listing

Privacy and cookies policy

Privacy Policy

Introduction

We at W Cloud Technologies (“We” or “Our” or “Us” or “Company”) understand that you as a user (“You” or “Your” or “Yourself” or “User”) care about how Your information is used and shared. We take Your privacy seriously and are committed to complying with applicable laws and regulations governing privacy (“Data Protection Laws”). We understand Our responsibility to appropriately manage, protect and process the information We collect from You.

This Privacy Policy ("Privacy Policy" or "Policy") is supplemental to our Terms of Use and is designed to help You understand how We collect, use, disclose, and/or process the information collected and received in the course of Your use of the Facilities (as defined in Our Terms of Use) or website http://COCOlisting.com (the “Platform”). By visiting the Platform or accessing and/or using the Facilities or any other services We may offer from time to time on the Platform in any manner, You acknowledge that You have read and accepted, and are subject to, the practices and policies outlined in this Policy and that You consent to Us collecting, using, disclosing and/or processing Your information as described in this Privacy Policy. The Company reserves the right to amend or modify this Privacy Policy at any time within the limits permitted by applicable Data Protection Laws. Such amended or modified Policy shall be published on the Platform. Your continued access to or use of the Platform and/or the Facilities following such modification shall be deemed acceptance of the modified Policy. 

If You do not consent to the processing of your information as described in this Privacy Policy, please do not access the Platform or use Our Facilities.

Capitalized terms used but not defined herein shall have the same meaning ascribed to them under the Terms of Use, unless specified otherwise.

Applicability

This Policy is applicable to all Users of the Platform and/or Facilities including Buyers, and Sellers unless explicitly stated otherwise.

When Do We Collect Information from You?

We may collect Your information when:

  1. Your access and/or use Our Platform or Facilities or register a User Account with Us.
  2. You submit forms, including but not limited to application forms or other forms related to the Products or Services, whether online or in physical form.
  3. You list any Product or Service or make any other Listing on the Platform.
  4. You enter into any agreements or provide documents or other information relating to your communication with Us or when You use our Facilities.
  5. You contact us through various channels, such as phone calls (which may be recorded), letters, faxes, social media platforms (including Telegram, WhatsApp, etc.), and emails, including when You contact Our customer service agents.
  6. You use electronic services or communicate with Us through the Platform, including but not limited to cookie usage, which We may implement when You use or access the Platform.
  7. You authorize, through Your device, the disclosure of any information to Our Platform.
  8. You link Your User Account to your online social media accounts or other User Accounts or use other social media features offered on the Platform.
  9. You engage in transactions through the Platform.
  10. You provide feedback or file complaints with Us.
  11. You register to participate in competitions or other activities, if any, offered by Us on the Platform.
  12. You provide your personal data to Us for any other reason.

Kindly note that the above is not an exhaustive and detailed representation of how We collect personal data about You. We may collect Your information from You, third parties, and other sources, including but not limited to business partners (such as payment service providers), credit assessors, credit data providers, marketing service providers, referral programs, public data, or data from government agencies, etc.

In some cases, You may provide information or personal data of other individuals to Us (such as family members (spouses, children, parents, and/or employees). If You provide such information or personal data to Us, You confirm and certify that You have obtained the consent of the relevant individuals for the processing of their personal data in accordance with this policy.

What Information Do We Collect From You?

We may collect and receive the following information from You. Kindly note that not all of Our Facilities or Your access to the Platform collects all of the information mentioned below.

  1. Credentials of Your User Account such as username.
  2. Profile information such as name, gender, email address, profile photograph, contact information, date of birth, etc.
  3. Information required for payment services (if any), such as credit or debit card number, bank account details, contact information, etc.
  4. Identification numbers such as national ID card, passport, NRIC/FIN number, or any other identity documents issued by respective government agencies and corresponding address.
  5. Information relating to location such as location from where Platform was accessed, last known location, etc.
  6. Data/ information sent or connected to devices used to access the Platform such as information about Your network, including Your contact list when You provide consent through Your devices or any person or Account you contact and any images, audio, or recorded videos when You upload such information on the Platform or when You provide consent through Your devices.
  7. Any other information disclosed by You in any of the above-mentioned ways and/or through the use of Our Facilities.
  8. Aggregate data collected during Your use of the Platform such as transaction and usage data, including details of product searches, order details, advertising views, and content on the Platform, and information related to Products and Services associated with You.
  9. Any communications between You and another User on the Platform.

You agree not to provide any inaccurate or misleading information to Us, and You agree to notify Us of any inaccuracies or changes to that information. We reserve the right to request additional supporting documents to verify any data/ information You provide to Us as We deem necessary.

If You do not wish to allow Us to collect the mentioned information/personal information, You may cancel at any time through the Platform. However, please note that canceling the collection of information/ personal data or withdrawing consent for its collection, use, or processing by Us may affect Your use of Our Facilities. For instance, canceling the collection of location-related data will lead to disabling of location-based features.

Communication with other Users

The Platform allows Users to connect and interact with other Users and to share information with each other to complete a transaction. The Company advises You to exercise caution and use of good judgment while sharing Your information with other Users. The Company does not usually monitor such information, nor does it remove/ delete it after Your Account has been deactivated, terminated or otherwise closed. You shall be solely responsible for the information You share with other Users on the Platform or elsewhere.

Purpose of Collecting Your Information

We may collect, use, disclose, and/or process your Information for the following purposes and any other purposes which will be notified to You by Us at the time of obtaining Your consent:

  1. To verify Your identity, update Our records, and for maintaining Your Account on the Platform.
  2. To provide You with the Facilities on the Platform
  3. To show a relevant and custom list of Products and/or Services to You.
  4. To develop, operate, improve, deliver, and maintain the Platform
  5. To evaluate and/or process Your submissions/transactions with Us, or Your interactions or communications with third parties through Our Facilities
  6. To respond to, process, manage, or complete transactions and/or fulfill requests regarding Your Products and Services, and to notify You of any service-related issues or Account abnormalities.
  7. To enforce the Terms of Use
  8. To safeguard the security, personal rights, or property of individuals and the security of other information/ personal data.
  9. To assess and/or approve Your creditworthiness and capabilities for loans, installment payments, or any credit-related products, as applicable.
  10. To manage or facilitate customer service, fulfill Your requests, handle or respond to inquiries received (or purportedly received) from You or on Your behalf.
  11. To contact or communicate with You through voice calls, messages, and/or fax, email, and/or postal mail, or in any other form, for the purpose of Your use of Our Facilities. You acknowledge and accept that such communication from Us may be in the form of correspondence, or documents to authorize other individuals to interact, connect with You, or observe certain activities of Yours on the Platform. This may also include notifying You when other Users send private messages, post comments about You on the platform, or connect with You using other online social media features, as well as messengers like Telegram, WhatsApp, Line, or others which You may mention in Your public profile, which may involve the disclosure of certain personal data on the outside of the envelope/package for delivery purposes.
  12. To allow others to interact with You, connect with You, or see some of Your activities on the Platform, and also to notify You when other Users send private messages, post comments for You on the Platform, or connect with You using other features on the Platform.
  13. For research, analysis, and development of various activities (including but not limited to data analysis, surveys, development of Facilities, and/or analyzing data based on Your interests or behavior) to analyze service usage, recommend Products and/or Services based on Your interests, improve Our Facilities, and/or enhance customer experiences.
  14. To verify and conduct surveys
  15. To send out communications for marketing and advertising purposes, in various methods and formats. You can unsubscribe from receiving marketing information at any time by selecting the unsubscribe function provided in electronic media. We may use Your contact information to send marketing materials from Us or related companies.
  16. To facilitate continuous customer programs, joint sales promotions with partners, loyalty programs, offers, and other joint marketing activities, the seller offers, or co-branded credit cards, which collaborate with Us.
  17. To respond to legal processes or comply with or as required by applicable laws, statutory provisions, or under relevant regulatory authority, or when We believe in good faith that the disclosure of Your information is necessary. This includes but is not limited to, complying with the provisions for data disclosure according to the laws that the Company is obliged to comply with (including using your name, contact information, and company name, if applicable).
  18. To compile statistical data and conduct research for internal reporting and/or as required by law and/or as required by data storage requirements.
  19. To perform background checks or other screening processes (including but not limited to background checks) as required by law or regulations or as part of Our risk management processes, which are either prescribed by law or implemented by Us.
  20. To prevent and investigate violations or suspected violations of Our Terms of Use, fraud, illegal activities, negligence, or misconduct, whether related to the use of Our Facilities or any other activities arising from Your use of the Platform.
  21. To respond to claims or threats made against the Company or other claims alleging infringement of the rights of others.
  22. To store, host, and back up (whether for recovery from damage or any other reasons) your personal data, whether within or outside the jurisdiction of the competent authority.

You acknowledge, agree, and consent that the Company may access, store, and disclose information in Your User Account, including content, in cases where it is required by law, court orders, or any orders from government agencies, authorities with jurisdiction over the Company or under any legal or regulatory process or based on good faith belief that such actions are necessary to: (a) comply with any applicable laws, (b) comply with orders from any government agencies or authorities with jurisdiction over the Company, (c) enforce the Terms of use and Privacy Policy, (d) comply with any demands, whether by threat or in truth, made against the Company on the ground that any Listing/ content violates any third party rights, (e) comply with Your requests regarding customer service, or (f) protect the rights and maintain the security of the Company’s property, Users, and/or the public.

In addition to the aforementioned purposes, We may need to collect, use, disclose, and/or process Your information for other specific purposes. However, We will inform You of such purposes at the time of obtaining Your consent, unless the processing of information is required by law without Your consent, as provided by the applicable Data Protection laws.

How Do We Use or Share Your Information?

We may share Your information in the manner given below:

  1. Information shared by You to register the User Account (such as User name, name, gender, etc.) may be available to viewing by other Users on the Platform. Any Listings uploaded and shared by You on the Platform will also be available for viewing and acting upon by other Users.
  2. Information shared by You may be shared with third-party service providers who assist the Company in performing certain aspects of Our Facilities, such as fulfilling requests for information, receiving and sending communications, updating marketing lists, analyzing data, providing support services, etc. Such service providers will have limited access to Your information and only such information will be shared that is necessary for such service providers to perform their services.
  3. Information may also be shared with third-party payment service providers for the purpose of providing certain payment processing or other ancillary services. In such cases, Your personal information may be used for verifying Your identity, processing payment services, conducting due diligence, checking creditworthiness, conducting background checks, or other screening activities within the permissible legal limits. 
  4. Your information may be shared with Our potential partners, investors, and any other parties with whom We enter into a collaboration, partnership, joint venture, or otherwise.
  5. When You agree to receive communications via telegram/WhatsApp, You agree to share Your contact details with the relevant Buyer/ Seller (as the case may be).
  6. We may share information relating to Your location with third-party data management platforms or advertising & analytics partners for the purposes of advertising, analytics, attribution, analytics, and market research.
  7. We may disclose Your personal information if required by law or if We believe that such disclosure is necessary to prevent fraud or crime or to protect Our Facilities, property or the personal safety of any person/ User.
  8. Your information may further be shared with:
  1. Government or regulatory authorities or courts having competent jurisdiction
  2. any third-party claimants or potential third-party claimants
  3. Your bank/financial institution/ payment service provider for the purposes of processing any payment, payment reversal, and/or dispute arising out of or in connection with Your use of their services.

With Whom Do We Share Your Information?

During the course of Our business activities, We may need to use, process, disclose, and/or transfer Your information to third-party service providers, or other third parties, located within or outside of Your country, for the purposes stated in this Policy. For one or more of these purposes, the aforementioned third-party service providers,  as well as other external parties, may handle Your personal data on Our behalf or in any other manner, as specified herein. We are committed to ensuring that external individuals and Our service providers securely store Your information/personal data and protect it from unauthorized access, collection, use, disclosure, unauthorized processing, or similar risks. We only retain Your personal data for as long as necessary for the purposes stated herein. The aforementioned external individuals include, but are not limited to:

  1. Buyers, Sellers, partners, or merchants with whom You transact or communicate through the Platform or in connection with Our Facilities for the purposes mentioned above.
  2. Other Users of the Platform for the purposes stated in this Policy
  3. Contractors, agents, service providers, and other external parties that We employ to support Our business. These individuals include but are not limited to, service providers such as financial services companies, advertising and marketing partners, telecommunications service providers, information technology service providers, and data centers.
  4. Government agencies and regulatory bodies with authority over the Company or as authorized by law.
  5. Buyers, transferees, or successors in the event of a merger, acquisition, divestiture, restructuring, corporate reorganization, cessation of operations, or sale or transfer of all or part of the Company. Whether through continuous operation or as part of a liquidation, complete cessation of operations, or similar proceedings, the personal data of Our service users held by the Company is considered an asset to transfer.
  6. External parties to whom We have disclosed information for the purposes stated in this Policy.

Kindly note that We do not share Your contact information - email and phone number. with other Users, Buyers, and Sellers, unless you yourself while publishing your items or services for sale. We strongly encourage you to use it to communicate with other Users through the in-built messaging service on the Platform. We advise You to refrain from sharing Your information on the Platform with other Users (either through Listings, over messages, or in any other manner) and exercise caution and good judgment in this regard. We, therefore, disclaim any responsibility or liability in this regard.

Anonymized Data

The Company respects Your privacy and does not sell Your personal information to any third party. The Company may disclose anonymized data and/or statistics about the Users of its Platform and/or Facilities to prospective investors, partners, advertisers, and other third parties for providing a description of Our Facilities, delivering targeted advertisements, or for any other lawful purpose. However, such data will not include any such information which may be used to identify You.

Transfer of Information

By using the Platform and/or its Facilities, You permit the Company to use Your information in Singapore, Thailand, Indonesia, and in any other country where the Company operates its business activities. You acknowledge and agree that the Data Protection Laws and other relevant laws of the country to which your data may be transferred, stored, or processed may have different standards of protection compared to the laws of Your country. However, the Company will ensure at all times that Your information is transferred in accordance with this Privacy Policy and protected in accordance with applicable Data Protection Laws.

Use of Cookies

We or third-party service providers on Our behalf, as well as Our advertising partners, may use "cookies" or other features from time to time to help Us or external parties to collect, store, or disclose data about Our use of Our Facilities or the Platform. These features help Us improve Our Facilities and the Platform, and/or enable Us to provide new services and features. They also enable Us and Our advertising partners to provide content relevant to Your interests, including targeted advertising.

"Cookies" are various identifiers that are stored on Your computer or mobile device and record information about Your computer or device, the way and time You use or visit the Platform, the number of Users, and other activities within Our Platform. We may link cookie data to Your personal information. Additionally, cookies may be linked to data about the Products You have selected to purchase and the web pages You have visited. We use this information to track Your shopping cart and provide content that is relevant to Your interests, to enable Our advertising partners to serve ads on various websites on the internet, and for data analysis and to monitor Your use of Our Facilities or the Platform.

You may choose to reject the use of cookies by adjusting the appropriate settings in Your browser or device. However, please note that if you reject/ limit the use of cookies, You may not be able to fully utilize the functionality of the Platform or the Facilities.

Security of Your Information

We implement various security measures to ensure the utmost security of Your personal information within Our systems and such measures are at no time less than the generally accepted industry standards. User information is stored in a secure network and can only be accessed by a limited number of authorized personnel who have special privileges to access such systems. However, We cannot guarantee the complete security of Your personal data.

We will retain Your personal data in accordance with applicable personal Data Protection Laws and/or any other relevant laws. We will immediately destroy or anonymize Your personal information when there is reasonable grounds to believe that (i) the purpose of collecting such personal data is no longer aligned with the retention of such personal data; (ii) it is no longer necessary to retain such personal data for legal or business purposes; and (iii) there is no longer a justifiable reason to retain such personal data. If You cease using the Platform or if Your rights to use the Platform and/or Facilities are revoked or terminated, the Company may continue to retain, use, and/or disclose Your personal data in accordance with applicable Data Protection Laws and Our binding obligations under such laws. We may securely destroy Your personal information without prior notification.

In Our effort to enhance Your experience, We may choose to link to or integrate third-party platforms within Our Platform. We may also engage in co-branding or establish other relationships to offer e-commerce transactions and/or services and other features to Users. These linked platforms will have separate privacy policies and security practices, even though they may have affiliations with Us. We do not have control over these linked platforms, as each platform may have independent privacy practices and data collection practices separate from Ours. Data collected from partnerships with brands or external third-party platforms (whether presented on or through our platform) may not be received from Us. We, therefore, disclaim any responsibility or liability for the content, security practices (or lack thereof), and activities of these linked platforms. These linked platforms are provided for Your convenience and accessed at Your own risk and responsibility. However, We strive to maintain the integrity of Our Platform and the links within each platform.

Accessing and Rectifying Your Information

You may access and/or rectify Your information in Your User Account through the account settings page on the Platform. If You do not have an Account with Us, You may access and/or rectify Your information/personal data under Our control or custody by submitting a written request to Us at support@cocolisting.com. In any case, We will need sufficient details from You to verify Your identity and the nature of Your request in order for Us to process Your request. Therefore, please submit your written request by sending an email to our data protection officer at admin@cocolisting.com.

Upon receipt of Your request for access to information/personal data, once We have sufficient information to process it, We will provide You with the relevant information/personal data within a reasonable period of time. Please note that Data Protection Laws may exempt certain types of personal data from access requests, and may specify the time within which We must provide access to Your data in various circumstances, regardless of Your request.

Upon receipt of Your request for rectification of information, once We have sufficient information to process it:

  1. We will rectify Your information within a reasonable time period. If We are unable to rectify it, We will notify You of the soonest possible timeframe within which We can rectify the information. Please note that Data Protection Laws may exempt certain types of personal data from rectification requests, and may specify the time within which We must rectify Your information in various circumstances, regardless of Your request.
  2. We will send the rectified information to all organizations to which We have disclosed Your information within one year prior to the date of rectification unless that organization does not require the rectified personal data for legal or business.

The Company reserves the right to refuse the rectification of Your information in accordance with the provisions specified in the applicable Data Protection Laws, which specify and/or grant the right to organizations to refuse the rectification of personal data in the situations specified.

How Can You Withdraw Your Consent?

You understand that withdrawing Your consent for collecting, using, and/or disclosing Your information/ personal data may result in Us being unable to continue providing the Facilities to You, and therefore, We may need to terminate any existing relationship and/or agreement with You. If You wish to withdraw Your consent regarding the collection, use, and/or disclosure and/or deletion of Your information under our control or custody, kindly write to Us at admin@cocolisting.com requesting deletion/ termination of Your Account with Us.

Conflict

If this Privacy Policy is translated into another language from English using third-party automated translation services or otherwise, in the event of any inconsistencies between the English version and the translated version, the text and meaning of the English language shall prevail.

Contact Us

If You have any questions, complaints, concerns or comments about this Privacy Policy, You may write to Us at admin@cocolisting.com 

Version dated May 31, 2023.