Privacy Policy Page
1. INTRODUCTION
1.1 Welcome to the cgwlcms platform run by cgwlcms Southeast Asia Limited and its affiliates
(individually and collectively, "cgwlcms", "we", "us" or "our"). cgwlcms takes its
responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is
committed to respecting the privacy rights and concerns of all Users of our cgwlcms website and
mobile application (the "Platform") (we refer to the Platform and the services we provide as
described on our Platform collectively as the "Services"). Users refers to a user who registers
for an account with us for use of the Services, including both buyers and sellers (individually
and collectively, “Users”, “you” or “your”). We recognize the importance of the personal data
you have entrusted to us and believe that it is our responsibility to properly manage, protect
and process your personal data. This Privacy Policy (“Privacy Policy” or “Policy”) is designed
to assist you in understanding how we collect, use, disclose and/or process the personal data
you have provided to us and/or we possess about you, whether now or in the future, as well as to
assist you in making an informed decision before providing us with any of your personal
data.
1.2 "Personal Data" or "personal data" means data, whether true or not, about an individual who
can be identified from that data, or from that data and other information to which an
organisation has or is likely to have access. Common examples of personal data could include
name, identification number and contact information.
1.3 By using the Services, registering for an account with us, visiting our Platform, or
accessing the Services, you acknowledge and agree that you accept the practices, requirements,
and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using,
disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO
THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR
SERVICES OR ACCESS OUR PLATFORM. If we change our Privacy Policy, we will notify you including
by posting those changes or the amended Privacy Policy on our Platform. We reserve the right to
amend this Privacy Policy at any time. To the fullest extent permissible under applicable law,
your continued use of the Services or Platform, including placing of any orders, shall
constitute your acknowledgment and acceptance of the changes made to this Privacy Policy.
1.4 This Policy applies in conjunction with other notices, contractual clauses, consent clauses
that apply in relation to the collection, storage, use, disclosure and/or processing of your
personal data by us and is not intended to override those notices or clauses unless we state
expressly otherwise.
1.5 This Policy applies to both buyers and sellers who use the Services except where expressly
stated otherwise.
2. WHEN WILL cgwlcms COLLECT PERSONAL DATA?
2.1 We will/may collect personal data about you:
when you register and/or use our Services or Platform, or open an account with us;
when you submit any form, including, but not limited to, application forms or other forms
relating to any of our products and services, whether online or by way of a physical form;
when you enter into any agreement or provide other documentation or information in respect of
your interactions with us, or when you use our products and services;
when you interact with us, such as via telephone calls (which may be recorded), letters, fax,
face-to-face meetings, social media platforms and emails, including when you interact with our
customer service agents;
when you use our electronic services, or interact with us via our application or use Services
on our Platform. This includes, without limitation, through cookies which we may deploy when you
interact with our application or website;
when you grant permissions on your device to share information with our application or
Platform;
when you link your cgwlcms account with your social media or other external account or use
other social media features, in accordance with the provider’s policies;
when you carry out transactions through our Services;
when you provide us with feedback or complaints;
when you register for a contest; or
when you submit your personal data to us for any reason
The above does not purport to be exhaustive and sets out some common instances of when personal
data about you may be collected.
3. WHAT PERSONAL DATA WILL cgwlcms COLLECT?
3.1 The personal data that cgwlcms may collect includes but is not limited to:
name;
email address;
date of birth;
billing and/or delivery address;
bank account and payment information;
telephone number;
gender;
information sent by or associated with the device(s) used to access our Services or
Platform;
information about your network and the people and accounts you interact with;
photographs or audio or video recordings;
government issued identification or other information required for our due diligence, know your
customer, identity verification, or fraud prevention purposes;
marketing and communications data, such as your preferences in receiving marketing from us and
third parties, your communication preferences and history of communications with us, our service
providers, and other third parties;
usage and transaction data, including details about your searches, orders, the advertising and
content you interact with on the Platform, and other products and services related to you;
location data;
any other information about the User when the User signs up to use our Services or Platform,
and when the User uses the Services or Platform, as well as information related to how the User
uses our Services or Platform; and
aggregate data on content the User engages with.
3.2 You agree not to submit any information to us which is inaccurate or misleading, and you
agree to inform us of any inaccuracies or changes to such information. We reserve the right at
our sole discretion to require further documentation to verify the information provided by
you.
3.3 If you sign up to be a user of our Platform using your social media account (“Social Media
Account”), link your cgwlcms account to your Social Media Account or use any cgwlcms social
media features, we may access information about you which you have voluntarily provided to your
Social Media Account provider in accordance with such provider's policies, and we will manage
and use any such personal data in accordance with this Policy at all times.
3.4 If you do not want us to collect the aforementioned information/personal data, you may opt
out at any time by notifying our Data Protection Officer in writing. Further information on
opting out can be found in the section below entitled "How can you withdraw consent,
request access to or correct information you have provided to us?" . Note, however, that opting
out or withdrawing your consent for us to collect, use or process your personal data may affect
your use of the Services and the Platform. For example, opting out of the collection of
location information will cause its location-based features to be disabled.
4. COLLECTION OF OTHER DATA
4.1 As with most websites and mobile applications, your device sends information which may
include data about you that gets logged by a web server when you browse our Platform. This
typically includes without limitation your device’s Internet Protocol (IP) address,
computer/mobile device operating system and browser type, type of mobile device, the
characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment
identifier (MEID) for your mobile device, the address of a referring web site (if any), the
pages you visit on our website and mobile applications and the times of visit, and sometimes a
"cookie" (which can be disabled using your browser preferences) to help the site remember your
last visit. If you are logged in, this information is associated with your personal account. The
information is also included in anonymous statistics to allow us to understand how visitors use
our site.
4.2 Our mobile applications may collect precise information about the location of your mobile
device using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process this
information for one or more Purposes including, without limitation, location-based services that
you request or to deliver relevant content to you based on your location or to allow you to
share your location to other Users as part of the services under our mobile applications. For
most mobile devices, you are able to withdraw your permission for us to acquire this information
on your location through your device settings. If you have questions about how to disable your
mobile device's location services, please contact your mobile device service provider or the
device manufacturer.
4.3 As when you view pages on our website or mobile application, when you watch content and
advertising and access other software on our Platform or through the Services, most of the same
information is sent to us (including, without limitation, IP Address, operating system, etc.);
but, instead of page views, your device sends us information on the content, advertisement
viewed and/or software installed by the Services and the Platform and time.
5. COOKIES
5.1 We or our authorized service providers and advertising partners may from time to time use
"cookies" or other features to allow us or third parties to collect or share information in
connection with your use of our Services or Platform. These features help us improve our
Platform and the Services we offer, help us offer new services and features, and/or enable us
and our advertising partners to serve more relevant content to you, including through
remarketing. “Cookies” are identifiers that are stored on your computer or mobile device that
record data about the computer or mobile device, how and when the Services or Platform are used
or visited, by how many people and other activity within our Platform. We may link cookie
information to personal data. Cookies also link to information regarding what items you have
selected for purchase and web pages you have viewed. This information is used to keep track of
your shopping cart, to deliver content specific to your interests, to enable our third party
advertising partners to serve advertisements on sites across the internet, and to conduct data
analysis and to monitor usage of the Services.
5.2 You may refuse the use of cookies by selecting the appropriate settings on your browser or
device. However, please note that if you do this you may not be able to use the full
functionality of our Platform or the Services.
6. HOW DO WE USE THE INFORMATION YOU PROVIDE US?
6.1 We may collect, use, disclose and/or process your personal data for one or more of the
following purposes:
to consider and/or process your application/transaction with us or your transactions or
communications with third parties via the Services;
to manage, operate, provide and/or administer your use of and/or access to our Services and our
Platform (including, without limitation, remembering your preference), as well as your
relationship and user account with us;
to respond to, process, deal with or complete a transaction and/or to fulfil your requests for
certain products and services and notify you of service issues and unusual account
actions;
to enforce our Terms of Service or any applicable end user license agreements;
to protect personal safety and the rights, property or safety of others;
for identification, verification, due diligence, or know your customer purposes;
to evaluate and make decisions relating to your credit and risk profile and eligibility for
credit products;
to maintain and administer any software updates and/or other updates and support that may be
required from time to time to ensure the smooth running of our Services;
to deal with or facilitate customer service, carry out your instructions, deal with or respond
to any enquiries given by (or purported to be given by) you or on your behalf;
to contact you or communicate with you via voice call, text message and/or fax message, email
and/or postal mail or otherwise for the purposes of administering and/or managing your
relationship with us or your use of our Services, such as but not limited to communicating
administrative information to you relating to our Services. You acknowledge and agree that such
communication by us could be by way of the mailing of correspondence, documents or notices to
you, which could involve disclosure of certain personal data about you to bring about delivery
of the same as well as on the external cover of envelopes/mail packages;
to allow other users to interact, connect with you or see some of your activities on the
Platform, including to inform you when another User has sent you a private message, posted a
comment for you on the Platform or connected with you using the social features on the
Platform;
to conduct research, analysis and development activities (including, but not limited to, data
analytics, surveys, product and service development and/or profiling), to analyse how you use
our Services, to recommend products and/or services relevant to your interests, to improve our
Services or products and/or to enhance your customer experience;
to allow for audits and surveys to, among other things, validate the size and composition of
our target audience, and understand their experience with cgwlcms’s Services;
for marketing and advertising, and in this regard, to send you by various mediums and modes of
communication marketing and promotional information and materials relating to products and/or
services (including, without limitation, products and/or services of third parties whom cgwlcms
may collaborate or tie up with) that cgwlcms (and/or its affiliates or related corporations) may
be selling, marketing or promoting, whether such products or services exist now or are created
in the future. You can unsubscribe from receiving marketing information at any time by using the
unsubscribe function within the electronic marketing materials. We may use your contact
information to send newsletters or marketing materials from us and from our related
companies;
to respond to legal processes or to comply with or as required by any applicable law,
governmental or regulatory requirements of any relevant jurisdiction or where we have a good
faith belief that such disclosure is necessary, including, without limitation, meeting the
requirements to make disclosure under the requirements of any law binding on cgwlcms or on its
related corporations or affiliates (including, where applicable, the display of your name,
contact details and company details);
to produce statistics and research for internal and statutory reporting and/or record-keeping
requirements;
to carry out due diligence or other screening activities (including, without limitation,
background checks) in accordance with legal or regulatory obligations or our risk management
procedures that may be required by law or that may have been put in place by us;
to audit our Services or cgwlcms's business;
to prevent or investigate any actual or suspected violations of our Terms of Service, fraud,
unlawful activity, omission or misconduct, whether relating to your use of our Services or any
other matter arising from your relationship with us;
to respond to any threatened or actual claims asserted against cgwlcms or other claim that any
Content violates the rights of third parties;
to store, host, back up (whether for disaster recovery or otherwise) of your personal data,
whether within or outside of your jurisdiction;
to deal with and/or facilitate a business asset transaction or a potential business asset
transaction, where such transaction involves cgwlcms as a participant or involves only a related
corporation or affiliate of cgwlcms as a participant or involves cgwlcms and/or any one or more
of cgwlcms's related corporations or affiliates as participant(s), and there may be other third
party organisations who are participants in such transaction. A “business asset transaction”
refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal or
financing of an organisation or a portion of an organisation or of any of the business or assets
of an organisation; and/or
any other purposes which we notify you of at the time of obtaining your consent.
(collectively, the “Purposes”).
6.2 You acknowledge, consent and agree that cgwlcms may access, preserve and disclose your
Account information and Content if required to do so by law or pursuant to an order of a court
or by any governmental or regulatory authority having jurisdiction over cgwlcms or in a good
faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply
with legal process; (b) comply with a request from any governmental or regulatory authority
having jurisdiction over cgwlcms; (c) enforce the cgwlcms Terms of Service or this Privacy
Policy; (d) respond to any threatened or actual claims asserted against cgwlcms or other claim
that any Content violates the rights of third parties; (e) respond to your requests for customer
service; or (f) protect the rights, property or personal safety of cgwlcms, its users and/or the
public.
6.3 As the purposes for which we will/may collect, use, disclose or process your personal data
depend on the circumstances at hand, such purpose may not appear above. However, we will notify
you of such other purpose at the time of obtaining your consent, unless processing of the
applicable data without your consent is permitted by the Privacy Laws.
7. HOW DOES cgwlcms PROTECT AND RETAIN CUSTOMER INFORMATION?
7.1 We implement a variety of security measures and strive to ensure the security of your
personal data on our systems. User personal data is contained behind secured networks and is
only accessible by a limited number of employees who have special access rights to such
systems. However, there can inevitably be no guarantee of absolute security.
7.2 We will retain personal data in accordance with the Privacy Laws and/or other applicable
laws. That is, we will destroy or anonymize your personal data when we have reasonably
determined that (i) the purpose for which that personal data was collected is no longer being
served by the retention of such personal data; (ii) retention is no longer necessary for any
legal or business purposes; and (iii) no other legitimate interests warrant further retention of
such personal data. If you cease using the Platform, or your permission to use the Platform
and/or the Services is terminated or withdrawn, we may continue storing, using and/or disclosing
your personal data in accordance with this Privacy Policy and our obligations under the Privacy
Laws. Subject to applicable law, we may securely dispose of your personal data without prior
notice to you.
