Security and privacy policy

BUYSINO values your personal data and the manner in which such personal data is collected, used, disclosed and retained. We are committed to managing your personal data in accordance with the applicable laws when you use the services on our platform or our services, whether through the website or the application, including when you contact us through customer service, or when you access our services or platform through a computer, a mobile device or any other internet-enabled device.

Please read this Privacy Policy carefully when you click or tick the "Sign up" box, the statement "I agree to the security and privacy policy of BUYSINO", the statement "I agree and consent to the collection, use, disclosure, storage, transfer and/or processing of my personal data for the purposes specified and under the terms of the security and privacy policy of BUYSINO", or any other similar wording appearing on the BUYSINO registration page, or provided while we are providing services to you or when the platform is accessed. You acknowledge that you have read and understood the terms of this security and privacy policy, and that you have agreed and consented to the collection, use, disclosure and/or processing of your personal data as specified and under the terms of this policy.

1. Introductory Privacy Policy

• 1.1 BUYSINO (referred to as "BUYSINO" or "we") takes your privacy very seriously. The BUYSINO entity that controls your personal data will be the BUYSINO service provider (corporate information pending verification). This may also include other BUYSINO entities with which you may have a contract, depending on your use of the services.
• 1.2 This Privacy Policy should be read together with the country-specific terms for your jurisdiction as set out in Clause 12 below.
• 1.3 When you use our services through the BUYSINO website or application (whether in website or mobile form), including the products, information, features and other services operated by BUYSINO, we will need to collect, use, disclose, store and/or process data, including your personal data, under this Privacy Policy. "Platform" means all related application and website platforms (whether in website or mobile form), and "services" means the products, information, features and other services provided by BUYSINO from time to time on the various platforms.
• 1.4 This Privacy Policy is intended to inform you about the ways in which we collect, use, disclose, store and/or process the data that we collect and receive while providing services or access to the platform to you as our user. We will collect, use, disclose, store and/or process your personal data under this Privacy Policy.
• 1.5 It is important that you read this Privacy Policy, as well as any related notices we may provide for the website and application, where we collect, use, disclose and/or process personal data about you, so that you are fully aware of the ways in which and the reasons why we need to use your data.
• 1.6 We may update this security and privacy policy from time to time. Any changes we make to this security and privacy policy in the future will be published on this page, and we will notify you of the relevant changes. Where permitted under local law, your continued use of the services, access to the platform, including the ordering of products (as set out in the terms of use) on the platform, or your express consent, after this security and privacy policy has been amended, updated or revised (whether or not you have read that document) will constitute your acknowledgement and acceptance of the changes we have made to this security and privacy policy. You accept that it is your responsibility to always read and check whether this security and privacy policy has been amended or updated.
• 1.7 This security and privacy policy applies together with the notices, contractual terms and other consent terms applicable to our collection, storage, use, disclosure and/or processing of your personal data, and this security and privacy policy shall not be deemed to replace such terms unless we state otherwise.
• 1.8 The terms of this security and privacy policy apply to all BUYSINO users.

2. Personal Data We Collect from You

• 2.1 We will collect the personal data listed below in accordance with the applicable local law. Where required by law, we will collect such personal data upon obtaining your consent.
• 2.2 Personal data means any information relating to an individual, whether recorded in a tangible form or not, and whether true or false, which can be used to identify that individual from that information (whether directly or indirectly) or from that information together with any other information that we have access to or may access.
• 2.3 We may ask you to provide certain information when you use the platform and/or carry out any act in relation to our services, such as:
  • (a) Personal identification and profile data, such as name, date of birth, gender, username and password, email address, telephone number, your interests and other information.
  • (b) Account and account transaction data, such as credit card details, bank account, delivery address, orders, etc.
  • (c) Usage data, such as access times and information on web pages visited.
  • (d) Marketing and communications data, such as your interests, survey responses, etc.
  • (e) Location data
• 2.4 We will automatically store and process certain types of data when you use your device to access our platform and carry out any act in relation to our services, for the purposes set out below. How we receive your personal data:
• 2.5 In the course of your use of the platform and our terms of service, we may receive personal data from you in the following cases:
  • (a) When you browse our website (whether via mobile phone, website or application)
  • (b) When you create a user account with us
  • (c) When you register for or use any other services on our platform
  • (d) When you carry out transactions relating to the ordering of products or use various functions on the platform
  • (e) When you activate or use any payment service relating to the functions available on the platform or provided by our third-party service providers
  • (f) When you use the application or mobile phone system functions available on the platform or services
  • (g) When you save user-generated content uploaded on the platform
  • (h) When you use the chat system on the platform
  • (i) When you register to receive our publications or marketing materials
  • (j) When you take part in a competition, a promotion or a survey
  • (k) When you participate in activities or campaigns on the platform
  • (l) When you sign in to your user account on our platform, or otherwise interact with us through external services or other applications such as Facebook or Google
  • (m) When other users on the platform post any comments on content you have uploaded to the platform, or when you post any comments on content uploaded to the platform by other users
  • (n) When a third party files a complaint against you or against content you have posted on the platform
  • (o) When you interact with us outside the internet system, including when you interact with customer relations representatives provided by our third parties
• 2.6 We may collect personal data from you, from third parties (including but not limited to agents, partners, contractors, associates and any other persons who provide services to us and who collect your data and/or perform service functions on our behalf or with persons with whom we work, including but not limited to payment service providers, government data sources, financial service providers, credit bureaus, delivery, marketing and other partner services), or from our affiliates; or such data may be collected automatically when you use the platform or services, as set out in this clause. Please also see clauses 2.12 to 2.16 below regarding the collection of computer data.
• 2.7 During your use of the platform and our provision of services, you acknowledge that you have given your consent (whether to us, to a third party or to our affiliate) for the transfer of personal data from third parties and/or our affiliates to BUYSINO for the purposes specified in this Privacy Policy or other terms.
• 2.8 You agree to submit only personal data that is accurate and not misleading, to keep such data current, and to inform us of any changes to the personal data you provide to us. We have the right to request documents and to carry out any necessary verification to verify the accuracy of the personal data you submit to us, as part of our user verification process or as required under law.
• 2.9 We may collect certain categories of your personal data only where you provide that personal data to us, or where it is provided under this Privacy Policy. If you choose not to provide your personal data to us, or withdraw your consent for us to use your personal data, we may be unable to provide certain types of our services or certain forms of use to you, or may be unable to give you access to the platform.
• 2.10 We may collect certain categories of your personal data only where you provide that personal data to us, or where it is provided under this Privacy Policy. If you choose not to provide your personal data to us, or withdraw your consent for us to use your personal data, we may be unable to provide certain types of our services or certain forms of use to you, or may be unable to give you access to the platform.
• 2.11 If you register as a user on our platform using a social media account, or connect your BUYSINO user account with a social media account, or use other social media systems of BUYSINO, we may access personal data about you that you have voluntarily provided to your social media service provider in accordance with that provider's policy, and we will handle your personal data in accordance with this Privacy Policy. Collection of computer data
• 2.12 We or our authorised service providers may use cookies, web beacons and any other similar technologies in providing services to you or in connection with your access to the platform.
• 2.13 When you visit the platform through a computer, a mobile device or any other device of yours that is connected to the internet, our servers will record the data automatically sent by your browser when you enter the website, which constitutes technical data and usage data as set out in section 2.2 above.
• 2.14 This data will be collected for analysis and assessment in order to help us improve the website, the application and the services, including to help us tailor content to suit your interests more quickly; the data is also collected to help us develop the services and platform so that you can use them more conveniently and efficiently.
• 2.15 A cookie is a small text file (usually consisting of letters and numbers) that is stored in the memory of your browser or device when you visit a website or view a message. Cookies enable us to recognise that device or browser. A web beacon is a small graphic image that may be included in our services and platform; web beacons help us count the number of users who have visited a given page so that we can understand your needs and interests.
• 2.16 You may manage and delete cookie data through your browser or the settings function of your device. However, some cookies are essential to the core operation of the system (for example, adding products to your shopping cart). Therefore, changing or deleting cookies may affect the operating systems used on the platform or our services.

3. Use and Disclosure of Personal Data

Purposes of Use

• 3.1 We will use and disclose personal data for the purposes set out below in accordance with the applicable local law. Where required by law, we will use and disclose such personal data upon obtaining your consent.
• 3.2 Depending on your status in dealing with us (for example, a buyer, a website visitor or a user of the mobile phone application), the personal data we collect from you or from third parties may be used for certain purposes as follows:
  • (a) To facilitate your use of the services or access to the platform
  • (b) To administer the online user account you may have registered with us
  • (c) To carry out analysis, research, business operations and development
    • • To understand users' experience of using the services and platform
    • • To develop the design or content of the various content display pages on the platform, and to customise user-specific content
    • • To identify users who access the platform
    • • To conduct opinion surveys, including research into users' basic information and user behaviour, in order to develop our current technology through learning tools or by any other means
    • • To develop additional usage features relating to you from the personal data you have provided to us (whether provided to us or to a third party), so that we can present information that is more appropriate and/or relevant to you
    • • For data analysis, testing and research, and for monitoring and analysis of usage and usage trends, and
    • • To develop our products and services
  • (d) Legal and operational purposes
    • • To verify your identity in connection with fraud detection purposes
    • • To compare and verify data with third parties to ensure that the data is accurate
    • • To handle complaints, comments, enforcement and takedown requests relating to any content connected with content you have uploaded to the platform
    • • To compile statistics and conduct data research for reporting and/or record-keeping as required by internal policy and as required by law
    • • To store, keep in systems and back up your personal data for legal or business operational purposes
    • • To disclose personal data in connection with a tender offer, acquisition or merger, whether in any part of the business, where we have complied with the conditions of the data protection laws relating to the disclosure of your personal data
    • • To prevent or investigate any breach or alleged breach of the terms and conditions, the security and privacy policy or any of our policies, fraud, unlawful acts, omissions or any wrongdoing arising from your use of the services, or in connection with any cause arising from any dealings between you and us
    • • For due diligence checks
    • • To comply with laws and legal requirements (which include displaying your name, contact details and company information), including orders to act under law in connection with any legal proceedings, orders from government agencies or regulatory bodies having jurisdiction over Lazada in connection with any legal proceedings, or in any other case as we consider appropriate
    • • To protect the life, health and safety of BUYSINO's employees and users and/or the public
  • (e) For any other purpose for which you have given your consent, where we are required to comply with the law, including notifying you when your consent is obtained

• 3.3 The personal data we have collected from you or through third parties may be used for the following other purposes
  • (1) Processing your orders for the purchase of products
    • • To process the orders you submit through the platform
    • • To deliver the products you order through the platform. We may send your personal data to third parties (such as delivery companies that are our partners) for the delivery of products to you
    • • To inform you of the delivery status of the products
    • • To provide customer care services in relation to your orders
    • • To verify and process payment transactions, including payment by credit card, transfer through a bank account, offline payment and money transfer, in connection with any payment relating to you, the promotional programmes you join and/or the services you use. In order to verify and process your payment transactions, we will need to transfer payment information, which may include personal data, to third parties such as our payment service providers
  • (2) Provision of services
    • • To display your username or user profile on the platform (including any reviews you may post)
    • • To facilitate the use of the websites and applications on the platform and all purchases made through the platform
    • • To respond to your questions, comments, requests or disputes, whether directly or through our third-party service providers
    • • To display scores available on the platform for campaigns or any other activities
  • (3) Marketing and advertising
    • • To provide information that we consider beneficial to you, or that you have requested from us
    • • To send marketing or promotional information relating to our services on our platform from time to time
  • (4) Others
    • • To get to know our buyers better, and
    • • To carry out automated decision-making processes in accordance with the purposes stated above, which will be carried out in accordance with our obligations under the applicable law, including notification to you and obtaining your consent
• 3.4 We may share (or permit the sharing of) your personal data with, and/or transfer your personal data to, third parties and/or our affiliates for the purposes set out above, and such third parties and affiliates may be located within or outside your jurisdiction, including but not limited to
  • (1) Service providers (such as agents, vendors, contracting parties, partners, contractors and associates) in relation to various services, such as payment services, transport and delivery systems, marketing, data analytics, market and customer research, surveys, social media, customer service, information technology data installation services and web hosting, etc.
  • (2) The service providers of such service providers
  • (3) Enforcement authorities, or government or regulatory bodies having jurisdiction over BUYSINO
  • (4) Other users of the platform or other service users
• 3.6 In sharing your personal data with such persons, we will use our efforts to ensure that third parties and our affiliates keep your personal data secure from unauthorised access, collection, use, disclosure, processing or any act entailing a similar risk, and retain your personal data only to the extent necessary to achieve the above purposes.
• 3.7 International data transfers. We may transfer or permit the transfer of your personal data outside your jurisdiction for the purposes set out in this Privacy Policy. However, we will not transfer or permit the transfer of your personal data outside your jurisdiction unless such transfer is in accordance with the requirements of law, which include, for example, notification to you and obtaining your consent regarding the country to which your personal data may be transferred and the relevant data protection standards of that destination country.
• 3.8 External service providers. We may share your personal data with our external service providers or our affiliates (such as payment service providers) so that those service providers or affiliates can offer various services to you in conjunction with your use of our services and platform. Your consent to and use of the services of our external service providers or affiliates is subject to the terms and conditions to be agreed between you and such external service providers or affiliates. When you accept the use of the services of our external service providers or affiliates, the collection, use, disclosure, retention, transfer or processing of your data (including personal data and any of your data that we have disclosed to such external service providers and affiliates) will be governed by the privacy policy of such external service providers or affiliates, which are regarded as the controllers of such data. You agree to direct any questions or complaints regarding the acceptance or use of the services of such external service providers or affiliates to the service provider as specified in that privacy policy.

4. Withdrawal of Consent to the Further Use, Disclosure, Retention and/or Processing of Your Personal Data

• 4.1 You may notify the withdrawal of your consent to the further use, disclosure, retention and/or processing of your personal data by contacting us through the contact details set out below, subject to the conditions and/or restrictions prescribed under law or regulation.
• 4.2 Please note that if you withdraw your consent to our use, disclosure, storage and/or processing of your personal data for the purposes and in the manner set out above, or exercise your rights under applicable law, we may no longer be able to provide our services to you or to perform any contract we have with you, and we will not be liable where we stop providing services to you or stop performing our contract with you. We reserve any rights and remedies available to us under law in such circumstances. Marketing information
• 4.3 You can always opt out of receiving marketing information. We may use your contact details to send you information from us or from our related companies.

5. Keeping Your Personal Data Up to Date

• 5.1 In order for you to continue using the platform and for us to provide services to you, it is important that the personal data you provide to us is accurate and complete. It is your responsibility to inform us if your personal data changes, or if there is reason for you to believe that the personal data we hold is inaccurate, incomplete, misleading or out of date.
• 5.2 You can update your personal data at any time by accessing your user account on the platform.
• 5.3 We have arranged for the sharing of your personal data that has been updated with the third parties or our affiliates to whom we have already shared your personal data, where it remains necessary to use your personal data for the purposes set out above.
• 5.4 You can notify your intention to permanently delete your user account from our platform by contacting BUYSINO staff by email [email protected] or through the problem-reporting channel on the website or application by yourself, by providing the details of the user account you wish to delete, such as membership ID, first and last name, telephone number and email. We will permanently delete the user account from the platform in accordance with your wish.

6. Access to and Correction of Your Personal Data

• 6.1 You may request information about your personal data that we have collected, or raise questions about the details of how we may have used, disclosed, retained or processed your personal data, through the account data settings on the platform or by contacting us using the contact details set out below; and you may request the correction of any errors or incompleteness in your personal data that we have collected through the same channel. In order to facilitate the handling of your request, we may need to ask you for additional information about that request. We may refuse a request to correct errors if we consider that the request is vexatious or unreasonable, where permitted under law.
• 6.2 Where permitted under the laws relating to data protection, we reserve the right to charge a reasonable administrative fee for retrieving your personal data records, and we will inform you of the details of that fee before acting on your request.

7. Security of Your Personal Data

• 7.1 In order to keep your personal data secure from unauthorised access, collection, use, disclosure, processing, copying, modification, deletion, damage or misuse, or from any risks of a similar nature, we have put in place appropriate physical and technical management measures, such as
  • (a) Limiting access to personal data to only those persons who need access
  • (b) Implementing technology products to prevent unauthorised access to computer systems
  • (c) Providing security systems as required under law
• 7.2 You should be aware that, in any event, no system for transmitting data over the internet or for storing data electronically is completely secure. Although we cannot guarantee security, we are highly committed to keeping your data secure, and we constantly review and improve our data security measures.

8. Retention of Personal Data

• 8.1 We will retain your personal data only for as long as we are required or permitted to do so under law, or as relevant to fulfil the purposes for which such data was collected.
• 8.2 We will cease to retain your personal data, or destroy the means by which the data can be linked to you, as soon as there is reason to believe that such retention no longer serves the purposes for which the personal data was collected and is no longer necessary for legal or business purposes.

9. Minors

• 9.1 BUYSINO does not sell any products to minors (minors having the same meaning as prescribed by law) or intend to provide services to minors or allow minors to use the platform, and it is not our policy to collect personal data relating to minors where we know it to be the personal data of a minor.
• 9.2 You confirm and warrant that you are older than the age of a minor and that you are capable of acknowledging, understanding and accepting the terms of this Privacy Policy. If you are a minor, you may use our platform only under the supervision of a parent or legal guardian.
• 9.3 If you are such a parent or legal guardian, please prohibit minors under your care from providing personal data to Lazada. Where a minor's personal data is disclosed to Lazada, you consent to the processing of the minor's personal data and accept and agree to be bound by this Privacy Policy and to be responsible for the acts of that minor.
• 9.4 We will not be responsible for any unauthorised use of the services on the platform by you, by a user acting on your behalf or by an unauthorised user. You must be responsible for any decisions regarding the use of the services on the platform and must take any action to prevent improper use of the platform services.

10. Third-Party Websites

• 10.1 The platform may contain links leading to other websites operated by third parties, such as our business partners, sellers or payment channels. We are not responsible for the privacy practices of such third-party operated websites. Please review the relevant privacy policies of such websites so that you understand how they will handle the data collected from you.
• 10.2 Where a third party is a person connected with us, we are unable to control such third-party websites. Please note that such third parties may set out data protection and personal data collection practices that differ from ours. For this reason, we will not be responsible or jointly liable for the handling of data or the security (or lack of security) and any activities of such links. In addition, please be informed that we provide such links solely for your convenience; you therefore access such links at your own risk. Nevertheless, we aim to maintain the integrity of the platform and welcome feedback regarding the destination websites of these links (including but not limited to links that do not work).

11. Questions, Comments, Concerns, Suggestions or Complaints

• 11.1 If you have any questions about data protection or data privacy, please refer to the list of frequently asked questions about data protection/data privacy.
• 11.2 If you have concerns relating to data protection and privacy practices, or wish to exercise any rights you have under the applicable law, please contact us through the following channels:
  Company: BUYSINO Service Provider
  Address: company registration details are being updated. Please contact BUYSINO support.
  Address: company registration details are being updated. Please contact BUYSINO support.

12. Your Data Protection Rights

• 12.1 You have the right to request to receive the personal data relating to you that we hold in a format that can generally be read or used by automatic tools or devices and that can be used or disclosed by automated means.
• 12.2 You have the right to do the following
  • (a) Make a request for us to send or transfer personal data in such a format to another organisation where it can be done by automated means, and
  • (b) Request to receive personal data in such a format that has been sent or transferred to another organisation, unless this is technically impossible
• 12.3 You have the right to restrict the processing of your personal data in the following cases:
  • (a) We are verifying your request for the correction of your data
  • (b) Where the personal data is subject to the right to erasure and you request restriction of use instead
  • (c) Where it is no longer necessary to retain that personal data, but you request that it be retained for the purpose of establishing, complying with, exercising or defending legal claims, or
  • (d) Where we are in the process of verifying and examining your objection request
• 12.4 You have the right to object to the processing of your personal data in the following cases:
  • (a) Where your personal data is being processed on the basis of our or another person's legitimate interests, unless there is an exception permitting the processing
  • (b) Where the personal data is processed for purposes relating to direct marketing, or
  • (c) Where the processing is for purposes relating to scientific, historical or statistical research, unless it is necessary for the performance of a task carried out in the public interest
• 12.5 You have the right to request that your personal data be erased, destroyed or made anonymous in the following cases:
  • (a) That personal data is no longer necessary for retention for the purposes of the collection, use or disclosure of the personal data
  • (b) You have withdrawn your consent and we have no legal authority to continue processing that personal data
  • (c) You have exercised your right to object and we must comply with your request, or
  • (d) Your personal data has been processed unlawfully
• 12.6 If you consider that the processing of your personal data is contrary to law or the relevant personal data protection law, you have the right to lodge a complaint with the competent authority.