Privacy Policy

Your privacy matters to us. In this Goboo Privacy Notice Platform Users we explain how Goboo Singapore E-Commerce Private Limited (“Goboo”) collects, uses and processes your personal data collected through our online platform, and our interactions with you via this online platform (together “Goboo Services”).

We may change this Goboo Privacy Notice Platform Users from time to time. At all times, we will publish the up-to-date version on our website and in our mobile application, together with a summary of key changes. For this reason, we suggest that you review this Goboo Privacy Notice Platform Users on a regular basis.  If we make any important changes to this Goboo Privacy Notice Platform Users (e.g. with regard to the personal data we collect, how we use it or why we use it), we will notify you.

1.           Who is the data controller?

 

Goboo Singapore E-Commerce Private Limited is the controller of the personal data processed on our platform.

 

If you have any questions or complaints in relation to the use of your personal data or if you would like to receive more information about how Goboo processes your personal data, please contact us via feedback@goboo.com

 

2.           What types of personal data do we collect?

 

Via our mobile platform, we collect, store, and use the following personal data about you.

 

Type of personal data

Details

Personal data relating to you as a consumer

·         Account personal data, such as your user-ID, password, mobile phone number, nick name, gender, region, language. In addition, if you sign up with a social media account, your social media account information such as your user access token.

 

·         Order data, such as recipient's address, location, name, e-mail address, postal code, shipping address, invoice number, delivery number, parcel order number, consignment, express courier ID, and purchase history.

 

·         After-sales and customer service data, such as user after-sales activities, after-sales quantity, delivery number, invoice voucher, pictures.

Personal data relating to you as a merchant

·         Account personal data, such as your company’s business address and license, trademark registration certificate (if the merchant is an individual or sole proprietor), and contact details of the company’s legal and contact person such as name and phone number.

Personal data relating to your use of our platform

 

·         Personalized data, such as your Google Advertising ID, favorited commodities, searched keywords, clicking and browsing behaviour and product preferences.

 

·         Equipment data, such as your equipment type, IMEI-number and (mobile) operating system and version.

Personal data relating to your use of our communications functionality

 

 

·         Communication data, such as your chat conversations, user ID, nickname, chat time, and satisfaction rating.

 

3.           How do we obtain your personal data?

 

Your personal data is (i) provided by you; (ii) obtained from third parties (e.g. Facebook, Google, Twitter, YouTube and Apple); and/or (iii) created by us in the course of your usage of our platform.

 

4.           Why do we process your personal data and what is applicable legal basis for our data processing?

 

Please find below an overview of each of the purposes for which we process your personal data as set out in paragraph 2 and the legal basis relied upon.

 

Purpose

Legal basis

Keeping and maintaining accurate and adequate merchants’ account administration

Necessary for the performance of a contract (if the merchant is an individual or sole proprietor), or necessary to meet our legitimate interests (if the merchant is a legal entity, namely in maintaining an adequate merchants administration).

To authorize merchants’ business scope in the interest of consumers

Necessary for the performance of a contract (if the merchant is an individual or sole proprietor), or necessary to meet our legitimate interests if the merchant is a legal entity, namely.

Keeping and maintaining accurate and adequate user administration, including user verification

Necessary for the performance of a contract, namely the Goboo User Agreement

Creating analytical reports for improvement of the platform and products

Necessary for the purpose of our legitimate interest, namely to maintain and improve our platform’s performance

Facilitating customer service, including communications such as chat services

Necessary for the purpose of our legitimate interest, namely to provide information and customer services

Facilitating after-sales services

Necessary for the purpose of our legitimate interest, namely to provide after care

Assessing and tracing customer service quality and results

Necessary for the purpose of our legitimate interest, namely to improve the quality and results of our customer service

Keeping and maintaining accurate and adequate purchase administration, including ensuring correct logistics delivery, facilitating financial reconciliation and accounting

Necessary for the performance of a contract, namely our purchase agreement with you, as well as necessary to meet our legitimate interests in maintaining an adequate business administration.

Maintaining and ensuring a secured online environment on our platform

Necessary for the purpose of our legitimate interest, namely to maintain a secure online environment on our platform, including to prevent and detect fraud and abuse in order to protect the security of our customers, Goboo and others.

Sending and analysing direct marketing communications, including newsletters, events, and product campaigns

Consent

Customizing your platform experience to your preferences, including sending push notifications

Consent

To determine your preferences, including to create personalized recommendations.

Consent

Authorization of vouchers and the user’s precise location

Consent

 

5.           Who do we share the personal data with?

 

To the extent applicable, we will disclose or share your personal data to / with the following third party:

 

Party

Purpose

Google Inc.

For the placement of (personalized) advertisements

Airwallex (Hong Kong) Limited

For the management of merchants’ cash-outs

 

Further, we may disclose or share your personal data if:

·            we sell our company or part thereof (including separate assets), or if we merge with another company. In such event, we may share your personal data with the new owner or merging party respectively, but only to the extent necessary for the purpose for which your personal data are processed;

·            we are subject to insolvency proceedings, as part of the sale of our assets by a liquidator (or similar); or

·            we are legally obliged to do so. In such event we shall share your personal data with the relevant supervisory authority, investigative authority or other governmental body.

 

6.           Third Party sites

 

              Our platform may contains links to websites operated by third parties (e.g. Facebook and Google). This Goboo Privacy Notice Platform Users does not apply to these third party website or services. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms and conditions and that we do not accept any responsibility or liability for their policies. Links should be clicked at your own risk, and it is your sole responsibility to review the applicable privacy policy and terms and conditions of any third party website accessed.

 

7.           What about Cookies?

 

To enable our systems to recognize your browser or device and to provide and improve Goboo –Services, we use cookies and other identifiers. For more information about cookies and how we use them, please read Goboo Cookies Policy.

 

8.           How long do we retain your personal data?

 

We do not process your personal data any longer than necessary for the processing purpose.

 

In this context, we keep your personal data for as long as your account is active. If your account has been inactive for a period of two years, counting from the moment of your last usage of the mobile application, Goboo will ask you whether you intend to keep your account. If you express that you do not wish to keep your account or if you do not respond to this notification, we will delete your account including all personal data from our server and back-up servers.

 

You can deactivate your account by sending an email to feedback@gooboo.com. Your entire account including all your personal data will then be deleted from our server.

If we are subject to a statutory retention period, we will retain your personal data for the period specified by the law.

 

Notwithstanding the above, we may retain your personal data for the establishment, exercise or defence of legal claims. Likewise, we may retain your personal data in order to make it available to the public prosecutor, the courts and public administrations for the period specified by the law.

 

In some circumstances, we may anonymize your personal data so that it can no longer be associated with you, in which case we may use such personal data without further notice to you.

 

9.           Where do we store your personal data?

 

Your personal data is stored in Germany, which means that it is stored within the European Economic Area (EEA). If you purchase goods on our platform, your personal data is also stored in China. This means that your personal data is also stored in a location outside of the European Economic Area (EEA).

 

In case of transfers of personal data to countries outside the EEA, in particular to China, we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the Standard Contractual Clauses of the European Commission (article 46(2)(c) GDPR). For more information on these Standard Contractual Clauses, please see here.

 

10.        What are your rights?

You have the right to access your personal data, the right to have your personal data rectified or erased, the right to restriction of the processing, the right to data portability and the right to object to the processing. Most of these rights are not absolute and are subject to exemptions in the law.

Below we set out your rights in more detail and give information on how you can exercise these. We will respond to your exercise of right request within one month, but have the right to extend this period to two months. If we extend the response period, we will let you know within one month from your request.

 

·            Access: you are entitled to ask us if we are processing your personal data and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If your request is clearly unfounded or excessive we reserve the right to charge a reasonable fee or refuse to comply in such circumstances.

·            Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected.

·            Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances. There are certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with legal claims.

·            Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

·            Data portability: you may request the transfer of a copy of certain of your personal data to you or another party (if technically feasible). You have the right to ask that we provide your personal data in an easily readable format to another company.

·            Objection: where we are processing your personal data based on our legitimate interest, you may object to processing on this ground. However, applicable laws may allow us to continue processing your personal data based on our legitimate interests.

Where you have provided your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. The withdrawal of your consent does not affect the lawfulness of the processing based on your consent before its withdrawal.

If you want to exercise any of these rights, or withdraw your consent, please contact at us at feedback@goboo.com, or use the feedback channel on our platform.

 

11.        How can you lodge a complaint with a supervisory authority?

 

If you have any complaint about the way we process your personal data, you may lodge a complaint with a supervisory authority in the country of your residence, where you work or where an alleged infringement of the applicable data protection law took place. A list of EU supervisory authorities and their contact details is available here.

 

Last updated: February 20th, 2021