Privacy Policy and Prohibited Items

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How we collect, use, and protect your personal information

Privacy Policy and Prohibited Items

Note: This Privacy Policy applies to all Users who are provided with various products and services through websites, apps, and new forms emerging with technological development by cocomart.io and are thus, duly protected under Rwanda’s Personal Data Protection and Privacy Law (DPP Law)

  1. INTRODUCTION
  2. DETAILS OF DATA PROCESSING
  3. DISCLOSURE OR SHARING OF PERSONAL INFORMATION
  4. RETENTION
  5. COOKIES
  6. YOUR RIGHTS
  7. MINORS
  8. SECURITY MEASURES
  9. PROHIBITED ITEMS
  10. CHANGES TO THIS PRIVACY POLICY
  11. HOW TO CONTACT US
  12. LANGUAGE

1. INTRODUCTION

We at cocomart.io (collectively “cocomart.io”, the “Platform” or “we”) recognize the importance of privacy and confidentiality of personal information. cocomart.io is a business to customer and business to business (“B2C/B2B”) platform which connects and facilitates sales and purchases of products and/or services between suppliers (“Vendors”) and buyers (“Buyers”). Collectively, the Vendors and Buyers shall be referred to as the “Users”. The Platform is for B2C/B2B transactions and therefore is made available for use by both businesses and individual or personal use subject to the laws of the country “Users” reside.

The controllers of your personal information are the legal entities set out in section 10.

“HOW TO CONTACT US”.

This cocomart.io Privacy Policy (“Privacy Policy”) sets out how we collect, process and disclose information in connection with the operation of the Platform for visitors (i.e., non-registered Platform Users) including personal information about the visitors and, representatives and employees of the Users. This Privacy Policy also applies to your use of the Platform via a mobile device, either through mobile applications or mobile-optimized websites.

This Privacy Policy does not apply to the extent we process personal information in the role of a processor or service provider on behalf of other companies.

If you have any questions or concerns about the use of your personal information, then please contact us using the contact details provided at section 10. “HOW TO CONTACT US” of this Privacy Policy. All capitalized terms not defined in this Privacy Policy shall have the meanings ascribed to them in the Terms of Use for the Platform, which can be found here.

2. DETAILS OF DATA PROCESSING

Below you will find an overview of what kind of personal information we process about you and for which purposes we collect this personal information.

Purpose of Data Collection Data Categories Involved Legal Basis (where applicable)
ACCOUNT ADMINISTRATION
We use your information to verify your eligibility to register as a Platform user in accordance with our Terms of Use; and set up/administer user accounts, such as providing log-in IDs and developing a Platform profile.
• Contact information
• Account information
• Business information
• Social media account information
PURCHASE AND DELIVERY OF PRODUCTS AND SERVICES
We use your information to take and handle orders, deliver products and services on the Platform, process payment, provide logistics and warehousing services via the Platform, facilitate customs clearance declarations/applications via the Platform and provide Users with customer service support, such as responding to queries, feedback, and managing claims and/or disputes.
• Contact information
• Account information
• Business information
• Transaction information
• Payment information
• Communication information
• User-generated content
• Device information
• Online activity information
• Location information
COMMUNICATE WITH YOU
We use your personal information to facilitate communication between Users and us, and between the Buyers and Vendors via the Platform, for the purpose of processing transactions and settlement, assessing fund withdrawal requests from Vendors, and improving the services and products of the Platform.
• Contact information
• Account information
• Transaction information
• Payment information
• Device information
• Location information
• Communication information
• Online activity information
PROVIDE VOICE, IMAGE AND CAMERA SERVICES
When you use services that require access to contents stored in and/or functions on your devices (including but not limited to photos, videos, microphone and/or camera), we will use your photos, videos and other personal information to respond to your requests, provide the requested services to you, and improve our services.
• Contact information
• User-generated content
• Communication information
• Device information
RECOMMENDATIONS AND PERSONALIZATION
We use your personal information to recommend features, products, and services that might be of interest to you, identify your preferences, and personalize your experience with the Platform. If you are a Buyer, we will share details of the last viewed products on the Platform to enable Vendors, their respective affiliates and/or their third-party services provider to contact you with details of products and/or services that might interest you.
• Contact information
• Business information
• Transaction information
• Online activity information
• Marketing and advertising information
• Location information
MARKETING AND ADVERTISING
We use your personal information to send and serve you 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. Cookies or other similar technologies may be used to provide you with advertising based upon your browsing activities and interests.
• Contact information
• Business information
• Transaction information
• Online activity information
• Marketing and advertising information
• Location information
RESEARCH AND DEVELOPMENT
We use your personal information to perform research or statistical analysis in order to improve the content and layout of the Platform, and use your personal information to improve the product offerings and services on cocomart.io, including, for example, using anonymized data for machine learning purposes.
• Contact information
• Account information
• Business information
• Device information
• Location information
• Online activity information
• User-generated content
• Social media account information
FRAUD PREVENTION AND CREDIT RISKS
We use personal information to prevent and detect fraud and abuse in order to protect the security of the Platform, our customers and others. We may also use scoring methods to assess and manage credit risks.
• Contact information
• Account information
• Business information
• Transaction information
• Payment information
• Communication information
• User-generated content
• Device information
• Location information
COMPLY WITH LEGAL OBLIGATIONS
In certain cases, we collect and use your personal information to comply with laws. For instance, we use your information to verify your identity and conduct security checks, KYC (know-your-customer) and anti-money laundering due diligence in order to set up user accounts.
• Contact information
• Account information
• Business information
• Communication information
• Transaction information
• Payment information
• Online activity information

The categories of personal information described in the table above are detailed below:

Information you provide to us:
If you are a representative or employee of any Buyer or Seller or a sole trader Buyer or Seller, subject to your use of the applicable functions and/or services on the Platform, we may ask you to provide:

● Contact information, such as contact/legal representative name, address, phone number of the company/the contact, email address of the company and the contact/legal representative, job title and department, ID information, phone bills of the contact/legal representative.
● Account information, such as your username and password, gender and your account settings.
● Business information, such as identity information, tax registration and/or related information about your business, such as your company name, registration number and date, company official website, business type and industry, corporate registration details and information about your business license, proof of business operation including lease agreement, property deed, utility bills and etc.
● Transaction information, such as transaction statements, billing/delivery address of the recipient of your order, payments and orders placed, and other details of the products you have supplied or purchased through the Platform.
● Payment information, such as bank account numbers, credit/debit card numbers, credit/debit card holders, expiration dates and security code and tracking information from cheques or money orders, bank statement and account opening page.
● In order to facilitate your use of the services available on the Platform (including on mobile-optimized 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 photos, videos, calendar and/or other files. If you are using the communication tools available on the Platform (particularly in case of voice communication), we may require access to your camera and/or microphone.
● 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.

Information that we may collect automatically:
If you are a Buyer or Seller or prospective Buyer or Seller, we may automatically collect:

● Device information, such as the type of device you use, unique device identification numbers, IP addresses, browser type, browsing patterns, advertising identifiers and other types of identifiers.
● Online activity information, such as page views and searches, information about content that has been viewed and/or downloaded, information about your activity on a page or screen, access times and duration of access, and other details of how you have interacted with our Platform.
● Location information, such as your general geographic location, and, with your permission, the approximate location data of your mobile device. Please note that for most mobile devices, you can manage or disable the use of precise location services for all applications in the settings menu of your mobile device.
● Communication information, such as posts and/or contents uploaded on the Platform, any comments on content you have uploaded to the Platform or on other Users’ content on the Platform.
● Marketing and advertising information, such as your interests based on your use of the Platform and your purchases, responses to surveys, promotions you participate in, preferences in receiving marketing content from us, communication preferences, preferences for particular products or services and your subscription data.
● User-generated content, such as profile photos, videos or audio recordings that you upload to the Platform as part of product reviews or by sharing content in socializing within the Platform.
● Other information, such as statistical information about the Platform and visitors to the Platform including, browser software, operating system, software and hardware attributes, number of sessions and unique visitors.

Some of this information may be collected using cookies and similar tracking technology, as explained further under our Cookies Policy.

Information that we receive from third parties:

● Social media account information, such as social media username, profile picture and your login details where you choose to log into the Platform using social media accounts or when you interact with us through an external service or application.
● Communication information, such as feedback and other communications with us (including when you interact with our subcontracted customer support agents), disputes/complaints from Vendors/Buyers on the Platform, copy of your correspondence if you contact us such as via our customer services department chat service, telephone or email (including in the case wherein those functions involved integration of services provided by third-party service providers) , chat information between you and other users via instant messaging services.
● Third parties that are engaged by us to provide verification services, such as conducting applicable anti-money laundering, fraud and “Know Your Customer” checks on the Buyers and Vendors, conducting due diligence and verification on Users. This includes your name, email address, company details, and contact information.
● Information about your interactions with products and services offered by our group companies and affiliates.
● If you choose to participate in reviewing or rating products and/or services on cocomart.io, we may receive personal information about you from third parties that work with us to conduct reviews into our services and/or rate us.

3. DISCLOSURE OR SHARING OF PERSONAL INFORMATION

We may disclose (or provide access to) personal information to the following categories of recipients:

● Other Platform Users where necessary in connection with the facilitation of purchases and communications made between you and the other Users.
● Our group companies and affiliates 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.
● Third party business partners and service providers 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:

● Our business partners that offer supplementary services to those provided by us, such as partners that resell our products and services, to the extent you consent to such sharing (where required by applicable law);
● Marketing and advertising platforms, such as Google, Twitter, Facebook and Instagram, and providers of analytics services relating to Users’ behaviour, 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. Some of this information may be collected using cookies and similar tracking technology. The processing activities of these third-party marketing platforms are governed by their own privacy policies, not this Privacy Policy;
● Due diligence and verification service providers, who collect and process personal information to perform due diligence and business verification services;
● Payment service providers who collect and process personal information to assist with settling the payments for transactions or process withdrawal requests for Vendors. 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 Vendors to determine whether a Seller can be permitted to make a fund withdrawal;
● Logistics partners for providing delivery services for Buyers, including return and exchange of products, and warehousing services for Vendors;
● Custom agents for customs clearances purposes;
● Cloud computing service providers to provide cloud storage services;
● Instant messaging service providers for enabling communications between the Buyers and Vendors via the Platform;
● Software development kit (“SDK”) service providers to provide SDK services;
● Customer service providers to provide after-sale services;
● 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 Users who participate in reviewing or rating cocomart.io’s products and/or services;
● External professional advisers, law enforcement agencies, insurers, government and regulators and other organizations where 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.
● Actual or potential business acquirers (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 acquirer that it must use your personal information only for the purposes disclosed in this Privacy Policy.

We may provide 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 may establish relationships with third parties and websites to offer you 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 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.

The instant messaging service on the platform is provided by our partner. We will use your chat information based on security, risk control and other compliance requirements based on our platform policies and rules, legal and regulatory requirements, response to requests from regulatory authorities, provision of services (including but not limited to transactions processing and dispute settlement between the Buyers and Vendors, Users complaints handling) and other analytical and service needs. You may refer to the applicable privacy policy of our partner for more data processing details relating to such service.

4. RETENTION

We retain your personal information as long as we have an ongoing legitimate business need to do so, for example to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it.

5. COOKIES

To enable our systems to recognize your browser or device and to provide and improve our services, we or our authorized service providers may use cookies, beacons and/or other similar technologies (collectively, “Cookies”). For more information about the types of Cookies we use, why, and how you can control them, please read our Cookies Policy.

6. YOUR RIGHTS

As a user of the Platform, you may have the following data protection rights, which you can exercise pursuant to applicable laws at any time by contacting us using the contact details provided under section 10. “HOW TO CONTACT US” below:

  • The right to access, correct, update or request deletion of your personal information.
  • The right to object to processing of your personal information when it is based on our legitimate interests, and separately the right to object to direct marketing.
  • 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 10. “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 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 live in a jurisdiction that provides for a right to appeal a denial of your request to exercise such rights, you may submit your appeal using the contact details provided under section

  1. “HOW TO CONTACT US” below.

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.

7. MINORS

The Platform is intended for adults. 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 ( “Minors”).

We do not intend to sell any of our products or services to Minors. If a Minor has provided us with personal information without parental or guardian consent, the parent or guardian should contact [email protected] to remove the information.

8. SECURITY MEASURES

We implement appropriate technical and organizational measures to prevent unauthorized access to the Platform, to maintain data accuracy and to ensure the correct use of the information we hold.

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. You must not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited email. 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 to us and you do so at your own risk.

9. PROHIBITED ITEMS

Inasmuch as we would like to respect the privacy of our users, and their rights to vend/buy on our platform in accordance to their personal choices, there are Items that we do no allow on our platform. This includes (but not limited to) the underlisted. The items can be delisted, vendors can be reported to relevant agencies even without warning. The list can be updated without prior notice, either to comply with laws and regulators or the terms of cocomart.io or both.

  • Adult items
  • Airsoft, air rifles & BB guns
  • Animal traps
  • Art (patented)
  • Artifacts and cave formations
  • Beta & OEM software (patented)
  • Chance listings (gambling/prediction markets)
  • Charity listings
  • Compilations of information
  • Cosmetics and perfume (bleaching, etc and/or according to regulations)
  • Counterfeit items n Coupons
  • Credit and debit cards
  • Disaster and tragedy and relief materials
  • Electronic equipment (according to regulations)
  • Electronically delivered items (passports, etc according to regulations)
  • Embargoed goods
  • Emissions control defeat devices
  • Encouraging illegal activity
  • Firearms and accessories
  • Government items
  • Hazardous materials
  • Human body parts
  • Illegal drugs and drug paraphernalia
  • Illegal explicit content
  • Military items
  • Offensive materials
  • Personal information
  • Police-related items
  • Prescription drugs
  • Prohibited adult items
  • Stamps
  • Stocks and securities
  • Stolen property
  • Violence related products/services
  • Weapons

10. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time including in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to notify you, consistent with the significance of the changes we make. We will obtain your consent if and when we materially change this Privacy Policy in a way that reduces the protection of your personal information collected in the past. Any changes to this Privacy Policy will be communicated by us posting an amended Privacy Policy on the Platform. Once posted on the Platform, the new Privacy Policy will be effective immediately. You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

11. HOW TO CONTACT US

You can click here to exercise your rights after accessing your account. And if you have any requests, questions or concerns about our use of your personal information and this Privacy Policy, you can contact our Data Protection Officer at [email protected].

If you are a registered member of the Platform, or regulators, you may reach out to us via the mechanisms set out above or contact our Privacy Representative:

  • Company Name: COREDAO BLOCKCHAIN COMMUNITY EDUCATION

SERVICE

12. LANGUAGE

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

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