Privacy Policy Page

I. Introduction

1.1 Welcome to the VEEPEE.G platform operated by VEEPEE.G Southeast Asia Limited and its affiliates (individually and collectively, “VEEPEE.G,” “we,” “us,” or “our”). VEEPEE.G takes its responsibilities under applicable privacy laws and regulations (“Privacy Law”) seriously and is committed to respecting the privacy rights and concerns of all users of our FRUUGO website and mobile application (“Platform”) (“We” refers to the Platform and the services we provide on our Platform, collectively, the “Services”). Users are those who register an account with us to use the Services, including buyers and sellers (individually and collectively, “Users,” “you,” or “your”). We recognize the importance of the personal data you entrust to us and believe it is our responsibility to properly manage, protect, and process your personal data. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to help you understand how we collect, use, disclose, and/or process the personal data you provide to us and/or that we possess about you, both now and in the future, and to help you make informed decisions before providing us with any of your personal data. 1.2 “Personal Data” or “personal information” means data of an individual that can be identified from that data or from other information that an organization has the right or may have the right to access, whether or not it is true. Common examples of personal data may include name, ID number, and contact information. 1.3 By using the Services, registering an account with us, accessing our platform, or accessing the Services, you acknowledge and agree to your acceptance of the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to our collection, use, disclosure, and/or processing of your personal data as described herein. If you do not agree 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 such changed or revised Privacy Policy on our platform. We reserve the right to modify this Privacy Policy at any time. Your continued use of the Services or Platform, including placing any order, to the maximum extent permitted by applicable law, constitutes your acknowledgment and acceptance of the changes made to this Privacy Policy. 1.4 This Policy applies together with other notices, contractual terms, and consent terms applicable to our collection, storage, use, disclosure, and/or processing of your personal data, and is not intended to overridden such notices or terms unless we expressly state otherwise. 1.5 This policy applies to both the buyer and seller of the services, unless otherwise expressly stated. Our disclosure and/or processing of your personal data is not intended to overwrite these notices or terms unless we expressly state otherwise.

2. When does VEEPEE.G collect personal data?

2.1 We will/may collect your personal data in the following situations:

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 in physical form;

When you enter into any agreement with us or provide other documents or information regarding your interaction with us, or when you use our products and services;

When you interact with us, such as by telephone (which may be recorded), letter, fax, face-to-face meetings, social media platforms, and email, including when you interact with our customer service agents;

When you use our electronic services, or interact with us through our applications or use services on our platform. This includes, but is not limited to, cookies that we may deploy when you interact with our applications or websites;

when you grant permission on your device to share information with our applications or platforms;

when you associate your VEEPEE.G account with your social media or other external accounts or use other social media features in accordance with the provider's policies;

when you transact through our services;

when you provide us with feedback or complaints;

when you register for a competition; or

when you submit your personal data to us for any reason.

The above is not exhaustive but lists some common situations in which we may collect your personal data.

3. What personal data will VEEPEE.G collect?

3.1 VEEPEE.G may collect personal data including, but not limited to:

Name;

Email address;

Date of birth;

Billing and/or delivery address;

Bank account and payment information;

Phone number;

Gender;

Information sent or related to the device 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, authentication, or fraud prevention;

Marketing and communication data, such as your preference for receiving marketing from us and third parties, your communication preferences, and your communication history with us, our service providers, and other third parties;

Usage and transaction data, including details about your searches, orders, advertisements and content you interact with on the platform, and other products and services relevant to you;

Location data;

Any other information about users when they register to use our services or platform and when they use the services or platform, and information related to how users use our services or platform; and

Aggregated data about the content users engage with.

3.2 You agree not to submit any inaccurate or misleading information to us, and you agree to notify us of any inaccuracies or changes to such information. We reserve the right, at our sole discretion, to request further documentation to verify the information you provide.

3.3 If you register as a user of our platform using your social media account (“Social Media Account”), link your VEEPEE.G account to your social media account, or use any VEEPEE.G social media features, we may access information that you have voluntarily provided to your social media account provider in accordance with that provider’s policy, and we will always manage and use any such personal data in accordance with this policy.

3.4 If you do not wish us to collect the above information/personal data, you may opt out at any time by giving written notice to our Data Protection Officer. For more information on opting out, please see the section below titled “How can you withdraw your consent, request access to, or correct the information you have provided to us?” However, please note that opting out or withdrawing your consent to our collection, use, or processing of your personal data may affect your use of the Services and Platform. For example, opting out of location information collection will result in the disabling of its location-based features.

4. Other Data Collection

4.1 As with most websites and mobile applications, the information your device sends may include data about you recorded by web servers while you browse our platform. This typically includes, but is not limited to, your device's Internet Protocol (IP) address, computer/mobile device operating system and browser type, mobile device type, mobile device characteristics, unique device identifier (UDID) or mobile device identifier (MEID) for your mobile device, the address of the referencing website (if any), the pages you visited on our website and mobile applications, and the time of your visit. Sometimes, there is also a "cookie" (which can be disabled using your browser preferences) to help the website remember your last visit. If you are logged in, this information will be associated with your personal account.

4.2 Our mobile applications may use technologies such as GPS and Wi-Fi to collect precise information about the location of your mobile device. We collect, use, disclose, and/or process this information for one or more purposes, including but not limited to location—services you request or that provide you with relevant content based on your location or allow you to share your location with other users—as part of the services under our mobile applications. For most mobile devices, you can revoke your permission for us to collect your location information through your device settings. If you have any questions about how to disable location services on your mobile device, please contact your mobile device service provider or device manufacturer.

4.3 When you view pages on our website or mobile application, when you watch content and advertisements on our platform or through the service, and when you access other software, most of the same information is sent to us (including but not limited to IP address, operating system, etc.); however, your device will not send us information about the content installed on the service and platform, advertisement views and/or software, and the time, rather than page views.

5. Cookies

5.1 We or our authorized service providers and advertising partners may use "cookies" or other features from time to time to allow us or third parties to collect or share information about your use of our services or platform. These features help us improve our platform and the services we offer, help us provide new services and features, and/or enable us and our advertising partners to provide you with more relevant content, including through remarketing. "Cookies" are identifiers stored on your computer or mobile device that record data about your computer or mobile device, how and when you use or access the service or platform, how many people use it, and other activities within our platform. We may associate cookie information with personal data. Cookies also link to information about the items you choose to purchase and the web pages you view. This information is used to track your shopping cart, provide content specific to your interests, enable our third-party advertising partners to place ads on our websites across the internet, conduct data analysis, and monitor service usage.

5.2 You can refuse the use of cookies by selecting the appropriate settings on your browser or device. However, please note that if you do so, you may not be able to use the full functionality of our platform or services.

6. How do we use the information you provide to 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 applications/transactions with us or your transactions or communications with third parties through the Services;

To manage, operate, provide, and/or administer your use and/or access to our Services and our platform (including, but not limited to, remembering your preferences), and your relationship with us and your user account;

To respond to, process, handle, or complete transactions and/or fulfill your requests for certain products and services, and to notify you of service issues and unusual account behavior;

To enforce our Terms of Service or any applicable end-user license agreement;

To protect personal safety and the rights, property, or safety of others;

For the purpose of identifying, verifying, conducting due diligence, or knowing your customers;

To assess and make decisions related to your credit and risk profile and eligibility for credit products;

To maintain and manage any software updates and/or other updates and support that may be required from time to time to ensure the smooth operation of our Services;

To process or facilitate customer service, execute your instructions, process or respond to any inquiries made by you or on your behalf (or allegedly made by you); To manage and/or control your relationship with us or your use of our services, we may contact or communicate with you via voice calls, text messages and/or fax messages, emails and/or postal mail, or other means, such as, but not limited to, conveying administrative information related to our services. You acknowledge and agree that we may communicate in this way by mailing you letters, documents, or notices, which may involve disclosing certain personal data about you to achieve the same delivery and on an outer envelope/mail package;

To allow other users to interact with you, contact you, or view some of your activities on the platform, including notifying you on the platform when other users send you private messages, post comments about you on the platform, or contact you using social features;

To conduct research, analysis, and development activities (including but not limited to data analysis, surveys, product and service development, and/or analysis) to analyze how you use our services, recommend products and/or services relevant to your interests, to improve our services or products, and/or enhance your customer experience;

To allow audits and surveys to verify the size and composition of the target audience and to understand their experience with VEEPEE.G services; For marketing and advertising purposes, and in this regard, we will send you marketing and promotional information and materials related to our products and/or services (including, but not limited to, products and/or services from third parties) through various media and communications in cooperation with or in partnership with products or services that VEEPEE. (and/or its affiliates or related companies) may be selling, marketing or promoting, whether such products or services exist now or will be created in the future. You can unsubscribe from receiving marketing messages at any time using the unsubscribe function in the electronic marketing materials. We may use your contact information to send newsletters or marketing materials from ourselves and our affiliated companies;

to respond to legal proceedings or comply with any applicable laws, governmental or regulatory requirements in any applicable jurisdiction, or where we have a strong reason to believe such disclosure is necessary, including but not limited to fulfilling disclosure requirements under any law binding on Lazada or its affiliated companies or affiliates (including, where applicable, displaying your name, contact details, and company details);

to generate statistical data and research for internal and statutory reporting and/or record-keeping requirements;

to conduct due diligence or other screening activities (including but not limited to background checks) pursuant to legal or regulatory obligations or risk management procedures that may be required by law or that we may have implemented;

to audit our services or the business of VEEPEE.G;

to prevent or investigate any actual or suspected breach of our Terms of Service, fraud, illegal activity, omissions, or misconduct, whether or not related to your use of our services or any other matter arising out of your relationship with us; To respond to any threats or actual claims against VEEPEE.G or other claims that infringe on the rights of any third party;

To store, host, or back up (whether for disaster recovery or otherwise) your personal data, whether within or outside your jurisdiction;

To process and/or facilitate business asset transactions or potential business asset transactions, where such transactions involve VEEPEE.G as a participant, or only involve VEEPEE.G's affiliates or related companies as participants, or involve VEEPEE.G and/or any one or more of VEEPEE.G's affiliates or related companies as participants, and there may be other third-party organizations involved in the transaction. "Business asset transaction" means the purchase, sale, lease, merger, consolidation, or any other acquisition, disposal, or financing of an organization or a part of an organization or any business or asset of an organization; and/or

any other purpose that we notify you of with your consent.

(collectively, the "Purposes").

6.2 You acknowledge, agree, and consent that VEEPEE.G may access, retain, and disclose your account information and content if required by law, pursuant to a court order, or by any government or regulatory body with jurisdiction over VEEPEE.G, or in good faith. VEEPEE.G believes such access, protection, or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with any government or regulatory body with jurisdiction over VEEPEE.G; (c) enforce the VEEPEE.G Terms of Service or this Privacy Policy; (d) respond to any threats or actual claims against VEEPEE.G or other claims that any content infringes on the rights of third parties; (e) respond to your customer service requests; and (f) protect the rights, property, or personal safety of VEEPEE.G, its users, and/or the public.

6.3 Because the purposes for which we/may collect, use, disclose, or process your personal data are subject to current circumstances, the aforementioned purposes may not occur. However, we will notify you of such other purposes with your consent, unless privacy law permits the processing of applicable data without your consent.7. How does VEEPEE.G protect and retain customer information?

7.1 We implement various security measures and strive to ensure the security of your personal data on our systems. User personal data is contained behind a secure network, accessible only to a select few employees with special access to such systems. However, absolute security cannot be guaranteed.

7.2 We will retain personal data in accordance with privacy laws and/or other applicable laws. That is, we will destroy or anonymize your personal data when we reasonably determine that (i) retaining such personal data is no longer necessary for the purpose for which it was collected; (ii) retention is no longer required for any legal or commercial purpose; and (iii) there is no other legitimate interest in further retaining such personal data. If you cease using the platform, or your license to use the platform and/or services is terminated or revoked, we may continue to store, use, and/or disclose your personal data in accordance with this Privacy Policy and our obligations under privacy laws. We may also process your personal data securely without prior notice to you under applicable law.

8. Will VEEPEE.G disclose information it collects from visitors to external parties?

8.1 In conducting our business, we may/may need to use, process, disclose, and/or transfer your personal data to our third-party service providers, agents, and/or our affiliates or related companies and/or other third parties for one or more of the purposes described above. Such third-party service providers, agents, and/or affiliates or related companies and/or other third parties will process your personal data on our behalf or otherwise for one or more of the purposes described above. We strive to ensure that third parties and our affiliates protect your personal data from unauthorized access, collection, use, disclosure, processing, or similar risks, and retain your personal data only for the purposes described above.

Our subsidiaries, affiliates, and related companies;

Buyers or sellers you transact or interact with on the platform, or buyers or sellers related to your use of the services for the purposes described above;

Other users of our platform for one or more of the purposes described above;

Contractors, agents, service providers, and other third parties we use to support our business. These include, but are not limited to, parties that provide us with administrative or other services, such as post offices, logistics service providers, financial service providers, advertising and marketing partners, telecommunications companies, information technology companies, and data centers;

government or regulatory bodies with jurisdiction over VEEPEE.G or permitted under Section 6.2;

the buyer or other successor in the event of a merger, divestiture, reorganization, restructuring, dissolution, or otherwise sale or transfer of some or all of VEEPEE.G's assets (whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings), where the personal data held by VEEPEE.G concerning our service users constitutes the transferred assets; or counterparties in business asset transactions involving VEEPEE.G or any of its affiliates or related companies; and

third parties to whom we disclose data for one or more purposes, and who in turn collect and process your personal data for one or more purposes.