(Effectiveas of Jan 08，2024)

A. USER INFORMATION COLLECTION AND REQUIREMENTS

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, when you apply for after-sales services.

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 license (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 Eoem, 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.

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 Eoem as a blogger or an influencer, we may also collect your social media account handles and posts / comments made in relation to the Platform.

We may collect information about the people or accounts with whom you share content or interact and contact information if you choose to upload or import it from a device (such as an address book).

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. To deletion of those data. you can revoke this in your account at dashboard.

B. 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;
Help you find people you may know who are also using Eoem
cookies or other similar technologies may be used to provide you with advertising based upon your browsing activities and interests (see section E. COOKIES below for more information).

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.

C. 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 or 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 in providing 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:

·Eoem 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, so that they may tailor the content you see when visiting our Platform 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 parties 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 organizations 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.

· To completed delete user data (including General user and Seller user).

Because all users and sellers data are currently associated with other financial affairs data that already available in the EOEM system(eoem.org), if you need to delete your personal data completely, please use the ticket system by dashboard or contact us by email, we need to prove the real identity of the user and related assets further confirmation after billing profile and then user data deletion.

- General user:
Data verify: The user account if has order disputes, monthly consumption fees, etc., EOEM will make statistics on this part of the data and confirm with the user. If there is no objection between the two parties, we will delete the user data within 3 business working days.and users related points, free red bonus, free coupons data etc will all be invalid in same time
- Seller users:
Data verify: the seller account if has unpaid fees for completion, whether there is an order dispute with consumer users, and whether they complete the relevant financial settlement, once both parties confirm that there is no error, we reserve the right for delete for 30 days. If there is no consumer user complaint within those days, it will be Next 3 business days to complete data deletion

· Legal Basis for Data Processing

We process personal information for the purposes set out in this Privacy Policy observing legal bases set out in the LGPD. Our legal basis for processing your personal information will depend on the personal information in question and the specific context in which we collect it, but will include when it is:

- necessary for the performance of the contract between you and Eoem Company Limited (for example, to provide the services requested by you and to identify and authenticate you so that you can use the Platform).

- necessary to comply with legal requirements (for example, to comply with applicable accounting rules and make required disclosures to law enforcement authorities);

- necessary to achieve our legitimate interests or those of third parties;

- based on your consent;

- necessary for the regular exercise of rights in judicial, administrative and arbitration proceedings;

- necessary for the protection of life and limb or of the data subject and third parties;

- used for credit protection purposes;

- used for other cases foreseen in the LGPD or applicable legislation.

If we collect and use your personal information based on our (or a third party\'s) legitimate interest, that interest will generally 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 business interest, for example in responding to your inquiries, improving our Platform and services, conducting marketing, or for the purpose 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 the possible consequences if you do not provide your personal information). In some cases, it may be necessary for you to provide us with personal information for processing as described above in order for us to provide you with all of our services and for you to use all of the features of our Platform.

 If you have questions or need more information about the legal basis on which we collect and use your personal information, please contact us by email or over support center ticket system.
 
 ·Your (register user) Rights

You have the following data protection rights, which you can exercise at any time by contacting us:

- The right to access your personal data and confirm the existence of processing.

- The right to correct, update or request anonymization, blocking or deletion of your personal information.

- The right to object to the processing of your personal information where it is based on our legitimate interests or in case of non-compliance with LGPD or applicable law.

- The right to ask us, in some situations, to restrict the processing of your personal information or to request portability of your personal information.

- The right to cancel marketing communications we send you at any time. You may exercise this right by clicking on the "unsubscribe" or "unsubscribe" link in marketing e-mails that we have sent to you. To unsubscribe from receiving other forms of marketing (such as postal marketing or telemarketing), please contact us by email or over support center ticket system

- If we collect and process your personal information with your consent, you have the right to withdraw your consent at any time and request deletion of your personal data. Withdrawing your consent will not affect the lawfulness of any processing carried out prior to your withdrawal, nor will it affect processing of your personal information carried out on a legal basis other than consent.

- The right to request a review of decisions based solely on automated processing, which may affect your interests.

- The right to petition the National Data Protection Authority - ANPD about our collection and use of your personal information.

- The right to request portability of your personal data to another service provider;

- The right to request information about with whom your personal data has been shared.

We respond to all requests we receive from individuals who wish 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 must inform us of such changes so that our records can be updated or corrected.

D. 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.

E. 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 Economic Area, UK or Brazil, please refer to section J. VISITORS FROM THE EUROPEAN ECONOMIC AREA, UK OR BRAZIL below for more information. If you are a Visitor from California, please refer to section K. VISITORS FROM CALIFORNIA below. If you have any questions regarding this Privacy Policy or if you wish to access or correct your personal information as a user of Eoem.org please login to check.

F. INTERNATIONAL TRANSFERS OF PERSONAL DATA

In connection with providing the services through our Platform, we will store your personal data processed through the Platform in the London, United States, Russia, Germany, China and/or Singapore, depending on the country you are located in. These countries have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). There will also be international transfers of your information among the above-mentioned countries. 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 or other mechanism provided for in the applicable law. if you have any question regarding this you can obtained by contacting us by email or over support center ticket system.