We are committed to protecting the privacy of our Clients and visitors to our websites.
WHO WE ARE
We are Lingble, a company that builds and operates online shops on our technology platform and conducts e-commerce activities, such as fulfilment, customer support and marketing, among others, on behalf of various brands and companies (our “Clients”).
The legal name of our primary operating company is Lingble Pte. Ltd. with its registered office located at 20 Bendemeer Road, #03-12, Singapore 339914.
You can contact us by post at the above addresses or by email at firstname.lastname@example.org.
WHAT PERSONAL DATA WE COLLECT
We collect Personal Data when you subscribe for Lingble Services, when you use our Administrative Panel, our platform, our website, or when you otherwise provide us information. We may also use third party service providers to help us review accounts for fraud or other concerns.
Information you provide us about you and your business, like your name, company name, address, email address, company bank account information, and phone number.
If you voluntarily submit information to our Services or our website, such as filling out a survey about your user experience or using our Administrative Panel messaging features, we collect the information you have provided as part of that request.
WHY WE COLLECT AND PROCESS YOUR DATA
Providing your personal information to us is voluntary, however, if you do not provide some or all of the information we request, we may not be able to provide you with certain services or information. We generally process your information when we need to do so to fulfill a contractual obligation (for example, to process the payment of Net Proceeds to your bank account), or where we or someone we work with needs to use your personal information for a reason related to their business (for example, to provide you with a service). All the personal information we collect and process is necessary to fulfill a contractual obligation, a legitimate business purpose or otherwise collected with your express consent, which you have the right to withdraw at any time.
PERSONAL DATA WE COLLECT FROM OTHER SOURCES
We also collect information about you from other sources including third parties from whom we purchase Personal Data and from publicly available information. We may combine this information with Personal Data provided by you. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. The Personal Data we collect from other sources includes identifiers, professional or employment-related information, education information, commercial information, visual information, internet activity information, and inferences about preferences and behaviors.
In particular, we collect such Personal Data from the following sources:
- Third party providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs and custom profiles, for purposes of targeted advertising, delivering relevant email content, determining eligibility and verifying contact information; and
- Another individual at your organization or who otherwise knows you who may provide us with your business contact information for the purposes of obtaining services.
HOW WE COLLECT AND USE INFORMATION
What Device and Usage Data We Collect
We use common information-gathering tools, such as tools for collecting usage data, cookies, web beacons, pixels, and similar technologies to automatically collect information that may contain Personal Data as you navigate our websites, our services, or interact with emails we have sent to you.
When you use our websites
We gather certain information automatically when individual users visit our websites. This information may include identifiers, commercial information, and internet activity information such as IP addresses (or proxy server information), device and application information, identification numbers and features, location information, browser type, plug-ins, integrations, Internet service provider and/or mobile carrier, the pages and files viewed, searches, referring website, app or ad, operating system, system configuration information, advertising and language preferences, date and time stamps associated with your usage, and frequency of visits to the websites. This information is used to analyze overall trends, help us provide and improve our websites, offer a tailored experience for website users, and secure and maintain our websites.
When you submit an enquiry via our websites
When you submit an enquiry through our website or one of our Lingble powered websites, email, phone or otherwise, we may ask you for information that will allow us to respond to your query, or otherwise resolve the problem you may have. Information we ask for will be solely that which is relevant to your enquiry, and may include, among other things, your name, company, contact telephone number, order number, issue and email address.
We use this information to respond to your query, including providing you with any requested information about our products and services or, on behalf of our Clients, a transaction in a Lingble-powered website. We may also ask you for additional information that may be required in order to fulfill a contractual obligation under our Services or otherwise as may be necessary to resolve the matter for which you contacted us. We may email or contact you several times after your enquiry in order to follow up on your interest and ensure that we have resolved any issues to your satisfaction. We will do this based on our legitimate interest in providing accurate information and customer support in relation to our services and products offered or on behalf of our Clients.
Your enquiry may be stored and processed through a third-party Customer Relationship Management (CRM) software provider that ensures that we do not miss any messages from you and that we follow through on your enquiries until they are resolved. We do not use the information you provide in these enquiries to make any automated decisions that might affect you.
When you use our Administrative Panel
In addition, we gather certain information automatically as part of your use of our cloud Services, such as our Administrative Panel. This information may include 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. This information is used to maintain the security of the Services, to provide necessary functionality, to improve performance of the Services, to assess and improve Client and user experience of the Services, to review compliance with applicable usage terms under the Agreement, to identify future opportunities for development of the Services, to assess capacity requirements, to identify Client and customer opportunities, and for the security of Lingble generally (in addition to the security of our Services). Some of the device and usage data collected by the Services, whether alone or in conjunction with other data, could be personally identifying to you. Please note that this device and usage data is primarily used to identify the uniqueness of each user logging on (as opposed to specific individuals), apart from where it is strictly required to identify an individual for security purposes or as required as part of our provision of the Services to our Clients.
When you sign up for our newsletter
When you sign up for our newsletter we collect your email address and receive consent for us to send you direct marketing and information that we think you may be interested in. Information may include announcements in relation to our services, special promotions, industry information, new blog posts, among others.
Your email address is necessary in order to deliver these communications to you. Your email address is shared with a third-party email marketing software provider, which allows us to prepare visually appealing email communications.
You may withdraw your consent to receive the newsletter or other emails at any time by clicking Unsubscribe at the bottom of any of our emails. Please allow approximately 10 business days for any opt-out requests to be processed.
Please note that even if you opt out of receiving promotional communications, we may continue to send you non-promotional emails, such as those about your account or our ongoing business relations.
When you participate in a promotion or survey
When you participate in a promotion, survey or similar promotional activity (“Promotions”) on or in connection with our website or our Services, you agree to the terms of the Promotion and enter into a contractual relationship with us or with our Clients that is limited to the purpose of that Promotion. The only information we collect in relation to any such Promotions is that which is sufficient to fulfil the obligations and purposes of the contractual relationship. Information provided in connection with any such promotions may include your name, company, contact telephone number and email address.
We do not use the information you provide when participating in promotions to make any automated decisions that might affect you.
When you purchase a product from a Lingble-powered website
Generally, acting as a data processor in Lingble-powered websites, we process your Personal Data as instructed by and on behalf of our applicable Client, who is the controller of the Personal Data in that context. Our Client may ask you for your name, address, contact telephone number, email address and credit card information. We also process information on your product preferences based on your purchases, and record your IP (Internet Protocol) address, which is the address of your computer on the Internet.
We will use your information to verify your credit card details for your purchase, process your order and assist in concluding a contract for sale of products between you and our relevant Client, as well as sending you the products or services you purchased. We will also send you a confirmation and receipt via email and we may use your email or telephone number to contact you regarding your purchase.
We require this information in order to process your payment, deliver your products or services and for our Client to fulfil our contract with you. We record your IP address in order to prevent abuse, to not violate our contractual obligations to our Client (and in turn their contractual obligations to third-parties), and, where applicable, to calculate the tax that applies to a sale, which our Client is required to do so by law.
In some cases, we may also process information you provide about others on behalf of our Client, such as when you purchase a gift card for someone and request that we deliver it electronically, create and share a “wish list” or decide to purchase and ship products to someone else. Our Client will use this information to fulfill your requests. Some of your information (only to the extent necessary to fulfill a purchase or effectuate a return/exchange) will be shared with our courier partners in order to effectuate the delivery of the product to you or the return/exchange to our Clients.
In other instances, we will collect via email identification proof required by the third-party service provider we utilize to prevent fraudulent transactions and chargebacks. This is required in order to be able to process your payment and complete the desired purchase on a Lingble-powered website. This is necessary for our Client to enter into the contract of sale with you. You are not obligated to provide this information. However, if not provided, your payment may not be completed with the payment method you chose to use, and the transaction will be rejected.
We do not collect or classify personal data according to the health or sex life of individual data subjects, but we note that some of the Clients that use our Services have Lingble-powered websites that sell health and personal products from which one might draw inferences about the health or sex life of their respective consumers. Our processing of associated data is carried out as necessary to perform transactions at the data subjects’ request and subject to appropriate safeguards of confidentiality.
Your information is stored on our cloud servers, which are located in Japan. Your credit card details are passed to third-party payment processors which are based in the EU and Japan. We do not retain or store your credit card or other payment method information.
We keep your order information for an indefinite period, as long as our Clients require us to process your Personal Data, or otherwise in accordance with our record retention policies and applicable law.
Additionally, almost every Client using the Lingble Services also uses non-Lingble services to support their business (for example, CRM software, email marketing software, social media and advertising software, or shipping providers). Lingble doesn’t control how these services use your personal information, and you should review any other service you use to make sure it meets your privacy expectations.
When you submit a review about our Clients or their products or upload a photo or other content on a Lingble-powered website
When you submit a review about one of our Clients or about a product, or when you upload a photo or other content (“Member Content”) on a Lingble-powered website we may record your IP address, which is the address of your computer on the Internet, and a Nickname of your choice.
We process this information to provide verified independent views about the products and services our Clients offer to potential customers and to ensure that the Member Content you provide does not violate their or our terms of service. Your Name or Nickname of choice and Member Content (but not your IP address) may be publicly displayed on the relevant Lingble-powered website and used and shared by our Clients in accordance with the Terms and Conditions of the relevant Lingble-powered site.
We do not use the information you provide to make any automated decisions that might affect you.
Your Personal Data is stored for as long as the product or services that the review refers to remains on the Lingble-powered website or until our Client instructs us to stop processing such data, after which it is deleted.
When you open an account in a Lingble-powered website
When you open an account in a Lingble-powered website we collect your email address and name on behalf of our relevant Client. Through your account our Client will request that we process information about shipping (including your contact information), your product preferences, reward points, out of stock and newsletter subscriptions, products in your wishlist, past purchases and customer support requests. We and our Clients use this information to improve your shopping and browsing experience, providing you rewards for shopping with our Clients or easily finding information that you chose to save or about your past purchases.
Social Media Features
Our websites may use social media features, such as the Facebook “like” button, the “Tweet” button and other sharing widgets (“Social Media Features”). Social Media Features may allow you to post information about your activities on our website to outside platforms and social networks. Social Media Features may also allow you to like or highlight information we have posted on our website or our branded social media pages. Social Media Features are either hosted by each respective platform or hosted directly on our website. To the extent the Social Media Features are hosted by the platforms themselves, and you click through to these from our websites, the platform may receive information showing that you have visited our websites. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our websites with your social media profile.
Some of our Clients also allow you to log in to certain Lingble-powered websites using sign-in services like Facebook Connect. These services authenticate your identity and provide you the option to share certain Personal Data from these services with us and our Clients such as your name and email address to pre-populate our sign-up form.
Your interactions with Social Media Features are governed by the privacy policies of the companies providing them.
PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA
We collect and process your Personal Data for the following purposes. Where required by law, we obtain your consent to use and process your Personal Data for these purposes. Otherwise, we rely on another authorized legal basis (including but not limited to the (a) performance of a contract or (b) legitimate interest) to collect and process your Personal Data.
- Providing our websites and Services: We process your Personal Data to perform our contract with you for the use of our websites and Services and to fulfill our obligations under an applicable Agreement or Order Form; if we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to operate and administer our websites and to provide you with content you access and request;
- Promoting the security of our websites and Services: We process your Personal Data by tracking use of our websites and Services, creating aggregated non-personal data, verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies to the extent it is necessary for our legitimate interest in promoting the safety and security of the services, systems and applications and in protecting our rights and the rights of others;
- Providing necessary functionality: We process your Personal Data to perform our contract with you for the use of our websites and Services; if we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to provide you with the necessary functionality required for your use of our websites and services;
- Managing user registrations: If you have registered for an account with us, we process your Personal Data by managing your user account for the purpose of performing our contract with you according to any applicable Agreement or Order Form for our Services;
- Handling contact and user support requests: If you fill out a “Contact Us” web form or request customer support via email, or if you contact us by other means including via a phone call, we process your Personal Data to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you;
- Managing promotions: If you register for a promotion, we process your Personal Data to perform our contract with you. Some promotions have additional rules containing information about how we will process your Personal Data;
- Developing and improving our websites and services: We process your Personal Data to analyze trends and to track your usage of and interactions with our websites and the Services to the extent it is necessary for our legitimate interest in developing and improving our websites and services and providing our users with more relevant content and service offerings, or where we seek your valid consent;
- Assessing and improving user experience: We process device and usage data as described above, which in some cases may be associated with your Personal Data, to analyze trends and assess and improve the overall user experience to the extent it is necessary for our legitimate interest in developing and improving the Services or our websites, or where we seek your valid consent;
- Reviewing compliance with applicable usage terms: We process your Personal Data to review compliance with the applicable usage terms in our Client’s contract to the extent that it is in our legitimate interest to ensure adherence to the relevant terms;
- Assessing capacity requirements: We process your Personal Data to assess the capacity requirements of our Services the extent that it is in our legitimate interest to ensure that we are meeting the necessary capacity requirements and service levels of our Services;
- Identifying customer opportunities: We process your Personal Data to assess new potential customer opportunities to the extent that it is in our legitimate interest to ensure that we are meeting the demands of our customers and their users’ experiences;
- Displaying personalized advertisements and content: We process your Personal Data to conduct marketing research, advertise to you, provide personalized information about us on and off our websites and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in advertising our websites and our Services, or, where necessary, to the extent you have provided your prior consent;
- Sending marketing communications: We will process your Personal Data or device and usage data, which in some cases may be associated with your Personal Data, to send you marketing information, products or services recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us and our affiliates and partners, including information about our services, promotions as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior; and
- Complying with legal obligations: We process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, respond to lawful requests, or for auditing purposes.
If we need to collect and process Personal Data by law, or under a contract we have entered into with you, and you fail to provide the required Personal Data when requested, we may not be able to perform our contract with you.
WHEN AND WHY WE SHARE YOUR INFORMATION
We work with a variety of companies to help us provide you with our Services to help you support your business. We sometimes share your Personal Data with these companies to help us provide you our Services.
- With vendors, agents, consultants, individuals, companies and other service providers that we employ and who need access to such information to carry out work on our behalf, on a strictly as-needed basis to fulfill legitimate business purposes;
- For information we collected on behalf of our Clients in a Lingble-powered website, with our Client and other third parties with your consent or for the purpose of fulfilling our contractual obligations with our Clients and allowing you to enter into a contract of sale for products or services in a Lingble-powered site;
- If we believe information disclosure is appropriate to comply with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation, including to meet public safety, national security or law enforcement requirements;
- If we believe information disclosure is appropriate or necessary to prevent or investigate suspected fraud, threats to physical safety, illegal activity, or violations of a contract (like our Agreement or an applicable Order Form) or our policies (like our Acceptable Use Policy) or to enforce or apply our Terms and Conditions and other agreements; or protect our rights, property, or safety, or those of our users or others;
- To help us conduct marketing and advertising;
- In connection with, or during negotiations of, any merger, sale of company assets, financing or transfer of all or a portion of our business to another company; and
- With your consent or at your direction or as part of our contractual rights or obligations to you.
We may also share aggregated or anonymized information with our partners or other relevant stakeholders, which cannot reasonably be used to identify you.
YOUR RIGHTS OVER YOUR INFORMATION
We believe you should be able to access and control your personal information no matter where you live. Depending on how you use Lingble, you may have the right to request access to, correct, amend, delete, port to another service provider, restrict, or object to certain uses of your personal information (for example, direct marketing or the selling of your Personal Data). We will not charge you more or provide you with a different level of service if you exercise any of these rights.
If you buy something from or use the services in a Lingble-powered store and wish to exercise these rights, you may email us at email@example.com and we will pass such request to our relevant Client. Please note that if you send us a request relating to your personal information, we have to make sure that it is you before we can respond. In order to do so, we may ask to see documentation verifying your identity, which we will discard after verification.
If you are not happy with our response to a request, you can contact us to resolve the issue. You also have the right to contact your local data protection or privacy authority at any time.
Because we need your personal information to provide Lingble services, we generally keep your personal information while you use Lingble products or services. We then retain your information before we begin our process to anonymize your personal information. We don’t do this immediately in case you reactivate your account, or if there is a legal complaint or audit relating to your business. If you have questions about this process, please contact us at firstname.lastname@example.org. Please keep in mind that after we anonymize your personal information, we may continue to use non-identifiable information to improve our services.
Finally, we do not and will not “sell” your personal information, as that term is used in California law.
WHERE WE SEND YOUR INFORMATION
To operate our business, we may send your personal information outside of your state, province, or country. This data may be subject to the laws of the countries where we send it. When we send your information across borders, we take steps to protect your information, and we try to only send your information to countries that have strong data protection laws and ensure a similar degree of protection is afforded to it. If you would like more information about where your information might be sent, please contact us.
SAFEGUARDING YOUR PERSONAL INFORMATION
We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Our teams work tirelessly to protect your information, and to ensure the security and integrity of our platform. However, we all know that no method of transmission over the Internet, and method of electronic storage, can be 100% secure. This means we cannot guarantee the absolute security of your Personal Data.
OUR CLIENTS’ CUSTOMERS’ INFORMATION
In order to power your Store and business, we collect and use personal information about your customers. In general, we only collect and use this personal information as directed by you, and as further described in our Data Processing Addendum, entered into by you, as our Client when signing the Agreement or an Order Form. Legally speaking, in relation to you, as our Client, we are a “data processor” and a “service provider” as these terms are used in European and California privacy law. We will never use your customers’ information to independently market or advertise to your customers unless they are also using one of our applications or services directly. We also do not and will not “sell” your customers’ information, as that term is used in California law.
HOW WE USE “COOKIES” AND OTHER TRACKING TECHNOLOGIES
We do not knowingly collect any personal information from children under the age of 13. We do not sell products for purchase by children and all children’s products we sell are for purchase by adults only.
CALIFORNIA DO NOT TRACK DISCLOSURE
Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Do Not Track browser settings or signals.
August 22, 2020.