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Privacy Statement

Grobest Group Limited and its affiliates (collectively, “Grobest”, “we”, “our” or “us”) value your privacy. We commit to protect your privacy with the highest level of security. To understand how we process your personal data, please read this Privacy Statement (hereinafter this “Statement”) carefully:

What is personal data?

Personal data means data that can be used to identify, or can reasonably be linked directly or indirectly to, an individual. Identification can be by the data alone or in conjunction with any other data in our possession. Examples of personal data include your name, phone number, address, country of residence, photographs, email address.

What roles do we play in processing your data?

We are the data controller with respect to processing your data. This means that we decide how your personal data is processed and for what purposes. We know that you care how data about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly.

When are your personal data collected?

Your personal data can be collected by us:

whenever you become our customer;
whenever you register with us directly or through our sales agents and distributors, both online (each time you log in) and offline;
whenever you fill in forms and contracts that we send to you;
whenever you use our services and products;
whenever you subscribe to our newsletters, reply to our invitations (for conferences, etc.);
whenever you contact us via the various channels we offer you;
whenever you are filmed by our surveillance cameras located in or near our office premises.

These images are recorded solely for the purpose of protecting property and people’s safety, and for preventing abuse, fraud or other criminal activities from which our customers and ourselves could also become victims (the presence of the cameras are indicated by stickers with our contact details).

Personal data we collect and the purposes of collection

We will use automatic or non-automatic methods permitted by the laws and regulations to collect and process your personal data. The chart below outlines, by the business process involved, the types of personal data we collect under such process, the purpose of collection and processing, and how we process your personal data. Most importantly, we describe how you can manage your personal data with us.

Progress	Online and Offline Registration Registration with our sales agents and distributors
Types of personal data we collect from you	-Name -Email address -Mailing address -Phone number -IP address -Chat and service history -Cookies -Device ID or token, unique identifier, device type -Referral URL -Connection data (type of operating system you use, your software information, browser type, browser language and version, ad data, access times), your browsing history, and your web log information
Purpose of collection and processing and How we process and manage your personal data	We comply with our obligations under applicable privacy laws by keeping your personal data up to date; by storing and destroying it securely; by collecting and retaining only the necessary that we need to service you; by protecting your personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect your personal data. We use your personal data to communicate with you in relation to our sale of products and services to you via different channels. Such data will be used to design our products and services, to take and handle your purchase orders, and to deliver products and services to you. We use your personal data to conduct marketing activities through online and offline channels (including through social media channels such as Facebook and Line), by informing you of our products and services, and to periodically send you newsletters regarding our news, activities and events, new products, and promotional offers. We will use your data to administer sweepstakes, promotions, and contests. You may choose to opt out of these marketing activities at any time (refer to the “Your rights over your data” section below); in such case, we will stop sending you marketing materials or personalized content without undue delay. We use your personal data to identify your interests and preferences, and to recommend products and services that you may be interested in, and to personalize your experience with us. We will also use your personal data to contact you to conduct research about your opinions of current services and products or of potential new services and products that may be offered by us. We use your personal data to customize, measure, and improve our advertising based on your service or advertising preferences. We may use third-party advertising companies to serve ads when you visit our website. These companies may use information about your visits to the website and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you (refer to the “Data transfers” section below).. We use your personal data to provide functionality to our website, to analyze website performance, fix errors and troubleshoot problems, to customize, measure, and improve our services and our advertising, and to improve your website experience and our services, such as sending you service-related announcements when it is necessary to do so. We use your personal data to maintain the integrity and safety of our data technology systems which store and process your personal data. We use your personal data to share your contact details with our sales agents and distributors in your geographic region, so that they can assist us to deliver our services and products to you, and with our affiliate offices around the world within our group companies, for the purposes of internal administration and back-office support, to ensure our network security, and to prevent fraud (refer to the “Data transfers” and “International data transfers” sections below). We use your personal data to comply with our legal obligations under relevant laws, to assist law enforcement authorities and respond to subpoena, to enforce or defend our policies or contract with you, and to detect and investigate data breaches, illegal activities, and fraud. We will store your device and connection data in our user databases for internal analytics purposes, but we will redact the personal data within the online browsing and chat history. We will use your IP address for the following purposes: send the most appropriate banners based on geographic area or information derived from your IP address. estimate the total number of visitors from specific countries or regions all over the world. help to identify customers. You can choose not to provide data to us, but we may then not be able to service you where such services require processing such data. All the data we collect from you may be stored as log files in our server or as augmented information associated with you or your devices. These log files are used for analysis, research, auditing, and other purposes. Your data is stored in log files until the data is transferred to backup databases. We routinely back up a copy of your data to prevent loss of your data in case of a server breakdown or human error. However, all such copies of your data in our backup database will be retained only for as long as our data retention policy permits (refer to the “Retention and Deletion” section below), and will in any case be deleted immediately upon your request.

Progress

Online and Offline Registration
Registration with our sales agents and distributors

Types of personal data we collect from you

-Name
-Email address
-Mailing address
-Phone number
-IP address
-Chat and service history
-Cookies
-Device ID or token, unique identifier, device type
-Referral URL
-Connection data (type of operating system you use, your software information, browser type, browser language and version, ad data, access times), your browsing history, and your web log information

Purpose of collection and processing and How we process and manage your personal data

We comply with our obligations under applicable privacy laws by keeping your personal data up to date; by storing and destroying it securely; by collecting and retaining only the necessary that we need to service you; by protecting your personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect your personal data.

We use your personal data to communicate with you in relation to our sale of products and services to you via different channels. Such data will be used to design our products and services, to take and handle your purchase orders, and to deliver products and services to you.

We use your personal data to conduct marketing activities through online and offline channels (including through social media channels such as Facebook and Line), by informing you of our products and services, and to periodically send you newsletters regarding our news, activities and events, new products, and promotional offers. We will use your data to administer sweepstakes, promotions, and contests. You may choose to opt out of these marketing activities at any time (refer to the “Your rights over your data” section below); in such case, we will stop sending you marketing materials or personalized content without undue delay.

We use your personal data to identify your interests and preferences, and to recommend products and services that you may be interested in, and to personalize your experience with us. We will also use your personal data to contact you to conduct research about your opinions of current services and products or of potential new services and products that may be offered by us.

We use your personal data to customize, measure, and improve our advertising based on your service or advertising preferences. We may use third-party advertising companies to serve ads when you visit our website. These companies may use information about your visits to the website and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you (refer to the “Data transfers” section below)..

We use your personal data to provide functionality to our website, to analyze website performance, fix errors and troubleshoot problems, to customize, measure, and improve our services and our advertising, and to improve your website experience and our services, such as sending you service-related announcements when it is necessary to do so.

We use your personal data to maintain the integrity and safety of our data technology systems which store and process your personal data.

We use your personal data to share your contact details with our sales agents and distributors in your geographic region, so that they can assist us to deliver our services and products to you, and with our affiliate offices around the world within our group companies, for the purposes of internal administration and back-office support, to ensure our network security, and to prevent fraud (refer to the “Data transfers” and “International data transfers” sections below).

We use your personal data to comply with our legal obligations under relevant laws, to assist law enforcement authorities and respond to subpoena, to enforce or defend our policies or contract with you, and to detect and investigate data breaches, illegal activities, and fraud.

We will store your device and connection data in our user databases for internal analytics purposes, but we will redact the personal data within the online browsing and chat history. We will use your IP address for the following purposes:

send the most appropriate banners based on geographic area or information derived from your IP address.
estimate the total number of visitors from specific countries or regions all over the world.
help to identify customers.

You can choose not to provide data to us, but we may then not be able to service you where such services require processing such data.

All the data we collect from you may be stored as log files in our server or as augmented information associated with you or your devices. These log files are used for analysis, research, auditing, and other purposes. Your data is stored in log files until the data is transferred to backup databases. We routinely back up a copy of your data to prevent loss of your data in case of a server breakdown or human error. However, all such copies of your data in our backup database will be retained only for as long as our data retention policy permits (refer to the “Retention and Deletion” section below), and will in any case be deleted immediately upon your request.

Progress	Purchase Orders
Types of personal data we collect from you	-Name -Email address -Mailing address -Phone number -IP address -Service history
Purpose of collection and processing and How we process and manage your personal data	We comply with our obligations under applicable privacy laws by keeping your personal data up to date; by storing and destroying it securely; by collecting and retaining only the necessary that we need to service you; by protecting your personal data from loss, misuse, unauthorized access and disclosure and by ensuring that appropriate technical measures are in place to protect your personal data. We use your personal data to communicate with you in relation to our sale of products and services to you via different channels. Such data will be used to design our products and services, to take and handle your purchase orders, and to deliver products and services to you. We use your personal data to build an internal vendor or customer account file. The information in this file will only be used to provide you with our products and services. We conduct marketing activities through online and offline channels (including through social media channels such as Facebook and Line), by informing you of our products and services, and to periodically send you newsletters regarding our news, activities and events, new products, and promotional offers. You may also choose to opt out of these marketing activities at any time; in such case, we will stop sending you marketing materials or personalized content without undue delay. If you would like to opt out of marketing activities, please click the “unsubscribe” button at the bottom of the newsletter and/or promotional offer, or contact us to exercise your right to withdraw your consent to marketing activities (refer to the “Contact us” section below). We use your personal data to identify your interests and preferences, and to recommend products and services that you may be interested in, and to personalize your experience with us. We will also use your personal data to contact you to conduct research about your opinions of current services and products or of potential new services and products that may be offered by us. We use your personal data to customize, measure, and improve our advertising based on your service or advertising preferences. We may use third-party advertising companies to serve ads when you visit our website. These companies may use information about your visits to our websites and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you (refer to the “Data transfers” section below). We use your personal data to share your contact details with our sales agents and distributors in your geographic region, so that they can assist us to deliver our services and products to you, and with our affiliate offices around the world within our group companies, for the purposes of internal administration and back-office support, to ensure our network security, and to prevent fraud (refer to the “Data transfers” and “International data transfers” sections below). We use your personal data to comply with our legal obligations under relevant laws, to enforce or defend our policies or contract with you, and to detect and investigate data breaches, illegal activities, and fraud. You can choose not to provide data to us, but we may then not be able to service you where such services require processing such data. All the data we collect from you may be stored as log files in our server or as augmented information associated with you or your devices. These log files are used for analysis, research, auditing, and other purposes. Your data is stored in log files until the data is transferred to backup databases. We routinely back up a copy of your data to prevent loss of your data in case of a server breakdown or human error. However, all such copies of your data in our backup database will be retained only for as long as our data retention policy permits (refer to the “Retention and Deletion” section below), and will in any case be deleted upon your request.

Progress

Purchase Orders

Types of personal data we collect from you

-Name
-Email address
-Mailing address
-Phone number
-IP address
-Service history

Purpose of collection and processing and How we process and manage your personal data

We comply with our obligations under applicable privacy laws by keeping your personal data up to date; by storing and destroying it securely; by collecting and retaining only the necessary that we need to service you; by protecting your personal data from loss, misuse, unauthorized access and disclosure and by ensuring that appropriate technical measures are in place to protect your personal data.

We use your personal data to build an internal vendor or customer account file. The information in this file will only be used to provide you with our products and services.

We conduct marketing activities through online and offline channels (including through social media channels such as Facebook and Line), by informing you of our products and services, and to periodically send you newsletters regarding our news, activities and events, new products, and promotional offers. You may also choose to opt out of these marketing activities at any time; in such case, we will stop sending you marketing materials or personalized content without undue delay. If you would like to opt out of marketing activities, please click the “unsubscribe” button at the bottom of the newsletter and/or promotional offer, or contact us to exercise your right to withdraw your consent to marketing activities (refer to the “Contact us” section below).

We use your personal data to customize, measure, and improve our advertising based on your service or advertising preferences. We may use third-party advertising companies to serve ads when you visit our website. These companies may use information about your visits to our websites and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you (refer to the “Data transfers” section below).

We use your personal data to comply with our legal obligations under relevant laws, to enforce or defend our policies or contract with you, and to detect and investigate data breaches, illegal activities, and fraud.

You can choose not to provide data to us, but we may then not be able to service you where such services require processing such data.

What is our lawful basis for processing your personal data?

We generally collect and process your personal data as described above if you provide your explicit consent beforehand, e.g. when establishing contact or obtaining information. This allows you to decide whether you wish to transfer your data to us, to allow us to process your data in the manner described above. We will collect, process and use the personal data supplied by you only for the purposes communicated to you and will not disclose it to third parties other than as mentioned in this Statement. We further detail the circumstances of data disclosure to third parties in the section “Sharing your personal data” below.

The lawful basis for us to process your general personal data is processing with your consent and as necessary for us to enter into and to perform our service contract with you. You also have the right to withdraw your consent to our processing of your data at any time if we are relying on your consent to process your data (refer to “Your rights over your data” section below). If we are not able to obtain a valid consent to process your personal data from you, or if you have withdrawn your consent to our processing your data, we may still collect and process your personal data based on the following legitimate and justifiable interests:

Implementation and operation of a group-wide organizational structure and group-wide information sharing;
Prevention of fraud, misuse of company IT systems, or money laundering;
Operation of a whistleblowing scheme;
Physical security, IT and network security;
Internal investigations;
Complying with governmental and judicial investigations, to initiate or defend legal claims or for the purpose of civil, criminal, or administrative proceedings, or as otherwise required by law (refer to “Data transfers” section below).

In the above circumstances, provided that we are not required by law to process your data, you may object to such processing, and unless we have compelling legitimate grounds for the processing which override your interests, right and freedoms, we will refrain from processing your personal data.

Processing of certain sensitive personal data

In accordance with the applicable privacy laws, we currently do not collect or process the following categories of sensitive data relating to you: your racial or ethnic origin, political opinions, religious beliefs, trade union membership, health data, genetic data, biometric data. In the unlikely event that we have to process this type of sensitive data, we would always request your prior explicit consent, subject to applicable privacy laws.

Necessity to provide us data

You are not under any obligation to provide us any personal data. The choice is yours. However, please note that without certain data from you, we may not able to process your online or offline inquiries or undertake some or all of our obligations to you under our service contract with you, or adequately provide you with our full range of services. If you would like to obtain more detail about this, please contact us following the instructions in the “Contact Us” section below.

Cookies

We may use cookies to collect personal data whenever you visit our website, regardless of whether you provide your data to us. The data collected with these technologies helps us personalize your experience, prevent fraud and enhance the security of our website and service. You can disable or decline some cookies for our website and services. For more details of the collection and use of cookies, please refer to our Cookie Policy.

Retention and deletion

We store your personal data within the following periods, whichever is longer:

within the duration necessary for fulfilling the above purposes;
within the period we are required by applicable laws or regulations to retain the data;
or as long as necessary to assist with any governmental and judicial investigations, to initiate or defend legal claims or for the purpose of civil, criminal, or administrative proceedings.

Data transfers

Your personal data will be treated as strictly confidential and will be shared only with the categories of data recipients listed below. We will only share your data with third-party data controllers outside of the Grobest and our affiliates with your consent, and you will have an opportunity to choose for us not to share your data in such event.

We may disclose your personal data to the following recipients:

Our affiliated entities within our global group of companies and branches worldwide to provide you our services, for internal administration purposes, to detect and deal with data breaches, illegal activities, and fraud, and to maintain the integrity of our information technology systems.
Third party service providers whom we sub-contract to work on our behalf or for us and therefore may have access to your data only for purposes of performing these tasks on our behalf and under obligations similar to those in this Statement, who perform functions such as information processing, auditing, credit reference, managing and enhancing customer data, providing customer service, logistics support, marketing support, informational systems technical support, to help us provide, analyze, and improve our services such as data storage, database management, web analytics, and improvement of our service features, and to assist us in detecting and dealing with data breaches, illegal activities, and fraud.
Our business partners to jointly provide you our services.
Counterparties to merge or acquire all or a portion of our business assets where personal data may be transferred as one of our business assets.
Governments and/or government-affiliated institutions, courts, or law enforcement agencies, to comply with our obligations under relevant laws and regulations, enforce or defend our policies or contracts with you, respond to claims, or in response to a verified request or subpoena relating to a government or criminal investigation or proceeding or suspected fraud or illegal activity that may expose us, you, or any other of our customers to legal liability.
Third parties involved in a legal proceeding, if they provide us with a court order or substantially similar legal procedure requiring us to do so.

We may provide you with opportunities to connect with third party applications or services through our website. If you choose to connect with any such third-party applications or services, we may facilitate sharing of your data, with your prior consent. These third-party applications or services may also send cookies to your device. However, we do not control the applications or services of those third parties or how they use your data, and your use of such applications and services is not governed by this Statement. Please review the terms and the privacy policies of those third parties before using their applications or services.

Most of the advertisements which are sent to your web browser are made by us. At present, we do not allow other companies, called third-party ad servers or ad networks, to provide advertisements on our website.

International data transfers

Grobest is a multinational group with companies and operations worldwide. By using our services and providing us with your data, you hereby acknowledge and agree that we may transfer your personal data to the above-mentioned recipients who may be in countries other than the country in which you reside. Although these countries may have data protection laws that are different to the laws of the country you reside in, we ensure appropriate safeguards in place so that your personal data will remain protected in accordance with this Statement.

Data from Minors

Our products and services are not designed nor intended to be used by children under 16 years of age. If children under such minimum age of the relevant jurisdiction must use our products and services, explicit parental consent must be provided and verified. If we are notified or discover that data collected is from a child under such minimum age, we will take procedures to delete the data as soon as possible.

Your rights over your data

In accordance with applicable data protection laws, you may exercise the following rights over your personal data:

You may request to access your personal data or request a copy of your personal data, provided that your request will not adversely impact Grobest or others’ interests and rights.
You may request Grobest to supplement or correct your personal data, provided that you are able to provide a reasonable explanation.
You may request Grobest to cease processing or erase your personal data, provided that Grobest has no legal grounds to keep processing your personal data.
You may notify Grobest to withdraw your consent to our processing of your personal data at any time, where we rely on your consent to process your data.
You may object to our using your personal data to engage in direct marketing.
You have the right to lodge a complaint regarding our processing of your data, with the competent authority where you reside.

If you would like to exercise any of the above rights, please refer to the “Contact us” section below.

After receiving your request, we will validate your identity, then evaluate your request and inform you how we intend to proceed on your request. Under certain circumstances in accordance with applicable privacy laws and regulations, we may withhold access to your data, or decline your request to modify, erase or restrict the processing of your data.

If you no longer wish to receive correspondences, emails, or other communications from us, you may optout by contacting us using the contact information provided below (refer to “How to contact us” section below).

If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

If you would like to opt out of marketing activities, please click the “unsubscribe” button at the bottom of the newsletter and/or promotional offer, or click the [unsubscribe marketing promotions function] in our website, or contact us to exercise your right to withdraw your consent to marketing activities (refer to the “Contact us” section below).

Security

We have implemented technical and organizational security measures to safeguard the personal data in our custody and control. Such measures include, for example, limiting access to personal data only to employees with a need to know and third parties who need to know such data for the purposes described in this Statement, as well as other administrative, technical and physical safeguards.

While we endeavor to use our efforts protect our systems, databases, website, operations and data against unauthorized access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any data, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.

How to contact us

If you have any questions about this Statement or intend to exercise any of your rights over your data, you may notify us by clicking “Contact Us” > “Send the Request” on our website, or you may send us an email to our Privacy Department using the following mailbox: communications@grobest.com.

Changes to Statement

We may make amendments to this Statement when needed to reflect changes in our privacy practice. We will notify you of such amendment through our website or send the amendment to your email address. We encourage you to regularly review this Statement to understand how your data is handled.

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