Privacy Policy

Sylarb.com Privacy Policy

(Effective as of January 18, 2024)

Table of Contents

1. COLLECTION OF INFORMATION

•       Information That You Provide to Us
•       Information That We Collect Automatically
•       Information That We Receive From Third Parties

B.USE OF PERSONAL DATA

C.DISCLOSURE OR SHARING OF PERSONAL DATA

D.RETENTION

1. RIGHTS REGARDING PERSONAL DATA
2. COOKIES
3. MINORS
4. SECURITY MEASURES

I.CHANGES TO THIS PRIVACY POLICY

1. VISITORS FROM THE EUROPEAN ECONOMIC AREA AND UK

•       Legal Basis for Data Processing.
•       Your Rights.

1. VISITORS FROM THE UNITED STATES
2. VISITORS FROM BRAZIL

•       Legal Basis for Data Processing.
•       Your Rights.

1. INTERNATIONAL TRANSFERS OF PERSONAL DATA
2. LANGUAGE
3. HOW TO CONTACT US.

We at Sylarb (“we”, or “us”) recognize the importance of privacy and confidentiality of personal information.

Sylarb.com (“Sylarb” or, the “Platform”) is a business to consumer (or “B2C”) platform which connects and facilitates sales and purchases between business sellers (or “Sellers”) and consumer buyers (or “Buyers”).

This Privacy Policy sets out the ways in which we collect, use and disclose information in connection with the operation of the Platform, including personal information about you, Platform users, visitors and representatives. This Privacy Policy also applies to the use of the Platform via your mobile device. Other Sylarb services are governed by separate Privacy Policies, please refer to the Privacy Policy applicable to those services.

Depending on your location, the entity responsible for the handing of your personal information is:

• For users located in Mainland China: If you are a registered member of the Platform, and you are from mainland China, you are contracting with Sylarb 
• For users located in the United States: If you are a registered member of the Platform, and you are from United States, you are contracting with Sylarb E-Commerce 

1. COLLECTION OF INFORMATION

The personal information that we collect broadly falls into the following categories:

Information That You Provide To Us:

If you are a Buyer, we will ask you to provide:

•       contact information including: name; address; phone number; email address;
•       purchase and payment information including: credit card or similar payment information that you intend to purchase with; billing and delivery address;
•       information about your purchases including: the goods purchased and how many;
•       information about and to support complaints made in connection with the Platform or goods and/or services purchased via the Platform;
•       ID (such as a passport) for identification verification in certain circumstances, when you apply for after-sales services.

If you are a Seller (i.e. an employee or representative of a Seller or a sole trader Seller (we’ll refer to you as a Seller)), we will ask you to provide:

•       information about the Seller’s business (if applicable) including corporate registration, business licenses (if applicable), tax or similar information;
•       details about the goods and products that the Seller intends to sell via the Platform;
•       purchase and payment information including bank account or other payment information that the Seller intends to be paid by.
•       If you attend one of our industry events or other functions, contact details such as your name, address, phone number, fax number and email address.
•       If you are a certified blogger / influencer for Sylarb, we may also ask you to provide us with your contact information and social media accounts / blog information.
•       If you choose to provide us with any additional information, such as in response to questionnaires for market research/analytics. This may include marital status, nationality, gender, date and/or year of birth, annual income, monthly spending and user preferences. If you prefer not to provide such information, the use of our services and products will not be affected.

Information That We Collect Automatically:

If you are a Buyer or Seller or prospective Buyer or Seller we will automatically collect:

• A copy of any correspondence with us, including any verification information we ask for, if you contact us for any reason (such as our customer service department chat service, telephone or email).
• Details of transactions and communications over the Platform, including the types and specifications of the goods sold and purchased, pricing and delivery information, any dispute records, communications between Buyers and Sellers over the Platform and any information disclosed in any discussion forum.
• Details of Platform buying and browsing activities, for these purposes we will automatically collect information from your device. In some jurisdictions, including countries in the European Economic Area and the UK, this information will be considered as personal information under applicable data protection laws. Specifically, this collected information may include IP addresses, date and time of access to the Platform, device type, unique device identification numbers, browser type, broad geographic location (e.g. country or city-level location), browsing patterns and details of how you have interacted with our Platform and the goods and services available on it. In addition, we gather information about the Platform and visitors to the Platform including browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors. Some of this information may be collected using cookies and similar tracking technology, as explained further under section F “COOKIES” below. Where we are required by applicable law, we will seek your prior consent to the collection of information using cookies and similar tracking technologies. We also may derive or collect inferences about you based on your buying and browsing activity information and other information we have collected about you.

If you are successfully certified by Sylarb as an Sylarb blogger or an influencer, we may also collect your social media account handles and posts/comments made in relation to the Platform.

We may collect information about the people or accounts with whom you share content or interact and contact information if you choose to upload or import it from a device (such as an address book).

Information That We Receive From Third Parties:

If you are a Buyer or Seller we may receive personal information about you from:

• Social media platforms if you choose to register for a Platform account via a social media account. Exactly what information we receive will depend on your privacy settings with the applicable platform, but would typically include basic public profile information such as:
• Your social media user name, nickname or username
• Your social media profile picture
• Country
• Company name (if applicable).
• Third parties that are engaged by us to provide verification services, such as conducting suitable money laundering, fraud and “Know Your Customer” checks on Buyers and Sellers. This includes your name, email address, company details, and contact information.

We will only collect personal information from third parties where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. 

1. USE OF PERSONAL DATA

We collect and use your personal information for the following purposes:

• verifying Platform account registrations, including conducting fraud, security, “Know Your Customer” and anti-money laundering checks in order to approve your Seller account;
• verifying your eligibility as a Platform blogger or influencer;
• setting up / administering Buyer and Seller accounts, including providing log-in IDs and setting up payment / transaction accounts;
• providing customer service support, such as responding to your queries, feedback and managing claims and/or disputes;
• providing/supporting general Platform services, facilitating communication between Buyers and Sellers, processing transactions and payments, assessing advance withdrawal requests from Sellers and providing logistics and delivery services, supporting Sellers with logistics and delivery;
• supporting Buyer and/or Seller clearance declarations / applications where made via the Platform;
• providing relevant membership benefits, including birthday rewards, membership offers and coupons, anniversary awards, exclusive member prices;
• verifying your identity and purchases in connection with product warranty or other after-sales claims;
• assessing and monitoring account security and transaction risks of Buyers and Sellers, such as detecting and preventing fraud, money laundering and other security incidents;
• sending and serving tailored marketing and advertising that we believe will be of interest to you based on the ways in which you use the Platform, your browsing records, and order history (we may use cookies and other similar technologies to provide you with marketing and advertising based upon your browsing activities and interests (see section F. COOKIES below for more information).
• conducting research and analytics to ensure the security of our Platform, to improve the content and layout of the Platform, and to improve our Platform, product offerings and services;
• Help you find people you may know who are also using Sylarb;

We may also use your personal information for other purposes that are compatible with the purposes we have disclosed to you if and where this is permitted by applicable data protection laws. You can request further information about the compatibility of other purposes upon request.

1. DISCLOSURE OR SHARING OF PERSONAL INFORMATION

We disclose/share personal information with the following categories of recipients:

•   Other Platform Buyers and/or Sellers where necessary to support purchases and communications made between you. If you are a Buyer, Sellers that you purchase from will also control personal information about you relevant to or connected with your Platform purchases and communications with them. Please refer to Seller Privacy Policies for information about how they will process your information.
•     Third party partners and service providers and/or affiliates engaged by or working with us to assist us in providing services to you or who otherwise process personal information for purposes described in this Privacy Policy or notified to you when we collect your personal information. Categories of these partners and service providers include:
•     Sylarb group entities and affiliated companies and/or their designated service providers that work with us to provide processing services such as software, tools, systems and messaging services for purposes described in this Privacy Policy;
•   our business partners (for example, in order for them to provide you with discounts or offers that may interest Buyers or prospective Buyers) where you have consented to receiving such information from them if required by applicable data protection laws;
•     marketing and advertising partners, such as Google, Twitter, Facebook, Instagram, and VKontakte, and providers of analytics services relating to users’ behavior such as Appsflyer, Criteo, so that they may tailor the content you see when visiting our Platform for analytics and/or advertising purposes. These partners may combine information they collect on our Platform with data on their platforms and data they collect from other websites or through other sources in order to conduct targeted advertising. The processing activities of these third parties marketing platforms are governed by their own privacy policies, not this Privacy Policy (please refer to section F “COOKIES” below);
•   payment service providers that provide payment processing services. The activities of payment service providers may be governed by their own privacy policies, not this Privacy Policy;
•     credit risk assessment providers to conduct risk assessment on Sellers to determine whether a Seller can be permitted to make an advance withdrawal;
•   logistics partners for providing delivery services for Buyers and Sellers, including return and exchange of products, and warehousing services for Sellers;
•   customs agents for customs clearances purposes, where applicable to support Buyers and Sellers with international sales/purchases;
•     cloud computing or other hosting service providers to provide cloud storage services;
•     warranty service providers to provide product warranty services where requested by a Buyer or Seller;
•     customer service support providers to provide after-sale services or other customer service support;
•     risk control service providers to assess the security of Buyer and Seller accounts and transaction risks; and
•     third party rating / reviewing service providers to carry out reviews of our services with customers if you choose to participate in reviewing or rating Platform products and/or services;
•   To our professional advisers, law enforcement agencies, insurers, government and regulatory and other organizations where we believe it is necessary to comply with applicable laws or to exercise, establish or defend our legal rights or protect your vital interests or those of any other person; or as otherwise required or permitted by applicable laws.
•     To an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy.
•   To any other person with your consent to the disclosure.

We have established relationships with other parties and websites to offer you the benefit of products and services which we do not offer. We offer you access to these other parties and their websites either through the use of hyperlinks to these sites from our Platform or through offering “co-branded” sites in which both we and other parties share the same uniform resource locator (URL), domain name or pages within a domain name on the Internet. In some cases you may be required to submit personal information to register or apply for products or services provided by such third parties or co-branded partners. This Privacy Policy does not apply to these third-party sites or co-branded sites. The privacy policies of those other parties may differ from ours, and we have no control over the information that you submit to those other sites. You should read the relevant privacy policy for those third parties sites and co-branded sites before responding to any offers, products or services advertised by them.

1. RETENTION

We will retain your personal information for as long as we have an ongoing legitimate business need to do so, to provide services or products to you, or as required or permitted by applicable laws. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. How long your data is kept for will also depend on how you use our website (for example if you are logged in as a member or you are visiting our website as a guest) and what the information you provide to us is used for. For example, if you are a registered member, certain data will be retained for a length of time following termination or deletion of your account, in order to comply with applicable laws [(for example, if a court order is received about your account, we would retain your account data for longer than the usual retention period when an account is deleted)] or in case of disputes. In other instances, the period of retention may be determined according to your activity on the Platform or to comply with a specific arbitration period/resolve a dispute.

1. RIGHTS REGARDING PERSONAL DATA

Under applicable laws, you may have rights of access to personal information held by us and other rights. If you are a Visitor from the European Economic Area or UK, please refer to section J. VISITORS FROM THE EUROPEAN ECONOMIC AREA or UK below for more information. If you are a Visitor from THE UNITED STATES, please refer to section K. VISITORS FROM THE UNITED STATES below. If you are a Visitor from Brazil, please refer to section L. VISITORS FROM BRAZIL. If you have any questions regarding this Privacy Policy or if you wish to access or correct your personal information as a user of Sylarb.com, please click here.

1. COOKIES

This section explains how we use cookies and similar technologies (we refer to them collectively as “cookies”) to recognize you when you visit our Platform. It explains what these technologies are and why we use them, as well as your rights to control them.

What are cookies?

A cookie is a string of information that is sent to your browser and stored on your computer’s or mobile device’s hard drive. If you do not de-activate or erase the cookie, each time you use the same browser or device to access the Platform, our web servers will be notified of your visit to the Platform and, in turn, we may have knowledge of your visit and the pattern of your usage.

Cookies set by the site or app owner (in this case, Sylarb) are called “first party Cookies”. Cookies set by third parties other than the site or app owner are called “third party Cookies”. Third party Cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third-party cookies can recognize your device both when it visits the website in question and also when it visits certain other websites.

Cookies are also categorized as “session Cookies” (which are erased once you close the browser or shut down the device) and “persistent Cookies” (which remain even after closing the browser or shutting down the device/application and which are activated each time you visit the Platform). Session cookies use encrypted data to authenticate you. Persistent Cookies do not store account numbers or passwords. We use both session cookies and persistent cookies.

Why do we use Cookies?

We use first- and third-party Cookies for several reasons.

Some Cookies are required for technical and/or security reasons in order for our Platform to operate, and we refer to these as “essential” or “strictly necessary” Cookies. First party Cookies are mainly served to enable basic functionality on our Platform; including web analytics Cookies that help us understand how users use our web pages and how we can improve their use. For example, we use essential or strictly necessary Cookies to enable us to remember goods added to your shopping basket and to recognize you when you sign into your account.

We also use social media Cookies. You may register for Platform membership and “share” Platform content through social media such as Facebook and Twitter. Sometimes we embed videos from websites like YouTube. These websites have their own privacy policies which govern their use of information, which you can find on the respective websites.

We also use Cookies to enable us to track and target the interests of Platform visitors to enhance the experience on our Platform by researching visiting patterns and conducting interest-based advertising; assisting our partners in tracking user visits to the Platforms; and to track progress and participation in promotions and the success of our email marketing campaigns. We use first- and third-party Cookies for these purposes.

What about other tracking technologies, like web beacons?

Cookies are not the only way to recognize or track visitors to our Platform. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Platform or opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Platform to another, to deliver or communicate with cookies, to understand whether you have come to our Platform from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

How can I control Cookies?

You can determine if and how a cookie will be accepted by configuring the privacy setting of the browser you are using to access the Platform or the “privacy setting” of your device. As the means by which you can refuse Cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information. If you adjust the privacy setting in the browser, your mobile device will continue collecting data unless you adjust the privacy setting of the device, and vice versa.

In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.

Certain features of the Platform depend on Cookies. Please be aware that if you choose to block Cookies, you may not be able to sign in or use those features, and preferences that are dependent on Cookies may be lost.

Google Analytics (More information) Our Platform uses Google Analytics, an internet analytics service provided by Google, Inc. (“Google”). Google’s Cookies allow us analyze use of the Platform by telling us which pages our users are viewing, which ones are most popular, what time of day our Platform are visited, if users have previously visited our Platform, from which website users are redirected to our Platform were and the like. The data generated by the cookie about your use of the Platform will be transmitted to Google and stored by Google on servers in the United States.

The Platform uses an anonymization tool of IP addresses so that the IP addresses are truncated within the territory of the Member States of the European Union and the other members of the agreement on the European Economic Area. In some cases, non-truncated IP address may be transmitted to Google’s servers in the US and then truncated there.

Google uses the data on behalf of Sylarb to evaluate your use of the Platform, to compile reports on website activity for the website operators and for other website activity and internet usage services. Google may disclose this information to third parties under the terms of the law or for further processing by third parties on behalf of Google. For more information about Google Analytics Cookies, visit: the Google Help pages and Privacy Policy: Google Privacy Policy: https://policies.google.com/privacy; and the Google Analytics Help Centre: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.

Through your browser settings, you can block Cookies; however, this can lead to problems with the use of some functionalities of the website. Through the add-on “Google Analytics Opt-out” you can through your current web browser opt-out to the use of Google Analytics from then on: http://tools.google.com/dlpage/gaoptout?hl=en.

More information can be found here: https://support.google.com/analytics/answer/6004245.]

1. SECURITY MEASURES

We implement appropriate technical and organisational measures to prevent unauthorized access to the Site, to maintain data accuracy and to ensure the correct use of the information we hold. Upon becoming aware of a data breach, we will notify you and the regulatory authorities in accordance with the timescales and scope required by applicable data protection law.

For registered users of the Platform, some of your information can be viewed and edited through your account, which is protected by a password. It is your responsibility to keep your password secure and confidential. We recommend that you do not divulge your password to anyone. We have instructed our personnel to never ask you for your password. If you share a computer with others, you should not save your log-in information (e.g., user ID and password) on that shared computer. Remember to sign out of your account and close your browser window when you have finished your session

No data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we use appropriate technical and organizational measures to protect the information we hold for you, we cannot guarantee the security of any information you transmit over the internet.

1. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments.

When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make and as required by applicable law, such as by posting an amended Privacy Policy on the Platform.

1. VISITORS FROM THE EUROPEAN ECONOMIC AREA OR UK

This section applies if you are based in the European Economic Area (“EEA”) or UK. The data controller of your personal information is Sylarb.com For contact details, please see section O. HOW TO CONTACT US below.

Please also note, if you are a Buyer, Sellers will also act as a data controller of personal information about and your Platform purchases and communications with them. Please refer to the Privacy Policies of those Sellers for more information about the ways in which they will process such information.

Legal Basis for Data Processing

We process personal information for the purposes set out in this Privacy Policy. Our legal basis to process for processing your personal information will depend on the personal information concerned and the specific context in which we collect it.  but will include where it is:

•       necessary for the performance of contract between you and Sylarb.com Singapore E-Commerce Private Limited (for example, to provide you with the services you request and to identify and authenticate you so you may use the Platform);
•       necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement);
•       necessary for our legitimate interests and not overridden by your rights.
•       and/or where it is based on your consent.

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Platform and services, manage our relationship with you and communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our Platform and our services, undertaking marketing, or for the purposes of ensuring the security of our Platform and services and detecting or preventing illegal activities such as fraud. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If we ask you to provide personal information to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). In some instances, you may be required to provide us with personal information for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Platform.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under section O. HOW TO CONTACT US below.

Your Rights

If you are a resident of the EEA or UK, you have the following data protection rights, which you can exercise at any time by contacting us using the contact details provided under section O. HOW TO CONTACT US below:

•       The right to access your personal information and confirm the existence of processing.
•       The right to correct, update or request anonymization, blocking or deletion of your personal information.
•       The right to object to processing of your personal information when it is based on our legitimate interests.
•       The right to ask us, in some situations, to restrict processing of your personal information or request portability of your personal information.
•       The right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you to opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under section O. HOW TO CONTACT US below.
•       If we have collected and process your personal information with your consent, then you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
•       The right to request the review of decisions exclusively based in automated processing, which might affect your interests.
•       The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected.

1. VISITORS FROM THE UNITED STATES

This section applies if you are based in the United States, the data controller of your personal information is Sylarb E-Commerce One Pte. Ltd. (incorporated in Singapore with Company Reg. No. 202216156R)], and your data will be stored in the United States. For contact details, please see section O. HOW TO CONTACT US below. Please also note, if you are a Buyer, Sellers will also act as a data controller of personal information about and your Platform purchases and communications with them. Please refer to the Privacy Policies of those Sellers for more information about the ways in which they will process such information.

Information Pertaining to Children

Our Platform is not directed to and we do not intend to, or knowingly, collect, or solicit personal information online from users under the age of 18, nor children under the age of 13. We do not knowingly collect personal information from children under the age of 13 or have any reasonable grounds to believe that children under the age of 13 are accessing or using our Platform. If you believe that a child under 13 may have provided us personal information, please contact us using the contact details provided under section O. HOW TO CONTACT US below.

Additional Information for California residents

This section supplements the description of our information collection and sharing practices elsewhere in this Policy to provide certain disclosures to California residents whose personal information we process pursuant to the California Consumer Privacy Act (“CCPA”).

Collection, Use and Disclosure of Personal Information. During the preceding 12 months, we have collected, used, and/or disclosed the categories of personal information described above in section A. COLLECTION OF INFORMATION. For example, depending on the services you use, this may include your identifiers (e.g., IP addresses and email addresses), commercial information (e.g. records of products purchased), internet or other electronic network activity information (e.g. buying and browsing activities on the Platform), geolocation data (your country and address) and records of requests and interactions to our customer support service. This may also include inferences we draw from the other information we collect.

Use of Personal Information. The business purposes for which we collect and handle personal information is described above in section B. USE OF PERSONAL DATA.

Disclosure of Personal Information. We disclose or share personal information in the ways described above in section C. DISCLOSURE OF PERSONAL DATA, including by allowing third parties that provide us analytics and advertising services to collect information through cookies and other similar technologies.  We do not believe that we currently sell personal information as defined by the CCPA, and accordingly, we do not treat this as a sale of personal information for purposes of state law, although you do have the choices that we describe to you in this Privacy Policy. We believe that third party cookies we permit to be associated with our Platform restrict their data processing to what is permitted by service providers under the CCPA, and do not result in a sale of perspnal information by us. You can opt out of any future sale of personal information by using the contact details provided under section O. HOW TO CONTACT US below

Privacy Rights. If you are a resident of California, you have the following rights under the California Consumer Privacy Act (“CCPA”):

• You have the right to request deletion of your personal information that we have collected, subject to certain exemptions, and to have such personal information deleted, except where necessary for certain exempt purposes.
• You have the right to request a copy of the specific pieces of personal information that we have collected about you in the prior 12 months.
• You have the right to request a description of the categories of personal information about you that we have collected, used, disclosed or sold in the prior 12 months. Specifically, you may request a description of the:

• categories of personal information we have collected;
• categories of sources from whom we have collected personal information;
• business and/or commercial purposes for collecting or selling your personal information;
• categories of third parties with whom we have disclosed or shared your personal information;
• categories of personal information that we have disclosed or shared with a third party for a business purpose; and
• categories of third parties to whom we have sold personal information and the specific categories of personal information sold to each category of third party.

• You have the right to opt out of the sale of your personal information.
• You have the right not to be discriminated against because you exercise your rights under the CCPA. We will not charge you different prices or provide different quality of services unless those differences are related to your information or otherwise permitted by law.

To submit a request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the personal information that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors, to ensure that we accurately fulfill your request and do not infringe on the privacy rights of other individuals.

To exercise your rights, you or your authorized agent may contact us using the contact details provided under section O. HOW TO CONTACT US below. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you to verify information about your use of the Platform. If you use an agent, we may require you to provide the agent with signed permission to submit a request, require that you verify your identity directly, or otherwise require you to confirm you have provided the authorized agent with permission. You may submit a request as frequently as you would like, but we are not required to respond to requests to provide personal information to you more than twice in any 12-month period.

California Shine the Light Law. Since 2005, California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share our customer’s personal information with third parties for their own direct marketing purposes, without their approval. For inquiries regarding our disclosure policy, please use the contact details provided under section O. HOW TO CONTACT US below.

Do Not Track. California Business and Professions Code Section 22575(b) (as amended effective January 1, 2014) permits our customers who are California residents to be informed as to how we respond to Web browser “Do Not Track” settings. As ‘Do Not Track’ is a standard that is currently being developed, we do not take actions to respond to ‘Do Not Track’ settings, and instead we adhere to the standards set out in this Privacy Policy. If you would like to find out more about Do Not Track you may find the following link useful: http://www.allaboutdnt.com/.

Additional information for Nevada residents

Under Nevada law, Nevada residents who have purchased goods or services from us may opt out of the “sale” of “covered information” (as such terms are defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons. “Covered information” includes first and last name, address, email address, and phone number, or an identifier that allows a specific person to be contacted either physically or online.  As discussed above, we share your information with certain third parties that we believe can provide you with offers and promotions for products and service of interest to you and in the other ways described above.  We do not believe that our sharing in this regard would qualify as a sale under Nevada law. Nonetheless, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to record your preference to opt out by using the contact details provided under section O. HOW TO CONTACT US below. Please note we may take reasonable steps to verify your identity and the authenticity of the request.

1. VISITORS FROM BRAZIL

This section applies if you are based in Brazil. The controllers of the personal data are Sylarb.com Singapore E-Commerce Private Limited (incorporated in Singapore with Company Registration No. 200720572D). Your data will be stored in the United States. For contact details, please see section O. HOW TO CONTACT US below. Please also note, if you are a Buyer, Sellers will also act as a data controller of personal information about and your Platform purchases and communications with them. Please refer to the Privacy Policies of those Sellers for more information about the ways in which they will process such information. The personal data processing activities performed by us under the Platform for the Brazilian market, which includes any processing activity (i) carried out in Brazil, (ii) aimed at offering or providing goods or services or processing data of individuals located in Brazil, or (iii) collected in Brazil; users of the Platform in Brazil are carried out in accordance with the laws of Brazil, including the Marco Civil da Internet, Federal Law No. 12.965/2014 (“MCI”) and the General Data Protection Law, Federal Law No. 13.709/2018 (“LGPD”).

We process the categories of personal information described in Section A of our Privacy Policy. Depending on the services you use, this may include your identifiers (e.g. IP addresses, date and time of access to the Platform, and email addresses), business and internet or other electronic network activity information. It may also include inferences we draw from other information we collect.

Legal Basis for Data Processing

We process personal information for the purposes set out in this Privacy Policy observing legal bases set out in the LGPD. Our legal basis for processing your personal information will depend on the personal information in question and the specific context in which we collect it, but will include when it is:

– necessary for the performance of the contract between you and Sylarb.com Singapore E-Commerce Private Limited (for example, to provide the services requested by you and to identify and authenticate you so that you can use the Platform).

– necessary to comply with legal requirements (for example, to comply with applicable accounting rules and make required disclosures to law enforcement authorities);

– necessary to achieve our legitimate interests or those of third parties;

– based on your consent;

– necessary for the regular exercise of rights in judicial, administrative and arbitration proceedings;

– necessary for the protection of life and limb or of the data subject and third parties;

– used for credit protection purposes;

– used for other cases foreseen in the LGPD or applicable legislation.

If we collect and use your personal information based on our (or a third party’s) legitimate interest, that interest will generally be to operate our Platform and services, manage our relationship with you and communicate with you as necessary to provide our services to you and for our legitimate business interest, for example in responding to your inquiries, improving our Platform and services, conducting marketing, or for the purpose of ensuring the security of our Platform and services and detecting or preventing illegal activities such as fraud. We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are.

If we ask you to provide personal information to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as the possible consequences if you do not provide your personal information). In some cases, it may be necessary for you to provide us with personal information for processing as described above in order for us to provide you with all of our services and for you to use all of the features of our Platform.

If you have questions or need more information about the legal basis on which we collect and use your personal information, please contact us using the contact information provided in section O. HOW TO CONTACT US below.

Your Rights

You have the following data protection rights, which you can exercise at any time by contacting us using the contact details provided in section O. HOW TO CONTACT US below:

– The right to access your personal data and confirm the existence of processing.

– The right to correct, update or request anonymization, blocking or deletion of your personal information.

– The right to object to the processing of your personal information where it is based on our legitimate interests or in case of non-compliance with LGPD or applicable law.

– The right to ask us, in some situations, to restrict the processing of your personal information or to request portability of your personal information.

– The right to cancel marketing communications we send you at any time. You may exercise this right by clicking on the “unsubscribe” or “unsubscribe” link in marketing e-mails that we have sent to you. To unsubscribe from receiving other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact information provided in section O. HOW TO CONTACT US below.

– If we collect and process your personal information with your consent, you have the right to withdraw your consent at any time and request deletion of your personal data. Withdrawing your consent will not affect the lawfulness of any processing carried out prior to your withdrawal, nor will it affect processing of your personal information carried out on a legal basis other than consent.

– The right to request a review of decisions based solely on automated processing, which may affect your interests.

– The right to petition the National Data Protection Authority – ANPD about our collection and use of your personal information.

– The right to request portability of your personal data to another service provider;

– The right to request information about with whom your personal data has been shared.

We respond to all requests we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. If you are aware of changes or inaccuracies in your information, you must inform us of such changes so that our records can be updated or corrected.

To exercise your rights, you or your authorized legal representative may contact us using the contact details provided in section O. HOW TO CONTACT US below. Once we receive your request, we may verify it by requesting sufficient information to confirm your identity, including requesting that you verify information about your use of the Platform.

1. INTERNATIONAL TRANSFERS OF PERSONAL DATA

In connection with providing the services through our Platform, we will store your personal data processed through the Platform in the United States, Russia, Germany, China and/or Singapore, depending on the country you are located in. These countries have data protection laws that may have different provisions to the laws of your country. There will also be international transfers of your information among the above-mentioned countries. We take appropriate steps to ensure that recipients of your personal information are bound to duties of confidentiality and we implement appropriate measures to ensure your personal information will remain protected in accordance with this Privacy Policy, such as standard contractual clauses or other mechanism provided for in the applicable law. A copy of the relevant clauses can be obtained by contacting us using the contact details provided under section O. HOW TO CONTACT US below.

1. LANGUAGE

If there is any conflict between the English version and another language version of this Privacy Policy, the English version shall prevail.