Privacy Policy

This is the SGBestBuy Privacy Policy Statement (“Privacy Policy”) and the purpose of this document is to inform you of how TRAXX Trading Pte Ltd, Traxx IT Services Pte Ltd, Traxx Payments Pte Ltd, and Traxx Asia (Hong Kong) Co., Ltd (“SGBestBuy”) manages, collects, uses and discloses your Personal Data, which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”).

When you submit information to us, or sign up as a customer on our Website to purchase, view or otherwise surf any of the products or services offered by us (the “Products and Services”), you agree and consent to SGBestBuy (including its related corporations and business units) (collectively, the "Companies"), as well as their respective representatives and/or agents collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies' authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.

SGBestBuy may update this Privacy Policy to ensure that it is consistent with industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on our Website.

Personal Data

In this Privacy Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

Collection of Personal Data

SGBestBuy collects Personal Data, either directly from you or from your authorised representatives (i.e. persons whom you have authorised, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), from third parties, or from publicly available sources or through our Website in the following ways:

> When you submit a form for registering as a customer on our Website or any other forms relating to any of our Products and Services
> When you interact with our customer service team, for example, via telephone calls, letters, face-to-face meetings and emails
> When you use some of our services, for example, websites and apps including establishing any online accounts with us
> When you request that we contact you, be included in an email or other mailing list
> When you respond to our promotions, initiatives or to any request for additional Personal Data
> When you are contacted by, and respond to, our marketing representatives and customer service team
> When we receive references from business partners and third parties, for example, where you have been referred by them
> When you submit your Personal Data to us for any other reasons.

When you browse our Website, you generally do so anonymously, however, once you give us your personal information, you are not anonymous to us. If you choose to provide us with personal information, you consent to the transfer process and storage of that information on our servers.

We may collect and store the following personal information:

_• Email address, physical contact information, the date of birth and gender information, and (depending on the service used) sometimes financial information, such as credit card or bank account numbers;
_• Transactional information based on your activities on the Website (such as buying, selling, bidding, item and content you generate or that relates to your account);
_• Postage, billing and other information you provide to purchase or dispatch an item;
_• Community discussions, chats, dispute resolution, correspondence through our Website, and correspondence sent to us;
_• Other information from your interaction with our Website, services, content and advertising, including computer and connection information, statistics on page views, traffic to and from the Website, ad data, IP address and standard web log information;
_• Additional information we ask you to submit to authenticate yourself or if we believe you are violating site policies (for example, we may ask you to send us an ID or bill to verify your address, or to answer additional questions online to help verify your identity or ownership of an item you list);
_• Information from other companies, such as demographic and navigation data; and
_• Other supplemental information from third parties (for example, if you incur a debt to the Company, we will generally conduct a credit check by obtaining additional information about you from a credit bureau, as permitted by law).

If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Products and Services you have requested.

Use & Disclosure of Personal Data

SGBestBuy may use and disclose your Personal Data for the following purposes:

_• Responding to your queries and requests;
_• Managing the administrative and business operations of SGBestBuy and complying with internal policies and procedures;
_• Facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
_• Matching any Personal Data held which relates to you for any of the purposes listed herein;
_• Resolving complaints and handling requests and enquiries;
_• Preventing, detecting and investigating crime and analyzing and managing commercial risks;
_• Providing media announcements and responses;
_• Monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
_• Organising promotional events;
_• Legal purposes (including but not limited to obtaining legal advice and dispute resolution);
_• Conducting investigations relating to disputes, billing or fraud;
_• Meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on SGBestBuy (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and
_• Purposes which are reasonably related to the aforesaid.

Where permitted under the Act:

SGBestBuy may also collect, use and disclose your Personal Data for the following “Additional Purposes”:

_• Analytics and tracking;
_• Conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programmes in relation to SGBestBuy’s Products and Services, and to improve our service delivery and your customer experience at our touchpoints;
_• Providing additional Products and Services and benefits to you, including promotions, loyalty and reward programmes from SGBestBuy;
_• Matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of Products and Services by SGBestBuy;
_• Leads generation and management for marketing SGBestBuy’s Products and Services;
_• Administering contests, competitions and marketing campaigns, and
_• Personalising your experience at SGBestBuy’s touchpoints;
_• Communicating to you advertisements involving details of our Products and Services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you (including but not limited to upselling, cross selling and online marketing);
_• Purposes which are reasonably related to the aforesaid.

In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for SGBestBuy Additional Purposes, to the vendors or other third party service providers in connection with promotions and services offered by SGBestBuy.

SGBestBuy may also collect, use and disclose your Personal Data for the following “Preferred Partners Additional Purposes”:

_• Conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programmes with our preferred partners;
_• Matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of products and services (including promotions, loyalty and reward programmes) by our preferred partners;
_• Leads generation and management for marketing the products and services offered by our preferred partners;
_• Administering contests, competitions and marketing campaigns in connection with the products and services offered by our preferred partners;
_• Communicating to you advertisements involving details of the products, services, special offers and rewards offered by our preferred partners, either to our customers generally, (including but not limited to upselling, cross selling and online marketing); and
_• Purposes which are reasonably related to the aforesaid.

In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for Preferred Partners' Additional Purposes, to the vendors or other third party service providers in connection with promotions and services offered by SGBestBuy’s preferred partners.

If you have provided your Singapore telephone number(s), SGBestBuy may contact you using such Singapore telephone number(s) (including via voice call, sms, and/or other means) with information about our Products and Services or those products and services offered by our preferred partners (including discounts, flash sales and/or special offers).

In relation to particular Products and Services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

Should you wish to withdraw your consent for us to send you sales, marketing or promotional information via a specific mode, please inform us as follows:

> To withdraw consent from receiving SMS promotions: please unsubscribe by following the steps provided in the promotional SMS;
> To withdraw consent from promotional emails: please click on the Unsubscribe link in the promotional emails.

Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to thirty (30) days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials through a specific mode, we may still contact you for other purposes in relation to the Products and Services that you hold or have subscribed to with SGBestBuy.

Disclosure of Personal Data

SGBestBuy will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:

_• SGBestBuy’s related corporations and employees to provide content, Products and Services to you, address your questions and requests in relation to your customer accounts, subscription and billing or order arrangements with us as well as our Products and Services, to activate, deactivate, install, maintain and operate our systems and/or services;
_• Companies providing services relating to insurance and consultancy to SGBestBuy;
_• Agents, contractors or third party service providers who provide operational services to SGBestBuy, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services to SGBestBuy;
_• Vendors or third party service providers in connection with marketing promotions and services offered by SGBestBuy or its preferred partners;
_• Commercial shops and retailers in relation to providing rewards and benefits;
_• Any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;
_• Our professional advisers such as auditors and lawyers;
_• Relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
_• Any other party to whom you authorise us to disclose your Personal Data to.

Using Information from this Website

We enable you to share personal information to complete transactions. When users are involved in a transaction, they may have access to each other's name, user ID, email address and other contact and postage information. In all cases, you must comply with the Act and all other applicable law, and give other users a chance to remove themselves from your database and a chance to review what information you have collected about them.

You agree to use user information only for:

> Fulfillment of the transaction through this Website and purposes related to the transaction;
> Using services offered through this Website (e.g. escrow, postage and fraud complaints); or
> Other purposes that a user expressly chooses.

Cookies

A cookie is a small piece of information that is placed on your computer when you visit certain websites.

SGBestBuy uses cookies on its Website for the following purposes:

> Enabling certain features and functions on our Website, e.g. remembering your user-id, browsing and other service preferences;
> Building up a profile of how you and other users use the Website;
> Improving the efficiency of our Website;
> Administering services to you and to advertisers; and
> Establishing usage statistics.

Most internet browsers provide you the option of turning off the processing of cookies (please see the “help” section of your browser), but this may result in the loss of functionality, restrict your use of the Website and/or delay or affect the way in which it operates.

Advertisements on the SGBestBuy website may be provided by third party advertisers and their agencies. These may generate cookies to track how many people have seen a particular advertisement (or use the services of third parties to do this), and to track how many people have seen it more than once. SGBestBuy does not control these third parties and their cookie policies and if you have questions about their cookie policies, please contact the respective third party advertising agencies.

SGBestBuy is not responsible for the Privacy policies (including Personal Data protection and cookies), content or security of any third party websites linked to the SGBestBuy website.

No Spam, Spyware or Spoofing

Our users and us do not tolerate spam, thus you may set your communication preferences in SGBestBuy so we communicate to you as per your request. You are not authorised to add other users of this Website, even a user who has purchased an item from you, to your mailing list (email or physical mail) without their express consent. To report SGBestBuy-related spam or spoof emails to SGBestBuy, please contact us via the Contact Page. You may not use our communication tools to send spam or otherwise send content that would violate our User Agreement. We automatically scan and may manually filter messages to check for spam, viruses, phishing attacks and other malicious activity or illegal or prohibited content, but we do not permanently store messages sent through these tools. We do not rent or sell these email addresses.

Account Protection

Your password is the key to your account, thus keep your password secure. Use unique numbers and letters and do not disclose your password to anyone. If you do share your password or your personal information with others, you are fully responsible for all activity, liability and damages. If you lose control of your password, you may lose substantial control over your personal information and may be subject to legally binding actions taken on your behalf. SGBestBuy cannot and will not be liable for any loss or damage arising from your failure to keep your password secure. Therefore, if your password has been compromised for any reason, you should immediately notify us and change your password.

SGBestBuy reserves the right, in SGBestBuy's sole discretion, to cancel unconfirmed or inactive accounts. SGBestBuy reserves the right to refuse service to anyone, for any reason, at any time.

Accessing, Reviewing, Changing and Retaining Your Personal Information

You can see, review and change most of your personal information by signing on to the Website. We will not manually modify your personal information because it is very difficult to verify your identity remotely. You must keep your account information up-to-date and accurate at all times, including a valid email address. Once you make a public posting, you may not be able to change or remove it.

We will retain Personal Data in accordance with the Act and/or other applicable laws. That is, we will destroy or anonymous your Personal Data as soon as it is reasonable to assume that:-

_• Purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data;
_• Retention is no longer necessary for any legal or business purposes. If you cease using the Website, or your permission to use the Website and/or the Products and Services is terminated, we may continue storing, using and/or disclosing your Personal Data in accordance with this Privacy Policy and our obligations under any applicable law. Subject to applicable law, we may securely dispose of your Personal Data without prior notice to you. SGBestBuy will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Security

SGBestBuy encrypts sensitive information (such as credit card number) using secure socket layer technology (SSL). SGBestBuy follows generally accepted industry standards to protect the personal information submitted to us, both during transmission and once SGBestBuy receives it. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Third Parties

Except as otherwise expressly included in this Privacy Policy, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to others, whether they are buyers or sellers on our Website or other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. We encourage you to ask questions and to review their privacy policies before you disclose your personal information to others.

Governing Law

This Privacy Policy and your use of this Website shall be governed in all respects by the laws of Singapore.

Effective Date: [Date]
Updated: [Date]

SGBestBuy reserves the right to alter these policies at any time. Your continued use of the Sites and Services after such changes have been posted shall constitute your acceptance of such revised Terms of Service. If your questions are not answered online, you may write to us at support@sgbestbuy.com.