Privacy policy
Privacy Policy
PART A: New Version (Effective as of May 25, 2018)
(Updated as of May 24, 2018)
Table of
Contents
A. COLLECTION
OF INFORMATION..
B. USE OF
PERSONAL DATA..
C. DISCLOSURE
OF PERSONAL DATA..
D. RIGHTS
REGARDING PERSONAL DATA..
E. COOKIES.
F.
MINORS.
G. SECURITY
MEASURES.
H. CHANGES TO
THIS PRIVACY POLICY..
I. VISITORS
FROM THE EUROPEAN UNION..
Legal Basis
for Data Processing.
International
Transfers of Personal Data.
Your
Rights.
J. HOW TO
CONTACT US.
Abarrot.com recognize
the importance of privacy as well as the importance of maintaining the
confidentiality of personal information. This Privacy Policy applies to all
products and services provided by us and sets out how we collect, use and
disclose information in relation to users of the Sites. This Privacy
Policy also applies to use of our services and products via a mobile device,
either through mobile applications or mobile-optimized websites.
All capitalized terms not defined in this document
shall have the meanings ascribed to them in the Terms of Use of the Sites,
which can be found
here
Your privacy
is important to us and we have taken steps to ensure that we do not collect
more information from you than is necessary for us to provide you with our
services and to protect your account:
·
Information including user name, address, phone
number, and email address, will be collected at the time of user registration
on the Sites. If you are registering an Abarrot.com account through
social media platforms such as Facebook or Twitter, we may collect your account
name and profile photo at those platforms.
If you choose
to answer our supplemental questionnaires for registered members, we may also
collect 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.
·
If you are registered as a seller or service
provider, in addition to the information mentioned above, we may also collect
your identity information, tax registration number and information about your
business, such as the information about your business license.
·
If you are successfully certified by Abarrot.com 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 the Site’s members.
·
If you contact our customer service, we may record
your conversation with us and collect additional information to verify your
identity.
·
In connection with any transaction and payment
services, or services under our buyer protection schemes, information,
including but not limited to, bank account numbers, billing and delivery
information, credit/debit card numbers, expiration dates and security code and
tracking information from cheques or money orders may be collected 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 Sites.
·
We record details of users’ activities on the
Sites. Information relating to such transactions (including, but not limited
to, the types and specifications of the goods, pricing and delivery
information, any dispute records and any information disclosed in any
discussion forum) may be collected when transactions are conducted on or
facilitated through the Sites.
·
From time to time, we collect information about our
users and prospective users during trade shows, industry events and other
functions. The information we may collect at these events includes, but not
limits to, user name, address, phone number, fax number and email address.
·
We record users' buying and browsing activities on
our platform including but not limited to IP addresses, browsing patterns,
buyer behavioral patterns and equipment information. In addition, we gather statistical
information about the Sites and visitors to the Sites including, but not
limited to, IP addresses, browser software, operating system, software and
hardware attributes, pages viewed, number of sessions and unique visitors.
Certain data
we collect may be defined as personal data under applicable data protection law
(“Personal Data”).
To enable us
to provide our services and products to users, users need to provide certain
categories of data (which may include Personal Data), such as user name,
address, phone number, and email address. If certain data is required, we will
let you know at the time of collection. In the event that users do not provide
sufficient data marked as necessary, we may not be able to complete the
registration process or provide certain products or services.
We collect
and use your Personal Data for the following purposes:
·
verifying your identity;
·
verifying your eligibility to register as a user of
the Sites or become a blogger or an influencer of the Sites;
·
processing your registration as a user, providing
you with a log-in ID for the Sites and maintaining and managing your
registration;
·
providing you with customer service and responding
to your queries, feedback, claims or disputes;
·
facilitating communication between buyers and
sellers on the Sites, processing transactions and payments, assessing advance
withdrawal requests from sellers and providing delivery services;
·
assessing account security and transaction risks of
members, detecting and preventing fraud and other security incidents;
·
personalizing our communication with you based on
your browsing records, equipment information we collected and your order
history, and performing research or statistical analysis in order to improve
the content and layout of the Sites, and to improve our product offerings and
services, including, for example, using anonymized data for machine learning
purposes;
·
identifying, developing and marketing 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 (see section E. COOKIES below). Where we are required
by applicable law, we will seek your consent prior to sending you
communications for marketing purposes; and
We may also
use your Personal Data 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 OF PERSONAL
DATA
We may
disclose and transfer (whether within or outside the jurisdiction of the
Abarrot entity that is the controller) your Personal Data to our partners and
to service providers engaged by us to assist us to provide services to you or
who otherwise process Personal Data for purposes described in this Privacy
Policy or notified to you when we collect your Personal Data.
Examples of these partners or service providers
include:
·
our business partners (for example, in order for
them to provide you with discounts or offers that may interest you);
·
marketing platforms, such as Google, Twitter,
Facebook, Instagram, and VKontakte, and providers of analytics services
relating to users’ behavior, in order to tailor the content you see when
visiting our Sites. These marketing platforms may combine information
they collect on our Sites with data on their platforms and data they collect
from other websites or through other sources in order to conduct targeted
advertising. The activities of these third party marketing platforms are
governed by their own privacy policies, not this Privacy Policy;
·
payment service providers to assist with payment
for transactions or providing withdrawing service for sellers. 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, including return and exchange of products, and warehousing services
for sellers;
·
custom agents for customs clearances purposes;
·
cloud computing service providers to provide cloud
storage services;
·
warranty service providers to provide warranty
services;
·
customer service providers to provide after-sale
services; and
·
risk control service providers to assess the
security of members’ accounts and transaction risks.
These Service
Providers must abide by our data privacy and security requirements and are only
permitted to use your Personal Data in connection with the purposes specified
above, and not for their own purposes.
For the
purposes specified above, we may share your Personal Data with affiliated
companies in the Abarrot Group and/or their designated Service Providers, which
comprises a group of companies operating leading online and mobile marketplaces
in consumer and business-to-business commerce, as well as cloud computing and
other services.
When 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 Data to
our professional advisers, law enforcement agencies, insurers, government and
regulatory and other organizations, or as otherwise required or permitted by
applicable laws.
We may
disclose your Personal Data 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 Data only for the purposes disclosed in this Privacy
Policy.
We may also
disclose your Personal Data to any other person with your consent to the
disclosure
We retain
your Personal Data 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.
Information
you submit to the Sites for publication may be made publicly available on the
Sites and therefore accessible by any internet user. You should exercise
caution when deciding what information you submit to us for publication.
We may
provide aggregated or anonymized data to third parties, but when we do so, the
information we share is in a de-identified format that does not personally
identify you.
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 Sites 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 Data 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 third parties. You should
read the relevant privacy policy for those third party sites and co-branded
sites before responding to any offers, products or services advertised by those
parties
D. RIGHTS REGARDING
PERSONAL DATA
Under the
applicable laws, you may have the rights of access to Personal Data held by us
and other rights. If you are a Visitor from the European Union, please
refer to section I. VISITORS FROM THE EUROPEAN UNION below for more
information.
If you have any questions regarding this Privacy Policy or if you wish to
access or correct your Personal Data, you may send your request
to Abarrot.com.
If and to the extent permitted by applicable law, we may charge you a fee for
the processing of any request you make regarding your Personal Data.
We use
"cookies" to store specific information about you and track your
visits to the Sites, either through a compute or via a mobile device. It is not
uncommon for websites to use cookies to enhance identification of their
visitors
A
"cookie" is a small amount of data 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 mobile
device to access the Sites, our web servers will be notified of your visit to
the Sites and in turn we may have knowledge of your visit and the pattern of your
usage. The cookies will enable us to remember your information so you do
not have to re-enter it every time you use the Site.
In addition,
we use cookies to manage the security of our Sites, to gather information about
usage by users; to research visiting patterns and conduct interest-based
advertising; to assist our partners to track user visits to the Sites and
process orders; and to track progress and participation in promotions.
For these
additional purposes identified above, 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 Sites or the privacy setting of your mobile 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.
You have the
right to decide whether to accept or reject cookies. If you choose to set your
web browser controls to reject cookies, you may still use our website though
your access to some functionality and areas of our website may be restricted.
Certain features
of the Site 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.
We use two
types of cookies: 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 Sites). The session cookies use
encrypted data to unambiguously authenticate you. The persistent cookies do not
store account numbers or passwords.
We use both
first party cookies (cookies that are set by us at Abarrot and serve mainly to
enable basic functionality on our Sites, including web analytics cookies that
help us understand how users use our web pages and how we can improve their
use) and third party cookies (these cookies are not set by Abarrot, but by our
selected partners).
In addition
we also use social media cookies. Some pages on our Sites allow you to
"share" content through social media such as Facebook and Twitter.
Sometimes we embed videos from websites like YouTube. These websites set their
own cookies on which we have no influence. To refuse their cookies, please
follow the instructions on their websites. In addition, these websites have
their own privacy policy, which you can find on the respective websites.
Below we
briefly identify the cookies we use on our Sites:
|
Provider
|
Cookie
|
Cookie-Type
|
Purpose
|
|
Google,
Inc.
|
_ga,
_gat, _utma, _utmb, _utmc, _utmt, _utmz
|
Analyse-Cookie
|
Helps us assess how users
interact with the content of the web pages so we can improve our website. The
cookies are installed by a tool called "Google Analytics". For more
details please consult: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
|
|
Abarrot
(.abarrot.com)
|
ali_beacon_id, ali_apache_id, ali_apache_track
|
Persistent
Cookie
|
Generates and allocates
an ID which we assign to you to verify behaviour on the Sites
|
|
Abarrot
(.abarrot.com)
|
ali_apache_tracktmp
|
Session
Cookie
|
Generates and allocates
an ID which we assign to you to verify behaviour on the Sites
|
|
Abarrot
(.abarrot.com)
|
cna,
isg, l
|
Persistent
Cookie
|
Generates and allocates
an ID which we assign to you to verify behaviour on the Sites
|
|
Abarrot
(.abarrot.com)
|
xman_f, xman_us_f,
aep_common_f
|
Persistent
Cookie
|
Generates a tag that
shows a user's login status and how data is shown to the user
|
|
Abarrot
(.abarrot.com)
|
xman_t, xman_us_t
|
Session-Cookie
|
Generates a tag that
shows a user's login status and how data is shown to the user
|
|
Abarrot
(.abarrot.com)
|
aep_usuc_f
|
Persistent
Cookie
|
Sets the location, region
and currency, according to user settings
|
|
Abarrot
(.aliexpress.com)
|
acs_usuc_t
|
Session
Cookie
|
Generates a temporary tag
to identify a session in the browser
|
|
Abarrot
(.abarrot.com)
|
intl_common_forever
|
Persistent
Cookie
|
Sets the location, region
and currency, according to user settings, mainly for Abarrot
|
|
Abarrot
(.abarrot.com)
|
aeu_cid
|
PersistentCookie
|
Generates and allocates
an ID which we assign to you to track affiliate links
|
|
Abarrot
(.abarrot.com)
|
intl_locale
|
Session
Cookie
|
Sets the location, region
and currency, according to user settings, mainly for Aliexpress and Alibaba compatibility
|
Google
Analytics
Our Sites
uses Google Analytics, an internet analytics service provided by Google, Inc.,
1600 Amphitheater Parkway Mountain View, California, 94043, USA
("Google"). Google Analytics uses "cookies", which are text
files that are stored on your computer and used to analyze the use of the
Sites. For example, Google's cookies allow us to tell us which pages our users
are viewing, which ones are most popular, what time of day our Sites are
visited, if users have previously visited our Sites, from which website users
are redirected to our Sites were and the like. The data generated by the cookie
about your use of the Sites will be transmitted to Google and stored by Google
on servers in the United States.
The website
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. The
non-truncated IP address are only exceptionally transmitted to Google’s servers
in the US and then truncated there.
Google uses
the data on behalf of the website operator to evaluate your use of the website,
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.
For more
information about Google Analytics cookies, visit the Google Help pages and
Privacy Policy:
Google
Privacy Policy: https://policies.google.com/privacy
Google
Analytics Help
Center: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
The IP address that your browser will pass on to Google
Analytics will not be associated with any other data stored by Google. Through
your browser settings, you can block cookies; however, this can lead to
problems with the use of some functionalities of the website. Through the
add-on "Google Analytics Opt-out" you can through your current web
browser opt-out to the use of Google Analytics from then
on: http://tools.google.com/dlpage/gaoptout?hl=en
.
More information can be found
here: https://support.google.com/analytics/answer/6004245
.
The Sites and
their contents are not targeted to minors (those under the age of 18) and we do
not intend to sell any of our products or services to minors. If a minor has
provided us with Personal Data without parental or guardian consent, the parent
or guardian should contact DataProtection abarrot.com.
We employ
commercially reasonable security methods to prevent unauthorized access to the
Sites, to maintain data accuracy and to ensure the correct use of the
information we hold.
For
registered users of the Sites, some of your information can be viewed and
edited through your account, which is protected by a password. We recommend
that you do not divulge your password to anyone. Our personnel will never ask
you for your password in an unsolicited phone call or in an unsolicited email.
If you share a computer with others, you should not choose to 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 try to protect the information we hold
for you, we cannot guarantee the security of any information you transmit to us
and you do so at your own risk.
H. 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. We will obtain your consent to any material Privacy
Policy changes if and where this is required by applicable data protection
laws.
Any changes
to this Privacy Policy will be communicated by us posting an amended Privacy
Policy on the Sites. Once posted on the Sites, the new Privacy Policy will be
effective immediately. You can see when this Privacy Notice was last updated by
checking the “last updated” date displayed at the top of this Privacy
Notice.
I. VISITORS FROM THE
EUROPEAN UNION
This section
of the Privacy Policy applies only if you use our Sites or services covered by
this Privacy Policy from a country that is a Member State of the European
Union, and supplements the information in this Privacy Policy.
If you are in the EEA your controller is Abarrot.com
Singapore E-Commerce Private Limited (incorporated in Singapore with Company
Reg. No. 200720572D). For contact details, please see section J. HOW TO
CONTACT US
below.
Legal Basis for Data
Processing
We process
Personal Data for the purposes set out in this Privacy Policy, as described
above. Our legal basis to process Personal Data will depend on the Personal
Data concerned and the specific context in which we collect it. However, we
will normally collect and process Personal Data about you only where it is:
necessary for the performance of any contract between you and Abarrot.com
Singapore E-Commerce Private Limited (for example, to provide you with the
services you request and to identify and authenticate you so you may use the
Sites); necessary to comply with legal requirements (for example, to comply
with applicable accounting rules and to make mandatory disclosures to law
enforcement); necessary for our legitimate interests and not overridden by your
rights; and/or where it is based on your consent
.
If we collect
and use your Personal Data in reliance on our legitimate interests (or those of
any third party), this interest will normally be to operate our Sites 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 Sites
and our services, undertaking marketing, or for the purposes of ensuring the
security of our Sites 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 Data 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 Data is mandatory or not (as well as of
the possible consequences if you do not provide your Personal Data). In some
instances, you may be required to provide us with Personal Data 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 Sites.
We retain
your Personal Data 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 Data, we will either
delete or anonymise it or, if this is not possible (for example, because your
Personal Data has been stored in backup archives), then we will securely store
your Personal Data and isolate it from any further processing until deletion is
possible.
If you have questions about or need further
information concerning the legal basis on which we collect and use your
Personal Data, please contact us using the contact details provided under
section J. HOW TO CONTACT US
below.
International Transfers of
Personal Data
Our business may require us to transfer your
Personal Data to countries outside of the European Economic Area (“EEA”),
including to countries that may not provide the same level of data protection
as your home country such as the United States and China. We take appropriate
steps to ensure that recipients of your Personal Data are bound to duties of
confidentiality and we implement appropriate measures to ensure your Personal
Data will remain protected in accordance with this Privacy Policy, such as
standard contractual clauses.
A copy of those clauses can
be obtained by contacting
DataProtection@service.abarrot.com (for
Abarrot.com users).
If you are a resident of the European Economic
Area, you have the following data protection rights, which you can exercise at
any time by contacting us using the contact details provided under
section J. HOW TO CONTACT US
below:
•
The right to access, correct, update or request deletion of your Personal
Data.
•
The right to object to processing of your personal information when it is based
on our legitimate interests, and separately the right to object to direct
marketing.
•
The right to ask us, in some situations, to restrict processing of your
personal information or request portability of your personal information.
• The right to
opt-out of marketing communications we send you at any time. You can exercise
this right by clicking on the “unsubscribe” or “opt-out” link in the marketing
e-mails we send you. To opt-out of other forms of marketing (such as
postal marketing or telemarketing), then please contact us using the contact
details provided under section J. HOW TO CONTACT US
below.
•
If we have collected and process your personal information with your consent,
then you have the right to withdraw your consent at any time. Withdrawing your
consent will not affect the lawfulness of any processing we conducted prior to
your withdrawal, nor will it affect processing of your personal information
conducted in reliance on lawful processing grounds other than consent.
•
The right to complain to a data protection authority about our collection and
use of your personal information. For more information, please contact your
local data protection authority.
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.
J.
HOW TO CONTACT US
If you have
any requests, questions or concerns about our use of your Personal Data and
this Privacy Policy, please contact us in abarrot.com.
PART B
:
Old Version
Privacy Policy
(Updated as of 28 September 2017)
Abarrot.com
is an electronic commerce platforms predominantly used by business
entities to facilitate electronic commerce and such business use does not
generally involve the collection of personal information of individuals.
Abarrot recognizes the importance of privacy as well as the importance of maintaining
the confidentiality of personal information. This Privacy Policy applies to all
products and services provided by us and sets out how we may collect, use and
disclose information in relation to users of the Sites.
You may use
our services and products via a mobile device either through mobile
applications or mobile optimized websites. This Privacy Policy also applies to
such use of our services and products.
All capitalized terms not defined in this document
shall have the meanings ascribed to them in the Terms of Use of the Site, which
can be found
here
. If you are a user from mainland China, the
Abarrot entity that you are contracting with is Albarrot Advertising Co., Ltd.
If you are a user from Hong Kong and Macau, you are contracting with Abarrot.com
Hong Kong Limited. If you are a user outside mainland China, Hong Kong and
Macau, you are contracting with Abarrot.com Singapore E-Commerce Private
Limited (“Abarrot”, “we”, “us”, “our”).
A. COLLECTION
OF INFORMATION
1. Your
privacy is important to us and we have taken steps to ensure that we do not
collect more information from you than is necessary for us to provide you with
our services and to protect your account.
2.
Information including, but not limited to, user name, address, phone number,
fax number, email address, gender, date and/or year of birth and user
preferences ("Registration Information") may be collected at the time
of user registration on the Sites.
3. In
connection with any transaction and payment services or services under our
buyer protection schemes we provide on the Sites, information, including but
not limited to, bank account numbers, billing and delivery information,
credit/debit card numbers and expiration dates and tracking information from
cheques or money orders ("Account Information") may be collected to,
among other things, facilitate the sale and purchase as well as the settlement
of purchase price of the products or services transacted on or procured through
the Sites.
4. We record
and retain details of users’ activities on the Sites. Information relating to
such transactions including, but not limited to, the types and specifications
of the goods, pricing and delivery information, any trade dispute records and
any information disclosed in any discussion forum provided by us and/or other
affiliated companies of the Abarrot Group (“Activities Information”) may be
collected when sale and purchase transactions are conducted on or facilitated
through the Sites
5. From time
to time, we collect information about our users and prospective users during
trade shows, industry events and other functions. The information we may
collect at these locations may include, but is not limited to, user name,
address, phone number, fax number and email address ("Event
Information").
6. We record
and retain records of users' buying and browsing activities on our platform
including but not limited to IP addresses, browsing patterns and buyer
behavioral patterns. In addition, we gather statistical information about the
Sites and visitors to the Sites including, but not limited to, IP addresses,
browser software, operating system, software and hardware attributes, pages
viewed, number of sessions and unique visitors (together "Browsing
Information").
7.
Registration Information, Account Information, Activities Information, Event
Information and Browsing Information generally relate to business entities and
are together referred to as business data (“Business Data”). Insofar and only
insofar as they constitute personally identifiable data of living individuals,
such information are together referred to as personal data (“Personal Data”).
8. It is
mandatory for users of the Sites to provide certain categories of Business Data
and Personal Data (as specified at the time of collection). In the event that
users do not provide any or sufficient Business Data and/or Personal Data
marked as mandatory, we may not be able to complete the registration process or
provide such users with our products or services.
B. USE OF
PERSONAL DATA
If you
provide any Personal Data to us, you are deemed to have authorized us to
collect, retain and use that Personal Data for the following purposes:
1. verifying
your identity;
2. verifying
your eligibility to register as a user of the Sites;
3. processing
your registration as a user, providing you with a log-in ID for the Sites and
maintaining and managing your registration;
4. providing
you with customer service and responding to your queries, feedback, claims or
disputes;
5. to
facilitate communication between buyers and sellers on the Sites and processing
your transactions on the Sites;
6. performing
research or statistical analysis in order to improve the content and layout of
the Sites, to improve our product offerings and services and for marketing and
promotional purposes;
7. subject to
obtaining your consent in such form as may be required under the applicable
law, we (including our affiliated companies and their designated Service
Providers (as defined in C.1 below)) may use your name, phone number,
residential address, email address, fax number and other data ("Marketing
Data") to provide notices, surveys, product alerts, communications and
other marketing materials to you relating to goods and services offered by us
on the Sites including but not limited to Gold Suppliers membership, Verified
Members membership, Free Members membership (each of Gold Suppliers membership,
Verified Members membership, and Free Members membership, a “Membership” and
collectively, the “Memberships”) the value added services ancillary to the
Memberships, and other products and services offered by us and/or our affiliated
companies and their designated Service Providers from time to time to members
of the Sites;
8. if you
voluntarily submit any information to the Sites for publication on the Sites
through the publishing tools, including but not limited to, Company or Business
Profile, Product Catalog, Trade Leads, TrustPass Profile, Business Trust System
and any discussion forum, then you are deemed to have given consent to the
publication of such information on the Sites ("Voluntary
Information"); and
9. making such
disclosures as may be required for any of the above purposes or as required by
law, regulations and guidelines or in respect of any investigations, claims or
potential claims brought on or against us.
C. DISCLOSURE
OF PERSONAL DATA
1. You
further agree that we may disclose and transfer (whether within or outside the
jurisdiction of the Abarrot entity that you are contracting with) your Personal
Data to service providers engaged by us and/or other affiliated companies of
the Abarrot Group to assist us with providing you with our services (including
but not limited to data entry, database management, promotions, products and
services alerts, delivery services, payment extension services, membership
authentication and verification services and logistics services) ("Service
Providers"). These Service Providers are under a duty of confidentiality
to us and are only permitted to use your Personal Data in connection with the
purposes specified at B.1 to B.9 above, and not for their own purposes.
2. You agree
that we may disclose and transfer (whether within or outside the jurisdiction
of the Abarrot entity that you are contracting with), for the purposes
specified at B.1 to B.9 above, your Personal Data to other affiliated companies
and/or their designated Service Providers of the Abarrot Group, which comprises
a group of companies operating leading online and mobile marketplaces in
consumer and business-to-business commerce, as well as cloud computing and
other services.
3. When
necessary we may also disclose and transfer (whether within or outside the
jurisdiction of the Abarrot entity that you are contracting with) your Personal
Data to our professional advisers, law enforcement agencies, insurers,
government and regulatory and other organizations for the purposes specified at
B.9 above.
4. Any
Personal Data supplied by you will be retained by us and will be accessible by
our employees, any Service Providers engaged by us and third parties referred
to at C.2 and C.3 above, for or in relation to any of the purposes stated in
B.1 to B.9 above.
5. All
Voluntary Information may be made publicly available on the Sites and therefore
accessible by any internet user. Any Voluntary Information that you disclose to
us becomes public information and you relinquish any proprietary rights
(including but not limited to the rights of confidentiality and copyright) in
such information. You should exercise caution when deciding to include personal
or proprietary information in the Voluntary Information that you submit to us.
6. We may
share your Account Information with banks or vendors to enable your
transactions on the Sites to be completed. In addition, we may use your Account
Information to determine your credit-worthiness and, in the process of such
determination, we may need to make such Account Information available to banks
or credit agencies. While we have in place up-to-date technology and internal
procedures to keep your Account Information and other Personal Data secure from
intruders, there is no guarantee that such technology or procedures can
eliminate all of the risks of theft, loss or misuse.
7. We may
provide statistical information to third parties, but when we do so, we do not
provide personally-identifying information without your permission.
8. 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 the Sites or through offering "co-branded" sites in
which both we and other parties share the same uniform resource locator, 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 third parties. You should
read the relevant privacy policy for those third party sites and co-branded
sites before responding to any offers, products or services advertised by those
parties
D. RIGHT TO
ACCESS/CORRECT PERSONAL DATA
Under the
applicable laws, you have the right of access to personal information held by
us and to request correction of the information.
If you have any questions regarding this Privacy Policy or if you wish to access
or correct your Personal Data, you may send your request in writing to the
following address:
Legal Counsel, The Legal Department
Abarrot.com Guadalajara, Mexico
If you are a user from Mainland China, please send your request in writing to
the following address:
In accordance with the applicable laws, we reserve the right to charge you a
reasonable fee for the processing of any data access or correction request.
E. COOKIES
We use
"cookies" to store specific information about you and track your visits
to the Sites. It is not uncommon for websites to use cookies to enhance
identification of their users.
A
"cookie" is a small amount of data that is sent to your browser and
stored on your computer's hard drive. A cookie can be sent to your computer's
hard drive only if you access the Sites using a computer. If you do not
de-activate or erase the cookie, each time you use the same computer to access
the Sites, our web servers will be notified of your visit to the Sites and in
turn we may have knowledge of your visit and the pattern of your usage.
Generally, we
use cookies to identify you and enable us to i) access your Registration
Information or Account Information so you do not have to re-enter it; ii)
gather statistical information about usage by users; iii) research visiting
patterns and help target advertisements based on user interests; iv) assist our
partners to track user visits to the Sites and process orders; and v) track
progress and participation in promotions.
You can
determine if and how a cookie will be accepted by configuring the browser which
is installed in the computer you are using to access the Sites. If you choose,
you can change those configurations. By setting your preferences in the
browser, you can accept all cookies or you can choose to be notified when a
cookie is sent or you can choose to reject all cookies. If you reject all
cookies by choosing the cookie-disabling function in your browser, you may be
required to re-enter information on the Sites more often and certain features
of the Sites may be unavailable.
F. MINORS
The Sites and
their contents are not targeted to minors (those under the age of 18) and we do
not intend to sell any of our products or services to minors. However, we have
no way of distinguishing the age of individuals who access our Site. If a minor
has provided us with personal information without parental or guardian consent,
the parent or guardian should contact our Legal Department at the address set
out in paragraph D above to remove the information.
G. SECURITY
MEASURES
We employ
commercially reasonable security methods to prevent unauthorized access to the
Sites, to maintain data accuracy and to ensure the correct use of the
information we hold.
For
registered users of the Sites, your Registration Information and Account
Information (if any) can be viewed and edited through your account, which is
protected by a password. We recommend that you do not divulge your password to
anyone. Our personnel will never ask you for your password in an unsolicited
phone call or in an unsolicited email. If you share a computer with others, you
should not choose to 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 try to protect the information we hold
for you, we cannot guarantee the security of any information you transmit to us
and you do so at your own risk.
H. CHANGES TO
THIS PRIVACY POLICY
Any changes
to this Privacy Policy will be communicated by us posting an amended and
restated Privacy Policy on the Sites. Once posted on the Sites the new Privacy
Policy will be effective immediately. You agree that any information we hold
about you (as described in this Privacy Policy and whether or not collected
prior to or after the new Privacy Policy became effective) will be governed by
the latest version of the Privacy Policy.
I. YOUR
FEEDBACK
We welcome
your input regarding our Privacy Policy and any comments on the services we
provide to you. You may send us your comments and responses by post to: The
Legal Department, Abarrot.com Hong Kong Limited, 26/F, Tower One, Times Square,
1 Matheson Street, Causeway Bay, Hong Kong.
If you are a
user from Mainland China, please send us your comments and responses to the
following address: The Legal Department, Abarrot Advertising Co., Ltd., No. 699,
Guadalajara, Mexico.