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 information including: name; address; phone number; email address;
· purchase and payment information including: credit card or similar payment information that you intend to purchase with; billing and delivery address;
· information about your purchases including: the goods purchased and how many;
· information about and to support complaints made 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. a Vendor or representative of a Seller or a sole trader Seller (we’ll refer to you as a Vendor), we will ask you to provide:
· information about your business (if applicable) including corporate registration, business licenses (if applicable), tax or similar information;
· details about the goods and products that the Seller intends to sell via the Platform;
· purchase and payment information including 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 your name, address, phone number, fax number and email address.
· If you are a certified blogger / influencer for Toroblanche, 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 Vendor or prospective Buyer or Vendor 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.
If you are successfully certified by Toroblanche as a Toroblanche 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 Vendor 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
· Country
· 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 includes your name, email address, company details, and contact information.
We will only collect personal information from third parties where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
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 eligibility as 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 Sellers with logistics and delivery;
· supporting Buyer and/or Vendor clearance declarations / applications where 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 risks of Buyers and Vendor, 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 you based on the ways in which you use the Platform, your browsing records, and order history (we may use cookies and other similar technologies to provide you with marketing and advertising based upon your browsing activities and interests (see section F. COOKIES below for more information).
· conducting research and analytics to ensure the security of our Platform, to improve the content and layout of the Platform, and to improve our Platform, product offerings and services;
· Help you find people you may know who are also using Toroblanche;
We may also use your personal information for other purposes that are compatible with the purposes we have disclosed to you if and where this is permitted by applicable data protection laws. You can request further information about the compatibility of other purposes upon request.
C. DISCLOSURE OR SHARING OF PERSONAL INFORMATION
We disclose/share personal information with the following categories of recipients:
· Other Platform Buyers and/or Vendors where necessary to support purchases and communications made between you. If you are a Buyer, Vendors 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 Vendor Privacy Policies for information about how they will process your information.
· Third party partners and service providers and/or affiliates engaged by or working with us to assist us in providing services to you or who otherwise process personal information for purposes described in this Privacy Policy or notified to you when we collect your personal information. Categories of these partners and service providers include:
· 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;
· marketing and advertising partners, such as Google, Twitter, Facebook, Instagram, and providers of analytics services relating to users’ behavior such as Appsflyer, Criteo, so that they may tailor the content you see when visiting our Platform for analytics and/or advertising purposes.
· payment service providers that provide payment processing services. The activities of payment service providers may be governed by their own privacy policies, not this Privacy Policy;
· credit risk assessment providers to conduct risk assessment on Sellers to determine whether a Seller can be permitted to make an advance withdrawal;
· logistics partners for providing delivery services for Buyers and Vendors, including return and exchange of products, and warehousing services for Sellers;
· customs agents for customs clearances purposes, where applicable to support Buyers and Vendors with international sales/purchases;
· cloud computing or other hosting service providers to provide cloud storage services;
· warranty service providers to provide product warranty services where requested by a Buyer or Vendor;
· customer service support providers to provide after-sale services or other customer service support;
· risk control service providers to assess the security of Buyer and Vendor accounts and transaction risks; and
· third party rating / reviewing service providers to 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 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; or as otherwise required or permitted by applicable laws.
· To an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy.
· To any other person with your consent to the disclosure.
We have established relationships with other parties and websites to offer you the benefit of products and services which we do not offer. We offer you access to these other parties and their websites either through the use of hyperlinks to these sites from our Platform or through offering “co-branded” sites in which both we and other parties share the same uniform resource locator (URL), domain name or pages within a domain name on the Internet. In some cases you may be required to submit personal information to register or apply for products or services provided by such third parties or co-branded partners. This Privacy Policy does not apply to these third-party sites or co-branded sites. The privacy policies of those other parties may differ from ours, and we have no control over the information that you submit to those other sites. You should read the relevant privacy policy for those third parties sites and co-branded sites before responding to any offers, products or services advertised by them.
D. RETENTION
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, or 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 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. 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 [(for example, if a court order is received about your account, we would retain your account data for longer than the usual retention period when an account is deleted)] 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.
F. COOKIES
This section explains how we use cookies and similar technologies (we refer to them collectively as “cookies”) to recognize you when you visit our Platform. It explains what these technologies are and why we use them, as well as your rights to control them.
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, Toroblanche) are called “first party Cookies”. Cookies set by third parties other than the site or app 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.
Why do we use 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.
We also use Cookies to enable us to track and target the interests of Platform visitors to enhance the experience on our Platform by researching visiting patterns and conducting interest-based advertising; assisting our partners in tracking user visits to the Platforms; and to track progress and participation in promotions and the success of our email marketing campaigns. We use first- and third-party Cookies for these purposes.
What about other tracking technologies, like web beacons?
Cookies are not the only way to recognize or track visitors to our Platform. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Platform or opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Platform to another, to deliver or communicate with cookies, to understand whether you have come to our Platform from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.
How can I control Cookies?
You can determine if and how a cookie will be accepted by configuring the privacy setting of the browser you are using to access the Platform or the “privacy setting” of your device. As the means by which you can refuse Cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information. If you adjust the privacy setting in the browser, your mobile device will continue collecting data unless you adjust the privacy setting of the device, and vice versa.
Certain features of the Platform depend on Cookies. Please be aware that if you choose to block Cookies, you may not be able to sign in or use those features, and preferences that are dependent on Cookies may be lost.
Google Analytics (More information) Our Platform uses Google Analytics, an internet analytics service provided by Google, Inc. (“Google”). Google’s Cookies allow us analyze use of the Platform by telling us which pages our users are viewing, which ones are most popular, what time of day our Platform are visited, if users have previously visited our Platform, from which website users are redirected to our Platform were and the like. The data generated by the cookie about your use of the Platform will be transmitted to Google and stored by Google on servers in the United States.
The Platform uses an anonymization tool of IP addresses so that the IP addresses are truncated within the territory of the Member States of the European Union and the other members of the agreement on the European Economic Area. In some cases, non-truncated IP address may be transmitted to Google’s servers in the US and then truncated there.
Google uses the data on behalf of Toroblanche to evaluate your use of the Platform, to compile reports on website activity for the website operators and for other website activity and internet usage services. Google may disclose this information to third parties under the terms of the law or for further processing by third parties on behalf of Google.
G. MINORS
The Platform is intended for adults and users must be over 18 to use our Platform. We do not intend to sell any of our products or services to minors, as defined by applicable law. If a minor has provided us with personal information without parental or guardian consent, the parent or guardian should contact us to remove the information.
H. SECURITY MEASURES
We implement appropriate technical and organisational measures to prevent unauthorized access to the Site, to maintain data accuracy and to ensure the correct use of the information we hold. Upon becoming aware of a data breach, we will notify you and the regulatory authorities in accordance with the timescales and scope required by applicable data protection law.
For registered users of the Platform, some of your information can be viewed and edited through your account, which is protected by a password. It is your responsibility to keep your password secure and confidential. We recommend that you do not divulge your password to anyone. We have instructed our personnel to never ask you for your password. If you share a computer with others, you should not save your log-in information (e.g., user ID and password) on that shared computer. Remember to sign out of your account and close your browser window when you have finished your session
No data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we use appropriate technical and organizational measures to protect the information we hold for you, we cannot guarantee the security of any information you transmit over the internet.
I. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time in response to changing legal, technical or business developments.
When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make and as required by applicable law, such as by posting an amended Privacy Policy on the Platform.
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Platform and services, manage our relationship with you and communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our Platform and our services, undertaking marketing, or for the purposes of ensuring the security of our Platform and services and detecting or preventing illegal activities such as fraud. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
If we ask you to provide personal information to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). In some instances, you may be required to provide us with personal information for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Platform.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided in the website.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected.
Information Pertaining to Children
Our Platform is not directed to and we do not intend to, or knowingly, collect, or solicit personal information online from users under the age of 18, nor children under the age of 13. We do not knowingly collect personal information from children under the age of 13 or have any reasonable grounds to believe that children under the age of 13 are accessing or using our Platform. If you believe that a child under 13 may have provided us personal information, please contact us using our contact details provided