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TradePe Privacy Policy

1.0 INTRODUCTION

This General Privacy Policy (“Policy”) explains how we may collect and use information that TradePe, its related corporations and/ or associated companies (“TradePe“) obtains about you, and your rights in relation to that information.

Please read this Policy to understand how we will collect, use, and process your personal data and the rights you have in relation to your personal data. This Policy may be amended from time to time. Please visit this page if you want to stay up to date, as we will post any changes in our approach to data privacy here.

By providing your explicit consent and/ or by your provision of information to us, you acknowledge the terms of this Policy and the use and disclosure of your personal data as set out in this Policy.

2.0 SCOPE OF POLICY

This Policy applies to our processing of personal data in relation to the provision of any of our products and/or services, including:

a. when you request information from us;

b. when you engage our services and/or purchase our products;

c. as a result of your relationship with one or more of our clients;

d. where you apply for a job or work placement; and

e. your use of our websites (including our associated sites) and online services (including our mobile apps, if any).

3.0 DEFINITION

Personal Data

‘Personal Data’ is any information which either directly or in combination with other information is available or likely to be availed by an organization that identifies an individual. Examples of Personal Data could include names, email ids, phone numbers etc. Certain types of Personal Data known as ‘Special Categories of Personal Data or Sensitive Personal Data’ include passwords, financial details, official identifiers, etc.

For the purposes of this Policy, Personal Data includes Sensitive Personal Data.

4.0 HOW YOUR PERSONAL DATA IS COLLECTED

Directly

We generally collect your personal data directly from you when you are one of our customers. When you enter a contract with us, you will be asked to provide personal data. This information is likely to include your name, address, date of birth, email address, phone number, and financial information and/or any other information considered as personal data  that may deem necessary by TradePe to perform its business activities from time to time.

We may also collect personal data from you when you make transactions or otherwise interact with us, for example by contacting our customer service personnel or reporting a problem on our website. The categories and range of personal data we collect, and hold will vary from customer to customer. However, our policy is to collect only the personal data necessary for the provision of services to You.

Business Contacts & Suppliers

We collect certain limited personal data about our business contacts, including subcontractors and individuals associated with our suppliers and subcontractors, and service providers (including professional advisors and individuals associated with our service providers). Personal data collected in this context usually includes (but may not exclusively be limited to) name, employer name, contact title, phone, email, and other business contact details.

Careers & Recruitment

If you apply for a job or work placement you may need to provide information about your education, employment, nationality, and state of health. Your application will constitute your express consent to our use of this information to assess your application and to allow us to carry out both recruitment analytics and any monitoring activities which may be required of us under applicable law as an employer. We may also carry out screening checks (including reference, background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks) and consider you for other positions. We may disclose your personal data (including diversity and equal opportunities data) to academic institutions, recruiters, screening check providers, health service providers, professional and trade associations, law enforcement agencies, recruitment analytics and diversity research providers, referees, and your current and previous employers. We may also collect your personal data from these parties in some circumstances. Without your personal data we may not be able to progress considering you for positions with us.

Automatically

When you use our online services or visit our website, we may collect the following information from you automatically:

details of visits made to our website such as the volume of traffic received, logs (including, the internet protocol (IP) address and location of the device connecting to the online services and other identifiers about the device and the nature of the visit) and the resources accessed.

We use cookies to collect certain personal data. For further information on Cookies please refer to our Cookie Policy.

5.0 PURPOSE AND USE OF PERSONAL DATA

We may use/process your personal data in the following circumstances:

a. to create and maintain  your account with us;

b. performance of a contract with you;

c. to comply with TradePe's legal or regulatory obligations;

d. to process your job application;

e. to send marketing and promotional offers to you 

f. fulfillment of customer service request 

g. to provide our services including this website to you;

h. to provide and improved experience when you avail our services and products;

i. to notify you about changes to the products and/or services that we offer and (where you have indicated your consent) to directly market these products and/or services to you;

j. research, statistical and survey purposes;

k. to allow you to participate in interactive features of our products and services;

l. as part of our efforts to keep our products and/or services safe and secure;

m. to analyze your credit risk (if applicable);

n. to handle payment and collection processes to and from customers;

o. for anti-money laundering, prevention of terrorist financing, and identity verification purposes.

With reference to above stated purposes the following data elements may be collected as applicable:

During Registration

  • Organization name

  • Primary contact first name

  • Primary contact last name

  • Primary email

  • Country code

  • Primary contact no.

  • Company website

  • Primary address

  • Country

  • State

  • City

  • Postal code

During KYC

  • Identification proof

  • Address proof

For Billing

  • Billing address

  • Country

  • State

  • City

  • Postal code

  • Taxation type

  • Taxation ID

  • Credit limit

  • Billing cycle

  • Bill date

  • Currency

  • Billing type

For Support

  • First name

  • Last name

  • Email

  • Country code

  • Contact no.

Marketing

We (and permitted third parties) may contact you for direct marketing purposes via social media, direct messages, post, telephone, email and SMS/MMS. This marketing may relate to:

a. Products and services we (or permitted third parties) feel may interest you;

b. Information about other goods and services we offer that are similar to those that you have already used or inquired about;

c. Upcoming events, promotions, and new products and/or services or other opportunities as well as

d. those of selected third parties who are contracted by TradePe; and

e. If you no longer wish to receive marketing communications from us, you may click on the unsubscribe link on any marketing communication that you receive from us.

For clarity, any telephone calls that you make to us may be recorded for training or security purposes and may be stored and used to verify your instructions to us.

6.0 WHO DO WE SHARE YOUR PERSONAL DATA WITH

We may share your personal data with the following categories of recipients:

Regulatory Bodies

We may disclose your personal data:

a. to regulators and law enforcement agencies (including those responsible for enforcing anti-money laundering legislations);

b. in response to an inquiry from a government agency;

c. to data protection regulatory authorities; and

d. to other regulatory authorities with jurisdiction over our activities.

Service Providers

We may disclose your personal data to third party service providers who require access to such information for the purpose of providing specific services to us. These third parties will generally only be able to access your data to provide us with their services and will not be able to use it for their own purposes.

Professional Advisors & Auditors

We may disclose your personal data to professional advisors (such as legal advisors and accountants) or auditors for the purpose of providing professional services to us.

Change of Ownership

In the event, we sell or buy any business assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. If TradePe or substantially all its assets are acquired by a third party, personal data held by us about our clients will be one of the transferred assets.

7.0 HOW WE PROTECT YOUR PERSONAL DATA

We care about protecting your information and put in place appropriate measures that are designed to prevent unauthorized access to, and misuse of, your personal data. These include measures to deal with any suspected data breach.

We do this by having in place a range of appropriate technical and organizational measures, for example, the protection of passwords using industry standard encryption such as AES 256, measures to preserve system security and prevent unauthorized access and back-up systems to prevent accidental or malicious loss of data.

8.0 HOW LONG WE KEEP YOUR PERSONAL DATA

We will not keep your personal data for longer than is necessary for the purposes for which we have collected it, unless we believe that the law or other regulation requires us to retain it. In determining the appropriate retention period for different types of personal data, the amount, nature, and sensitivity of the personal data in question, as well as the potential risk of harm from unauthorized use or disclosure of that personal data, the purposes for which we need to process it.

Once we have determined that we no longer need to hold your personal data, we will delete it from our systems or render it inaccessible/unusable by TradePe or its third parties. with due regard to protection of privacy of the said personal data.

9.0 GUIDELINES FOR CHILDREN

Services provided by TradePe are intended for general public and are not meant for individuals below 18 years of age.

We do not knowingly or intent to gather personal information from children. If you have any concerns, please contact our Privacy Officer / DPO at [email protected].

10.0 YOUR RIGHTS TO PERSONAL DATA

If you wish to access, rectify, or delete your data, please contact our Privacy Officer / DPO at [email protected]. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled) of receipt of your request. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

You may also withdraw your consent previously provided by writing to us on [email protected]. Please note, that should you withdraw your consent, it may hamper our ability to provide services to you and may result in complete cessation of all services to You. TradePe or any of its authorized third parties will not be liable for any losses suffered by You because of the same.

11.0 DATA STORAGE IN PSEUDONYMISED OR ANONYMISED FORMAT

We are likely to also store your personal data in pseudonymised or anonymised format to the extent permissible by law for various reasons including but not limited to archiving purposes, statutory compliances, making internal reports and more.

12.0 CHANGES TO THIS POLICY

We may change this Privacy Policy from time to time and reserve the right to do so any time. This Policy is effective as of 03.01.2024. Updated Policy will be provided at earliest when any changes are made. This shall be circulated either through email or by providing a prominent Policy of the change on the website.

You are advised to check the Policy periodically.