1.
INTRODUCTION
1.1 Welcome
to the GB Mall platform run by gbhub.io. GB Mall takes its
responsibilities under applicable privacy laws and regulations ("Privacy
Laws") seriously and is committed to respecting the privacy rights and
concerns of all Users of our GB Mall website (the "Site")
(we refer to the Site and the services we provide as described in our Site
collectively as the "Services"). We recognize the importance of the
personal data you have entrusted to us and believe that it is our
responsibility to properly manage, protect and process your personal data. This
Privacy Policy (“Privacy Policy” or “Policy”) is designed to assist you in
understanding how we collect, use, disclose and/or process the personal data
you have provided to us and/or we possess about you, whether now or in the
future, as well as to assist you in making an informed decision before
providing us with any of your personal data. Please read this Privacy Policy
carefully. If you have any questions regarding this information or our privacy
practices, please see the section entitled "Questions, Concerns or
Complaints? Contact Us" at the end of this Privacy Policy.
1.2
"Personal Data" or "personal data" means data, whether true
or not, about an individual who can be identified from that data, or from that
data and other information to which an organisation has or is likely to have
access. Common examples of personal data could include name, identification
number and contact information.
1.3 By
using the Services, registering for an account with us, visiting our website,
or accessing the Services, you acknowledge and agree that you accept the
practices, requirements, and/or policies outlined in this Privacy Policy, and
you hereby consent to us collecting, using, disclosing and/or processing your
personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF
YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR
SERVICES OR ACCESS OUR WEBSITE. If we change our Privacy Policy, we will post
those changes or the amended Privacy Policy on our website. We reserve the
right to amend this Privacy Policy at any time.
2. WHEN WILL GB MALL COLLECT PERSONAL DATA?
2.1 We
will/may collect personal data about you:
(a) when you register and/or use our Services or Site, or
open an account with us;
(b) when you submit any form, including, but not limited to,
application forms or other forms relating to any of our products and services,
whether online or by way of a physical form;
(c) when you enter into any agreement or provide other
documentation or information in respect of your interactions with us, or when
you use our products and services;
(d) when you interact with us, such as via telephone calls
(which may be recorded), social media platforms and emails;
(e) when you use our electronic services, or interact with us
via our application or use services on our website. This includes, without
limitation, through cookies which we may deploy when you interact with our
application or website;
(f) when you carry out transactions through our Services;
(g) when you provide us with feedback or complaints;
(h) when you register for a contest; or
(i) when you submit your personal data to us for any reason.
The above
does not purport to be exhaustive and sets out some common instances of when
personal data about you may be collected.
2.2 When
you visit, use or interact with our mobile application or the Site, we may
collect certain information by automated or passive means using a variety of
technologies, which technologies may be downloaded to your device and may set
or modify settings on your device. The information we collect may include,
without limitation, your Internet Protocol (IP) address, computer/mobile device
operating system and browser type, type of mobile device, the characteristics
of the mobile device, the unique device identifier (UDID) or mobile equipment
identifier (MEID) for your mobile device, the address of a referring web site
(if any), and the pages you visit on our website and mobile applications and
the times of visit. We may collect, use disclose and/or process this
information only for the Purposes (defined below).
2.3 Our
mobile applications may collect precise information about the location of your
mobile device using technologies such as GPS, Wi-Fi, etc.. We collect, use,
disclose and/or process this information for one or more Purposes including,
without limitation, location-based services that you request or to deliver
relevant content to you based on your location or to allow you to share your
location to other Users as part of the services under our mobile applications.
For most mobile devices, you are able to withdraw your permission for us to
acquire this information on your location through your device settings. If you
have questions about how to disable your mobile device's location services,
please contact your mobile device service provider or the device manufacturer.
3. WHAT
PERSONAL DATA WILL GB MALL COLLECT?
3.1 The
personal data that GB Mall may collect includes but is not limited
to:
• name;
• email
address;
• date of
birth;
• billing
address;
• bank
account and payment information;
• telephone
number;
• gender;
• any other
information about the User when the User signs up to use our Services or
website, and when the User uses the Services or website, as well as information
related to how the User uses our Services or website; and
• aggregate
data on content the User engages with.
3.2 If you
do not want us to collect the aforementioned information/personal data, you may
opt out at any time by notifying our Data Protection Officer in writing about
it. Further information on opting out can be found in the section below
entitled "How can you opt-out, remove, request access to or modify
information you have provided to us?" . Note, however, that opting out of
us collecting your personal data or withdrawing your consent for us to collect,
use or process your personal data may affect your use of the Services. For
example, opting out of the collection of location information will cause its
location-based features to be disabled.
4. SETTING
UP AN ACCOUNT
In order to
use certain functionalities of the Services, you must became a GBhub member user account, only entitle to register as a seller on GBmall, for further
information kindly refer to GBhub website. which requires you to submit certain personal
data. When you register and create an account, we require you to provide us
with your name and email address as well as a user name that you select. We
also ask for certain information about yourself such as your telephone number,
email address, shipping address, photo identification, bank account details,
age, date of birth, gender and interests. Upon activating an account, you will
select a user name and password. Your user name and password will be used so you
can securely access and maintain your account.
5. VIEWING
WEB PAGES
As with
most websites, your computer sends information which may include personal data
about you that gets logged by a web server when you browse our Site. This
typically includes without limitation your computer's IP address, operating
system, browser name/version, the referring web page, requested page,
date/time, and sometimes a "cookie" (which can be disabled using your
browser preferences) to help the site remember your last visit. If you are
logged in, this information is associated with your personal account. The
information is also included in anonymous statistics to allow us to understand
how visitors use our site.
6. COOKIES
6.1 We may
from time to time implement "cookies" or other features to allow us
or third parties to collect or share information that will help us improve our
Site and the Services we offer, or help us offer new services and features.
“Cookies” are identifiers we transfer to your computer or mobile device that allow
us to recognize your computer or device and tell us how and when the Services
or website are used or visited, by how many people and to track movements
within our website. We may link cookie information to personal data. Cookies
also link to information regarding what items you have selected for purchase
and pages you have viewed. This information is used to keep track of your
shopping cart, for example. Cookies are also used to deliver content specific
to your interest and to monitor website usage.
6.2 You may
refuse the use of cookies by selecting the appropriate settings on your
browser. However, please note that if you do this you may not be able to use
the full functionality of our Site or the Services.
7. VIEWING
AND DOWNLOADING CONTENT AND ADVERTISING
As with
browsing web pages, when you watch content and advertising and access other
software on our Site or through the Services, most of the same information is
sent to us (including, without limitation, IP Address, operating system, etc.);
but, instead of page views, your computer sends us information on the content,
advertisement viewed and/or software installed by the Services and the website
and time.
8.
COMMUNITY & SUPPORT
8.1 We
provide customer service support through email, Whatsapp and feedback
forms. In order to provide customer support, we will ask for your email address
and mobile phone number. We only use information received from customer support
requests, including, without limitation, email addresses, for customer support
services and we do not transfer to or share this information with any third
parties.
8.2 You can
also post questions and answer other User questions in our community forums.
Our forum and messaging services allow you to participate in our community; to
do so, we maintain information, such as your user ID, contact list and status
messages. In addition, these and similar services in the future may require us
to maintain your user ID and password.
9. SURVEYS
From
time-to-time, we may request information from Users via surveys. Participation
in these surveys is completely voluntary and you therefore have a choice
whether or not to disclose your information to us. Information requested may
include, without limitation, contact information (such as your email address),
and demographic information (such as interests or age level). Survey
information will be used for the purposes of monitoring or improving the use
and satisfaction of the Services and will not be transferred to third parties,
other than our contractors who help us to administer or act upon the survey.
10. HOW DO
WE USE THE INFORMATION YOU PROVIDE US?
10.1 We may
collect, use, disclose and/or process your personal data for one or more of the
following purposes:
(a) to consider and/or process your application/transaction
with us or your transactions or communications with third parties via the
Services;
(b) to manage, operate, provide and/or administer your use of
and/or access to our Services and our website, as well as your relationship and
user account with us;
(c) to manage, operate, administer and provide you with as
well as to facilitate the provision of our Services, including, without
limitation, remembering your preferences;
(d) to tailor your experience through the Services by
displaying content according to your interests and preferences, providing a
faster method for you to access your account and submit information to us and
allowing us to contact you, if necessary;
(e) to respond to, process, deal with or complete a
transaction and/or to fulfil your requests for certain products and services
and notify you of service issues and unusual account actions;
(f) to enforce our Terms of Service or any applicable end
user license agreements;
(g) to protect personal safety and the rights, property or
safety of others;
(h) for identification and/or verification;
(i) to maintain and administer any software updates and/or
other updates and support that may be required from time to time to ensure the
smooth running of our Services;
(j) to deal with or facilitate customer service, carry out
your instructions, deal with or respond to any enquiries given by (or purported
to be given by) you or on your behalf;
(k) to contact you or communicate with you via voice call, Whatsapp text message and/or , email and/or otherwise for the purposes of
administering and/or managing your relationship with us or your use of our
Services, such as but not limited to communicating administrative information
to you relating to our Services.
(l) to inform you when another User has sent you a private
message or posted a comment for you on the Site;
(m) to conduct research, analysis and development activities
(including, but not limited to, data analytics, surveys, product and service
development and/or profiling), to analyse how you use our Services, to improve
our Services or products and/or to enhance your customer experience;
(n) to allow for audits and surveys to, among other things,
validate the size and composition of our target audience, and understand their
experience with GB Mall's Services;
(o) where you give us your prior consent, for marketing and
in this regard, to send you by various modes of communication such as postal
mail, email, location-based services or otherwise, marketing and promotional
information and materials relating to products and/or services (including,
without limitation, products and/or services of third parties whom GB
Mall may collaborate or tie up with) that GB Mall (and/or its
affiliates or related corporations) may be selling, marketing or promoting,
whether such products or services exist now or are created in the future. If
you are in Singapore, In the case of the sending of marketing or promotional
information to you by voice call, Whatsapp text to your Singapore facsimile number,
we will not do so unless we have complied with the requirements of Singapore’s
Privacy Laws in relation to use of such latter modes of communication in
sending you marketing information or you have expressly consented to the same;
(p) to respond to legal processes or to comply with or as
required by any applicable law, governmental or regulatory requirements of any
relevant jurisdiction, including, without limitation, meeting the requirements
to make disclosure under the requirements of any law binding on GB
Mall or on its related corporations or affiliates;
(q) to produce statistics and research for internal and
statutory reporting and/or record-keeping requirements;
(r) to carry out due diligence or other screening activities
(including, without limitation, background checks) in accordance with legal or
regulatory obligations or our risk management procedures that may be required
by law or that may have been put in place by us;
(s) to audit our Services or GB Mall's business;
(t) to prevent or investigate any actual or suspected violations
of our Terms of Service, fraud, unlawful activity, omission or misconduct,
whether relating to your use of our Services or any other matter arising from
your relationship with us.
(u) to store, host, back up (whether for disaster recovery or
otherwise) of your personal data, whether within or outside of your
jurisdiction;
(v) to deal with and/or facilitate a business asset
transaction or a potential business asset transaction, where such transaction
involves GB Mall as a participant or involves only a related
corporation or affiliate of GB Mall as a participant or
involves GB Mall and/or any one or more of GB
Mall's related corporations or affiliates as participant(s), and there may
be other third party organisations who are participants in such transaction. A
“business asset transaction” refers to the purchase, sale, lease, merger,
amalgamation or any other acquisition, disposal or financing of an organisation
or a portion of an organisation or of any of the business or assets of an
organisation; and/or
(w) any other purposes which we notify you of at the time of
obtaining your consent.
(collectively, the “Purposes”).
10.2 As the
purposes for which we will/may collect, use, disclose or process your personal
data depend on the circumstances at hand, such purpose may not appear above.
However, we will notify you of such other purpose at the time of obtaining your
consent, unless processing of the applicable data without your consent is
permitted by the Privacy Laws.
11. SHARING
OF INFORMATION FROM THE SERVICES
Our
Services enable Users to share personal information with each other, in almost
all occasions without GB Mall's involvement, to complete
transactions. In a typical transaction, Users may have access to each other’s
name, user ID, email address and other contact and postage information. Our
Terms of Service require that Users in possession of another User’s personal
data (the “Receiving Party”) must (i) comply with all applicable Privacy Laws;
(ii) allow the other User (the “Disclosing Party”) to remove him/herself from
the Receiving Party’s database; and (iii) allow the Disclosing Party to review
what information have been collected about them by the Receiving Party.
12. HOW
DOES GB MALL PROTECT AND RETAIN CUSTOMER INFORMATION?
12.1 We
implement a variety of security measures and strive to ensure the security of
your personal data on our systems. User personal data is contained behind
secured networks and is only accessible by a limited number of employees who
have special access rights to such systems. However, there can inevitably be no
guarantee of absolute security.
12.2 We
will retain personal data in accordance with the Privacy Laws and/or other
applicable laws. That is, we will destroy or anonymize your personal data as
soon as it is reasonable to assume that (i) the purpose for which that personal
data was collected is no longer being served by the retention of such personal
data; and (ii) retention is no longer necessary for any legal or business
purposes. If you cease using the Site, or your permission to use the Site
and/or the Services is terminated or withdrawn, we may continue storing, using
and/or disclosing your personal data in accordance with this Privacy Policy and
our obligations under the Privacy Laws. Subject to applicable law, we may
securely dispose of your personal data without prior notice to you.
13. DOES GB
MALL DISCLOSE THE INFORMATION IT COLLECTS FROM ITS VISITORS TO OUTSIDE PARTIES?
13.1 In
conducting our business, we will/may need to disclose your personal data to our
third party service providers, agents and/or our affiliates or related
corporations, and/or other third parties, whether sited in Singapore or outside
of Singapore, for one or more of the above-stated Purposes. Such third party
service providers, agents and/or affiliates or related corporations and/or
other third parties would be processing your personal data either on our behalf
or otherwise, for one or more of the above-stated Purposes. Such third parties
include, without limitation:
(a) our
subsidiaries, affiliates and related corporations;
(b)
contractors, agents, service providers and other third parties we use to
support our business. These include but are not limited to those which provide
administrative or other services to us such as mailing houses, telecommunication
companies, information technology companies and data centres;
(c) a buyer
or other successor in the event of a merger, divestiture, restructuring,
reorganization, dissolution or other sale or transfer of some or all of GB
Mall's assets, whether as a going concern or as part of bankruptcy,
liquidation or similar proceeding, in which personal data held by GB
Mall about our Service Users is among the assets transferred; or to a
counterparty in a business asset transaction that GB Mall or any of its
affiliates or related corporations is involved in; and
(d) third
parties to whom disclosure by us is for one or more of the Purposes and such
third parties would in turn be collecting and processing your personal data for
one or more of the Purposes
13.2 This
may require, among other things, share statistical and demographic information
about our Users and their use of the Services with suppliers of advertisements
and programming. This would not include anything that could be used to identify
you specifically or to discover individual information about you.
13.3 For
the avoidance of doubt, in the event that Privacy Laws or other applicable laws
permit an organisation such as us to collect, use or disclose your personal
data without your consent, such permission granted by the laws shall continue
to apply.
13.4 Third
parties may unlawfully intercept or access personal data transmitted to or
contained on the site, technologies may malfunction or not work as anticipated,
or someone might access, abuse or misuse information through no fault of ours.
We will nevertheless deploy reasonable security arrangements to protect your
personal data as required by the Privacy Laws; however there can inevitably be
no guarantee of absolute security such as but not limited to when unauthorised
disclosure arises from malicious and sophisticated hacking by malcontents
through no fault of ours.
14.
INFORMATION ON CHILDREN
The
Services are not intended for children under the age of 13. We do not knowingly
collect or maintain any personal data or non-personally-identifiable
information from anyone under the age of 10 nor is any part of our Site or
other Services directed to children under the age of 13. As a parent or legal
guardian, please do not allow such children under your care to submit personal
data to GB Mall. In the event that personal data of a child under the age
of 13 in your care is disclosed to GB Mall, you hereby consent to the
processing of the child's personal data and accept and agree to be bound by this
Policy on behalf of such child. We will close any accounts used
exclusively by such children and will remove and/or delete any personal data we
believe was submitted without any parental consent by any child under the age
of 13.
15.
INFORMATION COLLECTED BY THIRD PARTIES
15.1 Our
Site uses Google Analytics, a web analytics service provided by Google, Inc.
("Google"). Google Analytics uses cookies, which are text files
placed on your computer, to help the website analyse how Users use the Site.
The information generated by the cookie about your use of the website
(including your IP address) will be transmitted to and stored by Google on
servers in the United States. Google will use this information for the purpose
of evaluating your use of the website, compiling reports on website activity
for website operators and providing other services relating to website activity
and Internet usage. Google may also transfer this information to third parties
where required to do so by law, or where such third parties process the information
on Google's behalf. Google will not associate your IP address with any other
data held by Google.
15.2 We,
and third parties, may from time to time make software applications downloads
available for your use on or through the Services. These applications may
separately access, and allow a third party to view, your identifiable
information, such as your name, your user ID, your computer's IP Address or
other information such as any cookies that you may previously have installed or
that were installed for you by a third party software application or website.
Additionally, these applications may ask you to provide additional information
directly to third parties. Third party products or services provided through
these applications are not owned or controlled by GB Mall. You are
encouraged to read the terms and other policies published by such third parties
on their websites or otherwise.
16.
DISCLAIMER REGARDING SECURITY AND THIRD PARTY SITES
16.1 WE DO
NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU
PROVIDE ON THIRD PARTY SITES. We do implement a variety of security measures to
maintain the safety of your personal data that is in our possession or under
our control. Your personal data is contained behind secured networks and is
only accessible by a limited number of persons who have special access rights
to such systems, and are required to keep the personal data confidential. When
you place orders or access your personal data, we offer the use of a secure
server. All personal data or sensitive information you supply is encrypted into
our databases to be only accessed as stated above.
16.2 In an
attempt to provide you with increased value, we may choose various third party
websites to link to, and frame within, the Site. We may also participate in
co-branding and other relationships to offer e-commerce and other services and
features to our visitors. These linked sites have separate and independent
privacy policies as well as security arrangements. Even if the third party is affiliated
with us, we have no control over these linked sites, each of which has separate
privacy and data collection practices independent of us. Data collected by our
co-brand partners or third party web sites (even if offered on or through our
Site) may not be received by us.
16.3 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 Site 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).
17. WILL GB
MALL TRANSFER YOUR INFORMATION OVERSEAS?
Your
personal data and/or information may be transferred to, stored or processed
outside of your country. In most cases, your personal data will be processed in
Singapore, where our servers are located and our central database is
operated. GB Mall will only transfer your information overseas in
accordance with Privacy Laws.
18. HOW CAN
YOU OPT-OUT, REMOVE, REQUEST ACCESS TO OR MODIFY INFORMATION YOU HAVE PROVIDED
TO US?
18.1 Opting Out and Withdrawing Consent
18.1.1 To
modify your email subscriptions, please let us know by sending an email to our
Personal Data Protection Officer at the address listed below. Please note that
due to email production schedules, you may still receive emails that are
already in production.
18.1.2 You
may withdraw your consent for the collection, use and/or disclosure of your
personal data in our possession or under our control by sending an email to our
Personal Data Protection Officer at the email address listed below in Section
19.2 and we will process such requests in accordance with this Privacy Policy
and our obligations under the Privacy Laws and other applicable laws.
18.1.3 Once
we have your clear withdrawal instructions and verified your identity, we will
process your request for withdrawal of consent, and will thereafter not
collect, use and/or disclose your personal data in the manner stated in your
request. If we are unable to verify your identity or understand your
instructions, we will liaise with you to understand your request.
18.1.4
However, your withdrawal of consent could result in certain legal consequences
arising from such withdrawal. In this regard, depending on the extent of your
withdrawal of consent for us to process your personal data, it may mean that we
will not be able to continue providing the Services to you, we may need to
terminate your existing relationship and/or the contract you have with us,
etc., as the case may be, which we will inform you of.
18.2 Requesting Access and/or Correction of Personal Data
18.2.1 If you
have an account with us, you may personally access and/or correct your personal
data currently in our possession or control through the Account Settings page
on the Site. If you do not have an account with us, you may request to access
and/or correct your personal data currently in our possession or control by
submitting a written request to us. We will need enough information from you in
order to ascertain your identity as well as the nature of your request so as to
be able to deal with your request. Hence, please submit your written request by
sending an email to our Personal Data Protection Officer at the email address
listed below in Section 19.2.
18.2.2 For
a request to access personal data, once we have sufficient information from you
to deal with the request, we will seek to provide you with the relevant
personal data within 30 days (or, if you are resident in Malaysia, 21 days).
Where we are unable to respond to you within the said 30 days (or, if you are
resident in Malaysia, 21 days), we will notify you of the soonest possible time
within which we can provide you with the information requested. Note that
Privacy Laws may exempt certain types of personal data from being subject to
your access request.
18.2.3 For
a request to correct personal data, once we have sufficient information from
you to deal with the request, we will:
(a) correct your personal data within 30 days (or, if you are
resident in Malaysia, 21 days). Where we are unable to do so within the said
period, we will notify you of the soonest practicable time within which we can
make the correction. Note that Privacy Laws may exempt certain types of
personal data from being subject to your correction request as well as provides
for situation(s) when correction need not be made by us despite your request;
and
(b) we will send the corrected personal data to every other
organisation to which the personal data was disclosed by us within a year
before the date the correction was made, unless that other organisation does
not need the corrected personal data for any legal or business purpose.
18.2.4
Notwithstanding sub-paragraph (b) immediately above, we may, if you so request,
send the corrected personal data only to specific organisations to which the
personal data was disclosed by us within a year before the date the correction
was made.
18.2.5 We
will/may also be charging you a reasonable fee for the handling and processing
of your requests to access your personal data. If we so choose to charge, we
will provide you with a written estimate of the fee we will be charging. Please
note that we are not required to respond to or deal with your access request
unless you have agreed to pay the fee.
18.2.6 We
reserve the right to refuse to correct your personal data in accordance with
the provisions as set out in Privacy Laws, where they require and/or entitle an
organisation to refuse to correct personal data in stated circumstances.
19.
QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US
19.1 If you
have any questions or concerns about our privacy practices or your dealings
with the Services, please do not hesitate to contact: [email protected]
19.2 If you
have any complaint or grievance regarding how we are handling your personal
data or about how we are complying with Privacy Laws, we welcome you to contact
us with your complaint or grievance.
Please
contact us through email with your complaint or grievance:
E-mail: [email protected] and
Attention it to the "Personal Data Protection Officer".
Please send
all legal notices to suppor[email protected] and
Attention it to the “General Counsel”.
19.3 Where
it is an email or a letter through which you are submitting a complaint, your
indication at the subject header that it is a Privacy Law complaint would
assist us in attending to your complaint speedily by passing it on to the
relevant staff in our organisation to handle. For example, you could insert the
subject header as “Privacy Complaint”.
We will
certainly strive to deal with any complaint or grievance that you may have
fairly and as soon as possible.
20. TERMS
AND CONDITIONS
Please also
read the Terms of Service establishing the use, disclaimers, and limitations of
liability governing the use of the Site and the Services and other related
policies.