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Privacy Policy

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CLICKING OR CHECKING “SIGN UP”, “I AGREE TO papmall®’S PRIVACY POLICY”, “I AGREE AND CONSENT TO THE COLLECTION, USE, DISCLOSURE, STORAGE,
TRANSFER AND/OR PROCESSING OF MY PERSONAL DATA FOR THE PURPOSE STATED IN, AND UNDER THE TERMS OF, papmall®’S
PRIVACY POLICY” OR SIMILAR STATEMENTS AVAILABLE AT THE papmall® REGISTRATION PAGE OR IN THE COURSE OF
PROVIDING YOU WITH THE SERVICES OR ACCESS TO THE PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THE
TERMS
OF THIS PRIVACY POLICY AND THAT YOU HAVE AGREED AND CONSENTED TO THE COLLECTION, USE, DISCLOSURE, STORAGE, TRANSFER
AND/OR PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED AND UNDER THE TERMS HEREIN.

 

1. Introduction to this Privacy Policy

1.1. papmall® and its affiliates refer to collectively or individually “papmall®”,
“we” or “us” take your privacy seriously. 1.2. In the course of providing you with the
Services or access to the Platform (as defined in the Terms of Service), we will be collecting, using, disclosing,
storing and/or processing data, including your personal data. 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. 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 on specific occasions 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, access to the Platform or use of the Services, including placing Orders
(as
defined in the Terms of Service) on the Platform, or express consent thereto, shall constitute your acknowledgment
and
acceptance of the changes we make to this Privacy Policy. You agree that it is your responsibility to check back
frequently to see any updates or changes 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 all of papmall®’s users.

2. The Personal Data We Collect From You

2.1. 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. 2.2. During the course of your use of the Platform and the provision
of the Services, we may collect personal data about you, as follows:

(i) Identity data, such as your name, gender, profile picture, and date of birth; (ii) Contact data, such as
billing
address, delivery address, email address and phone numbers; (iii) Biometric data, such as voice files when you use
our
voice search function, and facial and other bodily features and voice of yourself and/or another person featured in
your video when you upload videos onto the Platform; (iv) Account data, such as bank account details, bank
statements,
credit card details and payment details (such account data may also be collected directly by our affiliates and/or
third party payment service providers); (v) Transaction data, such as details about orders and payments, and other
details of products and Services related to you; (vi) Technical data, such as Internet protocol (IP) address, your
login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating
system and platform, international mobile equipment identity, device identifier, IMEI, MAC address, cookies (where
applicable) and other information and technology on the devices you use to access the Platform; (vii) Profile data,
such as your username and password, orders related to you, your interests, preferences, feedback and survey
responses;
(viii) Usage data, such as information on how you use the Platform, products and Services or view any content on the
Platform, including the time spent on the Platform, items and data searched for on the Platform, access times and
dates, as well as websites you were visiting before you came to the Platform and other similar statistics; (ix)
Location data, such as when you capture and share your location with us in the form of photographs or videos and
upload such content to the Platform; (x) Marketing and communications data, such as your preferences in receiving
marketing from us and our third parties, your communication preferences and your chat, email or call history on the
Platform or with third party customer service providers; and (xi) Additional information we may request you to
submit
for due diligence checks as required for identity verification (such as copies of government issued identification,
e.g. passport, ID cards, etc.) or if we believe you are violating our Privacy Policy or our Terms of Service.

How we receive your personal data

2.3. During the course of your use of the Platform and our provision of the Services, we may receive personal data
from you in the situations, as follows: (a) When you browse our website (both mobile and web versions); (b) When you
create an account with us; (c) When you apply for, subscribe to or otherwise use any of the Services; (d) When you
make a transaction regarding the products available on the Platform; (e) When you activate or use any
payment-related
functions available on the Platform or provided by our third party service providers; (f) When you use any of the
features, functions available on the Platform or Services; (g) When you record any user-generated content which is
uploaded on the Platform; (h) When you use the chat function on the Platform; (i) When you subscribe to our
publications or marketing collaterals; (j) When you enter a competition, promotion or survey; (k) When you
participate
in any activity or campaign on the Platform; (l) 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; (m) 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; (n) When a third party lodges a complaint against you or the content
you have posted on the Platform; and (o) When you interact with us offline, including when you interact with our
outsourced customer service agents. 2.4. 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 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. See also section 10 below on the collection of computer data. 2.5. Where we
collect personal data from third parties and/or our affiliates, we will only collect your personal data, where
permitted by law, for or in connection with the purposes for which those third parties or our affiliates are
engaged,
for the purposes of our collaboration with the third parties or affiliates, or for the requirement to carry out
verification or due diligence checks. 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 papmall® for the purposes set out in this Privacy
Policy or any other terms. 2.6. You must only submit personal data which is accurate and not misleading and you must
keep it up to date and inform us of any changes to the personal data 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. 2.7. 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. 2.8. If you provide personal data of any third party to us, you represent and warrant that you have
obtained the necessary consent, license and permissions from that third party to share and transfer his/her personal
data to us, and for us to collect, store, use and disclose that data in accordance with this Privacy Policy. 2.9. If
you sign up to be a user on our Platform using your social media account or link your papmall® user account to
your social media account or use certain other papmall® 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.

3. Use and Disclosure of Your Personal Data

Purpose of Use

3.1. The personal data we collect from you or via third parties may be used for certain purposes, as follows:

(i) Processing your order for products

  • 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; and
  • To verify and carry out payment transactions (including any credit/debit card payments, bank transfers, offline
    payments, remittances, or e-wallet transactions) in relation to payments related to 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 facilitate your use of the Services or access to the Platform;
  • To administer your account (if any) with us;
  • 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;
  • To allow other users to identify you (via the “Find my friends” or any other similar function) as a
    user of the Service, to allow you to find other users and to connect with them on the Platform, and to support the
    socialising function of the Services (where applicable);
  • To assess your application for loan facilities and/or to perform credit risk assessments in relation to
    application for financing services (where applicable); and
  • To facilitate the integration of third party’s loyalty membership programs (including those supported by
    brands) with our Platform.

(iii) Marketing and advertising

  • To provide you with information we think you may find useful or which you have requested from us (provided you
    have opted to receive such information);
  • To send you marketing or promotional information about our products and services on our Platform from time to
    time
    (provided you have opted to receive such information);
  • To help us conduct marketing and advertising; and
  • To promote the Services and use information that you give to us, such as user-generated content (including video
    content) that you can choose to upload or broadcast on our Platform and will be accessible on the Internet and may
    be shared by the public (the latter of which is not within our control), as part of our advertising and marketing
    campaigns to promote the Platform.

(iv) Legal and operational purposes

  • To ascertain your identity in connection with fraud detection purposes;
  • To compare information, and verify with third parties in order to ensure that the information is accurate;
  • To process any complaints, feedback, enforcement action and take-down requests in relation to any content you
    have
    uploaded to the Platform;
  • To produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
  • To store, host, back up your personal data;
  • To prevent or investigate any actual or suspected violations of our Terms of Service, Privacy Policy, 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 perform due diligence checks;
  • 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, in connection with any legal proceedings, or
    otherwise deemed necessary by us; and
  • Where necessary to prevent a threat to life, health or safety.

(v) Analytics, research, business and development

  • To understand your user experience with the Services and the Platform;
  • To improve the layout or content of the pages of the Platform and customise them for users;
  • To identify visitors on the Platform;
  • To conduct surveys, including carrying out research on our users’ demographics and behavior;
  • To improve our current technology (e.g. voice recognition tech, etc) via machine learning or other means;
  • To derive further attributes relating to you based on personal data provided by you (whether to us or third
    parties), in order to provide you with more targeted and/or relevant information;
  • To conduct data analysis, testing and research, monitoring and analysing usage and activity trends;
  • To further develop our products and services; and
  • To know our buyers better.

(vi) Other

  • Any other purpose to which your consent has been obtained; and
  • To conduct automated decision-making processes in accordance with any of the above purposes.

Who we disclose your personal data to

3.2. 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 above-mentioned purposes. These third parties and affiliates, which may be
located inside or outside your jurisdiction, include but are not limited to: (i) Service providers (such as agents,
vendors, contractors and partners) in areas such as payment services, logistics and shipping, marketing, data
analytics, market or consumer research, survey, social media, customer service, installation services, information
technology and website hosting; (ii) Their service providers and related companies; and (iii) Other users of the
Platform or Services. 3.3. In disclosing your personal data to them, 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 to achieve the
above-mentioned purposes. 3.4. We may also share personal data in connection with any proposed purchase, merger or
acquisition of any part of our business, provided that we satisfy the requirements of applicable data protection law
when disclosing your personal data.

International data transfer

3.5. We may transfer or permit the transfer of your personal data outside of your jurisdiction for any of the
purposes set out in this Privacy Policy. However, we will not transfer or permit any of your personal data to be
transferred outside of such jurisdiction unless the transfer is in compliance with applicable laws.

Third party services

3.6. We may share your personal data with our third party service providers or affiliates (e.g. payment service
providers) in order for them to offer services to you other than those related to your use of the Platform or our
Services. Your acceptance and use of the third party service provider’s or our affiliate’s services
shall
be subject to terms and conditions as may be agreed between you and the third party service provider or our
affiliate.
Upon your acceptance of the third party service provider’s or our affiliate’s service offering, the
collection, use, disclosure, storage, transfer and processing of your data (including your personal data and any
data
disclosed by us to such third party service provider or affiliate) shall be subject to the applicable privacy policy
of the third party service provider or our affiliate, which shall be the data controller of such data. You agree
that
any queries or complaints relating to your acceptance or use of the third party service provider’s or our
affiliate’s services shall be directed to the party named in the applicable privacy policy.

4. Withdrawal of Consent to Continued Use, Disclosure, Storing and/or Processing of Personal Data

4.1. You may communicate the withdrawal of your consent to the continued use, disclosure, storing and/or processing
of your personal data by contacting us using the contact details below, subject to the conditions and/or limitations
imposed by applicable laws or regulations. 4.2. Please note that if you communicate your withdrawal of your consent
to
our use, disclosure, storing or processing of your personal data for the purposes and in the manner as stated above
or
exercise your other rights as available under applicable local laws, we may not be in a position to continue to
provide the Services to you or perform any contract we have with you, and we will not be liable in the event that we
do not continue to provide the Services to, or perform our contract with you. Our legal rights and remedies are
expressly reserved in such an event.

Marketing information

4.3. You may unsubscribe from receiving marketing information at any time in our mobile application settings or by
using the unsubscribe function within the electronic marketing material. We may use your contact information to send
newsletters from us and from our related companies.

5. Updating Your Personal Data

5.1. It is important that the personal data you provide to us is accurate and complete for you to continue using
the
Platform and for us to provide the Services. You are responsible for informing us of changes to your personal data,
or
in the event you believe that the personal data we have about you is inaccurate, incomplete, misleading or out of
date. 5.2. You can update your personal data anytime by accessing your account on the Platform. 5.3. We take steps
to
share the updates to your personal data with third parties and our affiliates with whom we have shared your personal
data if your personal data is still necessary for the above-stated purposes.

6. Accessing and Correcting Your Personal Data

6.1. You may request information about your personal data which we have collected, or enquire about the ways in
which
your personal data may have been used, disclosed, stored or processed by us via the personal account information
setting on our Platform or by contacting us using the contact details below. You may also request correction of any
error or omission in your personal data which we have collected in the same way. In order to facilitate processing
of
your request, it may be necessary for us to request further information relating to your request. Where permissible
under law, we may refuse such correction requests if deemed vexatious or unreasonable. 6.2. Where permitted by
applicable data protection laws, we reserve the right to charge a reasonable administrative fee for retrieving your
personal data records. If so, we will inform you of the fee before processing your request.

7. Security of Your Personal Data

7.1. To safeguard your personal data from unauthorised access, collection, use, disclosure, processing, copying,
modification, disposal, loss, misuse, modification or similar risks, we have introduced appropriate administrative,
physical and technical measures such as: (a) Restricting access to personal data to individuals who require access;
(b) Maintaining technology products to prevent unauthorised computer access; (c) Using 128-bit SSL (secure sockets
layer) encryption technology when processing your financial details; and/or (d) implementing other security measures
as required by applicable law. 7.2. You should be aware, however, that no method of transmission over the Internet
or
method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the
security of your information and are constantly reviewing and enhancing our information security measures.

8. Retention of Personal Data

8.1. We will only retain your personal data for as long as we are either required or permitted to by law or as
relevant for the purposes for which it was collected. 8.2. We will cease to retain your personal data, or remove the
means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no
longer serves the purposes for which the personal data was collected, and is no longer necessary for any legal or
business purpose.

9. Minors

9.1. papmall® 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 papmall®. In the event that such personal data of a
minor
is disclosed to papmall®, 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. Collection of Computer Data

10.1. We or our authorised service providers may use cookies, web beacons, and other similar technologies in
connection with your use of the Services or access of the Platform. 10.2. When you visit the Platform through your
computer, mobile device, or any other device with Internet connectivity, our company servers will automatically
record
data that your browser sends whenever you visit a website, such as the technical data and usage data outlined in
Section 2 above. 10.3. This data is collected for analysis and evaluation in order to help us improve our website
and
the services and products we provide, as well as to help us to personalise the content to match your preferred
interests more quickly. The data is also collected to make the Services and the Platform more convenient and useful
to
you, and to provide more relevant advertising related to market products, services and features to you. 10.4.
Cookies
are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when
you visit a website or view a message. They allow us to recognise a particular device or browser. Web beacons are
small graphic images that may be included on our Services and the Platform. They allow us to count users who have
viewed these pages so that we can better understand your preference and interests 10.5. You may be able to manage
and
delete cookies through your browser or device settings. However, certain cookies are required to enable core
functionality (such as adding items to your shopping basket), so please note that changing and deleting cookies may
affect the functionality available on the Platform or through our Services.

11. Third Party Sites

11.1. 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.

12. Questions, Feedback, Concerns, Suggestions or Complaints

12.1 if you have any queries or complaints about this Privacy Policy or how we handle your personal data, please
feel
free to contact us via our online chat service or as follows:

PAPMALL LIMITED.

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