1. Introduction

1.1

Welcome to the Cdiscount platform operated by Cdiscount Southeast Asia Limited and its affiliates (the “Platform”). Cdiscount 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 Cdiscount website and mobile application (the “Platform”) (collectively, the Platform and the services we provide are referred to as the “Services”).

“Users” refers to individuals who register an account to use the Services, including both buyers and sellers (individually or collectively, “Users,” “you,” or “your”). We recognize the importance of the personal data you entrust to us and consider it 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 hold about you, whether now or in the future, and to help you make an informed decision before providing any personal data.

1.2

“Personal Data” or “personal information” means data that identifies an individual, whether true or not, or data that can be used in combination with other information to identify an individual. Common examples of personal data include your name, identification number, and contact information.

1.3

By using the Services, registering an account, visiting the Platform, or accessing the Services, you acknowledge and agree to accept the practices, requirements, and policies set out in this Privacy Policy, and you consent to our collection, use, disclosure, and/or processing of 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 the Services or access the Platform. If we update this Privacy Policy, we will notify you, including by posting the changes or the updated Privacy Policy on the Platform. We reserve the right to modify this Privacy Policy at any time. To the fullest extent permitted by applicable law, your continued use of the Services or Platform, including placing any orders, constitutes your acknowledgment and acceptance of any changes made to this Privacy Policy.

1.4

This Policy applies in conjunction with other notices, contractual terms, or consent clauses that apply to the collection, storage, use, disclosure, and/or processing of your personal data by us. This Policy is not intended to override those notices or clauses unless expressly stated otherwise.

1.5

This Policy applies to both buyers and sellers who use the Services, except where expressly stated otherwise.

2. When Does Cdiscount Collect Personal Data?

2.1

We will/may collect personal data about you in the following circumstances:

• When you register and/or use our Services or Platform, or open an account;

• When you submit any forms, including but not limited to application forms or other forms related to our products or services, whether online or offline;

• When you enter into any agreement or provide documentation or information regarding your interactions with us, or when you use our products or services;

• When you interact with us via phone (which may be recorded), letters, fax, face-to-face meetings, social media platforms, or email, including interactions with our customer service representatives;

• When you use our electronic services, interact via our app, or use Services on the Platform, including but not limited to cookies deployed when you interact with our app or website;

• When you grant permissions on your device to share information with our app or Platform;

• When you link your Cdiscount account with social media or other external accounts, or use social media features, in accordance with the provider’s policies;

• When you carry out transactions through our Services;

• When you provide feedback or complaints;

• When you register for contests or promotions;

• When you provide us with personal data for any other reason.

The above is not exhaustive but highlights common situations when we may collect your personal data.

3. What Personal Data Does Cdiscount Collect?

3.1

Cdiscount 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;

• Telephone number;

• Gender;

• Information from or associated with devices used to access the Services or Platform;

• Information about your network and accounts you interact with;

• Photographs or audio/video recordings;

• Government-issued identification or other information required for due diligence, Know Your Customer (KYC), identity verification, or fraud prevention;

• Marketing and communications data, such as your preferences for receiving marketing from us or third parties, communication history, and preferences;

• Usage and transaction data, including your searches, orders, interactions with ads and content on the Platform, and other product/service interactions;

• Location data;

• Other information provided during registration or use of the Services/Platform, as well as information regarding your use of the Services/Platform;

• Aggregate data regarding content the user engages with.

3.2

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

3.3

If you register using a social media account, link your Cdiscount account to a social media account, or use any Cdiscount social media features, we may access information you voluntarily provide to your social media provider and will handle such personal data in accordance with this Policy.

3.4

If you do not want us to collect the above information/personal data, you may opt out at any time by notifying our Data Protection Officer in writing. Opting out may affect your use of the Services and Platform; for example, disabling location collection may prevent location-based features.

4. Collection of Other Data

4.1

Like most websites and mobile apps, your device sends information that may include data about you, which can be logged by a web server when you browse the Platform. This typically includes, but is not limited to: IP address, operating system and browser type, device type and characteristics, device unique identifier (UDID or MEID), referring website, pages visited and times of visits, and cookies (which can be disabled via browser settings). If logged in, this information is associated with your personal account and included in anonymous statistics to analyze Platform usage.

4.2

Our mobile applications may collect precise location information using technologies such as GPS or Wi-Fi to provide location-based services you request, deliver location-relevant content, or allow sharing your location with other users. You can withdraw permission through your device settings.

4.3

When viewing pages, content, or advertisements, or using software on the Platform or Services, similar data is sent to us, including information on content, ads, or installed software and time.

5. Cookies

5.1

We or our authorized service providers and advertising partners may use cookies or other features to collect or share information, improve the Platform and Services, provide new features, or serve relevant content via remarketing. Cookies are stored on your device and may be linked to personal data.

5.2

You can refuse cookies through your browser or device settings, but some Platform or Service functionality may be affected.

6. How Do We Use Your Information?

6.1

We may collect, use, disclose, and/or process your personal data for purposes including but not limited to:

• Processing transactions, applications, or communications with third parties;

• Managing and operating Services and Platform, including remembering preferences;

• Responding to requests, completing transactions, and notifying service issues;

• Enforcing Terms of Service or end-user license agreements;

• Protecting rights, property, and safety;

• Identification, verification, due diligence, or KYC;

• Credit evaluation and risk management;

• Software updates and support;

• Customer service and responding to instructions or inquiries;

• Communication via phone, SMS, fax, email, or mail;

• Enabling other users to interact with or view some of your activities;

• Research, analysis, and product/service development;

• Audits, surveys, and statistical analysis;

• Marketing and advertising;

• Compliance with legal, governmental, or regulatory requirements;

• Internal or statutory reporting;

• Due diligence or risk management;

• Auditing services or Cdiscount business;

• Preventing or investigating violations, fraud, or misconduct;

• Responding to claims or third-party rights violations;

• Storing, hosting, or backing up personal data;

• Handling or assisting business asset transactions;

• Any other purposes for which we obtain your consent.

Collectively, these are referred to as the “Purposes.”

6.2

You acknowledge and consent that Cdiscount may access, preserve, and disclose your account information and content if required by law, court order, or governmental/regulatory authority, or if reasonably necessary to enforce Terms, respond to claims, provide customer service, or protect rights, property, or safety.

6.3

The specific purposes for collecting, using, disclosing, or processing personal data may vary depending on circumstances. We will notify you of additional purposes at the time of obtaining consent, unless permitted by law without your consent.

7. How Does Cdiscount Protect and Retain Customer Information?

7.1

We implement various security measures to ensure the safety of your personal data. User data is stored behind secure networks and is only accessible to a limited number of employees with special access rights. Absolute security cannot be guaranteed.

7.2

We retain personal data in accordance with Privacy Laws and other applicable laws. We will destroy or anonymize personal data when we reasonably determine that:
(i) the purpose of collection is no longer served;
(ii) retention is no longer legally or commercially necessary;
(iii) no other legitimate interest requires further retention.
If you cease using the Platform or your access is withdrawn, we may continue to store, use, or disclose your data in accordance with this Policy and legal obligations. We may securely dispose of personal data without prior notice.