This Site protects your privacy by adhering to the European Union General Data Protection Regulation (GDPR). We will not use your personal information or any other data for any purpose that you do not consent to.
“Dashboard” - the internal administrative page that allows suppliers to manage their account;
“Supplier” - each entity or person(s) subscribing to, using or accessing the Site, directly or indirectly, for the purpose of supplying goods;
“Customer” - each entity or person(s) using the Site for the purpose of buying goods;
“Affiliate” - site owner (an individual or business) who promotes products or service in return for payment once an action has been completed;
“Services” - all services Company offers to Suppliers and Customers;
“Third Party” - an individual or entity that is involved in a transaction but is not one of the principals and has a lesser interest;
“Data subject” - a natural person whose personal information we receive, collect and poses;
If you don’t want us to collect or process your personal information in the ways described in this Policy, you shouldn’t use the Services. Terms and Conditions for Buyers and Terms and Conditions for Suppliers of Vawoo.com require all Suppliers and Customers to be at least 18 years old. Those under 18 years old are not permitted to use the Site or the Services. By using the Services, you authorize the Site to use your information.
2. Information Collected or Received
3. Data Subject Rights
4. Choice & Control
6. Messages from Site
8. Information Uses, Sharing & Disclosure
9. Legitimate Interests
11. Processing of Personal Data
12. Data Retention
13. Withdrawing Consent
14. Data Breach Notification
16. Contact Site
The Site automatically receives and records pseudonymous data from your browser, such as your IP address, cookie identifiers, protocol address, your browser type and data about which pages you visit in order to allow us to operate and provide the Services. This information is stored in log files and is collected automatically. We may combine this information from your browser with other information that we collect about you. This information is used to prevent fraud and to keep the Services secure, to analyze and understand how the Services work for members and visitors, and to provide advertising and a more personalized experience for members and visitors.
By using the Site, you agree that we can place these types of cookies on your device.
These cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Session cookies allow you to be recognized within our Site so any page changes or item or data selection you do is remembered from page to page. The most common example of this functionality is the shopping cart feature. When you visit our shopping pages and select some items, the session cookie remembers your selection so your shopping cart will have the items you selected when you proceed to checkout. Without session cookies, the new checkout page would not recognize your past activities on prior pages and your shopping cart would always be empty.
Persistent / Permanent cookies
Persistent cookies help our Site to remember your information and settings on subsequent visits, speeding up or enhancing your experience of services or functions offered. This results in faster and more convenient access since, for instance, you don't have to login again.
First-party cookies are issued from the website you have accessed. These cookies often serve to give memory to the website about your data and preferences.
These cookies are installed by third parties with the aim of collecting certain information to carry out various research into behavior, demographics etc.
All you need to do is to find the file/folder on your computer where the cookie data is stored and to delete it. If you do this by hand, you need to remember the process and to repeat it periodically.
If you want to block cookies, you’ll have to configure your browser to categorically refuse all cookies that try to access your computer or other device.
USES AND SHARING
We use, store, and process information, including personal information received from you or collected by us, in order to provide, improve and develop services needed for correct work of the Site, create and maintain trusted relationships between the Site and the users and comply with your legal rights.
We use the information that we gather from users in a number of ways:
1. To Provide All Necessary Services:
Enable you to create, access and manage your personal supplier, customer or affiliate account;
Enable you to communicate with other users of the Site;
Send you service support messages, instructions, security notifications, updates, newsletters (if you subscribe on them). Please note that you may unsubscribe from our newsletters at any time;
Conduct profiling based on your interactions and customize your experience (such as making listing suggestions based on your orders’ history and preferences), send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences;
Order products (for Customers) and maintain orders (for Suppliers).
2. To Create and Maintain Trusted Environment:
Protect your account from frauds, spam, abusement or other harmful or unpleasant activity and prevent it from happening;
Conduct security investigations and risk assessments;
Deal with and resolve any disputes and other problems that may occur with your account;
Verify or authenticate information provided by you such as but not limited to your age, ID, address validation or other account information;
Comply with your rights and our legal obligations;
We process this information given our legitimate interest in protecting your data and our Site.
3. To provide Payment Service:
The Payment data is processed by the Payment Data Controller in its legitimate interest and in order to provide users with valid Payment Services.
Enable to use Payment Services for any purpose that involves financial transactions. Your data will be revealed to payment service providers;
Detect and prevent frauds, abuses and other financially harmful activity;
Conduct security investigations;
Comply with legal obligations (such as but not limited to anti-money laundering regulations).
Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined if they fail to meet these obligations.
Public information can be seen by anyone, including those who don't have an account.
We may share your personal information with VAWOO team in order to provide you with all relevant products and necessary services.
If you purchase an item, we’ll share your shipping information with the Supplier; we could use your reviews suggestions to improve the Services; we use data analytics and work with certain third-party service providers to ensure site functionality, to improve the Services, and for targeted online advertising and marketing; and of course, we use your email address to communicate with you. We also partner with service providers and other third parties that collect, use, promote, and analyze information about the Site, its members and visitors.
2. INFORMATION COLLECTED OR RECEIVED
INFORMATION YOU GIVE US
We ask for and collect the following information about you, in order to be able to provide you with all the requested services. You may give us information about you and/or your company by filling in forms on our site Vawoo.com, or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site as a Supplier or a Customer.
• By applying for a Supplier account you will provide us with the following information (but this may be not limited to):
1. Account Information: When you sign up for a VAWOO Supplier Account, we require certain information such as your first and last names, e-mail address and password, your company name, company’s description and URL (optional), your business address such as city, country, state/province, Zip/postal code, phone and fax (optional).
2. Profile and Listing Information: To use certain features of the Site, we may ask you to provide your products data which include but may be not limited to your products’ pictures, descriptions, prices, EC-ID numbers, which is mostly public.
3. Identity Verification Information: To help create and maintain a trusted environment, we at our sole discretion may require identity verification information such as your ID or other authentication information.
• By registering as a Customer, the information you give us will include:
1.Account Information: Your first and last names, e-mail and password, country, date of birth.
2. Additional Information: Once you proceeded to checkout, you will have to provide additional information to that requested from you when registering your customer account. The information includes but is not limited to your shipping and billing address;
3. Identity Verification Information: In special cases we may request your ID card, driving license or any other authentication information in order to verify your identity;
4. Payment Information: To use our payment services we may require you to provide certain financial information such as your valid bank card data.
• By registering as an Affiliate you will provide us with the following information:
1.Account Information: Your first and last names, e-mail and password, date of birth.
2. Profile information: To use certain features as a Vawoo Affiliate, we require you to provide the data of your Affiliate area such as the website URL(s) where Vawoo platform will be promoted, the number of visits to your website and the frequency of such visits.
3. Identity Verification Information: In special cases we may request your ID card, driving license or any other authentication information in order to verify your identity.
4. Payment Information: To use our payment services we may require you to provide certain financial information such as your valid credit/debit card data. Please note that we may at your sole discretion not save your credit/debit card data in our system.
• You do not provide us with personal information (except of obligatory age verification), if you just visit our platform, with no registering and sign in procedures.
Please note that the Site does not collect any sensitive data, including but not limited to: religion, ethnic origin, political views, sex orientation, etc.
For Services that require registration, you should provide a name associated with your account that you can choose and that represents your identity on the Site. You may review and change that name through your account settings. Depending on which services you choose to use, additional information, such as billing and payment information, a telephone number, and/or a physical postal address, may be necessary for us in order to provide a particular service. For example, we need a physical postal address, if you order from the Site for delivery. As a Supplier, if you choose to use our payment service, such as advertising, the Site may require information such as your date of birth, bank account information, credit/debit card information, and/or other proof of identification in order to verify your identity and provide this service to you and to comply with applicable law. We may need to store credit card information (or arrange for it to be stored) and use it for both billing and payment purposes. In order to use certain products or services on the Site, you may be required to complete an application; information that you submit through the application processes will not be displayed publicly and will only be used internally by the Site, unless otherwise specified.
The name associated with your account, which you may review and change in your account settings, is publicly displayed and connected to our Site activity. Other people may see the reviews, ratings, profile information, and comments in community spaces.
INFORMATION YOU CHOOSE TO GIVE US
You may choose to provide us with additional information in order to obtain various features.
You may choose to publish your location when you supply the Site. Connecting your account to third-party applications or services is optional. If you choose to connect your account to a third-party application, the Site may receive information from that application. We may use that information as part of providing the Services to you. You can also choose to share some of your activity on the Site with certain social media networks which are connected to your Site account, and you can revoke your permission anytime in your account settings.
INFORMATION WE AUTOMATICALLY COLLECT FROM YOU
Technical and Geo-location information. When you enter the Site, we automatically collect the information concerning your location as determined as your IP address or mobile device’s GPS, browser type and version, operating system. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu.
Usage information. We collect the information from your Shopping Cart and Wishlist content, your orders history, interactions with the Site such as the pages or content you view or search, your account information updates: your active and non-active products, categories, shipping history, your participation in community discussions, chats, or dispute resolutions and other actions.
Cookies. Cookies are small pieces of data sent from a website and stored on your computer by your web browser (if you allow) that enables the sites or service provider systems to recognize your browser and capture and remember certain information.
The Site may receive or obtain information (for example, an email address or IP address) about a person who is not yet a registered Site member (a “non-member”) in connection with certain Site features, such as when a non-member chooses to subscribe to a Site newsletter, a member invites a non-member to visit the Site, or a member sends a gift card code to a non-member. Non-member information is used only for the purposes disclosed when it was submitted to Site or to facilitate action authorized by the non-member. A non-member can contact Site Support if they do not want the Site to retain their information.
You may access or update the personal information you provided to us at any time.
3. DATA SUBJECT RIGHTS
To use services available for the account type the data subject follows:
The right to be informed
The right to rectification
You have right at your sole discretion to manage, change, or correct your personal data if you see it is inaccurate or untruthful. You can do so via your personal account settings or by contacting us. In the last case, we will erase or fix inaccurate or incomplete data.
The right to be forgotten
When data is no longer relevant to its original purpose, you have withdrawn consent, the personal data have been unlawfully processed, or there is another reason you no longer want your personal information to be processed, you have the right to request that your data be erased and all dissemination ceased. Your request will be honored without undue delay and at latest within one month of receiving it.
You can delete your personal and non personal data at any time, as well as disable and remove your personal account form the Site by clicking ‘Delete Account’ button in your account settings. In such cases, we will delete your personal information.
We use redundant systems for storing your personal information. Removing your personal data requires taking several careful steps.
So when you remove information from your account, we follow a strict process to delete it. To begin, we remove the information form where it was being used, so it’s no longer available for public. We then immediately begin the process of removing the information from the active systems where it’s being stored. During the time it takes to delete information, our systems stop serving it. As part of our redundant system, your information may also be in our backup storage, which is difficult for us to access, but available for use to help our services recover in case of a disaster. You deleted data may remain in our backup system for up to 6 months. Sometimes or in special cases, instead of removing your data after you delete your account, we may anonymize your data so it’s not associated with you. We also may use technical measures like encryption, to make sure the data is unreadable and inaccessible. If your account was deleted by mistake, please contact us and we will try to recover it and get it back.
Right to object processing
Upon request, the Site will provide you with information about whether we hold any of your personal information. In certain circumstances, you also have the right to object to certain processing activities in relation to your personal data carried out by the Site. As a data subject you can object to the processing of your data whenever the processing is based on our legitimate interest, or for purposes of scientific/historical research and statistics. You have to state a motivation for the data objection, unless the processing is carried out for direct marketing purposes, in which case no motivation is needed to exercise this right. If an objection to the processing of personal data is received and there is no grounds to refuse, the processing activity will stop. While the processing activity (including storage) is stopped, erasure may not be appropriate if the data is processed for other purposes (including the fulfillment of legal or contractual obligation) as the data will need to be retained for those purposes. Requests will be honored without undue delay and at latest, within one month of receiving the request. If you have a groundless request to object some your personal information, we will satisfy your request without charging a fee. The decision will need to be legitimately justified. If we refuse this request, we will inform you without unnecessary delay and within one month of receiving the request.
The right to restrict processing
You have the right to restrict the processing of your personal data in cases where you’ve contested its accuracy; if you have objected to the processing; if you consider the processing unlawful and you request restriction instead of erasure; or other reasons.
The right to data portability
You have the right to export your personal data in a structured, machine readable and commonly used XML format at any time, and obtain a copy of your data free of charge. This right only applies to personal data and as such does not apply to genuinely anonymous data (data that can’t be linked back to the individual). Your Request will be honored without undue delay and at latest, within one month of receiving it.
4. CHOICE & CONTROL
We know that members of our community value having control over their own information, so the Site gives you the choice of providing, editing or removing certain information, as well as choices about how we contact you. You may change or correct your personal account information through your account settings. You may also remove certain optional information that you no longer wish to be publicly visible through the Services.
The Site may send you messages about the Services or your activity. Some of these messages are required, service-related messages for members (such as transactional messages or legal notices). Other messages are not required, such as newsletters.
If you have chosen to connect your account to an external third-party application, such as Facebook, you can change your settings and remove permission by changing your account settings. If you no longer wish to use the Services or receive service-related messages, then you may close your account. In order to close the account, you may contact support service of the Site and specify whether you would like for your information to be deleted. All data subjects have the right to withdraw their content at any time.
If you do not want your contacts to be able to find you on Site through your email address, phone number, or social networking connections, then you may opt out through your account settings. If you do not wish to be located on Site via your full name, you can remove your full name and instead may use a nickname or alias as your name in your public account information. If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please go to the contact us page.
6. MESSAGES FROM THE SITE
On occasion, the Site may need to contact you. These messages are delivered by email or by Dashboard, and every account is required to keep a valid email address on file to receive messages. The Site may need to contact you by telephone to provide member support or for transaction-related purposes if you give us permission to call you. Additionally, and with your consent, the Site may send you SMS (or similar) messages or physical mails in order to provide you with customer support or with information about products and features that you may find of interest. You may update your contact preferences in your account settings.
Some messages from the Site are service-related and necessary for members and visitors. You agree that the Site can send you non-marketing emails or messages, such as those related to transactions, your account, security, or product changes. Examples of service-related messages include an email address confirmation/welcome email when you register your account, notification of an order, service availability, modification of key features or functions, and correspondence with Site’s support team.
When you register for an account you agree to receive marketing emails and messages from us. You can unsubscribe at any time from marketing emails through the opt-out link included in marketing emails or messages. The data subjects may also control some marketing emails or messages through their account settings as well as through the opt-out link included in marketing emails or messages.
The Site is both a platform and community. We offer several features that allow members to connect and communicate in public spaces, such as reviews. You don't have to use these features, but if you do, please use common sense and good judgment when posting in these community spaces or sharing your personal information with others through the Services. Be aware that any personal information that you choose to submit there can be read, collected, or used by others, or could be used to send unsolicited messages to you.You are responsible for the personal information that you choose to post in community spaces through the Services.
8. INFORMATION USES, SHARING AND DISCLOSURE
We respect your privacy. The Site will not disclose your name, email address or other non-public information to third parties without your consent, except as specified in this policy. We rely on three separate and overlapping bases to process your personal information lawfully. First, it’s necessary for us to process your personal information in certain ways in order to provide the Services to you, in accordance with an agreement between you and us, namely, our Terms and Conditions (for example, providing a Supplier your shipping address so that they can send you the item you purchased on Vawoo). Second, where you have given us valid consent to use your data in certain ways, we will rely on your consent. Third, as described in more detail below in the section titled “Legitimate Interests”, in certain cases we may process your information where necessary to further Site's legitimate interests, where those legitimate interests are not overridden by your rights or interests.
We use your information to provide and improve the Services and our products, for billing and payments, for identification and authentication, for targeted online marketing, to contact members or interested parties, and for general research and aggregate reporting. For example, in accordance with our existing case resolution process, we may use information you provide to resolve disputes with the Site or other members. We may learn the sorts of products that you’re interested in from your browsing and purchasing behavior on the Site and suggest potential purchases as a result. Similarly, we or our suppliers may advertise our Services or our suppliers’ products through a variety of different mediums.
The Site may release your personal information to a third party in the following limited circumstances: in response to lawful requests by public authorities, including to meet legitimate national security or law enforcement requirements; to protect, establish, or exercise our legal rights or defend against legal claims, including to collect a debt; to comply with a subpoena, court order, legal process, or other legal requirement; or when we believe in good faith that such disclosure is necessary to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to our property, or violations of Site's Terms and Conditions.
If the Site receives a lawful, verified request for a member’s records or information in one of the limited circumstances described in the previous paragraph, the Site may disclose personal information, which may include, but may not be limited to, a member’s name, address, phone number, email address, and company name. Find out more about how Site responds to requests for records or information about members of Site’s community in our Requests for Information Policy.
The Site is affiliated with a variety of businesses and works closely with them for a variety of purposes, including assisting us to perform and improve the Services. With your consent, these businesses may offer promotions (including email promotions).
The Site also needs to engage third-party companies and individuals (such as payment processors, research companies, and analytics and security providers) to help us operate and provide the Services. These third parties have only limited access to your information, may use your information only to perform these tasks on our behalf, and are obligated to the Site not to disclose or use your information for other purposes.
We use non-technically necessary cookies and similar technologies only with your consent. If you prefer to prevent third parties from setting and accessing cookies on your computer, you may set your browser to block cookies. We can speak only for ourselves; this policy does not apply to the practices of third parties that the Site does not own or control or individuals that the Site does not employ or manage. If you provide your information to others, different practices may apply to the use or disclosure of the information that you provide to them. The Site does not control the privacy policies of third parties, including other websites. The Site is not responsible for the privacy or security practices of the Site members or other websites on the Internet, even those linked to or from the Services. We encourage you to ask questions before you disclose your personal information to others.
9. LEGITIMATE INTERESTS
The Site relies on several legitimate interests in using and sharing your personal information. These interests include:
-improving and customizing the Services for our community;
-understanding how the Services are being used;
-exploring and unlocking ways to develop and grow our business;
-obtaining insights into usage patterns of the Services;
-ensuring the safety and security of the Services; and
-enhancing our members’ protection against spam, harassment, IP infringement, crime, and security risks of all kind.
We use different technologies to process your information and to help improve the safety and reliability of the Site. This includes detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm the Site, our users, or the public.
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and after it is received. Your account information is protected by a password. It is important that you protect against unauthorized access to your account and information by choosing your password carefully and by keeping your password and computer secure, such as by signing out after using the Services. If you have any questions about the security of your personal information, you can apply to us through the contact us page.
The Site encrypts certain information (such as credit card numbers) using secure socket layer technology (SSL). The Site follows generally accepted industry standards to protect the personal information submitted to us, both during transmission and after it is received. Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.
11. PROCESSING OF PERSONAL DATA
When processing your personal data we warrant that the information will be:
processed lawfully, fairly and in a transparent manner;
collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
adequate, relevant and limited to the amount necessary to provide you with our services;
accurate and, where necessary, kept up to date;
stored for longer periods solely for archiving purposes in the public interest, research or statistical purposes;
processed in a manner that ensures appropriate security of your personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures
12. DATA RETENTION POLICY
In some cases, we retain data for limited periods when it needs to be kept for legitimate business or legal purposes. Sometimes business and legal requirements oblige us to retain certain information, for specific purposes, such as but not limited to: security, fraud and abuse prevention, financial record keeping, complying with legal or regulatory requirements, ensuring the continuity of our services for an extended period of time. The Site will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active (i.e., for the lifetime of your Site member account), or as needed to provide the Services to you.
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want the Site to use your information and to provide the Services to you, you may close your account by clicking ‘Delete account’ button. When you delete data in your personal account, we immediately start the process of removing it from the Site. First, we aim to immediately remove it from view and the data may no longer be used to personalize your experience here. The Site will privately retain some information about you to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, and enforce our agreements. In addition, suppliers may also be required to retain and use your information in order to comply with their legal obligations. We also retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for the Site’s safety and security, to improve the functionality of the Site, or we are legally obligated to retain them for longer time periods.
13. WITHDRAWING CONSENT
We ask for your agreement to process your information for specific purposes. You have choices regarding the information we collect and how we use it. You have the right to withdraw your consent to our processing of your information and your use of the Services. You can do this at any time by contact us page.
If you withdraw your consent to the use or sharing of your personal information for the purposes set out in this Policy, you may not have access to all (or any) of the Services, and we might not be able to provide you all (or any) of the Services.
You reserve the right to review, update and/or remove your profile information at any time as well as your whole account. If you decide to delete your personal Supplier, Customer or Affiliate account, we warrant that all the data concerning your personal and non personal information will be removed from the Site.
Please note that, in certain cases, we may continue to process your information after you have withdrawn consent and requested that we delete your information, if we have a legal basis to do so. For example, we may retain certain information if we need to do so to comply with an independent legal obligation, or if it is necessary to do so to pursue our legitimate interest in keeping the Services safe and secure.
14. DATA BREACH NOTIFICATION
In case of a personal data breach, the Site will without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the supervisory authority about the data breach to unless the personal data breach is unlikely to result in a risk to the rights and freedoms of data subject. If the personal data breach is likely to result in a high risk to the rights and freedoms of any natural person registered on the Site, we will inform the data subject about the personal data breach without undue delay.
16. CONTACT US
If you have questions or suggestions about personal information you can contact Site Support team via contact us page.
Date of Last Revision: June 21, 2020