Privacy Policy
Updated on: 08/03/2019
Your privacy is important to us. To help protect your privacy, we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used at this Site.
This Privacy Policy describes our collection, use, disclosure, retention and protection of your Information including your personal information. It applies to any BaloTrade site where this Privacy Policy appears in the footer, and to any BaloTrade application, service or tool (collectively "Services" or “BaloTrade”) where this Privacy Policy is referenced, regardless of how you access or use them, including through mobile devices. By using our Services and/or registering with us, you acknowledge having read this Privacy Policy and you expressly agree to our collection, use, disclosure, retention and protection of Information, including your personal information, in accordance with this Privacy Policy and our Terms and Conditions Link.
If you are domiciled within Africa, you will be entering into a contract with BaloTrade Ltd a company incorporated in Nigeria with company registration number RC 1457510;
If you are domiciled within United States of America, you will be entering into a contract with BaloTrade LLC a company incorporated in the State of Delaware, United States of America with company registration file number 6812625;
If you are domiciled outside Africa and United States of America, you will be entering into a contract with BaloTrade Ltd a company incorporated in the United Kingdom with company registration number 11416248.
BaloTrade is your data controller, and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with global privacy standards as well as any applicable national laws. We may process and retain your personal information on our servers anywhere in the world where our data centers are located.
CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy at any time by posting the amended terms on this site. All amended terms automatically take effect 30 days after they are posted. We will announce any material changes to this Privacy Policy on our site and/or via email.
OUR COLLECTION
BaloTrade is conscious of the importance of privacy and we have taken steps to ensure that we do not collect more information from you than is necessary for us to provide you with our services and to protect your account. We collect some or all of the following:
- Information including user name, address, phone number, and email address, will be collected at the time of registration on this Site. If you are registering an account through social media platforms such as Facebook or Twitter, we may collect your account name and profile photo at those platforms.
- If you choose to answer our supplemental questionnaires for registered members, we may also collect 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.
- If you are registered as a Supplier, in addition to the information mentioned above, we may also collect your identity information, tax registration number and information about your business, such as the information about your business license.
- If you are successfully certified by BaloTrade as a blogger or an influencer, in addition to the information mentioned above, we may also collect your live stream videos, your social media account names and profile photos, and posts or comments made by the Site’s members.
- If you contact our customer service, we may record your conversation with us and collect additional information to verify your identity.
- In connection with any payment services, information, including but not limited to, bank account numbers, billing information, credit/debit card numbers, expiration dates and security code may be collected for membership subscriptions on our Site.
- We record details of users’ activities on this Site. Information relating to such transactions (including, but not limited to, the types and specifications of the goods, pricing and delivery information, any dispute records and any information disclosed in any discussion forum) may be collected when transactions are conducted on or facilitated through this Site.
- From time to time, we collect information about our users and prospective users during trade shows, industry events and other functions. The information we may collect at these events includes, but are not limited to, user name, address, phone number, fax number and email address.
- We record users' buying and browsing activities on our platform including but not limited to IP addresses, browsing patterns, buyer behavioral patterns and equipment information. In addition, we gather statistical information about our Site and visitors to the Site including, but not limited to, IP addresses, browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors.
Certain data we collect may be defined as ‘Personal Data” under applicable data protection laws.
"Personal Data" is information that can be associated with a specific person and could be used to identify that specific person, whether from that data or from that data and other information that BaloTrade has or is likely to have access to. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.
To enable us to provide our services and products to users, users need to provide certain categories of data, which may include personal data, such as user name, address, phone number, and email address. If certain data is required, we will let you know at the time of collection. In the event that users do not provide sufficient data marked as necessary, we may not be able to complete the registration process or provide certain products or services.
THE USE OF DATA
We collect and use your personal data for the following purposes:
- To verify your identity;
- To verify your eligibility to register as a user of this Site or become a blogger or an influencer of this Site;
- To process your registration as a user, providing you with a member ID and log-in details for the Site and maintaining and managing your registration;
- To provide you with customer service and responding to your queries, feedback, claims or disputes;
- To facilitate communication between buyers and suppliers on the Site, and processing membership subscription payments;
- To assess account security and transaction risks of members, detecting and preventing fraud and other security incidents;
- To personalize our communication with you based on your browsing records, equipment information we collected and your order history, and performing research or statistical analysis in order to improve the content and layout of this Site, and to improve our product offerings and services, including, for example, using anonymized data for machine learning purposes;
- To identify, develop and market products and services that we believe you will value, including across browsers and devices, in accordance with the applicable laws. Cookies or other similar technologies may be used to provide you with advertising based upon your browsing activities and interests. Where we are required by an applicable law, we will seek your consent prior to sending you communications for marketing purposes; and
- We may also use your Personal Data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.
DISCLOSURE
We may disclose and transfer your Personal Data to our partners and to service providers engaged by us to assist us to provide services to you or who otherwise process Personal Data for purposes described in this Privacy Policy or notify to you when we collect your Personal Data. Examples of these partners or service providers include but is not limited:
- Our business partners (for example, in order for them to provide you with discounts or offers that may interest you);
- Marketing platforms, such as Google, Twitter, Facebook, and Instagram, and providers of analytics services such as Google Analytics and other advertising software relating to the users’ behavior, in order to tailor the content you see when visiting our Site. These marketing platforms may combine information they collect on our Site with data on their platforms and data they collect from other websites or through other sources in order to conduct targeted advertising. The activities of these third party marketing platforms are governed by their own privacy policies, not this Privacy Policy;
- Payment service providers to assist with payment for transactions or providing withdrawing service for supplier. The activities of payment service providers may be governed by their own privacy policies, not this Privacy Policy;
- Credit risk assessment providers to conduct risk assessment on supplier to determine whether a supplier can be permitted to make an advance withdrawal;
- Logistics partners for providing delivery services for buyers, including return and exchange of products, and warehousing services for Suppliers;
- Custom agents for customs clearances purposes;
- Cloud computing service providers to provide cloud storage services;
- Warranty service providers to provide warranty services;
- Customer service providers to provide after-sale services; and
- Risk control service providers to assess the security of members’ accounts and transaction risks.
These Service Providers must abide by our data privacy and security requirements and are only permitted to use your Personal Data in connection with the purposes specified above, and not for their own purposes.
For the purposes specified above, we may share your Personal Data with companies affiliated to BaloTrade and/or their designated Service Providers, which comprises a group of companies operating leading online and mobile marketplaces in consumer and business-to-business commerce, as well as cloud computing and other services.
When 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, we may also disclose and transfer your Personal Data to our professional advisers, law enforcement agencies, insurers, government, regulatory bodies and other organizations, or as otherwise required or permitted by applicable laws.
We may disclose your Personal Data 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 Data only for the purposes disclosed in this Privacy Policy.
We may also disclose your Personal Data to any other person with your consent to the disclosure.
We retain your Personal Data as long as we have an ongoing legitimate business need to do so for example to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws.
Information you submit to this Site for publication may be made publicly available on the Site and therefore accessible by any internet user. You should exercise caution when deciding what information you submit to us for publication.
We may provide aggregated or anonymized data to third parties, but when we do so, the information we share is in a de-identified format, that does not personally identify you.
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 Site 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 Data 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
RIGHTS OF USERS
Under the applicable laws, you may have the rights of access to Personal Data held by us and other rights.
If you have any questions regarding this Privacy Policy or if you wish to access or correct your Personal Data, you may send your request by filling out our “contact us” form.
If and to the extent permitted by the applicable laws, we may charge you a fee for the processing of any request you make regarding your Personal Data.
If you are a resident of the European Union, you have the following data protection rights, which you can exercise at any time by filling the “contact us” form:
- The right to access, correct, update or request deletion of your Personal Data.
- The right to object to processing of your personal information when it is based on our legitimate interests, and separately the right to object to direct marketing.
- The right to ask us, in some situations, to restrict processing of your personal information or request portability of your personal information.
- The right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing, please contact us by filling the “contact us” form.
- If we have collected and processed your personal information with your consent, then you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
- We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
- If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected.
Our business may require us to transfer your Personal Data to countries outside of the European Union (“EU”), including to countries that may not provide the same level of data protection as your home country. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and we implement appropriate measures to ensure your Personal Data will remain protected in accordance with this Privacy Policy.
COOKIES
We use "cookies" to store specific information about you and track your visits to this Site, either through a computer or via a mobile device.
A "cookie" is a small amount of data that is sent to your browser and stored on your computer's or mobile device’s hard drive. If you do not de-activate or erase the cookie, each time you use the same browser or mobile device to access this Site, our web servers will be notified of your visit and in turn we may have knowledge of your visit and the pattern of your usage. The cookies will enable us to remember your information so you do not have to re-enter it every time you use the Site.
In addition, we use cookies to manage the security of our Site, to gather information about usage by users; to research visiting patterns and conduct interest-based advertising; to assist our partners to track a user’s visit to our Site and process orders; and to track progress and participation in promotions.
For these additional purposes identified above, you can determine if and how a cookie will be accepted by configuring the privacy setting of the browser you are using to access this Site or the privacy setting of your mobile device. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser's help menu for more information. If you adjust the privacy setting in the browser, your mobile device will continue collecting data unless you adjust the privacy setting of the device, and vice versa.
You have the right to decide whether to accept or reject cookies. If you choose to set your web browser controls to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted.
We also use cookies to serve targeted ads from Google, Facebook, Bing, and other third-party vendors. In addition, most advertising networks offer you a way to opt- out of targeted advertising. Furthermore we also use social media cookies. Some pages on our Site allow you to share content through social media such as Facebook and Twitter. Sometimes we embed videos from websites like YouTube. These websites set their own cookies, which we have no influence over. To refuse their cookies, please follow the instructions on their websites. In addition, these websites have their own privacy policy, which you can find on the respective websites.
Certain features of this Site depend on cookies. Please be aware that if you choose to block cookies, you may not be able to sign in or use those features, and preferences that are dependent on cookies may be lost.Â
We use both first party cookies (cookies that are set by us at BaloTrade and serve mainly to enable basic functionality on our Site, including web analytics cookies that help us understand how users use our web pages and how we can improve their use) and third party cookies (these cookies are not set by BaloTrade, but by our selected partners).
MINORS
This Site and its contents are not targeted at minors (those under the age of 18) and we do not intend to sell any of our products or services to minors. If a minor has provided us with Personal Data without parental or guardian consent, the parent or guardian should contact us immediately by filling the “contact us” form to remove the information.
SECURITY MEASURES
We employ commercially reasonable security methods to prevent unauthorized access to this Site, to maintain data accuracy and to ensure the correct use of the information we hold.
For registered users of this 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., Member 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 try to protect the information we hold for you, we cannot guarantee the security of any information you transmit to us and you do so at your own risk.
LEGAL BASIS FOR DATA PROCESSING
We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process Personal Data will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect and process Personal Data about you only where it is: (1) necessary for the performance of any contract between you and BaloTrade (for example, to provide you with the services you request and to identify and authenticate you so you may use the Site); (2) necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); (3) 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 Data in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Site 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 Site and our services, undertaking marketing, or for the purposes of ensuring the security of our Site 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 Data 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 Data is mandatory or not (as well as the possible consequences if you do not provide your Personal Data). In some instances, you may be required to provide us with Personal Data 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 Site.
We retain your Personal Data as long as we have an ongoing legitimate business need to do so for example to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws. When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us by sending a mail to support@balotrade.com.