privacy Laws.
7. HOW DOES ASKOshop PROTECT AND RETAIN
CUSTOMER INFORMATION?
7.1 We implement a variety of security measures and
strive to ensure the security of your personal data on our systems. User
personal data is contained behind secured networks and is only accessible by a
limited number of employees who have special access rights to such
systems. However, there can inevitably be no guarantee of absolute
security.
7.2 We will retain personal data in accordance with the
Privacy Laws and/or other applicable laws. That is, we will destroy or
anonymize your personal data when we have reasonably determined that (i) the
purpose for which that personal data was collected is no longer being served by
the retention of such personal data; (ii) retention is no longer necessary for
any legal or business purposes; and (iii) no other legitimate interests warrant
further retention of such personal data. If you cease using the Platform, or
your permission to use the Platform and/or the Services is terminated or
withdrawn, we may continue storing, using and/or disclosing your personal data
in accordance with this Privacy Policy and our obligations under the Privacy
Laws. Subject to applicable law, we may securely dispose of your personal data
without prior notice to you.
8. DOES ASKOshop DISCLOSE THE INFORMATION IT
COLLECTS FROM ITS VISITORS TO OUTSIDE PARTIES?
8.1 In conducting our business, we will/may need to use,
process, disclose and/or transfer your personal data to our third party service
providers, agents and/or our affiliates or related corporations, and/or other
third parties, which may be located in Singapore or outside of Singapore, for
one or more of the above-stated Purposes. Such third party service providers,
agents and/or affiliates or related corporations and/or other third parties
would be processing your personal data either on our behalf or otherwise, for
one or more of the above-stated Purposes. We endeavour to ensure that the third
parties and our affiliates keep your personal data secure from unauthorised
access, collection, use, disclosure, processing or similar risks and retain
your personal data only for as long as your personal data is needed for the
above-mentioned Purposes. Such third parties include, without limitation:
● our subsidiaries, affiliates and related corporations;
● buyers or sellers you have transacted with or
interacted with on the Platform or in connection with your use of the Services
for the above-stated Purposes;
● other users of our Platform for one or more of the
above-stated Purposes;
● contractors, agents, service providers and other third
parties we use to support our business. These include but are not limited to
those parties which provide administrative or other services to us such as
mailing houses, logistics service providers, financial services providers,
advertising and marketing partners, telecommunication companies, information
technology companies, and data centres;
● governmental or regulatory authorities having
jurisdiction over ASKOshop or as otherwise permitted under Section
6.2;
● a buyer or other successor in the event of a merger,
divestiture, restructuring, reorganization, dissolution or other sale or
transfer of some or all of ASKOshop’s assets, whether as a going concern
or as part of bankruptcy, liquidation or similar proceeding, in which personal
data held by ASKOshop about our Service Users is among the assets
transferred; or to a counterparty in a business asset transaction that Exit
Shop or any of its affiliates or related corporations is involved in; and
third parties to whom disclosure by us is for one or more of the Purposes and
such third parties would in turn be collecting and processing your personal
data for one or more of the Purposes
8.2 We may share user information, including statistical
and demographic information, about our Users and information about their use of
the Services with advertising partners and third party suppliers of
advertisements, remarketing, and/or other programming.
8.3 For the avoidance of doubt, in the event that Privacy
Laws or other applicable laws permit an organisation such as us to collect, use
or disclose your personal data without your consent, such permission granted by
the laws shall continue to apply. Consistent with the foregoing and subject to applicable
law, we may use your personal data for recognized legal grounds including to
comply with our legal obligations, to perform our contract with you, to achieve
a legitimate interest and our reasons for using it outweigh any prejudice to
your data protection rights, or where necessary in connection with a legal
claim.
8.4 Third parties may unlawfully intercept or access
personal data transmitted to or contained on the site, technologies may
malfunction or not work as anticipated, or someone might access, abuse or
misuse information through no fault of ours. We will nevertheless deploy
reasonable security arrangements to protect your personal data as required by
the Privacy Laws; however there can inevitably be no guarantee of absolute
security such as but not limited to when unauthorised disclosure arises from
malicious and sophisticated hacking by malcontents through no fault of ours.
8.5 ASKOshop allows you to share videos
from YouTube in ASKOshop ("YouTube Content"). To
facilitate this, ASKOshop uses YouTube API Services made available
by YouTube. By using sharing YouTube Content, you hereby agree to be
bound by the Google Privacy Policy (http://www.google.com/policies/privacy).
8.6 As set forth in ASKOshop’s Terms of Service,
Users (including any employees, agents, representatives, or any other person
acting for such User or on such User’s behalf) in possession of another User’s
personal data through the use of the Services (the “Receiving Party”) hereby
agree that, they will (i) comply with all applicable Privacy Laws with respect
to any such data, including any collection, processing, storage or transfer of
such data; (ii) allow ASKOshop or the User whose personal data the
Receiving Party has collected (the “Disclosing Party”) to remove his or her
data so collected from the Receiving Party’s database; and (iii) allow Exit
Shop or the Disclosing Party to review what information has been collected
about them by the Receiving Party, in each case of (ii) and (iii) above, in
compliance with and where required by applicable laws.
8.7 Notwithstanding anything set forth herein, Sellers
(including any employees, agents, representatives, or any other person acting
for such User or on such User’s behalf) shall comply with all applicable
Privacy Laws and, in respect of any buyer’s personal data received from Exit
Shop, (i) are not permitted to use such buyer’s personal data except as
reasonably necessary to respond to buyers’ enquiries and to carry out respond
to, process, deal with or complete a transaction without the buyers’ and Exit
Shop’s prior written consent; (ii) should refrain from contacting buyers using
such information outside of the ASKOshop platform; (iii) are not
permitted to disclose such buyer’s personal data to any unauthorized third
parties without the buyer’s and ASKOshop’s prior written consent; (iv)
shall employ sufficient security measures to protect each ASKOshop user’s
personal data in their possession, retain such data only for as long as necessary
for the purposes above and in accordance with the Privacy Laws, and to
delete or return such data to ASKOshop upon any request from Exit
Shop or as soon as reasonably possible upon completion of the transaction;
and (v) to inform ASKOshop’s Personal Data Protection Officer at service@exithing.com
in the event of any potential data breach or other loss of such user’s data.
9. INFORMATION ON CHILDREN
9.1 The Services are not intended for children under the
age of 13. We do not knowingly collect or maintain any personal data or
non-personally-identifiable information from anyone under the age of 13 nor is
any part of our Platform or other Services directed to children under the age
of 13. As a parent or legal guardian, please do not allow such children
under your care to submit personal data to ASKOshop. In the event that
personal data of a child under the age of 13 in your care is disclosed to Exit
Shop, you hereby consent to the processing of the child’s personal data and
accept and agree to be bound by this Policy on behalf of such child. We
will close any accounts used exclusively by such children and will remove
and/or delete any personal data we believe was submitted without parental
consent by any child under the age of 13.
10. INFORMATION COLLECTED BY THIRD PARTIES
10.1 Our Platform uses Google Analytics, a web analytics
service provided by Google, Inc. ("Google"). Google Analytics uses
cookies, which are text files placed on your device, to help the Platform
analyse how Users use the Platform. The information generated by the cookie
about your use of the Platform (including your IP address) will be transmitted
to and stored by Google on servers in the United States. Google will use this
information for the purpose of evaluating your use of the Platform, compiling
reports on website activity for website operators and providing other services
relating to website activity and Internet usage. Google may also transfer this
information to third parties where required to do so by law, or where such
third parties process the information on Google's behalf. Google will not
associate your IP address with any other data held by Google.
10.2 We, and third parties, may from time to time make
software applications downloads available for your use via the Platform or
through the Services. These applications may separately access, and allow a
third party to view, your identifiable information, such as your name, your
user ID, your device’s IP Address or other information such as any cookies that
you may previously have installed or that were installed for you by a third
party software application or website. Additionally, these applications may ask
you to provide additional information directly to third parties. Third party
products or services provided through these applications are not owned or
controlled by ASKOshop. You are encouraged to read the terms and other
policies published by such third parties on their websites or otherwise.
11. DISCLAIMER REGARDING SECURITY AND THIRD PARTY SITES
11.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA
AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We do implement
a variety of security measures to maintain the safety of your personal data
that is in our possession or under our control. Your personal data is contained
behind secured networks and is only accessible by a limited number of persons
who have special access rights to such systems, and are required to keep the
personal data confidential. When you place orders or access your personal data,
we offer the use of a secure server. All personal data or sensitive information
you supply is encrypted into our databases to be only accessed as stated above.
11.2 In an attempt to provide you with increased value,
we may choose various third party websites to link to, and frame within, the
Platform. We may also participate in co-branding and other relationships to
offer e-commerce and other services and features to our visitors. These linked
sites have separate and independent privacy policies as well as security
arrangements. Even if the third party is affiliated with us, we have no control
over these linked sites, each of which has separate privacy and data collection
practices independent of us. Data collected by our co-brand partners or third
party web sites (even if offered on or through our Platform) may not be
received by us.
11.3 We therefore have no responsibility or liability for
the content, security arrangements (or lack thereof) and activities of these
linked sites. These linked sites are only for your convenience and you
therefore access them at your own risk. Nonetheless, we seek to protect the
integrity of our Platform and the links placed upon each of them and therefore
welcome any feedback about these linked sites (including, without limitation,
if a specific link does not work).
12. WILL ASKOshop TRANSFER YOUR INFORMATION
OVERSEAS?
12.1 Your personal data and/or information may be
transferred to, stored or processed outside of your country for one or more of
the Purposes. In most cases, your personal data will be processed in Singapore,
where our servers are located. ASKOshop will only transfer your
information overseas in accordance with Privacy Laws.
13. HOW CAN YOU WITHDRAW CONSENT, REQUEST ACCESS TO OR
CORRECT INFORMATION YOU HAVE PROVIDED TO US?
13.1 Withdrawing Consent
13.1.1 You may withdraw your consent for the collection,
use and/or disclosure and/or request deletion of your personal data in our
possession or under our control by sending an email to our Personal Data
Protection Officer at service@exithing.com, and we will process such requests
in accordance with this Privacy Policy and our obligations under the Privacy
Laws and other applicable law. However, your withdrawal of consent may
mean that we will not be able to continue providing the Services to you and we
may need to terminate your existing relationship and/or the contract you have
with us.
13.1.2 Where you share YouTube Content, in addition to
withdrawing your consent by emailing us pursuant to Section 14.1.1, you may
also revoke ASKOshop’s access to your personal data via the Google
security settings page at
https://security.google.com/settings/security/permissions.
13.2 Requesting Access to or Correction of Personal Data
13.2.1 If you have an account with us, you may personally
access and/or correct your personal data currently in our possession or control
through the Account Settings page on the Platform. If you do not have an
account with us, you may request to access and/or correct your personal data
currently in our possession or control by submitting a written request to us.
We will need enough information from you in order to ascertain your identity as
well as the nature of your request so as to be able to deal with your request.
Hence, please submit your written request by sending an email to our Personal
Data Protection Officer at service@exithing.com.
13.2.2 We may charge you a reasonable fee for the
handling and processing of your requests to access your personal data. If we so
choose to charge, we will provide you with a written estimate of the fee we
will be charging. Please note that we are not required to respond to or deal
with your access request unless you have agreed to pay the fee.
13.2.3 We reserve the right to refuse to correct your
personal data in accordance with the provisions as set out in Privacy Laws,
where they require and/or entitle an organisation to refuse to correct personal
data in stated circumstances.
14. QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US
14.1 If you have any questions or concerns about our
privacy practices, we welcome you to contact us by e-mail at service@exithing.com