PRIVACY POLICY

SANLI GROUP PTE. LTD. (“our Company”, “we” or “SGShop”) offers via its website at www.sgshop.com (“our Site”) logistics and agency services to assist you in easy and fuss-free shopping on the major e-commerce platforms in China such as Taobao.com, JD.com, Tmall.com and other e-commerce sites in China (collectively, “Mirrored Sites”).  Our Site therefore also mirrors the Mirrored Sites in order to reflect the products (“Products”) of the merchants (“Mirrored Site Merchants”) listed on the Mirrored Sites.

In order to serve you better, we require information from you, some of which may be considered as personal data.  We understand however, the importance of the privacy and security of your information, and we have therefore set out in detail below how we collect and use your information.  Kindly review the terms and conditions of our Privacy Policy as follows so that you may be reassured that we take data protection seriously:

I).   Please note that your access and use of our Site is subject to our Company’s Terms of Use [P1] (“our Terms of Use”), as well as the terms and conditions as set out herein this Privacy Policy. Accordingly, by accessing our Site, signing up for membership, using our Services, purchasing the Products via our Site or using any of our services, you are agreeing to our collection of your information pursuant to this Privacy Policy.  Should you disagree with any clause in our Terms of Use and/or this Privacy Policy, please immediately cease your access of our Site and usage of any of our services.

II). In order for you to fully utilize our Site, enjoy the benefits conferred by our membership programme, receive updates (including your points accumulation and membership status) through your member account, participate in our promotions, receive our marketing materials, newsletters or updates for information and/or promotion regarding our services, products, the Mirrored Sites, the Mirrored Merchants and the Products (collectively “our Updates”), your Personal Data (as defined in clause 1.2 below) has to be provided to us, and we will need to keep and use your Personal Data in order to fulfil the purpose for which you have accessed our Site, subscribed to our Updates and/or engaged our services.

For expediency and for compliance with any changes in the law, we reserve the right to amend this Privacy Policy in our sole discretion at any time without prior notice to you, and you agree that your continued access of our Site and/or desire to receive our Updates constitutes your unconditional acceptance of our amended Privacy Policy.  You agree that it is your sole responsibility to keep yourself updated of any amendments by reviewing this Privacy Policy at our Site regularly.

1. Types of Data Collected

1.1 When you visit our Site, engage any of our services, purchase any Product, and/or sign up for our membership, we collect Personal Data and Anonymised Data.

1.2 “Personal Data” refers to information with personal identifiers that can be used separately or collectively to identify an individual, such as name, address, NRIC number, mobile number, email address, birthdate, gender, residency status, bank account number and credit card details.

1.3 "Anonymised Data" refers to information that is not associated with or linked to your Personal Data and cannot be used to identify individual persons.

2. Collection of Anonymised Data

2.1 We collect Anonymised Data about you when you access or use our Site via the application of generally acceptable web technologies including but not limited to "web beacons", "cookies", "clear GIFs", "widgets", "online evaluations", "surveys", “HTML5”, and third-party web analytics such as "Google analytics" (collectively, “Acceptable Technologies”).  This automatic collection of non-personal information includes (without limitation) collection of your IP Address, the web browser software that you used, the specific pages of our Site viewed by you, the Mirrored Sites that you view, and any other third party websites that you may have visited prior to our Site.  Our purpose for the aforesaid collection of information is for us to understand the preference of our visitors and users so as to enhance and facilitate the ease with which you are able to access or use our Site.

2.2 As part of the Anonymised Data that we collect, when you access our Site via your mobile device, we will also collect information regarding the type of mobile device that you are utilising so that our Site can provide you with the version of our Site best suited for access via your mobile device.

2.3 If you do not consent to our collection of Anonymised Data, please adjust the settings on your computer, tablet and mobile device to block or disable our use of the Acceptable Technologies.  In the event that you choose to access our Site without blocking or disabling or opting out of the Acceptable Technologies, such access by you will constitute your consent to our use of the Acceptable Technologies and our collection of information thereto.

2.4 To better assist you in understanding the generally accepted technology used in our collection of Anonymised Data:

2.4.1 “IP Address” refers to a number that is automatically assigned to your computer when you access the Internet. Under certain circumstances, your IP Address remains the same from browser session to browser session.  However, in the event that a consumer Internet access provider is utilized, your IP Address will likely vary from session to session. We track IP Addresses solely in conjunction with session cookies to analyse the flow of webpages on our Site.

2.4.2 “Cookies” refer to small pieces of data that a website or web app sends to your computer’s hard drive or mobile device’s internal storage while you are viewing the said website or utilizing the said web app. Our Site utilises both session cookies (they expire the moment your Internet browser is closed) and persistent cookies (they will remain in your computer and your mobile device until you actively take steps to delete them) so as to provide you with a more personalised and interactive experience on our Site. By changing the options on your Internet browser and adjusting the settings in your mobile device, you can control whether to accept or decline cookies.

2.4.3 “Clear GIFs” refer to clear electronic images that are used to track your opening of webpages on our Site, your frequency of accessing specific Mirrored Sites, and your regularity in accessing webpages relating to certain categories of Products, for the purpose of allowing us to find out whether the content on Our Site and the Mirrored Sites appeal to you.  Clear GIFs are also commonly known as "web beacons" and may be included on our Site and in conjunction with some of our services made available through our Site, which generally works in conjunction with cookies to identify users and user-behaviour.  Some of our HTML based emails also utilize Clear GIFs in order for us to assess what are the emails we sent that have been opened and acted upon. Clear GIFs collect only limited data, such as a cookie number, the time and date of when a particular webpage on our Site is accessed, and a description of the webpage on Our Site in which the clear GIF resides. Such collected Anonymised Data helps us to determine the effectiveness of the way our webpages are arranged on Our Site, the display of Mirrored Sites via our Site, our modes of communications and promotional campaigns.

2.4.4 "Third-party web analytics" refer to services provided by third party service providers for the assessment, analysis, measurement and reporting of the behaviour of visitors to a website in order to assess and improve the effectiveness of the website.  One of the most well-known third-party analytics service is "Google Analytics".

2.4.5 “HTML5 local storage” refer to caching services utilizing primarily a cache manifest file, which allows for storage of your preferences offline which will then be updated and synchronized when you go online.

3. Your Consent to our Collection, Retention and Use of Personal Data

3.1 In order for our Company to provide you with our services as well as to assist you in purchasing and receiving your purchased Products, you agree and consent to our Company collecting, using and retaining your Personal Data as follows:-

(i) When you sign up for our Updates, or you email us with any queries, you will be required to provide us with your Personal Data in order for us to add you to our mailing list, or to revert to your queries.

(ii) When you wish to use either our “Buy for Me” or “Ship for Me” services, you will be required to register a membership account with us, and we will require your Personal Data such as your credit card particulars and contact details in order to transact payment and to deliver your purchased Product.  To that end, we will also need to disclose your Personal Data to online payment solutions providers, financial institutions, credit card associations, Mirrored Site Merchants, Mirrored Sites, and courier/freight companies.

(iii) When you register for a member account with us, in order for us to provide you with information that may be of interest to you, we may request for information on your payment mode preferences, shipping/delivery preferences, birthdate (for birthday promotions, if any), product-type preference, and other information relevant to our provision of Mirrored Sites and our logistics and agency services via our Site (“Your Preferences”).  You can choose not to disclose Your Preferences to us, however, in the event that you do, such disclosure shall constitute your consent to us to send you information, updates, and promotions in relation to Your Preferences.

(iv) When you sign up for a membership account, you are automatically enrolled for our loyalty programme.  We will require your Personal Data in order to keep a record of and provide you with the benefits that accompany our membership and loyalty programmes, including calculation of your accumulated points available for coupon redemptions and upgrading of your membership status (to VIP and SVIP, if applicable).  Unless you terminate your membership account with us, we will keep your Personal Data for as long as you remain our member so that we can continue to provide you with the benefits available to all our members;

(v) When you use our “Buy for Me” or “Ship for Me” services, we will require your Personal Data in order to fulfil your instructions, including but not limited to placing orders on your behalf as your agent, transacting your purchases, delivering your purchased Products, and providing follow-up services; and

(vi) When you click on any of our Company’s Google ads or other internet based advertisements for more information regarding the Products, our services or our Site, we collect the Personal Data that you provide in order to follow up with you pertaining to your interest in the Products and/or our Site.

3.2 In addition, we will retain your Personal Data where necessary and for such duration as may be required in order for our Company to comply with applicable laws and regulations, assist in any legal investigations, meet the demands from any regulatory or law enforcement bodies, for utilization in legal proceedings, minimizing fraud, collection of debts, resolving disputes, identifying issues, enforcing contractual breaches and/or claiming for damages.

4. Disclosure of Personal Data

4.1  We may need to disclose your Personal Data to:

(i) third party service providers in order for us to facilitate your access to and use of our Site, for us to contact you as you may have requested via our our Site, for us to maintain and update your records to ensure that you receive the benefits of our membership and loyalty programme, and for us to provide you with any other perks accompanying your participation in our loyalty programme and/or promotional campaigns.  The aforesaid third party service providers have a contract with us to perform the services necessary for you to use our Site, and receive Updates, and such third party service providers therefore include but is not limited to webhost companies, website maintenance companies, database storage companies, loyalty programme service providers, companies that assist to perform mass mailing on our behalf, etc.;

(ii) Mirrored Sites, and/or the Mirrored Site Merchants whom you have selected to purchase Products from, in order for your purchase orders to be processed, and your purchased Products to be delivered to you;

(iii) our book-keepers, accounting firms, audit firms, law firms and/or other professional advisory firms who are maintaining our records in accordance with legal requirements;

(iv) governmental, regulatory or law enforcement bodies who have a legal right to demand for your Personal Data;

(v) financial institutions, banks, online payment service providers, credit card associations, credit bureaus, and other third parties whose services are required in order for you to make online payment for your purchased Products and our service fees;

(vi) credit bureaus, credit rating agencies and fraud preventing companies for the purpose of minimizing fraudulent activities via your Personal Data (which may include information pertaining to your credit cards); and

(vii) our affiliated or related companies and/or third parties to whom we may sell, divest, transfer, assign, share or otherwise engage in a transaction that involves, some or all of our Company’s assets (which may include your Personal Data), in the course of a corporate divestiture, corporate restructuring, merger, acquisition, joint venture, bankruptcy, dissolution, reorganisation, or any other similar transaction or proceeding.

Except as provided above, we do not sell, rent, licence or otherwise disclose your Personal Information to third parties or our affiliated companies.  We are careful in our selection of third party service providers, and all such third party service providers as well as our abovementioned affiliated companies are bound by obligations of data protection (pursuant to contracts and/or applicable laws) similar to the obligations herein this Privacy Policy.

5. Transferring Personal Data out of Singapore

5.1 Pursuant to the purposes and activities as set out in sections 2 and 3 above, it may be necessary for us to transfer your Personal Data out of Singapore, in particular to online payment service providers and to Mirrored Site Merchants who are based outside of Singapore.  You hereby agree and consent to the aforesaid transfer, on the understanding that the recipients[P2] of such Personal Data are also subject to applicable laws or contractual obligations similar to the obligations as set out in the Personal Data Protection Act 2012.

6. Accurate and Complete Personal Data

6.1 In order for us to provide you with our services, and to perform the activities as set out in sections 2 and 3 above, you warrant that the Personal Data that you provide to us is accurate, and that all Personal Data as may be relevant for that particular purpose/circumstance has been provided (for example, you must provide us with the correct delivery address in order for us to deliver your purchased Products to you).

7. Do-Not-Call ("DNC") Provisions and Registries

7.1 We respect your selections in relation to the channels via which you wish to receive our Updates.  Therefore, if you have registered your telephone and/or fax number with the Do-Not-Call Registries in relation to telephone calls, text or fax messages, we will not send you any Updates via the channels that you have opted out of by registering with the Do-Not-Call Registries.  However, if you have previously consented to our sending you Updates via your telephone number (calls or text messages) and/or facsimile number, we will continue doing so until you withdraw your consent by contacting our Data Protection Officer at dpo@sgshop.com.

8. Withdrawal of Consent

8.1 You may at any time withdraw your consent to our use, retention, disclosure or transfer of your Personal Data pursuant to this Privacy Policy by emailing our Data Protection Officer at dpo@sgshop.com.  However, please note that any such withdrawal of consent may result in us being unable to continue providing our services or fulfilling our contractual obligations with you, including but not limited to our inability to: (i) transact any purchases that you have instructed us purchase on your behalf; (ii) deliver to you your purchased Products; (iii) determine and provide you with VIP and SVIP member status and its associated benefits; (iv) provide you with points for coupon redemption; (v) provide you with any other benefits of our membership and loyalty programme that we may make available to our members from time to time; and (vi) provide you with the opportunity to participate in promotions.  Accordingly, your withdrawal of consent may also lead to the termination of any contract(s) that you may have with our Company or any Mirrored Site Merchant, for which our Company expressly reserves its rights and remedies thereto.  Our Data Protection Officer will further advise you on the legal consequences that may ensue should you contact him/her to withdraw your consent.

8.2 Should you wish to unsubscribe to our Updates, please click the "unsubscribe" option made available in our emails to you.  Please note however that this may result in our being unable to make available to you updates on our promotions or any promotions from any Mirrored Site or Mirrored Site Merchant, your benefits under our membership and loyalty programme and any ongoing promotions (which may also relate to our loyalty programme, or otherwise).

9. Access and Correction of Personal Data

9.1 Should you wish to access, update or make corrections to your Personal Data held with us, please email our Data Protection Officer at dpo@sgshop.com .

9.2 There will be no administrative fees or other charges levied for any request to correct or update your Personal Data.  However, for all other requests such as accessing your Personal Data held with us, obtaining a record of when you accessed our Site, a comprehensive list of all your transactions with Mirrored Site Merchants since your first signing on as a member, a comprehensive record of all service fees paid to us since your first transaction, etc., a reasonable administrative fee may be levied depending on your request as time and resources will be spent in accommodating your requests.

9.3 Should you have any queries or complaints pertaining to this Privacy Policy, our Terms of Use, your personal Data as registered with us, or in relation to our Company’s use, retention, disclosure or transfer of your Personal Data, or should you desire to learn more about our data protection policies and security measures, please email our Data Protection Officer at dpo@sgshop.com.

10. Minors

10.1 Our Site, our services, the Mirrored Sites and the Products are not meant for persons who may be defined as minors under applicable law. We do not knowingly collect Personal Data from minors, however, through the internet, we are not able to ascertain on our end whether such individuals are minors.  It is thus the responsibility of parents or guardians to ensure that their minors do not access our Site or provide us with Personal Data without their parental/guardian's consent.  If a parent or guardian becomes aware that his or her minor has accessed our Site or provided us with Personal Data without his/her consent, he or she should contact our Data Protection Officer atdpo@sgshop.com promptly. If we become aware that a minor under 18 has provided us with Personal Data without their parent or guardian's consent, we will delete such information from our records.

11. Security Measures for Protection of Personal Data

11.1 We ensure that our Site is protected by reasonable security measures afforded by current technology, and that all our data hosts and servers are similarly protected by such security measures, including but not limited to firewalls.

11.2 Your Personal Data is kept securely and protected against unauthorized access and disclosure.  We utilize security means such as (without limitation) password protection, encryption, locked and restricted access.  We have strict policies in place restricting access to Personal Data to only our authorized personnel on a need-to-know basis.

11.3 We will take practical steps to ensure that your Personal Data will not be kept longer than as set out herein this Privacy Policy, or for as long as is necessary for fulfilling the purposes for which you have entrusted us with your Personal Data, or as may be required for legitimate business or legal purposes, whichever is the latest.

12. Third Party Sites (including Social Network Sites)

12.2 Our Company may utilize reputable social media/network sites such as, but not limited to Facebook, Twitter, Instagram, Pinterest and LinkedIn (collectively the "Social Media Sites") so as to connect to your social networks.  In order to generate interest in our Site and services amongst the contacts in your social networks and to allow you to share your interest in the Products, we provide access to our Site to the third party Social Media Sites, and there are links on our Site to such Social Media Sites. The aforesaid association with the Social Media Sites does not constitute any endorsement or recommendation of any of the Social Media Sites by our Company nor vice versa. As per clause 11.1 above, kindly review the terms of use and privacy policies of the Social Media Sites before you use or access such Social Media Sites in conjunction with our Site, any of our promotions and our services made available via any Social Media Sites.

12.3 The association of our Site with the Social Media Sites makes available certain features which when used by you, may result in information being made available from your accounts with the Social Media Sites to our Company.  Such information which we collect about you shall constitute public information that is available in the general domain because such information was made publicly available by the Social Media Sites.  Should you prefer that we do not collect your information from the Social Media Sites, please (i) do not use the features or links that associates our Site with the Social Media Sites; and (ii) adjust the settings in your accounts with the Social Media Sites to prevent the sharing of your information with our Site.  Please note that our Company cannot control nor is our Company howsoever responsible for the sharing of your information by the Social Media Sites with third parties.

13. Governing Law and Jurisdiction

13.1 The terms and conditions of this Privacy Policy are governed by the laws of Singapore. In the event of any disputes arising from this Privacy Policy and/or your use of our Site, you must first contact our Data Protection Officer atdpo@sgshop.com regarding your concern and use your best endeavours to amicably settle any dispute in good faith.  We on our part will also use our best endeavours to amicably settle your concerns in good faith. However, if no amicable resolution is reached within 30 days, you agree to submit to the exclusive jurisdiction of the Courts of Singapore.