1. INTRODUCTION

1.1 Welcome to the Entresell website run by Entresell Private Limited. Entresell takes its responsibilities under applicable privacy laws and regulations seriously and is committed to respecting the privacy rights and concerns of all users of Entresell. 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 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 By using the Entresell website, and registering for an account on it, 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 or access our website. If we change our Privacy Policy, we will notify you including by posting those changes or the amended Privacy Policy on Entresell. We reserve the right to amend this Privacy Policy at any time. To the fullest extent permissible under applicable law, your continued use of Entresell, including placing of any orders, shall constitute your acknowledgment and acceptance of the changes made to this Privacy Policy.

1.3 This Private Policy applies to both buyers and sellers who use the Entresell website except where expressly stated otherwise.

2. WHEN WILL ENTRESELL COLLECT PERSONAL DATA?

2.1 We will/may collect personal data about you:

when you register and/or use the Entresell website, or open an account on it;

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 or interact with Entresell via our website. This includes, without limitation, through cookies which we may deploy when you interact with our website;

when you link your Entresell 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 Entresell;

when you provide us with feedback or complaints;

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 ENTRESELL COLLECT?

3.1 The personal data that Entresell 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 the Entresell website;

information about your network and the people and accounts you interact with;

photographs or audio or video recordings that you share with us;

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 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 Entresell website, and other Products and Services related to you;

location data;

any other information about the user when the user signs up to use the Entresell website, and when the user uses the Entresell website, as well as information related to how the user uses the Entresell website; 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 do not want us to collect the aforementioned information/personal data, you may opt out at any time by notifying our us in writing via support@entresell.com. 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 Entresell website. 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 the Entresell website. 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 As when you view pages on the Entresell websiute, 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 viewed.

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 Entresell. These features help us improve our website, help us offer new features, and/or enable us and our advertising partners serve more relevant content to you, including through remarketing. 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, and to conduct data analysis and to monitor usage of Entresell.

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 the Entresell website.

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 via the Entresell website;

to manage, operate, provide and/or administer your use of and/or access to the Entresell website (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 & Conditions 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 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 website;

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, email or otherwise for the purposes of administering and/or managing your relationship with us or your use of Entresell, such as but not limited to communicating administrative information to you relating to Entresell. 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 or connect with you;

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 the Entresell website, to recommend products and/or services relevant to your interests, to improve the Entresell website or Products/Services 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 the Entresell;

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 Entresell may collaborate or tie up with) that Entresell (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.

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 Entresell 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 Entresell or Entresell’s business;

to prevent or investigate any actual or suspected violations of our Terms & Conditions, fraud, unlawful activity, omission or misconduct, whether relating to your use of the Entresell website or any other matter arising from your relationship with us;

to respond to any threatened or actual claims asserted against Entresell 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 Entresell as a participant or involves only a related corporation or affiliate of Entresell as a participant or involves Entresell and/or any one or more of Entresell’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.

6.2 You acknowledge, consent and agree that Entresell 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 Entresell 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 Entresell; (c) enforce the Entresell Terms & Conditions or this Privacy Policy; (d) respond to any threatened or actual claims asserted against Entresell 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 Entresell, 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 applicable privacy laws and regulations.

7. HOW DOES ENTRESELL 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 applicable privacy laws and regulations 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 Entresell website, or your permission to use the Entresell website 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 applicable privacy laws and regulations. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.

8. DOES ENTRESELL DISCLOSE THE INFORMATION IT COLLECTS FROM ITS VISITORS TO OUTSIDE PARTIES?

8.1 In conducting our business, we will/may need to use, process, disclose and/or transfer your personal data to third parties, which may be located in Singapore or outside of Singapore, for one or more of the purposes listed in 6.1. Such third parties would be processing your personal data either on our behalf or otherwise, for one or more of the purposes listed in 6.1. We endeavour to ensure that the third parties keep your personal data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain your personal data only for as long as your personal data is needed for the purposes listed in 6.1. Such third parties include, without limitation:

buyers or sellers you have transacted with or interacted with on the Entresell website or in connection with your use of the Entresell website for the purposes listed in 6.1;

other users of the Entresell website for one or more of the purposes listed in 6.1;

contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those parties which provide administrative or other services to us such as mailing houses, logistics service providers, financial services providers, advertising and marketing partners, telecommunication companies, information technology companies, and data centres;

governmental or regulatory authorities having jurisdiction over Entresell or as otherwise permitted under Section 6.2;

a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Entresell’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by Entresell about our Users is among the assets transferred; or to a counterparty in a business asset transaction that Entresell or any of its affiliates or related corporations is involved in; and

third parties to whom disclosure by us is for one or more of the purposes listed in 6.1 and such third parties would in turn be collecting and processing your personal data for one or more of the purposes listed in 6.1.

8.2 We may share user information, including statistical and demographic information, about our users and information about their use of the Entresell website with advertising partners and third party suppliers of advertisements, remarketing, and/or other programming.

8.3 For the avoidance of doubt, in the event that the applicable privacy laws and regulations or other applicable laws permit an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the laws shall continue to apply. Consistent with the foregoing and subject to applicable law, we may use your personal data for recognized legal grounds including to comply with our legal obligations, to perform our contract with you, to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights, or where necessary in connection with a legal claim.

8.4 Third parties may unlawfully intercept or access personal data transmitted to or contained on the Entresell website, technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of ours. We will nevertheless deploy reasonable security arrangements to protect your personal data as required by the applicable privacy laws and regulations; however there can inevitably be no guarantee of absolute security such as but not limited to when unauthorised disclosure arises from malicious and sophisticated hacking by malcontents through no fault of ours.

8.5 As set forth in Entresell’s Terms & Conditions, users (including any employees, agents, representatives, or any other person acting for such user or on such user’s behalf) in possession of another user’s personal data through the use of the Entresell website hereby agree that, they will (i) comply with all applicable privacy laws and regulations with respect to any such data, including any collection, processing, storage or transfer or transfer of such data; (ii) allow Entresell or the user whose personal data they have collected to remove such data from their database; and (iii) allow Entresell or the person(s) whose data is being collected, to review such collected data, in each case of (ii) and (iii) above, in compliance with and where required by applicable laws.

8.6 Notwithstanding anything set forth herein, Sellers (including any employees, agents, representatives, or any other person acting for such User or on such User’s behalf) shall comply with all applicable privacy laws and regulations and, in respect of any buyer’s personal data received from the Entresell website, (i) are not permitted to use such buyer’s personal data except as reasonably necessary to respond to buyers’ enquiries and to carry out respond to, process, deal with or complete a transaction without the buyers’ and Entresell’s prior written consent; (ii) should refrain from contacting buyers using such information outside of the Entresell website; (iii) are not permitted to disclose such buyer’s personal data to any unauthorized third parties without the buyer’s and Entresell’s prior written consent; (iv) shall employ sufficient security measures to protect each Entresell user’s personal data in their possession, retain such data only for as long as necessary for the purposes above and in accordance with the applicable privacy laws and regulations, and to delete or return such data to Entresell upon any request from Entresell or as soon as reasonably possible upon completion of the transaction; and (v) to inform us at support@entresell.com in the event of any potential data breach or other loss of such user’s data.

9. INFORMATION ON CHILDREN

9.1 Entresell is not intended for children under the age of 13. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 13 nor is any part of Entresell directed to children under the age of 13. As a parent or legal guardian, please do not allow such children under your care to submit personal data to Entresell. In the event that personal data of a child under the age of 13 in your care is disclosed to Entresell, you hereby consent to the processing of the child’s personal data and accept and agree to be bound by Entresell’s Privacy Policy on behalf of such child. We will close any accounts used exclusively by such children and will remove and/or delete any personal data we believe was submitted without parental consent by any child under the age of 13.

10. INFORMATION COLLECTED BY THIRD PARTIES (CONFIRM WITH ERIC IF WE ARE USING GOOGLE ANALYTICS)

10.1 Entresell uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your device, to help Entresell analyse how users use the Entresell website. The information generated by the cookie about your use of Entresell (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Entresell website, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

10.2 We, and third parties, may from time to time make software applications downloads available for your use via the Entresell website. These applications may separately access, and allow a third party to view, your identifiable information, such as your name, your user ID, your device’s IP Address or other information such as any cookies that you may previously have installed or that were installed for you by a third party software application or website. Additionally, these applications may ask you to provide additional information directly to third parties. Third party products or services provided through these applications are not owned or controlled by Entresell. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise.

11. DISCLAIMER REGARDING SECURITY AND THIRD PARTY SITES

11.1 We do not guarantee the security of personal data and/or other information that you provide on third party sites.

11.2 In an attempt to provide you with increased value, we may choose various third party websites to link to, and frame within, the Entresell website. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our visitors. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third party web sites (even if offered on or through the Entresell website) may not be received by us.

11.3 We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for your convenience and you therefore access them at your own risk. Nonetheless, we seek to protect the integrity of Entresell and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).

12. WILL ENTRESELL TRANSFER YOUR INFORMATION OVERSEAS?

12.1 Your personal data and/or information may be transferred to, stored or processed outside of your country for one or more of the purposes listed in 6.1.

13. HOW CAN YOU WITHDRAW CONSENT, REQUEST ACCESS TO OR CORRECT INFORMATION YOU HAVE PROVIDED TO US?

13.1 Withdrawing Consent

13.1.1 You may withdraw your consent for the collection, use and/or disclosure and/or request deletion of your personal data in our possession or under our control by sending an email to us at support@entresell.com, and we will process such requests in accordance with this Privacy Policy and our obligations under the applicable privacy laws and regulations and other applicable law. However, your withdrawal of consent may mean that we will not be able to continue providing the services Entresell offers to you and we may need to terminate your existing relationship and/or the contract you have with us.

13.2 Requesting Access to or Correction of Personal Data

13.2.1 If you have an account with us, you may personally access and/or correct your personal data currently in our possession or control through the My Account page on the Entresell website. If you do not have an account with us, you may request to access and/or correct your personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request so as to be able to deal with your request. Hence, please submit your written request by sending an email to us at support@entresell.com.

13.2.2 We may charge you a reasonable fee for the handling and processing of your requests to access your personal data. If we so choose to charge, we will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.

13.2.3 We reserve the right to refuse to correct your personal data in accordance with the provisions as set out in the applicable privacy laws and regulations, where they require and/or entitle an organisation to refuse to correct personal data in stated circumstances.

14. QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US

14.1 If you have any questions or concerns about our privacy practices, we welcome you to contact us by e-mail at support@entresell.com.