VALID FROM JUNE 2021.
A. COLLECTION OF INFORMATION.
· Information provided by you
· Information collected automatically by us
· Information we receive from third parties.
B. USE OF PERSONAL INFORMATION.
C. DISCLOSURE OR SHARING OF PERSONAL INFORMATION.
· What are Cookies?
· Cookies we use
· How can I control Cookies?
· Other tracking technologies
· Google Analytics
G. SECURITY MEASURES.
I. VISITORS FROM THE EUROPEAN UNION.
· Legal basis for data processing.
· International transfers of personal information.
· User rights.
J. CONTACT US.
L. VISITORS FROM OTHER REGIONS
Platform, "we”, "us”: Refers to Bozinga.com, a Business-to-business (B2B) platform allowing for the connection and facilitation of sales and purchases of products & services, payment intermediary between Buyers and Sellers, dispute resolutions amongst Buyers and Sellers as well as online marketing services for Sellers.
User, Users, "you”: Refers to anyone who navigates in Bozinga.com. acting as Buyers, Sellers, or potential Buyers and/or Sellers.
Buyer or Buyers: Refers to the users who purchase products or services through the Platform from other Users known as Sellers. Please note that the platform is only meant for Businesses and not for individual use, therefore Buyers cannot purchase products for their own personal use.
Seller or Sellers: Refers to the users who sell products or services through the Platform to other Users known as Buyers. Please note that the platform is only meant for Businesses and not for individual use.
Cookie or Cookies: Refers to a small amount of data that is sent to your browser and stored on your computers or mobile device’s hard drive.
· We will ask you to provide certain contact information that is necessary for the registering for a Platform account on behalf of a Buyer or Seller, such as, but not limited to name, address, phone number, email address, job title and work area;
· We will ask you to provide certain identity information, tax registration and/or related information about your business, such as, but not limited to your company name, business type and industry, corporate registration details and information about your business license, if applicable;
· If you are a Seller we will also ask you to provide details about the goods and products that you intend to sell via the Platform and details about your sales/transactions on Bozinga.com;
· If you are a Buyer, we will also ask you to provide details or preferences about the goods and products that you may be interested in buying via the Platform and any details or preferences relevant to your purchases;
· If you are successfully certified by Bozinga.com 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 other users of the Platform;
· In connection with the facilitation of transactions, purchases and payments over the Platform, we will ask you to provide certain payment information. This might include, but not be limited to bank account numbers, billing and delivery information, credit/debit card numbers, expiration dates and security code and tracking information from cheques or money orders to facilitate the sale and purchase as well as the settlement of purchase price of the products or services transacted on or procured through the Platform;
· We will process any information provided to us in connection with disputes or to support complaints in connection with the Platform or goods and/or services purchased via the Platform. Please note, Buyers and/or Sellers may submit complaints regarding the products and services on the Platform and/or disputes between the Buyers and Sellers to the Platform and under such circumstances, we will process data provided to us by Buyers and/or Sellers that is relevant to the disputes or complaints submitted;
· Information submitted by the Seller regarding the offered products may be made publicly available on the Platform and therefore accessible by any internet user. This information may include, but is not limited to Business’ name, address, contact information and product(s) being sold. You should exercise caution when deciding what information, you submit to us for publication.
Information collected automatically by us
· When you contact us (through our customer services department chat service, telephone, or email), we may record a copy of your correspondence and may ask for additional information to verify your identity.
We will collect user’s contact details and other information from publicly available sources for the purposes of verifying and performing due diligence on the users.
We will collect user’s details of their activities, transactions, and interactions on the Platform such as, but not limited to information relating to the types and specifications of the products and services purchased, pricing and delivery information, dispute and complaint records, communications between users and any information disclosed through any discussion forum.
We may also collect information about the existing and prospective users, during or in connection with trade shows, industry events and/or other functions. Including representative contact names, addresses, phone numbers, fax numbers and email addresses.
· When you visit our Platform, we will automatically collect certain information from your device. In some countries, including countries in the European Economic Area, this information may be considered as personal information under applicable data protection laws. Specifically, this information may include, but is not limited to 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. Additionally, we will gather statistical information about the Platform and visitors to the Platform such as, but not limited to browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors. Collecting this information allows us to better understand the visitors who come to our Platform, where they come from, and what content is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Platform. Some of this information may be collected using Cookies and similar tracking technology, as explained further under the section E. "COOKIES”.
Information that we receive from third parties
o Your username or nickname
o Your profile pictures
o Company name
o Contact details
· We may receive personal information about you from third parties that are engaged by us to assist with providing verification services and conducting suitable money laundering and know-your-customer (KYC) checks on users, and to improve our marketing efforts. This may include your name, email address, company details and contact information for company representatives.
· If you choose to participate in reviewing or rating products and/or services on Bozinga.com, we may receive personal information about you from third parties that work with us to conduct reviews into our services and/or rate us.
Your personal information will be collected and used for the following purposes:
· To verify your identity and undergo security, KYC and anti-money laundering diligence and background checks in order to set up user accounts;
· To set up / administer user accounts, including providing log-in IDs and developing a Platform profile;
· To provide users with customer service support; responding to queries, feedback, and managing claims and/or disputes;
· To facilitate communication between Buyers and Sellers via the Platform, process transactions and settlement between Buyers and Sellers made over the Platform, and assess fund withdrawal requests from Sellers;
· To provide logistics and warehousing services (such as, but not limited to, customs clearance declarations via the Platform);
· To facilitate customs clearance declarations / applications via the Platform;
· To assess and monitor account security and transaction risks of users of Bozinga.com, detect and prevent fraud, money laundering and other security incidents;
· To identify, develop and market advertising products and services that we believe you will value, including across browsers and devices, in accordance with applicable laws. Cookies or other similar technologies may be used to provide you with advertising based upon your browsing activities and interests (see section E. "COOKIES" below). Where we are required by applicable law, we will seek your consent prior to sending you communications for marketing purposes;
· If you are a Buyer, we will share details of the last viewed products on the Platform to enable Sellers to contact you with details of products and/or services that might interest you. You can opt not to share this information with Sellers via the Buyer Privacy Settings.
· National and international transfer of Data. Transferring your Personal Data to other Data Controllers located within and/or outside your territory, according to the disclosed Processing uses and purposes.
· National and international transmission of Data. Transmitting your Personal Data to a r Data Processors located within and/or outside your territory, according to the disclosed Processing uses and purposes.
We may also use your personal information for other purposes compatible with the purposes disclosed above (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.
We may disclose and/or provide access to personal information to the following categories of recipients:
· Other Platform Users where necessary in connection with the facilitation of purchases and communications made between you and the other users.
o Our business partners (for instance, allowing them to provide you with discounts or offers that may interest you);
o Logistics partners for providing delivery services for Buyers, including return and exchange of products, and warehousing services for Sellers;
o Custom agents for customs clearances purposes;
o Cloud computing service providers to provide cloud storage services;
o Customer service providers to provide after-sale services;
o Risk control service providers to assess the security of users’ accounts and transaction risks; and
o Third party rating / reviewing service providers to carry out reviews of our services with customers if you choose to participate in reviewing or rating Bozinga.com products and/or services;
· To our professional advisers, law enforcement agencies, insurers, government, and regulatory and other organizations 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, we may also disclose and transfer your personal information or as otherwise required or permitted by applicable laws.
· To any other person with your consent to the disclosure.
We may provide aggregated or anonymized data to third parties. 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 third parties and websites to offer you products and services which we do not offer, and such third parties and websites may include, but are not limited to the following affiliated platforms of Bozinga.com.
We will retain your personal information 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.
What are Cookies?
A Cookie is a small amount of data that is sent to your browser and stored on your computers 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 the Platform, our web servers will be notified of your visit to the Platform and in turn we may have knowledge of your visit and the pattern of your usage.
Cookies set by the website or app owner (in this case, Bozinga.com) are called "first party Cookies”. Cookies set by parties other than the website owner are called "third party Cookies”. Third party Cookies enable third party features or functionality to be provided on or through the website (e.g., like advertising, interactive content, and analytics). The parties that set these third-party Cookies can recognize your device both when it visits the website in question and when it visits certain other websites.
Cookies can also be categorized as:
· Session Cookies, which are erased once you close the browser or shut down the device. The session Cookies use encrypted data to authenticate you.; and
· Persistent Cookies, which remain even after closing the browser or shutting down the device/application and which are activated each time you visit the Platform. The persistent Cookies do not store account numbers or passwords.
We use both session Cookies and persistent Cookies.
We use first- and third-party Cookies for several reasons. Some Cookies are required for technical and/or security reasons for our Platform to operate, and we refer to these as "essential" or "strictly necessary" Cookies. First party Cookies are mainly served to enable basic functionality on our Platform, including web analytics Cookies that help us understand how users use our web pages and how we can improve their use. For example, we use essential or strictly necessary Cookies to enable us to remember goods added to your Bozinga.com shopping basket and to recognize you when you sign into your Bozinga.com account.
In addition, we also use social media Cookies. You may register for Platform membership and "share" Platform content through social media such as Facebook and Twitter. Sometimes we embed videos from websites like YouTube. These websites have their own privacy policies which govern their use of information, which you can find on the respective websites.
Cookies we use
The specific categories of first- and third-party Cookies served through our Platform and the purposes they perform are described in the table below (please note that the specific Cookies served may vary):
Type of Cookie
Who serves these Cookies
These Cookies are strictly necessary for enabling access and use of our Platform. They provide necessary functionality to ensure the proper performance, security, and functionality of our Platform. These Cookies cannot be disabled.
Statistical Cookies including analytics Cookies collect information in aggregate form to help us determine and understand how users interact with and use our Platform. We use this information to help us to improve and optimize our Platform and its security.
Google Analytics (please see below for further information)
Personalization and Service Cookies:
These Cookies are used to remember your computer or mobile device when you visit a website. They remember your registration and login details and your settings and preferences such as language and region. They are also used to ensure you don´t have to login every time you use your browser to comment on articles and to ensure interactive services work effectively. Personalization Cookies are also used to recommend content we think you could be interested in by serving and measuring relevant advertising, based on what you have looked at before.
Personalization Cookies may also include social media Cookies which are used to enable you to log into our Platform using your social media accounts and to share pages and content that you find interesting on our Platform through third party social networking and other websites. These Cookies may also be used for advertising purposes too.
Marketing Cookies. Marketing Cookies help us to ensure we provide you with more targeted and relevant marketing. We will also use marketing Cookies to evaluate the effectiveness of our marketing communications by monitoring open rate and conversions.
How can I control Cookies?
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.
You can also control your Cookie preferences though the Cookie Preferences Tool in Bozinga.com’s privacy settings.
Certain features of the Platform 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.
Other tracking technologies
Cookies are not the only way to recognize or track visitors to our Platform. We may use other, similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Platform or opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Platform to another, to deliver or communicate with Cookies, to understand whether you have come to our Platform from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on Cookies to function properly, and so declining Cookies will impair their functioning.
Google Analytics (More information)
Our Platform uses Google Analytics, an internet analytics service provided by Google, Inc. ("Google"). Google's Cookies allow us analyze use of the Platform by telling us which pages our users are viewing, which ones are most popular, what time of day our Platform are visited, if users have previously visited our Platform, from which website users are redirected to our Platform were and the like. The data generated by the Cookie about your use of the Platform will be transmitted to Google and stored by Google on servers in the United States.
The Platform uses an anonymization tool of IP addresses so that the IP addresses are truncated within the territory of the Member States of the European Union and the other members of the agreement on the European Economic Area. The non-truncated IP address are only exceptionally transmitted to Google’s servers in the US and then truncated there.
Google uses the data on behalf of Bozinga.com to evaluate your use of the Platform, to compile reports on website activity for the website operators and for other website activity and internet usage services. Google may disclose this information to third parties under the terms of the law or for further processing by third parties on behalf of Google. For more information about Google Analytics Cookies, visit:
· the Google Analytics Help Center: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
The IP address that your browser will pass on to Google Analytics will not be associated with any other data stored by Google. Cookies You can block Cookies using your browser settings; however, this can lead to problems with the use of some functionalities of the website. Through the add-on "Google Analytics Opt-out" you can through your current web browser opt-out to the use of Google Analytics from then on: http://tools.google.com/dlpage/gaoptout?hl=en. More information can be found at https://support.google.com/analytics/answer/6004245
The Sites and their contents are not targeted to 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 DataProtection@bozinga.com (for Bozinga.com users) to remove the information.
We employ commercially reasonable security methods to prevent unauthorized access to the Sites, to maintain data accuracy and to ensure the correct use of the information we hold. Some of the measures we apply are:
· The users can get more information regarding security measures through any of the available channels that are considered to give answers regarding data protection to users or third parties in general.
For registered users of the Sites, 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 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
· Necessary for providing the services pursuant to the agreement between you and Bozinga.com LLC. E-Commerce and/or its affiliates (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. We will 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, 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 using the contact details provided under section J. " CONTACT US" below.
International transfers of personal information
If you are a resident of the EEA, you also have the following data protection rights, which you can exercise at any time by contacting us using the contact details provided under section J. "CONTACT US" below:
· The right to access, correct, update or request deletion of your personal information.
· 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 (such as postal marketing or telemarketing), then please contact us using the contact details provided under section J. "CONTACT US" below.
· If we have collected and process 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.
L. VISITORS FROM OTHER REGIONS
Other Privacy Obligations may apply if you are accessing and/or using the Platform from another region other than the European Union. To find if other Privacy Annexes apply to you, please follow this link to see the full list of available regions.
Annex A. Colombia
ANNEX A – COLOMBIA
VALID FROM JUNE 2021
IDENTIFICATION OF DATA CONTROLLER. CONTACT INFORMATION
· Address: Carrera 13A # 89-38 Office 629. Bogotá, Colombia.
· Telephone number: +57 1 256 0966
Previous, express, and informed consent given by the Data Subject for the Processing of its Personal Data.
Data Processor ("Processor”)
A natural or legal person, which can be public or private, that on its own or in association with other, Processes Personal Data on behalf of the Data Controller.
Data Controller ("Controller”)
A natural or legal person, which can be public or private, that on its own or in association with other, decides upon the Database and/or the Processing of the Private Data.
The carrying out of any operation or operations on Personal Data, such as collecting, storing, using, sharing, or deleting of Personal Data.
The Transfer of Personal Data from a Colombian-based Data Controller and/or Data Processor to another Data Controller within or outside the Colombian territory.
The sharing of Personal Data from a Data Controller to a Data Processor, located within or outside the Colombian Territory.
INTERNATIONAL TRANSFER AND/OR TRANSMISSION OF PERSONAL DATA
We will make sure that Collected Data from Colombian Users is not Transmitted/Transferred outside of the Country unless:
· The country to which the Data is being Transferred/Transmitted has an adequate level of Data Protection Laws as determined by the Colombian Data Protection Authority. The countries which have been recognized as having adequate levels of Data Protection Laws are, to date: Germany, Australia, Austria; Belgium; Bulgaria; Cyprus; Costa Rica; Croatia; Denmark; Slovakia; Slovenia; Estonia; Spain; United States of America; Finland; France; Greece; Hungary; Ireland; Island; Italy; Japan; Latvia; Lithuania; Luxemburg; Malta; Mexico; Norway; Netherlands; Peru; Polonia; Portugal; United Kingdom; Czech Republic; Republic of Korea, Romania; Serbia; Sweden; and the countries recognized by the European Commission as countries with adequate Data Protection standards; or,
· The country to which the Data is being Transferred/Transmitted does not have an adequate level of Data Protection as determined by the SIC has granted a conformity statement to Transmit and/or Transfer the Data to a third country that has not been listed as those with adequate levels of Data Protection.
· Know, update, and rectify your Personal Data directly with the Data Controller and Data Processor. This right can be exercised for partial data, inaccurate data, incomplete data, fractioned data, or data for which Processing is prohibited or for the Processing has not been authorized, amongst other.
· Request proof of the Authorization given to the Data Controller except when the authorization is not required by law.
· Being informed, upon request, of the use that will be given to the collected Data by the Data Controller and/or Data Processor.
· File complaints before Superintendence of Industry and Commerce ("SIC”), which is the Colombian Data Protection Authority, for any breaches to the GDPL.
· To revoke the Authorization and/or request the elimination of the Collected Data when the Processing breaches the legal and constitutional guarantees as established by the GDPL.
· Decide whether to Authorize the Processing of your sensitive data or not.
PROCEDURES FOR THE EXCERSISE OF THE USER’S RIGHTS
Bozinga.com will provide you with two different procedures to protect and exercise your rights under the GDPL: consultations and claims.
· Consultations:Data Subjects or their legal representatives can access their Personal Data stored in our Databases. Upon your request, we will disclose all information related to you or your personal identification. This consultation must be requested through the official communication channels of Bozinga.com, such as the email: DataProtection@bozinga.com . We will reply to your consultation request within the ten (10) days after receiving your initial communication. If for any reason we are not able to process the consultation within that timeframe, we will inform you of this delay and explain the reasons for it, and answer within the five (5) days after the initial term expires.
· Claims: If you or your legal representative consider that the Data, we have Collected from you must be corrected, updated, or suppressed, or if you or your legal representative consider that there has been a breach to the GDPL’s rights or obligations, you can submit a claim under the following conditions:
o The claim must be addressed at Bozinga.com and must include your identification information, your address and all the facts and documents that support the claim. If the claim were to be incomplete, we will inform you and grant you five (5) days to amend or complete the missing information. If you fail to answer or come back to us in the two (2) months following the initial claim, we will assume that you have desisted of the claim.
o Up to two (2) days after you have submitted a complete claim, your Data in our Databases will be tagged as "claim in progress” and will include the reasons for the claim.
o We will reply to your claim within the following fifth teen (15) labor days counted since the day we receive your claim. If for any reason we are not able to process the consultation within that timeframe, we will inform you of this delay and explain the reasons for it, and answer within the eight (8) days after the initial term expires.
It is important you note that no claims can be submitted to the Colombian Data Protection Authority before you have submitted and completed the consultation or the claim process.