Ecorigem Marketplace Platform – Privacy Policy

Last Revised: January 7, 2020

Ecorigem Ltd. its subsidiaries and affiliates (“Ecorigem“, “Company” “we” or “us“) respect the privacy of the visitors and/or users (“User” or “you”) of its eco-friendly marketplace at https://www.ecorigem.com/ (the “Platform“), and is committed to protecting the personal information that its Users share with it.

We believe that you have a right to know our practices regarding the information we may collect and use when you visit and/or use our Platform.

Capitalized terms, which are not defined herein, shall have the meaning ascribed to them in our Terms of Use at www.ecorigem.com  (“TOU“), into which this Privacy Policy is incorporated by reference.

1.             Your Consent (PLEASE READ CAREFULLY!)

BY ENTERING, CONNECTING TO, ACCESSING OR USING THE PLATFORM, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY (THE “PRIVACY POLICY“), INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DO NOT ANY WITH ANY TERM PROVIDED IN THIS PRIVACY POLICY, YOU MAY NOT ACCESS AND USE THE PLATFORM.

FOR AVOIDANCE OF DOUBT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING, TRANSFER AND USE OF YOUR PERSONAL INFORMATION. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO US.

2.             Which information we may collect on our Users?

We may collect two types of data and information from our Users:

a.     Non-personal Information. The first type of information is non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from whom we have collected the Non-personal Information. Non-personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us while such User is entering into and/or using the Platform. Non-personal Information which is being gathered consists of technical information, behavioral information and aggregated information (including aggregated information relating to purchases on the Platform), and may contain, among other things, the activity of the User on the Platform, type of operating system, User’s ‘click-stream’ or searches on the Platform, type and version of browser, keyboard language, screen resolution, time spent on various screens of the Platform, etc.

b.    Personal Information. The second type of information is individually identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature, including the following:

·       Users of the Platform automatically provide their IP address (or Mac Address, as applicable) mainly for enhancing the User’s experience and for geo-location and security purposes as further detailed below.

·       In addition, Personal Information which is being gathered consists of any personal details provided consciously and voluntarily by the User:

·      When Users open an Account, they are required to provide their full name, e-mail address, shipping address and to choose a password. Additional identifiable information may be requested in the future.

·      Alternatively, you may sign up to the Platform via one of your existing third party services accounts (e.g. Facebook or Google+). When you register to the Platform through such existing third party account, then the latter provide us with access to certain information, which is detailed and displayed to you in the notice, which appears during the integration process (which usually includes your name, email address, profile photo and user-id on such third party account). Please read carefully such notice in order to understand what information is made available to us via your third party accounts. We may collect your login information and other relevant information necessary to enable us to access your third party accounts in order to collect the abovementioned information. We may store the above-mentioned information (or any part of it), in order to achieve the purposes set forth herein.

If you are a Seller and already have existing online store account(s), you may be able to connect your Ecorigem Account with these third party accounts.

Please remember that the manner in which third party accounts use, store or disclose your information is governed solely by their policies and we will have no liability or responsibility for the privacy practices or other actions of such third parties. If you do not agree to these practices please do not use third party accounts in order to use our Platform.

·      For the purpose of offering Products (as a Seller), or purchasing Products (as a Customer), the User will be required to provide their full name, email address, phone number, accurate delivery address and other contact information. The foregoing information (together with other details relating to the ordered Products) will be disclosed to the applicable Seller(s).

·      Personal Information is collected from the details the Users provide in contact forms on the Platform, when requesting technical support via the support page on the Platform and/or when communicating, by any means, with Ecorigem. Such Personal Information may include, inter alia, your name, email address and telephone number. You may optionally provide via a contact form any text you wish to insert into the “message” box. Additional information may be requested via a contact form in the future.

·       When using the Platform, Users will have the option to use certain Online Payment Processors (as defined below) will require Users to fill out a billing form wherein the User will be required to provide to such Online Payment Processors certain Personal Information (such as, a credit card number and other related billing information) (see Section 7 below regarding the payment method). We will not store such information on our servers. We only keep token information such Online Payment Processors provide us with (and where applicable, the last four digits of your credit card number), and such information is strictly secured.

For avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance to the TOU and the Privacy Policy.

3.             How Do We Collect Information on Our Users?

There are two main methods we use:

a.       We collect information through your entry and use of the Platform. In other words, when you are using the Platform we are aware of it and may gather, collect and store the information relating to such usage (such as the Non-personal Information detailed above and your IP address), either independently or through the help of third party service providers as detailed below.

b.      We collect information, which you decide to provide us voluntarily. For example, we collect Personal Information, which you voluntarily provide when you fill in the contact form on the Platform or open an Account. We may gather, collect and store the Personal Information either independently or through the help of our authorized third party service providers as detailed below.  

4.             What are the Purposes of the Collection of Information?

Non-personal Information is collected in order to:  

• Use it for statistical and research purposes and for customization, development and improvement of our Platform.
• Keep the Platform safe and secured and for prevention of fraud.

Personal Information is collected in order to:  

• Operate the Platform (including the enablement of Product purchases via the Platform).
• Personalize and enhance the User’s experience while using the Platform.
• Verify the User’s identity when he/she signs into the Platform through his/her Account.
• Respond to the User’s questions and concerns and provide technical support.
• Enable payment through third party Online Payment Processors. Please note that we do not collect and store credit card or other financial information.
• Provide the Users with commercial and marketing materials, updates about Ecorigem’s developments, new offerings, and news regarding our Platform.
• Provide registered Users with updates about our developments, new offerings, news regarding the Platform and other services, etc.
• Determine general geolocation information (i.e., country) from which the User’s computer is connected to the Internet in order for us to know the general location of our Platform’s Users as well as in order to safeguard our Platform.
• Verify the User’s identity for the purpose of dealing with inappropriate interactions of Users and/or fraudulent use of our Platform.
• Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical purposes.
• Keep the Platform safe and secured and for prevention of fraud and crime.
• Comply with our legal obligations and in order to be able to protect our rights and legitimate interests, including in order to improve the Platform.

5.             Sharing Information with Third Parties

Without prejudice to the foregoing, Ecorigem will not share Personal Information with third parties other in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the TOU, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to User’s support requests; (e) respond to claims that any content available on the Platform violates the rights of third parties; (f) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third party has been posted or transmitted without their consent or as a form of harassment; (g) to protect the rights, property, or personal safety of Ecorigem , its Users, or the general public; (h) by virtue of undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets, so long as such acquirer maintains the same privacy terms hereunder; (i) to collect, hold and/or manage your Personal Information through Ecorigem‘s authorized third parties service providers (including, as applicable, their affiliates as necessary to provide us with the requested services), as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as your jurisdiction; (j) to store or process your Personal Information through Ecorigem’s affiliated companies, which may be located in a country that does not have the same data protection laws as your jurisdiction. Ecorigem requires its affiliated entities to agree to processing your Personal Information in compliance herewith; or (k) pursuant to your explicit approval prior to the disclosure.

For avoidance of doubt, Ecorigem may transfer and disclose Non-personal Information to third parties at its own discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of the Platform.

6.             Minors

The Platform is intended for Users over the age of sixteen (16). Therefore, Ecorigem does not intend and does not knowingly collect Personal Information from children under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Platform. If we learn that we collected Personal Information from children under the age of sixteen (16) we will delete that information as quickly as possible. Please contact Ecorigem at support@ecorigem.com if you have reasons to suspect that Ecorigem collected Personal Information from children under the age of sixteen (16) and will delete that information as quickly as possible.

7.             Online Payment Processors

8.             We accept certain online payment methods, using our Online Payment Processors, which enable Users to send and receive payments securely online using a credit card or bank account. We may add or change the Online Payment Processors at our sole discretion. Ecorigem is not affiliated with such Online Payment Processors (for more information see our TOU), as each is an independent contractor, and neither is the agent or employee of the other, and neither is responsible in any way for the actions or performance (or lack thereof) of the other. The use of the Online Payment Processors is at the User’s discretion and sole liability and risk. It is the User’s responsibility to abide by all the terms specified by the Online Payment Processors in their terms of use and privacy policies, including but not limited to any age restrictions specified therein. You acknowledge that you are fully assuming the risks of conducting any transactions via the Online Payment Processors.

9.             Security

We take reasonable measures to maintain the security and integrity of our Platform and User information and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use of your Personal Information will never occur.

ECORIGEM SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION.

10.         Third Party Service Providers

We may be using third party software or service in order to collect, host, store and/or process the information detailed herein. Ecorigem uses commercially reasonable efforts to engage with third parties that post a privacy policy governing their collection, processing and use of Non-personal Information and Personal Information. Such software includes without limitation:

Google Analytics, which privacy policy can be found at: https://policies.google.com/privacy?hl=en;

Please read such third party service providers’ terms of use and privacy policies to understand their privacy practices.

11.         Links to Third Party Websites

Certain links provided in the Platform permit Users to leave our Platform and enter non-Ecorigem sites or services. Those linked sites and services are provided solely as a convenience to you. Those linked sites and services are not under the control of Ecorigem and it is not responsible for the availability of such external sites or services, and does not endorse and is not responsible or liable for any content advertising, products, services or other information on or available from such linked sites and services or any link contained in a linked site or service. Ecorigem reserves the right to terminate any link at any time. You further acknowledge and agree that Ecorigem shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such linked sites or resource. Most of such linked sites and services provide legal documents, including terms of use and privacy policy, governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information they are collecting.

12.         Cookies and Other Tracking Technologies

When you access or use the Platform, we or our third party service providers may use industry-wide technologies such as “cookies” or other similar technologies which store certain information on your computer or device (“Cookies“), which will allow us to enable automatic activation of certain features and make your experience much more convenient and effortless. We or our authorized third party service providers may use both session cookies (which expire once you close the Platform) and persistent cookies (which stay on your system until you delete them). It is easy to disable or delete Cookies. Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you disable or erase cookies, your online experience may be limited. Cookies usually store only Non-personal Information, such as the web pages you have visited, the duration of your browsing, etc. Ecorigem does not control such third party service providers.

13.         Deletion or Modification of Personal Information

If for any reason you wish to delete or modify your Personal Information please send us an e-mail with adequate detail of your request to: [support@ecorigem.com] and we will make reasonable efforts to modify or delete any such Personal Information pursuant to any applicable privacy laws. Note that unless you instruct us otherwise we may retain your Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected, including without limitation, for future analytics and analysis, in order to comply with our legal or business requirements or obligations and to resolve disputes or to enforce our Terms, all as permitted under any applicable privacy laws.

Aggregated and/or anonymous information derived from your use of the Platform may remain on our servers indefinitely. 

14.         Advertisements

Users may receive advertisements and commercials (including without limitation coupons, discounts, etc.) from third party advertisers and/or our authorized service providers and/or vendors. By clicking the advertisements or commercials you may be transferred to a website of an advertiser or receive any other messages, information or offers from the advertiser and/or from others. Note that if you click on any of these advertisements, these advertisers may use local storage including without limitation cookies and other web-tracking technologies (such as tracking pixel agent or visitor identification technology, etc.) to collect data regarding advertisement performance, your interaction with such ads and our Platform and your interests (which may include, Non-personal and/or Personal Information (such as, device and network information, unique identifiers, gender, age and location) about you) in order to serve you advertisements and for the legitimate business interests of such third parties ad networks. We recommend that you review the terms of use and privacy policy of any advertiser with which you are interacting before doing so. Their privacy policy, not ours, will apply to any of those interactions.

All the information contained in such advertisements and commercials belongs solely to the advertisers and the Company makes no warranties or representations in respect of such, whether or not the Company has control over such advertisements or commercials and these are provided on an “AS IS” basis. In any event, the Company will not be liable for any damage or loss incurred to you as a result of or in connection with such advertisements or commercials. The Company, advertisers and/or related third parties may be entitled to certain shares of the earnings for such advertisements and/or commercials. You agree, acknowledge and consent that no right, title or interest is or shall be granted to you in any way with respect to any revenue share whatsoever in relation thereto.

15.         Direct Marketing

You hereby agree that we may use the contact details you provided us with for the purpose of informing you regarding our Platform and other services which may be of interest to you, and to send to you other marketing material, transmitted to the e-mail address you have provided. You may withdraw your consent via sending a written notice to Ecorigem by email to the following address: [support@ecorigem.com] or alternatively following the instructions for removing yourself from the mailing list which are available in the e-mail transmitted to you.

16.         International Data Transfer

We may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world (all solely for legitimate business purposes). Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information.

17.         Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Platform and any information collected therein. Ecorigem reserves the right to change this policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this policy on the homepage of the Platform and/or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such substantial changes will take effect seven (7) days after such notice was provided on our Platform or sent by e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Platform after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by law and without any prior notice.

18.         Got any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address: [support@ecorigem.com] and we will make an effort to reply within a reasonable timeframe.