Seataoo Privacy Policy
1. INTRODUCTION
1.1 Welcome to the Seataoo platform run by Happy Seataoo
Technology Co., Ltd.. and its affiliates (individually and collectively,
"Seataoo", "we", "us" or "our"). Seataoo 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 Seataoo 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 Seataoo 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 Seataoo 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 Seataoo COLLECT?
3.1 The personal data that Seataoo 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 Seataoo account
to your Social Media Account or use any Seataoo 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 Seataoo’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 Seataoo may collaborate or tie up with) that Seataoo (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 and/or adjusting
your settings in the Platform, as applicable. 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 Seataoo 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 Seataoo'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 Seataoo 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 Seataoo as a participant or involves only a
related corporation or affiliate of Seataoo as a participant or
involves Seataoo and/or any one or more of Seataoo'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 Seataoo 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 Seataoo 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 Seataoo; (c)
enforce the Seataoo Terms of Service or this Privacy Policy; (d)
respond to any threatened or actual claims asserted against Seataoo 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 Seataoo, 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 Seataoo 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 Seataoo 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 Seataoo 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 Seataoo’s assets, whether as a going concern or as part of
bankruptcy, liquidation or similar proceeding, in which personal data held
by Seataoo about our Service Users is among the assets transferred;
or to a counterparty in a business asset transaction that Seataoo 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 Seataoo allows you to share videos from YouTube in the Seataoo Livestream
feature ("YouTube Content"). To facilitate this, Seataoo 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 Seataoo’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 or transfer of such data; (ii)
allow Seataoo 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 Seataoo 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 Seataoo, (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 Seataoo’s prior written consent;
(ii) should refrain from contacting buyers using such information outside of
the Seataoo platform; (iii) are not permitted to disclose such buyer’s personal data to any unauthorized third parties without the buyer’s and Seataoo’s prior written consent;
(iv) shall employ sufficient security measures to protect each Seataoo 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 Seataoo upon any
request from Seataoo or as soon as reasonably possible upon
completion of the transaction; and (v) to inform Seataoo’s Personal Data Protection Officer at admin@Seataoo.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 Seataoo. In the event that personal data of a child under
the age of 13 in your care is disclosed to Seataoo, 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 Seataoo. 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 Seataoo 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 by us in Singapore, where our
servers are located. Seataoo 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 admin@Seataoo.shop, 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 13.1.1, you may also revoke Seataoo'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 admin@Seataoo.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 admin@Seataoo.com.