(Effective as of March 01, 2020

Table of Contents

1. COLLECTION OF INFORMATION.

• Information That You Provide to Us
• Information That We Collect Automatically
• Information That We Receive from Third Parties

1. USE OF PERSONAL DATA.
2. DISCLOSURE OF PERSONAL DATA.
3. RETENTION
4. RIGHTS REGARDING PERSONAL DATA.
5. COOKIES.
6. MINORS.
7. SECURITY MEASURES
8. CHANGES TO THIS PRIVACY POLICY
9. VISITORS FROM THE EUROPEAN UNION

• Legal Basis for Data Processing.
• International Transfers of personal information.
• Your Rights.

1. Language
2. HOW TO CONTACT US.

We at Ashob (“we”, or “us”) recognize the importance of privacy and confidentiality of personal information.

Ashob.com (“Ashob” or, the “Platform“) is a business to consumer (or “B2C“) platform which connects and facilitates sales and purchases between business sellers, (or “Sellers“, Influencers”) and consumer buyers (or “Buyers“).

This Privacy Policy sets out the ways in which we collect, use and disclose information in connection with the operation of the Platform, including personal information about you, Platform users, visitors and representatives. This Privacy Policy also applies to use of the Platform via your mobile device.

By using our Service you understand and agree that we are providing a Marketplace platform for you to post content, including photos, products images, vidoes ,comments and other materials (“User Content”), to the Service and to share User Content publicly. This means that other Users may search for, see, use, or share any of your User Content that you make publicly available through the Service, consistent with the terms and conditions of this Privacy Policy and our Terms of Use

Our Policy applies to all visitors, users, and others who access the Service (“Users”).

1. COLLECTION OF INFORMATION

The personal information that we collect broadly falls into the following categories:

Information That You Provide To Us:

If you are a Buyer, we will ask you to provide:

• contact information including: name; address; phone number; email address;
• purchase and/or payment information including: credit card or similar payment information that you intend to purchase with; billing and delivery address;
• information about your purchases including: the goods purchased and how many;
• information about and/or to support complaints made in connection with the Platform or goods and/or services purchased via the Platform;
• ID (such as a passport) for identification verification in certain circumstances
• If you are a Seller (i.e. an employee or representative of a Seller or a sole trader Seller (we’ll refer to you as a Seller)), we will ask you to provide:

• information about the Seller’s business (if applicable) including corporate registration, business licences (if applicable), tax or similar information;
• details about the goods and products that the Seller intends to sell via the Platform;
• purchase and/or payment information including bank account or other payment information that the Seller intends to be paid by.

If you attend one of our industry events or other functions, contact details such as user name, address, phone number, fax number and email address.

If you are a certified blogger / influencer for Ashob, we may also ask you to provide us with your contact information and social media accounts / blog information.

If you choose to provide us with any additional information, such as in response to questionnaires for market research / analytics. This may include marital status, nationality, gender, date and/or year of birth, annual income, monthly spending and user preferences. If you prefer not to provide such information, the use of our services and products will not be affected.

Finding your friends on Ashob:

• If you choose, you can use our “Find friends” feature to locate other people outside ASHOB either through (i) your contacts list, (ii) third-party social media sites or (iii) through your email service provider, (iv) or through a search of names and usernames on Ashob.
• If you choose to find your friends through (i) your device’s contacts list, then Ashob will access your contacts list to determine whether or not someone associated with your contact is using Ashob
• If you choose to find your friends through a (ii) third-party social media site, then you will be prompted to set up a link to the third-party service and you understand that any information that such service may provide to us will be governed by this Privacy Policy.
• If you choose to find your friends (iii) through a search of names or usernames on Ashob then simply type a name to search and we will perform a search on our Service.
• Note about “Invite Friends” feature:If you choose to invite someone to the Service through our “Invite friends” feature, you may select a person directly from your contacts list and send a text or email from your personal account. You understand and agree that you are responsible for any charges that apply to communications sent from your device, and because this invitation is coming directly from your personal account, Ashob does not have access to or control this communication.

Information That We Collect Automatically:

If you are a Buyer or Seller or prospective Buyer or Seller we will automatically collect:

• A copy of any correspondence with us, including any verification information we ask for, if you contact us for any reason (such as our customer service department chat service, telephone or email).
• Details of transactions and communications over the Platform, including the types and specifications of the goods sold and purchased, pricing and delivery information, any dispute records, communications between Buyers and Sellers over the Platform and any information disclosed in any discussion forum.
• Details of Platform buying and browsing activities, for these purposes we will automatically collect information from your device. In some countries, including countries in the European Economic Area and the UK, this information may be considered as personal information under applicable data protection laws. Specifically this collected information may include IP addresses, device type, unique device identification numbers, browser type, broad geographic location (e.g. country or city-level location), browsing patterns and details of how you have interacted with our Platform and the goods and services available on it. In addition, we gather information about the Platform and visitors to the Platform including browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors. Some of this information may be collected using cookies and similar tracking technology, as explained further under the section E “COOKIES” below. Where we are required by applicable law, we will seek your prior consent to the collection of information using cookies and similar tracking technologies.

If you are successfully certified by Ashob as a blogger or an influencer, we may also collect your social media account handles and posts / comments made in relation to the Platform..

Information That We Receive From Third Parties:

If you are a Buyer or Seller we may receive personal information about you from:

• Social media platforms if you choose to register for a Platform account via a social media account. Exactly what information we receive will depend on your privacy settings with the applicable platform, but would typically include basic public profile information such as:
  • Your social media user name, nickname or username
  • Your social media profile picture
  • Country
  • Company name (if applicable).
• Third parties that are engaged by us to provide verification services such as conducting suitable money laundering, fraud and “Know Your Customer” checks on Buyers and Sellers. This may include your name, email address, company details and contact information.

1. USE OF PERSONAL DATA

We collect and use your personal information for the following purposes:

• verifying Platform account registrations including conducting fraud, security, “Know Your Customer” and anti-money laundering checks in order to approve your Seller account;
• verifying your eligibility as a Platform blogger or influencer;
• setting up / administering Buyer and Seller accounts, including providing log-in IDs and setting up payment / transaction accounts;
• providing customer service support, responding to your queries, feedback and managing claims and/or disputes;
• providing/supporting general Platform services, facilitating communication between Buyers and Sellers, processing transactions and payments, assessing advance withdrawal requests from Sellers and providing logistics and delivery services;
• supporting Buyer and/or Seller clearance declarations / applications where made via the Platform;
• providing relevant membership benefits including birthday rewards, membership offers and coupons, anniversary awards, exclusive member prices;
• verifying your identity and purchases in connection with product warranty or other after-sales claims;
• assessing and monitoring account security and transaction risks of Buyers and Sellers, detecting and preventing fraud, money laundering and other security incidents;
• sending and serving tailored marketing and advertising that we believe will be of interest to you based on the ways in which you use the Platform, your browsing records, and order history;
• conducting research and analytics to ensure the security of our Platform, to improve the content and layout of the Platform, and to improve our product offerings and services;
• Cookies or other similar technologies may be used to provide you with advertising based upon your browsing activities and interests
• We may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you if and where this is permitted by applicable data protection laws.

1. DISCLOSURE OR SHARING OF PERSONAL DATA

We disclose/share personal information with the following categories of recipients:

• Other Platform Buyers and/or Sellers where necessary to support purchases and communications made between you. If you are a Buyer, Sellers that you purchase from will also control, personal information about you relevant to connected with your Platform purchases and communications with them. Please refer to Seller Privacy Policies for information about how they will process your information.
• Third party partners and service providers and/or affiliates engaged by or working with us to assist us to provide services to you or who otherwise process personal information for purposes described in this Privacy Policy or notified to you when we collect your personal information. Categories of these partners and service providers include:
  • Ashob group entities and affiliated companies and/or their designated service providers that work with us to provide processing services such as software, tools, systems and messaging services for purposes described in this Privacy Policy;
  • our business partners (for example, in order for them to provide you with discounts or offers that may interest Buyers or prospective Buyers) where you have consented to receiving such information from them if required by applicable data protection laws;
  • marketing and advertising partners, such as Google, Twitter, Facebook, Instagram, and VKontakte, and providers of analytics services relating to users’ behaviour, in order to tailor the content you see when visiting our Platform where you have consented to the collection of your information using Cookies for analytics and/or advertising purposes. These partners may combine information they collect on our Platform with data on their platforms and data they collect from other websites or through other sources in order to conduct targeted advertising. The processing activities of these third party marketing platforms are governed by their own privacy policies, not this Privacy Policy (please refer to section E “COOKIES” below);
  • payment service providers that provide payment processing services. The activities of payment service providers may be governed by their own privacy policies, not this Privacy Policy;
  • credit risk assessment providers to conduct risk assessment on Sellers to determine whether a Seller can be permitted to make an advance withdrawal;
  • logistics partners for providing delivery services for Buyers and Sellers, including return and exchange of products, and warehousing services for Sellers;
  • customs agents for customs clearances purposes where applicable to support Buyers and Sellers with international sales/purchases;
  • cloud computing or other hosting service providers to provide cloud storage services;
  • warranty service providers to provide product warranty services where requested by a Buyer or Seller;
  • customer service support providers to provide after-sale services or other customer service support;
  • risk control service providers to assess the security of Buyer and Seller accounts and transaction risks; and
  • third party rating / reviewing service providers to carry out reviews of our services with customers if you choose to participate in reviewing or rating Platform products and/or services;
• To our professional advisers, law enforcement agencies, insurers, government and regulatory and other organisations where we believe it is necessary to comply with applicable laws or to exercise, establish or defend our legal rights or protect your vital interests or those of any other person; or as otherwise required or permitted by applicable laws.
• To an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy.
• To any other person with your consent to the disclosure.

We have established relationships with other parties and websites to offer you the benefit of products and services which we do not offer. We offer you access to these other parties and their websites either through the use of hyperlinks to these sites from our Platform or through offering “co-branded” sites in which both we and other parties share the same uniform resource locator (URL), domain name or pages within a domain name on the Internet. In some cases you may be required to submit personal information to register or apply for products or services provided by such third parties or co-branded partners. This Privacy Policy does not apply to these third party sites or co-branded sites. The privacy policies of those other parties may differ from ours, and we have no control over the information that you submit to those third parties. You should read the relevant privacy policy for those third party sites and co-branded sites before responding to any offers, products or services advertised by those parties

1. RETENTION

We will retain your personal information for as long as we have an ongoing legitimate business need to do so, to provide services or products to you, as required or permitted by applicable laws. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. How long your data is kept for will also depend on how you use our website (for example if you are logged in as a member or you are visiting our website as a guest) and what the information you provide to us is used for. For example, if you are a registered member, certain data will be retained for a length of time following termination or deletion of your account, in order to comply with applicable laws or in case of disputes. In other instances, the period of retention may be determined according to your activity on the Platform or to comply with a specific arbitration period/resolve a dispute.

1. RIGHTS REGARDING PERSONAL DATA

Under applicable laws, you may have rights of access to personal information held by us and other rights. If you are a Visitor from the European Union, please refer to section J. VISITORS FROM THE EUROPEAN UNION below for more information.

If you have any questions regarding this Privacy Policy or if you wish to access or correct your personal information as a user of Ashob.com, please send us an email  at support@Ashob.com

1. COOKIES

This section explains how we use cookies and similar technologies (we refer to them collectively as “cookies“) to recognize you when you visit our Platform. It explains what these technologies are and why we use them, as well as your rights to control them.

What are cookies?

A cookie is a string of information that is sent to your browser and stored on your computer’s or mobile device’s hard drive. If you do not de-activate or erase the cookie, each time you use the same browser or device to access the Platform, our web servers will be notified of your visit to the Platform and in turn we may have knowledge of your visit and the pattern of your usage.

Cookies set by the site or app owner (in this case, Ashob) are called “first party cookies“. Cookies set by third parties other than the website owner are called “third party cookies“. Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognize your device both when it visits the website in question and also when it visits certain other websites.

Cookies are also categorized as “session cookies” (which are erased once you close the browser or shut down the device) and “persistent cookies” (which remain even after closing the browser or shutting down the device/application and which are activated each time you visit the Platform). Session cookies use encrypted data to authenticate you. Persistent cookies do not store account numbers or passwords. We use both session cookies and persistent cookies.

Why we use cookies?

We use first and third party cookies for several reasons.

Some cookies are required for technical and/or security reasons in order for our Platform to operate, and we refer to these as “essential” or “strictly necessary” cookies. First party cookies are mainly served to enable basic functionality on our Platform; including web analytics cookies that help us understand how users use our web pages and how we can improve their use. For example we use essential or strictly necessary cookies to enable us to remember goods added to your Ashob.com shopping basket and to recognize you when you sign into your Ashob.com account.

We also use social media cookies. You may register for Platform membership and “share” Platform content through social media such as Facebook and Twitter. Sometimes we embed videos from websites like YouTube. These websites have their own privacy policies which govern their use of information, which you can find on the respective websites.

We also use cookies to enable us to track and target the interests of Platform visitors to enhance the experience on our Platform by researching visiting patterns and conduct interest-based advertising; assisting our partners to track user visits to the Platforms; and to track progress and participation in promotions and the success of our email marketing campaigns. We use first and third party cookies for these purposes.

How can I control cookies?

You can determine if and how a cookie will be accepted by configuring the privacy setting of the browser you are using to access the Platform or the “privacy setting” of your device. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information. If you adjust the privacy setting in the browser, your mobile device will continue collecting data unless you adjust the privacy setting of the device, and vice versa.

You have the right to decide whether to accept or reject cookies. If you choose to set your web browser controls to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted.

In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.

Certain features of the Platform depend on cookies. Please be aware that if you choose to block cookies, you may not be able to sign in or use those features, and preferences that are dependent on cookies may be lost.

Google Analytics (More information) Our Platform uses Google Analytics, an internet analytics service provided by Google, Inc. (“Google”). Google’s cookies allow us analyze use of the Platform by telling us which pages our users are viewing, which ones are most popular, what time of day our Platform are visited, if users have previously visited our Platform, from which website users are redirected to our Platform were and the like. The data generated by the cookie about your use of the Platform will be transmitted to Google and stored by Google on servers in the United States.

The Platform uses an anonymization tool of IP addresses so that the IP addresses are truncated within the territory of the Member States of the European Union and the other members of the agreement on the European Economic Area. The non-truncated IP address are only exceptionally transmitted to Google’s servers in the US and then truncated there.

Google uses the data on behalf of Ashob.com to evaluate your use of the Platform, to compile reports on website activity for the website operators and for other website activity and internet usage services. Google may disclose this information to third parties under the terms of the law or for further processing by third parties on behalf of Google. For more information about Google Analytics cookies, visit:

• the Google Help pages and Privacy Policy: Google Privacy Policy: https://policies.google.com/privacy; and
• the Google Analytics Help Centre: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.

The IP address that your browser will pass on to Google Analytics will not be associated with any other data stored by Google. Through your browser settings, you can block cookies; however, this can lead to problems with the use of some functionalities of the website. Through the add-on “Google Analytics Opt-out” you can through your current web browser opt-out to the use of Google Analytics from then on: http://tools.google.com/dlpage/gaoptout?hl=en.

More information can be found here: https://support.google.com/analytics/answer/6004245.

1. MINORS

The Platform is intended for adults and users must be over 18 to use our Platform and we do not intend to sell any of our products or services to minors. If a minor has provided us with personal information without parental or guardian consent, the parent or guardian should contact support@Ashob.com to remove the information.

1. SECURITY MEASURES

We implement appropriate technical and organizational measures to prevent unauthorized access to the Site, to maintain data accuracy and to ensure the correct use of the information we hold. Upon becoming aware of a data breach, we will notify you and the regulatory authorities in accordance with the timescales and scope required by applicable data protection law.

For registered users of the Site, some of your information can be viewed and edited through your account, which is protected by a password. We recommend that you do not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited email. If you share a computer with others, you should not choose to save your log-in information (e.g., user ID and password) on that shared computer. Remember to sign out of your account and close your browser window when you have finished your session.

No data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we use appropriate technical and organizational measures to protect the information we hold for you, we cannot guarantee the security of any information you transmit to over the internet.

1. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent
with the significance of the changes we make, such as by posting an amended Privacy Policy on the Platform.

1. VISITORS FROM THE EUROPEAN UNION

This section applies if you are based in the European Economic Area (which for the purposes of this Privacy Policy shall include the UK in the event of the UK’s departure from the European Union) (“EEA“).

Your personal data will be stored in United States. For contact details, please see section L. HOW TO CONTACT US below. Please also note, if you are a Buyer or Influencer, Seller will also act as a data controller of personal information about and your Platform purchases and communications with them. Please refer to the Privacy Policies of those Sellers for more information about the ways in which they will process such information.

Legal Basis for Data Processing

We process personal information for the purposes set out in this Privacy Policy. Our legal basis to process for processing your personal information will depend on the personal information concerned and the specific context in which we collect it but will include where it is:

• necessary for the performance of contract between you and Ashob LLC (for example, to provide you with the services you request and to identify and authenticate you so you may use the Platform);
• necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement);
• necessary for our legitimate interests and not overridden by your rights; and/or where it is based on your consent.

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Platform and services, manage our relationship with you and communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our Platform and our services, undertaking marketing, or for the purposes of ensuring the security of our Platform and services and detecting or preventing illegal activities such as fraud. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If we ask you to provide personal information to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). In some instances, you may be required to provide us with personal information for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Platform.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under section L. HOW TO CONTACT US below.

HOW WE STORE YOUR INFORMATION

Storage and Processing:

• Your information collected through the Service may be stored and processed in the United States or any other country in which ASHOB its Affiliates or Service Providers maintain facilities.
• ASHOB, its Affiliates, or Service Providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.
• By registering for and using the Service you consent to the transfer of information to the U.S. or to any other country in which ASHOB, its Affiliates or Service Providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.
• We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, ASHOB cannot ensure the security of any information you transmit to ASHOB or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.
• Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and ASHOB, at all times. Your privacy settings may also be affected by changes the social media services you connect to ASHOB make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization.

International Transfers of personal information

If we sell or otherwise transfer part or the whole of ASHOB or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information such as name and email address, User Content and any other information collected through the Service may be among the items sold or transferred. You will continue to own your User Content. The buyer or transferee will have to honor the commitments we have made in this Privacy Policy. We take appropriate steps to ensure that recipients of your personal information are bound to duties of confidentiality and we implement appropriate measures to ensure your personal information will remain protected in accordance with this Privacy Policy, such as standard contractual clauses. A copy of those clauses can be obtained by contact us using the contact details provided under section L. HOW TO CONTACT US below .

Your Rights

If you are a resident of the EEA, you have the following data protection rights, which you can exercise at any time by contacting us using the contact details provided under section L. HOW TO CONTACT US below:

• The right to access, correct, update or request deletion of your personal information.
• The right to object to processing of your personal information when it is based on our legitimate interests.
• The right to ask us, in some situations, to restrict processing of your personal information or request portability of your personal information.
• The right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under section L. HOW TO CONTACT US below.
• If we have collected and process your personal information with your consent, then you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent
• The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected.

1. Language

If there is any conflict between the English version and another language version of this Privacy Policy, the English version shall prevail.

1. HOW TO CONTACT US

If you have any requests, questions or concerns about our use of your personal information and this Privacy Policy, and/or wish to contact the Data Protection Officer, please contact us at support@Ashob.com