PRIVACY POLICY

(Revised April 2025)

The purpose of this Privacy Policy is to explain how, when and why is your personal data processed by or through our website, as well as to inform you regarding the legal rights you have as a data subject related to the processing of your personal data.

This Privacy Policy does not consider the processing activities performed by our partners. Please check our partner’s privacy notices for information on the way they process your personal data as controllers.

1. WHO ARE WE?

The website www.lingble.com is owned and administrated by Lingble Pte. Ltd., a company incorporated by Singapore laws, headquartered in 78 Shenton Way, #20-03, Singapore 079120, hereinafter referred to as the “Controller” or “Us”.

Lingble is a global eCommerce solutions company taking local and regional brands to the world. With Lingble Global Guide^TM, partners are guided through a customized global brand journey that is built on experience, expertise and technology.

2. DEFINITIONS

Personal data or personal information – means any information regarding an identified or identifiable natural person;
Controller – means the natural or legal person that determines the purposes and means of the processing of personal data processing. Regarding the personal data processing activities performed through the website, the Controller is Lingble Pte. Ltd., “Us”, “We”;
Data subject – means the identified or identifiable natural person the personal data refers to;
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, storage, adaptation, consultation, use, disclose or deletion;
Consent of the Data subject – means any freely given, specific, informed and unambiguous indication of the user's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
The website - www.lingble.com
Services – means the services provided by Lingble related to eCommerce solutions

3. HOW DO WE COLLECT PERSONAL DATA?

As a rule, the Personal Data we process is collected directly from you as a Data Subject. However, there may be situations where data is collected indirectly from social media, from the website of the company you represent, from your employer as a contact person, from a third party who recommended you or from various public platforms (for example ad platforms).

When we do not receive personal data directly from you, we will inform you accordingly on the processing activities within the legal term.

4. CHILDREN AND SENSITIVE DATA

Our Website and Services are not intended for individuals below the age of 18. If you are between the ages of 13 and 17, inclusive, you are visiting the Website under the supervision of a parent or guardian. We do not intentionally collect Personal Information from individuals below the age of 18.

If you are the parent or legal guardian of a child below the age of 18 and you believe your child has provided us with personal information, please contact us to request the deletion of these personal data. If we confirm that we have collected this kind of personal information, we will delete that information as soon as possible.

We do not collect nor is our intention to collect personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation or personal data relating to criminal convictions and offences or related security measures, excepting the situations expressively regulated by the applicable law.

5. OUR PURPOSES FOR PROCESSING PERSONAL DATA, LEGAL GROUNDS AND RETENTION PERIODS

Below you will find information about the purposes for which we Process your Personal Data, the categories of Data we collect for those purposes, the legal grounds on which we carry out the Processing activities and the periods of time we store the Personal Data, in relation to the purposes of the Processing.

Where the lawful basis for the Processing is the Data Subject’s Consent, you may withdraw your consent at any time without constraint and without affecting the lawfulness of the Processing prior to its withdrawal.

5.1. Purpose: Process, manage and respond to your requests

Personal data categories: First name, last name, email address, social network profile, image, voice and telephone number depending on the communication channel you decide to contact us or that we agree to use in the communication between us and any other personal data that you choose to include in the message title and/or in the message.

We may also ask you for additional information that may be required in order to fulfil a contractual obligation under our Services or otherwise as may be necessary to resolve the matter for which you contacted us e.g. company name, role or representation powers, order number.

Legal ground: Processing of your personal data is based on the contractual relationship between you and us if the case, and also considering our legitimate interest to communicate with you and provide our service offer or support in solving your requests that arise from using our services, and to maintain and promote your satisfaction.

Retention period: We generally store your personal data for as long as we have a contract in place. Your data will be either deleted or anonymized within 1 (one) year from the termination date of the contract. If we have not entered in a contractual relationship, but you choose to contact us, we will store your personal data for a period of 1 (one) year, after which your data will be either deleted or anonymized.

If your data is required for a longer period of time due to legal storage reasons or to establish, exercise or defend a right in court, we store your data in accordance with personal data protection regulations for as long as it is requested by law or is necessary to fulfil the purpose.

5.2. Purpose: To inform you electronically about promotions, offers, or similar promotional activities, and any other information related to our services that we think you may be interested in (e.g., industry information, new blog posts).

Personal data categories: First name, last name, email address.

Legal ground: We rely on your consent to send you direct marketing and information that we think you may be interested in.

Retention period: Personal data will be retained until you withdraw your consent, after which the data will be deleted. You can withdraw your consent at any time, by clicking Unsubscribe at the bottom of any of our emails, without affecting the legality of the processing based on the consent before its withdrawal. Please allow approximately 10 (ten) business days for any opt-out requests to be processed.

5.3. Purpose: Initiate or carry out the contractual relationship with your employer – B2B contractual relationship

Personal data categories: First name, last name, email address, phone number, company name, role or representation powers, signature, company address and company phone number.

Legal ground: Processing of your personal data is performed considering our legitimate interests to conclude the service agreement and provide services to the company that you represent and to communicate announcements in relation to our services such as those about the ongoing business relations with the company that you represent.

Retention period: We will retain your personal data as long as there is a service agreement in place with the company that you represent, as well as for a period of 3 (three) years from the termination of the contractual relationship, after which your data will be either deleted or anonymized.

5.4. Purpose: Ensure functionality and security of our Website, perform checks and technical support, prevent and identify frauds

Personal data categories: Online Identifiers, commercial information, and internet activity information such as IP address (or proxy server), mobile device number, device and application identification numbers, location, browser type, internet service provider or mobile carrier, the pages and files viewed, website and webpage interactions including searches and other actions you take, operating system and system configuration information and date and time stamps associated with your usage.

Legal ground: Processing of your personal data is performed considering our legitimate interest to protect your personal data and to monitor and improve the information security of our services.

Retention period: We generally store your personal data for 3 (three) years, after which your data will be either deleted or anonymized.

5.5. Purpose: Comply with legal obligations such as accounting records, archiving, etc.

Personal data categories: First name, last name, company name, role or representation powers and any other personal information required by law.

Legal ground: Processing of your personal data is necessary for compliance with a legal obligation.

Retention period: Personal data will be retained according to the applicable legislation in force.

5.6. Purpose: Establish, exercise, or defend a right in proceedings before a court, administrative procedure or other formal proceedings in which we are involved

Personal data categories: First name, last name, company name, role or representation powers and any other personal information necessary to fulfil the purpose.

Legal ground: Processing of your personal data is performed considering our legitimate interest in defending or exercising our rights and interests and also to comply with a legal obligation to which we are subject.

Retention period: Personal data will be retained according to the applicable legislation in force or until the final settlement of the case.

5.7. Purpose: Select and recruit for filling vacant roles

Personal data categories: First name, last name, email address, phone number, education, professional experience, targeted role, profession or qualification, professional and social skills and any other relevant information provided by you, as a candidate, contained in your CV.

Optionally, we might collect and process personal data contained in your cover letter or in the indicated link to your work or portfolio, if you choose to provide us with such data.

Legal ground: Processing of your personal data is based on the contractual employment relationship between you and us and considering our legitimate interest to contact you for future vacant jobs.

Retention period: Personal data will be retained according to the applicable legislation in force and up to 1 (one) year from the end date of the selection and recruitment process, after which the data will be deleted.

5.8. Purpose: Collect your feedback through satisfaction surveys in order to help us improve our services and the planning of future events

Personal data categories: First name, last name, email address and any other personal information provided by you and contained in the review message.

Legal ground: We rely on your freely express consent when you voluntarily fill out our review form. You can withdraw your consent at any time, without affecting the legality of the processing based on the consent before its withdrawal.

Retention period: Personal data will be retained for as long as we have your consent until withdrawal, in which case data will be deleted. However, we can proceed to the deletion of personal data when we decide that it is no longer relevant for achieving the purpose for which it was given.

5.9. Purpose: Facilitate your participation to events e.g., webinars, conferences and to make the recording publicly available if the case

Personal data categories: First name, last name, email address, company, telephone number, role or representation powers, image, voice, country/location and any other personal data you voluntarily provide when using the chat, if the case

Legal ground: We rely on your freely express consent, granted by registering for the respective event.

If we decide to record the event and make it publicly available by posting it online e.g., on our website, we will inform you in advance, and ask for your consent prior to the processing.

You can withdraw your consent at any time, without affecting the legality of the processing based on the consent before its withdrawal.

Retention period: Personal data related to audio-video recordings will be retained for as long as we have your consent until withdrawal, or until we decide that the data is no longer relevant for this purpose, in which case data will be either deleted or anonymized.

If we decide not to record the event, we will keep your personal data for a period of 6 (six) months from the date of the event, after which the data will be deleted.

6. COOKIES

Our Website uses cookies, plug-ins and other online identifiers in order to ensure functional browsing or to provide a better browsing experience, to perform statistical analysis on accessing information on the site, or to provide you with custom content and advertising appropriate to your preferences and interests.

Cookies are small text files placed by the visited website or page, through the browser, on the device you use for browsing (computer, smartphone, etc.), which identifies the device when the website or the page is accessed.

Plug-ins are small software applications placed by social media platform providers that integrate them when they are included on the visited website or page.

Online identifiers may be placed by Lingble or by third-parties. In accordance with the permissions you have granted, our partners, third-party websites, will place cookies that will allow you to view the content of these third-party websites on our website and to share the content on the website. The third-parties may collect and use your personal data through their cookies for the purposes they have determined in accordance with their privacy policy. Lingble provides you with the identity information and links to these third-parties, as well as the option to accept or reject their online identifiers.

Personal data may be processed through cookies on the basis of the users’ prior consent, excepting those situations when the cookies and other online identifiers are used for the purpose of transmitting a communication via an electronic communications network or they are necessary in order to provide an information society service, expressly requested by the user. In such case, the processing of personal data is carried out in accordance with the legislation in force on personal data processing and privacy protection in the electronic communications sector on the basis of our legitimate interest of ensuring safe browsing of our website, both for us and for our users, by implementing appropriate technical and organizational measures.

Depending on the cookie type, the categories of personal data processed by cookies may be information about the used device, journal information like IP, searches, browser, browser’s language, hardware settings, date and time of the request, method used to send requests to the server, file capacity obtained in response, and other parameters regarding the user’s operating system.

Detailed information on the cookies our website uses may be found in our Cookie Policy.

How can you change and manage cookies?

Most web browsers allow you to manage cookies. You can choose to accept or reject all cookies, or just specific types of cookies.

The following links provide information on how to modify the cookies settings on some popular browsers:

7. AUTOMATED DECISION MAKING

We do not make decisions based solely on automatic data processing of your data including profiling that will have legal effects on you or that will affect you in a similar way to a significant extent.

8. DISCLOSURE AND TRANSFER OF PERSONAL DATA

We may transfer your personal information, to the extent that this is necessary, to the following categories of recipients: service partners, subcontractors, shipping providers, payment providers, archiving companies, IT service providers, software or hardware vendors, market research companies, marketing companies, public authorities, court or arbitral tribunals, as well as competent authorities to investigate criminal offenses.

Personal data may be disclosed or transferred to the categories of recipients mentioned above in order to provide our services at the highest quality level, ensuring the intervention of specialists by outsourcing parts of our business or to provide access to services and benefits according to our business partnerships or to ensure compliance the specific legal obligations to which we are subject according to the activity carried out.

In the event that, in exceptional cases, your data is transferred to third countries we will apply the technical and organisational measures required by law and you will be informed about the transfer in accordance with the legal requirements.

9. SECURITY OF PERSONAL DATA

The security of your Personal Data is important to us. Therefore, we maintain a variety of appropriate technical and organizational measures to protect your Personal Data from loss, misuse, and unauthorized access or disclosure. We limit access to Personal Data to employees who we believe reasonably need to retrieve that information to provide our services. Considering the current state of technology, we have implemented reasonable physical, electronic, and procedural safeguards designed to protect your Personal Data, such as limiting access, encrypting, anonymizing, or storing it on secure media.

Given the technological dynamics and the magnitude of the current threats in the online environment, despite our considerable efforts to ensure the highest possible level of protection of personal data, we cannot always guarantee the absolute effectiveness of the security measures implemented. For this reason, it is very important that you, as the Data subject, know the risks and take minimum measures to protect your Personal data, by thoroughly checking the sources of information, avoiding access to suspicious or unknown links, regular change of passwords and the use of appropriate anti-virus and anti-malware solutions.

10. YOUR RIGHTS AND HOW TO EXERCISE THEM

Right to be informed: You have the right to be informed regarding the processing of your personal data, as we are doing through this Privacy Policy.

Right of access: You have the right to obtain confirmation whether or not we process your Personal Data, as well as information on the specifics of the processing activities, as well as get access to that Personal data.

Right to rectification: You have the right to obtain from the Controller without undue delay the rectification of inaccurate Personal Data concerning you. Taking into account the purposes of the Processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to erasure: You have the right to obtain from the Controller the erasure of personal data concerning you without undue delay to the extent that the legal requirements are met. Personal Data will be erased when the legal requirements are met.

Right to restriction of processing: If the applicable legal provisions are met, you have the right to obtain the restriction of Processing of your Personal Data.

Right to data portability: If the applicable legal provisions are met, you have the right to receive your Personal data which you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit those data to another Controller.

Right to object: In certain situations, such as when we process Personal Data based on legitimate interest, you have the right to object the Processing of your Personal Data. In the event of unjustified opposition, the Controller is entitled to further process your Personal data.

Right to object commercial communication: You may also object to the Processing of your Personal Data for the purpose of sending commercial messages.

Right not to be subject to decisions based solely on automated processing: If the applicable legal provisions are met, you have the right not to be subject to a decision based solely on automatic processing, including profiling, which has legal effects on you or affects you similar to a significant extent.

Right to Opt-Out of Sale or Sharing of Personal Information: You have the right, at any time, to direct a business that sells personal information about the consumer to third parties not to sell the consumer's personal information.

Right to address to the Supervisory Authority: You have the right to file a complaint with the competent Supervisory Authority on any violation of your rights regarding the processing of your Personal Data.

If you want to contact the Supervisory Authority from your place of residence, another EU Member State, you may find the contact details at https://edpb.europa.eu/about-edpb/about-edpb/members_en#member-ie.

Consent withdrawal: To the extent that we process your Personal data based on your given Consent, you can withdraw your Consent at any time, without affecting the lawfulness of the Processing based on the consent prior to its withdrawal.

Except for the right to contact the Supervisory Authority, which you can exercise using the contact details indicated above, you can exercise your legal rights by contacting our Data Protection Officer in writing at the e-mail address [email protected].

We will respond to your requests without undue delay and in any case within one month of receiving the request. This period may be extended by two months where necessary, taking into account the complexity and number of applications. We will inform you of any such extension within one month of receiving the request, stating the reasons for the delay.

In the event that we do not take action on your request, we will inform you, without delay and no later than one month after receipt of the request, of the reasons for not taking action. In such a case, you have the possibility to lodge a complaint with the competent Supervisory Authority or to take a legal action.

11. EUROPEAN UNION REPRESENTATIVE

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons regarding the processing of personal data and on the free movement of such data (GDPR), Lingble’s designated representative in the European Union is Mr. Alexandru Ganea. If you are based in European Union, you may contact our representative by e-mail at [email protected].

12. UPDATES

This Policy is subject to periodic review and updating to ensure that it always corresponds to reality and it is in line with the applicable legal requirements. For this reason, please consult this section regularly to keep up to date with any changes. Any major changes to this Policy will be notified accordingly.

13. CONTACT

If you have any questions or concerns regarding the Processing of your Personal Data, this Privacy Policy or how it applies, or you wish to exercise any of your rights, you can contact the Data Protection Officer in one of the following methods:

Email: [email protected]
Website form: Contact Us - Lingble
Postal address: 78 Shenton Way, #20-03, Singapore 079120 mentioning “in the attention of the Data Protection Officer”.

We thank you for your interest,

Lingble team