We at E-touch ("we", "us") recognize the importance of privacy and confidentiality of personal information.  E-touch (the "Platform") is a B2B2C platform which connects and facilitates sales and purchases of products and/or services between suppliers (or "Sellers") and buyers (or "Buyers"). The Platform is for business to business and businesses to customer transactions.   This Privacy Policy sets out the ways in which E-touch collect, use and disclose information in connection with its operation of the Platform including personal information about Platform visitors and representatives and employees of Buyers and Sellers ("you").  This Privacy Policy also applies to use of our Platform via a mobile device, either through mobile applications or mobile-optimized websites. For details of the personal information that we collect when you use or interact with other E-touch services, please refer to the applicable Privacy Policy to those services.

1.     COLLECTION OF INFORMATION

The personal information that we may collect about you broadly falls into the following categories:

1.1 Information you provide to us 

If you are a representative or employee of any Buyer or a sole trader Buyer :

1.1.1  you will be asked to provide certain contact information that is necessary for the registering for a Platform account on behalf of a Buyer, including name, address, phone number, email address, job title and department;

1.1.2  you will be asked to provide certain identity information, tax registration and/or related information about your business, such as your company name, business type and industry, corporate registration details and information about your business license;

1.1.3  if you are a Buyer we will ask you to provide details or preferences about the goods and products that you may be interested in buying via the Platform and any details or preferences relevant to your purchases;

1.1.4  if you are successfully certified by E-touch 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 other users of the Platform;

1.1.5 in connection with the facilitation of transactions, purchases and payments over the Platform, you will be asked to provide certain payment information. This might include bank account numbers, billing and delivery information, credit/debit card numbers, expiration dates and security code and tracking information from cheques or money orders 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 Platform;

1.1.6 we will process any information provided to us in connection with disputes or to support complaints in connection with the Platform or goods and/or services purchased via the Platform. Please note, Buyers may submit complaints regarding the products and services on the Platform and/or disputes between the Buyers to the Platform and under such circumstances, we will process data provided to us by Buyers that is relevant to the disputes or complaints submitted. This may include health data of end-users (which may include minors as applicable) of products purchased on the Platform to the extent relevant to the disputes or complaints that are being reviewed by the Platform and to the extent that the individual(s) has provided their explicit consent to their data being shared with us for the purposes of handling the complaints and/or settling the disputes.

1.1.7  Information you submit to the Platform for publication may be made publicly available on the Platform and therefore accessible by any internet user. You should exercise caution when deciding what information you submit to us for publication.

1.2  Information that we collect automatically

1.2.1  If you contact us (such as via our customer services department chat service, telephone or email), we may record a copy of your correspondence and may ask for additional information to verify your identity.

1.2.2  We will collect contact details and other information of users from publicly available sources for the purposes of verifying the users and performing due diligence on the users.

1.2.3  We will collect details of user activities, transactions and interactions on the Platform including information relating to the types and specifications of the products and services purchased, pricing and delivery information, dispute and complaint records, communications between users and any information disclosed in any discussion forum.

2. USE OF PERSONAL INFORMATION

We collect and use your personal information for the following purposes:

2.1  verifying your identity and conducting security, KYC (know-your-customer) and anti-money laundering diligence and background checks in order to set up user accounts;

2.2 verifying your eligibility to register as a Platform user in accordance with our Terms of Use here;

2.3  setting up / administering user accounts, including providing log-in IDs and developing a Platform profile;

2.4 providing users with customer service support; responding to queries, feedback, and managing claims and/or disputes;

2.5 providing logistics and warehousing services (including, without limitation, customs clearance declarations via the Platform);

2.6  facilitating customs clearance declarations / applications via the Platform;

2.7 assessing and monitoring account security and transaction risks of users of E-touch, detecting and preventing fraud, money laundering and other security incidents;

2.8  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;  

3. DISCLOSURE OR SHARING OF PERSONAL INFORMATION 

3.1 We may disclose (or provide access to) personal information to the following categories of recipients:

3.1.1  Other Platform Users where necessary in connection with the facilitation of purchases and communications made between you and the other users.

3.1.2  Third party business partners, service providers and/or affiliates of E-touch engaged by us or working with us to assist us to provide 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 or service providers include:

3.1.3  Members of E-touch Group and their respective affiliates and/or their designated service providers that work with us to provide processing services such as software, tools, systems and messaging services for purposes described in this Privacy Policy;

3.1.4  our business partners (for example, in order for them to provide you with discounts or offers that may interest you);

3.1.5  marketing and advertising platforms, such as Google, Twitter, Facebook and Instagram, and providers of analytics services relating to users’ behavior, in order to tailor the content you see when visiting our Platform. These platforms may combine information they collect on our Platform with data on their platforms and data they collect from other websites or through other sources in order to conduct targeted advertising.  The processing activities of these third party marketing platforms are governed by their own privacy policies, not this Privacy Policy;

3.1.6  payment service providers who collect and process personal information to assist with settling the payments for transactions or process withdrawal requests for Sellers. The activities of payment service providers may be governed by their own privacy policies, not this Privacy Policy;

3.1.7 credit risk assessment providers to conduct risk assessment on Sellers to determine whether a Seller can be permitted to make a fund withdrawal;

3.1.8  logistics partners for providing delivery services for Buyers, including return and exchange of products, and warehousing services for Sellers;

3.1.9  custom agents for customs clearances purposes;

3.1.10  cloud computing service providers to provide cloud storage services;

3.1.11  customer service providers to provide after-sale services;

3.1.12   risk control service providers to assess the security of users’ accounts and transaction risks; and

3.1.13  third party rating / reviewing service providers to carry out reviews of our services with customers if you choose to participate in reviewing or rating E-touch products and/or services;

 3.2  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, we may also disclose and transfer your personal information or as otherwise required or permitted by applicable laws.

3.3  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.

3.4  To any other person with your consent to the disclosure.

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.

4. RETENTION 

We retain your personal information 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 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.

5. 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, 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.

6. 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 Platform. Once posted on the Platform, 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.