1. Introduction to this Privacy Policy
1.1. VELLUVOM and its affiliates (collectively or individually, "VELLUVOM", "we" or "us") take your privacy seriously. Depending on your location, the VELLUVOM entity controlling your personal data will be VELLUVOM Asia Hub.
1.2. In the course of you using VELLUVOM’s applications and websites (both web and mobile versions), as well as products, information, functions and other services operated by VELLUVOM, we will be collecting, using, disclosing, storing and/or processing data, including your personal data. In this Privacy Policy, Platform shall refer to all relevant applications and websites (both web and mobile versions), and Services shall refer to all products, information, functions and services provided by VELLUVOM from time to time at the Platform(s).
1.3. This Privacy Policy exists to keep you in the know about how we collect, use, disclose, store and/or process the data we collect and receive during the course of providing the Services or access to the Platform to you, our user, whether or not you have registered to use our Platform as a buyer or a seller. We will only collect, use, disclose, store and/or process your personal data in accordance with this Privacy Policy.
1.4. It is important that you read this Privacy Policy together with any other applicable notices we may provide for special applications where when we are collecting, using, disclosing and/or processing personal data about you, so that you are fully aware of how and why we are using your personal data.
1.5. We may update this Privacy Policy from time to time. Any changes we make to this Privacy Policy in the future will be reflected on this page and material changes will be notified to you. Where permissible under local laws, your continued use of the Services or access to the Platform, including placing Orders (as defined in the Terms of Use) on the Platform, or express consent thereto, following the modifications, updates or amendments to this Privacy Policy (whether or not you have reviewed such document) shall constitute your acknowledgment and acceptance of the changes we make to this Privacy Policy. You agree that it is your responsibility to review and check the Privacy Policy frequently to see if any updates or changes have been made to this Privacy Policy.
1.6. This Privacy Policy applies in conjunction with other notices, contractual clauses and 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 them unless we state expressly otherwise.
1.7. All of these terms apply to VELLUVOM's users, whether or not the users have created an account as buyers and/or sellers, unless otherwise stated specifically to apply only to buyers or only to sellers.
2. The Personal Data We Collect From You
2.1. We collect the personal data described below in accordance with applicable local laws and, if required, upon obtaining your consent.
2.2. Personal data means any information about an individual, whether recorded in a material form or not and whether true or not, who can be identified from that data (whether directly or indirectly), or from that data and other data to which we have or are likely to have access.
2.3. Depending on your use of our Platform and/or your interaction with our Services (such as when registering for our Services and/or logging into our Platform), you may be asked to provide us with certain information. While you can choose not to provide us with certain information, you might not be able to take advantage of many of our Services that are provided to you. The personal data that you may opt to provide to us are as follows:
(a) Identity and Profile Data, which may include your name, date of birth, gender, username and password, email address, telephone number, your interests, and any personal data in any photographs or videos or audio recordings that you upload onto our Platform.
• Where you are a seller, we may also collect your company name, address, date of incorporation, and other business-related information (e.g. company registration number, business licence, tax information, shareholder and director information
(b) Account and Transaction Data, which may include your credit card details, bank account details, bank statements, delivery/ billing address, payments and orders to and from you, and other details of products and services that you have supplied to or purchased through the Platform.
(c) Usage Data, such as information about how and when you use the Platform, products and Services or view any content on the Platform, as well as websites you were visiting before you came to the Platform and other similar statistics.
(d) Marketing and Communications Data, which may include your interests, survey responses, preferences in receiving marketing materials from us and your communication preferences, your preferences for particular products or services, as well as your feedback, chat, email or call history on the Platform or with third party service providers.
(e) Location data, such as when you check for deals near you or the delivery / pick-up status of orders.
2.4. We automatically collect and process certain types of information when you use your devices to access our Platform and interact with our Services for the purposes set out herein.
How we receive your personal data
2.5. During the course of your use of the Platform and our provision of the Services, we may receive personal data from you in the following situations:
(a) When you browse our websites (both mobile and web versions);
(b) When you create an account with us (as buyer or seller or otherwise);
(c) When, as a seller, you list products and/or services for sale on the Platform and/or on the platforms of our affiliates and conduct transactions with buyers in respect of the sale and purchase of those products and/or services;
(d) When you apply for, subscribe to or otherwise use any of the Services on our Platform and/or on the platforms of our affiliates;
(e) When you make a transaction regarding the products available on the Platform;
(f) When you activate or use any payment-related functions available on the Platform or provided by our third party service providers;
(g) When you use any of the features and functions available on the Platform or Services;
(h) When you record any user-generated content which is uploaded on the Platform;
(i) When you use the chat function on the Platform;
(j) When you subscribe to our publications or marketing collaterals;
(k) When you enter a competition, promotion or survey;
(l) When you participate in any activity or campaign on the Platform;
(m) When you log in to your account on the Platform or otherwise interact with us via an external service or application, such as Facebook or Google;
(n) When any other user of the Platform posts any comments on the content you have uploaded on the Platform or when you post any comments on other users’ content uploaded to the Platform;
(o) When a third party lodges a complaint against you or the content you have posted on the Platform; and
(p) When you interact with us offline, including when you interact with our outsourced customer service agents.
2.6. We may collect personal data from you, third parties (including but not limited to agents, vendors, contractors, partners and any others who provide services to us, who collect your personal information and/or perform functions on our behalf, or with whom we collaborate, including but not limited to payment service providers, government sources of data, financial services providers, credit bureaus, delivery, marketing and other service partners), our affiliates, or such data may be collected automatically when you use the Platform or the Services, as set out in this section. Please see also Sections 2.12 to 2.16 on the collection of computer data.
2.7. During the course of your use of the Platform and our provision of the Services, you agree that you have provided your consent (whether to us, the third party or our affiliates) to the transfer of your personal data from third parties and/or our affiliates to VELLUVOM for the purposes set out in this Privacy Policy or any other terms.
2.8. You agree to only submit personal data which is accurate and not misleading and to keep it up to date and inform us of any changes to the personal data that you have provided to us. We shall have the right to request for documentation and carry out the necessary checks to verify the personal data provided by you as part of our user verification processes or as required under law.
2.9. We will only be able to collect certain categories of personal data if you voluntarily provide the personal data to us or as otherwise provided for under this Privacy Policy. If you choose not to provide your personal data to us or subsequently withdraw your consent to our use of your personal data, we may not be able to provide you with certain features or functionality on the Services or access to the Platform.
2.10. In some situations, you may provide personal data of other individuals to us (such as your family members or friends or persons in your contact list), or when you add them as recipients or beneficiaries of any use of our Services. You represent and warrant that you have obtained the necessary consent, license and permissions from such individuals to share and transfer his/her personal data to us, and for us to collect, store, use, disclose or otherwise process that data in accordance with this Privacy Policy.
2.11. If you sign up to be a user on our Platform using your social media account or link your VELLUVOM account to your social media account or use certain other VELLUVOM social media features, we may access personal data about you which you have voluntarily provided to your social media provider in accordance with the provider's policies and we will manage your personal data in accordance with this Privacy Policy.
• To comply with legal and regulatory requirements (including, where applicable, the display of your name, contact details and company details), including any law enforcement requests, requests by any governmental or regulatory authority having jurisdiction over VELLUVOM, in connection with any legal proceedings, or as otherwise deemed necessary by us; and
• To protect the life, health or personal safety of VELLUVOM’s employees, its users and/or the public.
(e) Any other purpose to which your consent has been obtained, in compliance with our obligations under applicable laws, including to notify you at the time of obtaining your consent.
3.3. Where you are a buyer and/or you have signed in or registered with us, the personal data which we collect from you or via third parties may be used for other purposes, as follows:
(i) Processing your order for products (whether sold by us or a third party seller)
• To process orders you submit through the Platform;
• To deliver the products you have purchased through the Platform. We may pass your personal information on to a third party (e.g. our logistics partner) or relevant regulatory authority (e.g. customs) in order to make delivery of the product to you;
• To update you on the delivery of the products;
• To provide customer support for your orders, for example, to return products that you have purchased through the Platform; and
• To verify and carry out payment transactions (including any credit card payments, bank transfers, offline payments, remittances, or e-wallet transactions) in relation to payments related to you, promotions participated in by you and/or Services used by you. In order to verify and carry out such payment transactions, payment information, which may include personal data, will be transferred to third parties such as our payment service providers.
(ii) Providing Services
• To display your name, username or profile on the Platform (including on any reviews you may post);
• To respond to your queries, feedback, claims or disputes, whether directly or through our third party service providers;
• To display on scoreboards on the Platform in relation to campaigns, or any other activity;
(iii) Courts, tribunals, enforcement agencies, governmental or regulatory authorities having jurisdiction over VELLUVOM; and
9.1. VELLUVOM does not sell products to minors (which is to be determined based on the applicable law), nor does it intend to provide any of the Services or the use of the Platform to minors. We do not knowingly collect any personal data relating to minors.
9.2. You hereby confirm and warrant that you are above the age of minority and you are capable of understanding and accepting the terms of this Privacy Policy. If you are a minor, you may use our Platform only with the involvement of a parent or legal guardian.
9.3. As a parent or legal guardian, please do not allow minors under your care to submit personal data to VELLUVOM. In the event that such personal data of a minor is disclosed to VELLUVOM, you hereby consent to the processing of the minor’s personal data and accept and agree to be bound by this Privacy Policy and take responsibility for his or her actions.
9.4. We will not be responsible for any unauthorised use of the Services on the Platform by yourself, users who act on your behalf or any unauthorised users. It is your responsibility to make your own informed decisions about the use of the Services on the Platform and take necessary steps to prevent any misuse of the Services on the Platform.
10. Third Party Sites
10.1. The Platform may contain links to other websites operated by other parties, such as our business affiliates, merchants or payment gateways. We are not responsible for the privacy practices of websites operated by these other parties. You are advised to check on the applicable privacy policies of those websites to determine how they will handle any information they collect from you.
10.2. Please note that even if the third party is affiliated with us, we have no control over these third party websites, each of which may have their own separate privacy and data collection practices independent of us. 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).
11. Questions, Feedback, Concerns, Suggestions or Complaints
11.1. If you have any questions on personal data protection or data privacy, please reach out to us via email at info@velluvom.com.
Version dated 30 November 2022