Privacy Policy

Introduction

This Privacy Notice provides information on how Efresho collects and processes your personal data when you visit our website or mobile applications. It sets out what we do with your personal data, how we keep it secure, and explains the rights that you have in relation to your personal data.

Who We Are

Efresho is a leading e-commerce platform. Our platform consists of our marketplace, which connects sellers with consumers, our logistics service, which enables the shipment and delivery of packages from sellers to consumers, and our payment service, which facilitates transactions among participants active on our platform in selected markets.

This website and/or mobile app is operated by a member of the Efresho group of companies. Any personal data provided or collected by Efresho is controlled by the subsidiary that the website and/or mobile app relates to.

The Data We Collect About You

Personal data means any information that can be used to identify directly or indirectly a specific individual. We collect your personal data in order to provide tailored products and services and to continually improve our products and services. We may collect, use, store, and transfer different kinds of personal data for marketing and optimization purposes. Efresho also uses Google Digital Marketing to propose targeted offers for certain products and services to our customers.

Information You Provide to Us

We receive and store the information you provide to us including your identity data, contact data, biometric data, delivery address, and financial data. This includes:

• Contact Details: Such as your name, postal addresses, phone numbers, and email addresses.
• Demographic Information: Such as your date of birth, age or age range, and gender.
• Online Registration Information: Such as your password and other authentication information.
• Payment Information: Such as your credit card information and billing address.
• Questionnaire Information: Such as responses to customer satisfaction surveys or market research.
• Competition Entries/Submissions: And in certain cases, your marketing preferences.

Information We Automatically Collect/Generate or Obtain from Third Parties

We automatically collect and store certain types of information regarding your use of the Efresho marketplace including information about your searches, views, downloads, and purchases. In addition, we may receive information about you from third parties including our carriers, payment service providers, merchants/brands, and advertising service providers.

This information may include:

• Device Information: Such as your PC, tablet, or other mobile device.
• Usage Information: Such as details of web pages visited, products viewed, purchased, or added to an online shopping basket, and how long you spend on certain areas of a website or app.
• Personal Preferences: Including geographic location, social media username or ID, and social media profile information.

Cookies and Other Identifiers

A cookie is a small file of letters and numbers that we put on your computer, mobile phone, or tablet if you agree. Cookies allow us to distinguish you from other users of our website and mobile applications, which helps us to provide you with an enhanced browsing experience. For more information about cookies and how we use them, please read our Cookie Notice.

How We Use Your Personal Data

We use your personal data to operate, provide, develop, and improve the products and services that we offer, including the following:

• Registering you as a new customer.
• Processing and delivering your orders.
• Managing your relationship with us.
• Enabling you to participate in promotions, competitions, and surveys.
• Improving our website, applications, products, and services.
• Recommending/advertising products or services which may be of interest to you.
• Enabling you to access certain products and services offered by our partners and vendors.
• Complying with our legal obligations, including verifying your identity where necessary.
• Detecting fraud.

Legal Basis for Processing Personal Data

We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and used your personal data. In almost every case the legal basis will be one of the following:

• Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time.
• Our Legitimate Business Interests: Where it is necessary for us to understand our customers, promote our services, and operate effectively.
• Performance of a Contract with You: For example, where you have purchased a product from us and we need to use your contact details and payment information to process your order and send the product to you.
• Compliance with Law: Where we are subject to a legal obligation and need to use your personal data to comply with that obligation.

How We Share Your Personal Data

A. Purposes for Sharing

We may need to share your personal data with third parties for the following purposes:

• Sale of Products and Services: To deliver products and services purchased on our marketplace from third parties.
• Working with Third-Party Service Providers: To perform certain functions on our behalf such as fulfilling orders, delivering packages, analyzing data, providing marketing assistance, processing payments, transmitting content, and providing customer service.
• Business Transfers: As we continue to develop our business, we might sell or buy other businesses or services, transferring customer information as part of business assets.
• Detecting Fraud and Abuse: To other companies and organizations for fraud protection and credit risk reduction, and to comply with applicable law.

B. Conditions for Sharing

When we share your personal data with third parties, we:

• Require them to agree to use your data in accordance with this Privacy Notice and applicable law.
• Only permit them to process your personal data for specified purposes and in accordance with our instructions. We do not allow our third-party service providers to use your personal data for their own purposes.

International Transfers

We may transfer your personal data to locations in another country if this is permissible under applicable laws in your location. There are inherent risks in such transfers. We shall put in place necessary measures to protect your data and ensure the same level of protection available in the country of data origin.

Data Retention

We will take every reasonable step to ensure that your personal data is processed for the minimum period necessary for the purposes set out in this Privacy Notice. Your personal data may be retained in a form that allows for identification only for as long as:

• We maintain an ongoing relationship with you.
• Your personal data is necessary for the purposes set out in this Privacy Notice and we have a valid legal basis.
• Any applicable limitation period.

We will actively review the personal data we hold and delete it securely or anonymize it when there is no longer a legal, business, or consumer need for it to be retained.

Data Security

We have put in place security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. Access to your personal data is limited to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Your Legal Rights

A. Accuracy and Updates

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

B. Rights Under Data Protection Laws

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:

• Access, correct, or erase your personal data.
• Object to or restrict processing of your personal data.
• Ask that we transfer your personal data to a third party.
• Unsubscribe from our emails and newsletters.

C. Account Closure

You can permanently delete your data from our website and other applications by closing your account. Once your account is closed, all products and services that you access through your account will no longer be available.

D. Refusal of Requests

We can refuse to accede to your request where it is unreasonable or where you have failed to provide additional information necessary to confirm your identity.

Data Controllers & Contact

If you have any questions or concerns about Efresho’s Privacy Policy, or if you wish to exercise your legal rights in respect of your personal data, please contact our Data Privacy Officer by email at compliance@efresho.com.

We will investigate any complaint about the way we manage personal data and ensure that we respond to all substantiated complaints within prescribed timelines.