(Updated as of 12 April 2017)
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 and any trade dispute records (“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. 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 Profile, Product Catalog, Trade Leads, TrustPass Profile 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 Pumili entity that you are contracting with) your Personal Data to service providers engaged by us and/or other affiliated companies of the Pumili.com 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 Pumili.com 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 Pumili.com, 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 Pumili.com 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.
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.
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.
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.
F. 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. YOUR FEEDBACK