Updated on the 12th of March, 2020, effective immediately
We at Tololi (“we”, or “us”) recognize the importance of privacy and confidentiality of personal information.
Tololishop.com ("Tololi" or, the "Platform") is a business to consumer (or "B2C") platform which connects and facilitates sales and purchases between business sellers (or "Sellers") and consumer buyers (or "Buyers").
If you are a registered member of the Platform, and you are from Namibia, you are contracting with Tololi Online Store Cc. 2019/05483
If you are a registered member of the Platform and you are out of Namibia, the Tololishop.com contracting entity that you are contracting with is Shanghai Walvis International Trading Co., Ltd.
- COLLECTION OF INFORMATION
The personal information that we collect broadly falls into the following categories:
Information That You Provide with Us:
If you are a Buyer, we will ask you to provide:
- contact information including: name; address; phone number; email address;
- purchase and/or payment information including: bank account or similar payment information that you intend to purchase with; billing and delivery address;
- information about your purchases including: the goods purchased and how many;
- information about and/or to support complaints made in connection with the Platform or goods and/or services purchased via the Platform;
- ID (such as a passport) for identification verification in certain circumstances, when you apply for after-sales services.
If you are a Seller (i.e. an employee or representative of a Seller or a sole trader Seller (we'll refer to you as a Seller)), we will ask you to provide:
- information about the Seller's business (if applicable) including corporate registration, business licenses (if applicable), tax or similar information;
- details about the goods and products that the Seller intends to sell via the Platform;
- purchase and/or payment information including bank account or other payment information that the Seller intends to be paid by.
If you attend one of our industry events or other functions, contact details such as user name, address, phone number, fax number and email address.
If you are a certified blogger / influencer for Tololi, we may also ask you to provide us with your contact information and social media accounts / blog information.
If you choose to provide us with any additional information, such as in response to questionnaires for market research / analytics. This may include marital status, nationality, gender, date and/or year of birth, annual income, monthly spending and user preferences. If you prefer not to provide such information, the use of our services and products will not be affected.
By accepting our policies, you consent to us collecting this information:
If you are a Buyer or Seller or prospective Buyer or Seller we will automatically collect:
- A copy of any correspondence with us, including any verification information we ask for, if you contact us for any reason (such as our customer service department chat service, telephone or email).
- Details of transactions and communications over the Platform, including the types and specifications of the goods sold and purchased, pricing and delivery information, any dispute records, communications between Buyers and Sellers over the Platform and any information disclosed in any discussion forum.
- Details of Platform buying and browsing activities, for these purposes we will automatically collect information from your device. In some countries, including countries in the European Economic Area and the UK, this information may be considered as personal information under applicable data protection laws. Specifically, this collected information may include IP addresses, device type, unique device identification numbers, browser type, broad geographic location (e.g. country or city-level location), browsing patterns and details of how you have interacted with our Platform and the goods and services available on it. In addition, we gather information about the Platform and visitors to the Platform including browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors. Some of this information may be collected using cookies and similar tracking technology. Where we are required by applicable law, we will seek your prior consent to the collection of information using cookies and similar tracking technologies.
If you are successfully certified by Tololi as a blogger or an influencer, we may also collect your social media account handles and posts / comments made in relation to the Platform.
Information That We Receive from Third Parties, including but not limited to international or domestic delivery companies appointed by us, shopify.com as our technical support, Registered sellers with us. :
If you are a Buyer or Seller, we may receive personal information about you from:
- Social media platforms if you choose to register for a Platform account via a social media account. Exactly what information we receive will depend on your privacy settings with the applicable platform, but would typically include basic public profile information such as:
- Your social media user name, nickname or username
- Your social media profile picture
- Company name (if applicable).
- Third parties that are engaged by us to provide verification services such as conducting suitable money laundering, fraud and "Know Your Customer" checks on Buyers and Sellers. This may include your name, email address, company details and contact information.
- USE OF PERSONAL DATA
We collect and use your personal information for the following purposes:
- verifying Platform account registrations including conducting fraud, security, "Know Your Customer" and anti-money laundering checks in order to approve your Seller account;
- verifying your eligibility as a Platform blogger or influencer;
- setting up / administering Buyer and Seller accounts, including providing log-in IDs and setting up payment / transaction accounts;
- providing customer service support, responding to your queries, feedback and managing claims and/or disputes;
- providing/supporting general Platform services, facilitating communication between Buyers and Sellers, processing transactions and payments, assessing advance withdrawal requests from Sellers and providing logistics and delivery services;
- supporting Buyer and/or Seller clearance declarations / applications where made via the Platform;
- providing relevant membership benefits including birthday rewards, membership offers and coupons, anniversary awards, exclusive member prices;
- verifying your identity and purchases in connection with product warranty or other after-sales claims;
- assessing and monitoring account security and transaction risks of Buyers and Sellers, detecting and preventing fraud, money laundering and other security incidents;
- sending and serving 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;
- conducting research and analytics to ensure the security of our Platform, to improve the content and layout of the Platform, and to improve our product offerings and services;
- Cookies or other similar technologies may be used to provide you with advertising based upon your browsing activities and interests.
We may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you if and where this is permitted by applicable data protection laws.
- DISCLOSURE OR SHARING OF PERSONAL DATA
We disclose/share personal information with the following categories of recipients:
- Other Platform Buyers and/or Sellers where necessary to support purchases and communications made between you. If you are a Buyer, Sellers that you purchase from will also control, personal information about you relevant to connected with your Platform purchases and communications with them. Please refer to Seller Privacy Policies for information about how they will process your information.
- our business partners (for example, in order for them to provide you with discounts or offers that may interest Buyers or prospective Buyers) where you have consented to receiving such information from them if required by applicable data protection laws;
- credit risk assessment providers to conduct risk assessment on Sellers to determine whether a Seller can be permitted to make an advance withdrawal;
- logistics partners for providing delivery services for Buyers and Sellers, including return and exchange of products, and warehousing services for Sellers;
- customs agents for customs clearances purposes where applicable to support Buyers and Sellers with international sales/purchases;
- cloud computing or other hosting service providers to provide cloud storage services;
- warranty service providers to provide product warranty services where requested by a Buyer or Seller;
- customer service support providers to provide after-sale services or other customer service support;
- risk control service providers to assess the security of Buyer and Seller accounts and transaction risks; and
- third party rating / reviewing service providers to carry out reviews of our services with customers if you choose to participate in reviewing or rating Platform products and/or services;
- To our professional advisers, law enforcement agencies, insurers, government and regulatory and other organisations where we believe 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; or as otherwise required or permitted by applicable laws.
- To any other person with your consent to the disclosure.
We will retain your personal information for as long as we have an ongoing legitimate business need to do so, to provide services or products to you, as required or permitted by applicable laws. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. How long your data is kept for will also depend on how you use our website (for example if you are logged in as a member or you are visiting our website as a guest) and what the information you provide to us is used for. For example, if you are a registered member, certain data will be retained for a length of time following termination or deletion of your account, in order to comply with applicable laws or in case of disputes. In other instances, the period of retention may be determined according to your activity on the Platform or to comply with a specific arbitration period/resolve a dispute.
The Platform is intended for adults and users must be over 18 to use our Platform and 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 us to remove the information.
- SECURITY MEASURES
We implement appropriate technical and organisational measures to prevent unauthorised access to the Site, to maintain data accuracy and to ensure the correct use of the information we hold. Upon becoming aware of a data breach, we will notify you and the regulatory authorities in accordance with the timescales and scope required by applicable data protection law.
For registered users of the Site, some of your information can be viewed and edited through your account, which is protected by a password. We recommend that you do 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 choose to 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 organisational measures to protect the information, we hold for you, we cannot guarantee the security of any information you transmit to over the internet.
H Legal Basis for Data Processing
- necessary for the performance of contract between you and Shanghai Walvis International Co. Ltd., (for example, to provide you with the services you request and to identify and authenticate you so you may use the Platform);
- necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement);
- necessary for our legitimate interests and not overridden by your rights; and/or where it is based on your consent.
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Platform and services, manage our relationship with you and communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our Platform and our services, undertaking marketing, or for the purposes of ensuring the security of our Platform and services and detecting or preventing illegal activities such as fraud. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
If we ask you to provide personal information to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). In some instances, you may be required to provide us with personal information for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Platform.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us.