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Privacy Policy

Updated on the 31st of January, 2023, effective immediately.

We at Tololi (“we“, or “us“) recognise the importance of privacy and confidentiality of personal information.

www.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“), and a business to business (or “B2B”) platform which connects business sellers and to business consumers.

This Privacy Policy sets out how we collect, use and disclose information in connection with the operation of the Platform, including personal information about the individual, Platform users, visitors and representatives. This Privacy Policy also applies to the use of the Platform via your mobile device. Other Tololi services are governed by separate Privacy Policies, please refer to the applicable Privacy Policy for those services.

If you are a registered member of the Platform, and you are from Namibia, you are contracting with Tololi Online Store (PTY) LTD. 2022/0889

  1. 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 includes: name; address; phone number; email address;
  • purchase and/or payment information includes bank account or similar payment information that you intend to purchase with; billing and delivery address;
  • information about your purchases includes 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 (passport, national identification card and/or driver’s license) 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) includes 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 of Buyer or Seller. Additionally, 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 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.
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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.

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 username, nickname or username
    • Your social media profile picture
    • Country and Tagged locations
    • Company name (if applicable).
  • Third parties that are engaged by us to provide verification services such as conducting suitable anti-money laundering, fraud and “Know Your Customer” checks on Buyers and Sellers. This may include your name, email address, company details and contact information.
  1. 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; when made via the Platform;
  • providing relevant membership benefits; including birthday rewards, membership offers and coupons, anniversary awards, referral codes and 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, improve the content and layout of the Platform, and improve our product offerings and services;
  • Cookies or other similar technologies may be; used to provide you with advertising based on 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.


  1. DISCLOSURE OR SHARING OF PERSONAL DATA

We disclose/share personal information with the following categories of recipients:

  • Other Platform Buyers and/or Sellers; that were 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.
  • Third-party partners and service providers and/or affiliates; engaged by or working with us to assist us to provide services to you or who otherwise process personal information for purposes described in this Privacy Policy or will notify individuals when collecting your personal information. Categories of these partners and service providers include:
    • Tololi and affiliated companies, including but not limited to delivery companies, appointed manufacturers; com/or their designated service providers that work with us to provide processing services such as software, tools, systems and messaging services for purposes described in this Privacy Policy;
    • 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 receive such information from them if required by applicable data protection laws;
    • Marketing and advertising partners, such as Google, Twitter, Facebook, Instagram, Twitch, LinkedIn and TikTok, and providers of analytics services relating to users’ behaviour, in order to tailor the content you see when visiting our Platform where you have consented to the collection of your information using cookies for analytics and/or advertising purposes. These partners may combine information they collect on our Platform with data on their platforms and data they collect from other websites or through other sources in order to conduct targeted advertising. The processing activities of these third-party marketing platforms are governed by their own privacy policies, not this Privacy Policy.
    • Payment service providers that provide payment processing services. The activities of payment service providers may be governed by their own privacy policies, not this Privacy Policy;
    • Credit risk assessment providers to conduct a 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 upon request 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 an actual or potential buyer(and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy.
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  • To any other person with your consent to the disclosure.

We have established relationships with other parties and websites to offer you the benefit of products and services which we do not offer. We offer you access to these other parties and their websites either through the use of hyperlinks to these sites from our Platform or through offering “co-branded” sites in which both we and other parties share the same uniform resource locator (URL), domain name or pages within a domain name on the Internet. In some cases, you may be required to submit personal information to register or apply for products or services provided by such third parties or co-branded partners. This Privacy Policy does not apply to these third-party sites or co-branded sites. The privacy policies of those other parties may differ from ours, and we have no control over the information that you submit to those third parties. You should read the relevant privacy policy for those third-party sites and co-branded sites before responding to any offers, products or services advertised by those parties.


  1. RETENTION

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 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. 


  1. MINORS

If you are under 18 years of age, you may use our site only with the involvement of a parent or guardian. If you are a parent or guardian and you provide your cousaas1nsent to your child’s use of our site, you agree to be bound by these terms and conditions in respect to your child’s use of the site.


  1. SECURITY MEASURES

We implement appropriate technical and organisational measures to prevent unauthorised access to the Site, in order 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 over the internet.


  1. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make, such as by posting an amended Privacy Policy on the Platform.


  1. LEGAL BASIS FOR DATA PROCESSING

We process personal information for the purposes set out in this Privacy Policy. Our legal basis to process for processing your personal information will depend on the personal information concerned and the specific context in which we collect it but will include where it is:

  • necessary for the performance of the contract between you and Shanghai Walvis (is this still relevant?) 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 with 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.


  1. LANGUAGE

If there is any conflict between the English version and another language version of this Privacy Policy, the English version shall prevail.