• You will be asked to provide certain contact information that is necessary for the registering for a Platform account on behalf of a Buyer or Seller, including name, address, phone number, email address, job title and department; 

• You will be asked to provide certain identity information, tax registration and/or related information about your business, such as your company name, business type and industry,  corporate registration details and information about your business license; 

• If you are a Seller we will also ask you to provide details about the goods and products that you intend to sell via the Platform and details about your sales/transactions on www.whalegroup.com;

• If you are a Buyer we will also ask you to provide details or preferences about the goods and products that you may be interested in buying via the Platform and any details or preferences relevant to your purchases;

• In connection with the facilitation of transactions, purchases and payments over the Platform, you will be asked to provide certain payment information. This might include bank account numbers, billing and delivery information, credit/debit card numbers, expiration dates and security code and tracking information from cheques or money orders to facilitate the sale and purchase as well as the settlement of purchase price of the products or services transacted on or procured through the Platform;

• We will process any information provided to us in connection with disputes or to support complaints in connection with the Platform or goods and/or services purchased via the Platform.  Please note, Buyers and/or Sellers may submit complaints regarding the products and services on the Platform and/or disputes between the Buyers and Sellers to the Platform and under such circumstances, we will process data provided to us by Buyers and/or Sellers that is relevant to the disputes or complaints submitted. This may include health data of end-users (which may include minors as applicable) of products purchased on the Platform to the extent relevant to the disputes or complaints that are being reviewed by the Platform and to the extent that the individual(s) has provided their explicit consent to their data being shared with us for the purposes of handling the complaints and/or settling the disputes. 

• Information you submit to the Platform for publication may be made publicly available on the Platform and therefore accessible by any internet user. You should exercise caution when deciding what information you submit to us for publication. 

• In order to facilitate your use of the services available on the Platform (including on websites and/or mobile applications), we may request for access to, and you may provide us with,  contents stored in your devices including but not limited to contacts in address book,  photos,  videos and/or other files. If you are using our communication tools on the Platform (particularly in case of voice communication),  we may require access to your camera and/or microphone,  and may conduct voice recordings. 

• If you contact us (such as via our customer services department chat service,  telephone or email),  we may record a copy of your correspondence and may ask for additional information to verify your identity. 

• We will collect contact details and other information of users from publicly available sources for the purposes of verifying the users and performing due diligence on the users.

•  We will collect details of user activities,  transactions and interactions on the Platform including information relating to the types and specifications of the products and services purchased,  pricing and delivery information,  dispute and complaint records,  communications between users and any information disclosed in any discussion forum. 

•  From time to time,  we may also collect information about the existing and prospective users,  during or in connection with trade shows,  industry events and/or other functions. Including representative contact names,  addresses,  phone numbers,  fax numbers and email addresses. 

•  If you visit our Platform,  we will automatically collect certain information from your device. In some countries,  including countries in the European Economic Area,  this information may be considered as personal information under applicable data protection laws. Specifically this information may include IP addresses,  device type,  unique device identification numbers,  browser type,  geographic 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 statistical 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. Collecting this information enables us to better understand the visitors who come to our Platform, where they come from, and what content is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Platform. Some of this information may be collected using cookies and similar tracking technology,  as explained further under the section E “COOKIES” below. 

Information that we receive from third parties 

• 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 it would typically include basic public profile information such as:  

1.  Your user name or nickname

2.  Your profile picture

3.  Country 

4.  Company name

5.  Contact details 

We may receive personal information about you from third parties that are engaged by us to assist with providing verification services,  and conducting suitable money laundering and KYC (know-your-customer) checks on users,  and to improve our marketing efforts. This may include your name,  email address,  company details and contact information for company representatives. 

• If you choose to participate in reviewing or rating products and/or services on www.whalegroup.com ,  we may receive personal information about you from third parties that work with us to conduct reviews into our services and/or rate us. 

• Verifying your identity and conducting security,  KYC (know-your-customer) and anti-money laundering diligence and background checks in order to set up user accounts;

• verifying your eligibility to register as a Platform user in accordance with our Terms of Use here;

• Setting up / administering user accounts; 

• Providing users with customer service support; responding to queries,  feedback,  and managing claims and/or disputes;

• Providing logistics and warehousing services (including,  without limitation,  customs clearance declarations via the Platform);

• Facilitating customs clearance declarations / applications via the Platform;

• Assessing and monitoring account security and transaction risks of users of www.whalegroup.com , detecting and preventing fraud,  money laundering and other security incidents;

• Performing research or statistical analysis in order to improve the content and layout of the Platform, and to improve the product offerings and services on www.whalegroup.com ,  including, for example, using anonymized data for machine learning purposes;  

• Identifying, developing and marketing and advertising products and services that we believe you will value, including across browsers and devices, in accordance with applicable laws.  Cookies or other similar technologies may be used to provide you with advertising based upon your browsing activities and interests (see section E. "COOKIES" below).  Where we are required by applicable law, we will seek your consent prior to sending you communications for marketing purposes;  

• If you are a Buyer, we will share details of the last viewed products on the Platform to enable Sellers, their respective affiliates and/or their third-party services provider to contact you with details of products and/or services that might interest you. You can opt not to share this information with Sellers via the Buyer Privacy Settings here. 

• When you use services that require access to contents stored in and/or functions on your devices (including but not limited to contacts in address book, photos, videos, microphone and/or camera), we use your photos, videos, contact information in your address book, and other personal information to respond to your requests, provide the requested services to you, and improve our services. 

We may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest,  scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws. 

• Other Platform Users where necessary in connection with the facilitation of purchases and communications made between you and the other users. 

• Third party business partners, service providers and/or affiliates of www.whalegroup.com engaged by us or working with us to assist us to provide 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 or service providers include: 

1.  Our business partners (for example, in order for them to provide you with discounts or offers that may interest you);

2.  Marketing and advertising platforms, such as Google, Twitter, Facebook and Instagram, and providers of analytics services relating to users’ behavior, in order to tailor the content you see when visiting our Platform. These platforms 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 party marketing platforms are governed by their own privacy policies, not this Privacy Policy;

3.  Payment service providers who collect and process personal information to assist with settling the payments for transactions or process withdrawal requests for Sellers. The activities of payment service providers may be governed by their own privacy policies, not this Privacy Policy; 

4.  Credit risk assessment providers to conduct risk assessment on Sellers to determine whether a Seller can be permitted to make a fund withdrawal;

5.  Logistics partners for providing delivery services for Buyers, including return and exchange of products, and warehousing services for Sellers;

6.  Custom agents for customs clearances purposes;

7.  Cloud computing service providers to provide cloud storage services;

8.  Customer service providers to provide after-sale services; 

9.  Risk control service providers to assess the security of users’ 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 www.whalegroup.com 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, we may also disclose and transfer your personal information 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 may provide aggregated or anonymized data to third parties, but when we do so, the information we share is in a de-identified format that does not personally identify you. 

We have established relationships with third parties and websites to offer you products and services which we do not offer and such third parties and websites include the following affiliated platforms of www.whalegroup.com or their operators. 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 third parties. You should read the relevant privacy policy for those third party sites and co-branded sites before responding to any offers, products or services advertised by those parties.