Pixibo Try Before You Buy Privacy Policy
Last modified: 1 May 2021
Summary
In order for Pixibo to offer our Try Before You Buy service, Pixibo Pte. Ltd (Pixibo), UEN 201601536W, needs certain information to be collected from Pixibo's Retail Partners and their shoppers; Pixibo retail partners are third parties for whom Pixibo provides its Try Before You Buy and Try@Home service. We take the privacy of this information very seriously and this policy is provided to explain how and why we collect information from our users.

This Privacy Policy and its Addendum(s) ("Policy") describe how Pixibo, its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively "Pixibo", "we", "us" or "our") collect, use, process and disclose your Personal Data through the use of Pixibo's checkout products such as Try Before You Buy and Try@Home services operated by Pixibo (collectively, "Services").

This Policy applies to our consumers, vendors, partners (such as rider/driver and merchant partners), contractors and service providers (collectively "you", "your" or "yours").


"Personal Data" is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, bank and credit card details, email address, your image, government-issued identification numbers, and date of birth.
I. Collection of personal data
We collect Personal Data about you in the ways listed below. We may also combine the collected Personal Data with other Personal Data in our possession.If you have or are a party to multiple relationships with us (for example if you use our checkout products such as Try Before You Buy as well as signed up to receive email promotions and voucher codes from us), we will link your Personal Data collected across your various capacities to facilitate your use of our Services and for the Purposes described below.
You provide your Personal Data to us voluntarily
We collect your Personal Data when you voluntarily provide it to us. For example, you may provide your Personal Data to us when you:

• Checkout with Try Before You Buy on any of our merchant's websites. (such as your name, contact information and shipping address where needed);
• Interact with our social media pages (such as your social media account ID, sign up for promotions and vouchers etc);
• participate in contests or events organised by us (such as the pictures, audio files, or videos you may submit, which may include images of yourself);

In certain circumstances, you may need to provide your Personal Data in order to comply with legal requirements or contractual obligations, or where it is necessary to conclude a contract. Failure to provide such Personal Data, under such circumstance, may constitute failure to comply with legal requirements or contractual obligations, or inability to conclude a contract with you, as the case may be.
When our services are used
Personal Data may be collected through the normal operation of our widgets, checkout products and Services. Some examples are:

• transaction information (such as payment method and);
• information about how you interacted with our Services (such as features used and content viewed);
• personal data you enter in messages when you contact us via orders@pixibo.com or our social media channels.
Personal Data of minors
As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to Pixibo. In the event that such Personal Data of a minor is disclosed to Pixibo, you hereby consent to the processing of the minor's Personal Data and accept and agree to be bound by this Policy and take responsibility for his or her actions.
When you provide Personal Data of other individuals to us
In some situations, you may provide Personal Data of other individuals (such as your spouse, family members or friends) to us. For example, you may place an order for your spouse/housemate/friend. If you provide us with their Personal Data, you represent and warrant that you have obtained their consent for their Personal Data to be collected, used and disclosed as set out in this Policy.
II. Use of personal data
Pixibo may use, combine and process your Personal Data for the following purposes ("Purposes"):
Providing services and features
Your Personal Data will be used to provide, personalise, maintain and improve our widgets, apps,and Services.This includes using your Personal Data to:

• provide you confirmation of your Try Before You Buy order.
• create, administer and update your orders;
• validate your Try@Home order and process payments;
• Track orders and detect abnormal variations;
• perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends;
• protect the security or integrity of the Services and any facilities or equipment used to make the Services available;
• Process and manage your automatic discounts and vouchers.
• Process, manage or verify your use of our promotions, rewards and vouchers with Pixibo;
• Enable our partners to manage and allocate fleet resources; and
• Fulfil the services to you as a data processor, where you have provided consent to the data controller (i.e. the organisation you had purchased services from, and for whom Pixibo is providing services on behalf of) for such services to be rendered.
Safety and security
We use your data to ensure the safety and security of our Services and all users. This includes:

• Screening rider and delivery partners before enabling their use of our Services
• detecting, preventing and prosecuting crime.
Customer support
We use Personal Data to resolve customer support issues. For example, we may:

• investigate and address concerns;
• monitor and improve our customer support responses;
• respond to questions, comments and feedback; and
• inform you about steps taken to resolve customer support issues.
Research and development and security
We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and analyse your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our Services, develop new features, products and services.
Legal purposes
We may use the Personal Data we collect to investigate and resolve claims or disputes, or as allowed or required by applicable law.

We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.

For example, we may use your Personal Data to:

• comply with court orders or other legal, governmental or regulatory requirements
• enforce our Terms of Service or other agreements; and
• protect our rights or property in the event of a claim or dispute.

We may also use your Personal Data in connection with mergers, acquisitions, joint ventures, sale of company assets, consolidation, restructuring, financing, business asset transactions, or acquisition of all or part of our business by another company.
Marketing and promotions
We may use your Personal Data to market Pixibo and Pixibo's retail partners' products, services, events or promotions. For example, we may:

• send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and
• notify, invite and manage your participation in our events or activities.

We may communicate such marketing to you by post,short message service, and by email.

If you wish to unsubscribe to the processing of your Personal Data for marketing and promotions, please click on the unsubscribe link in the relevant email or message.
III. Disclosure of personal data
We need to share Personal Data with various parties for the Purposes. These parties include:
Other users
For example:

• If you are a shopper, we may share your shipping address and contact details with our driver partner fulfilling your Try Before You Buy order request.
• If you are a shopper, we may share your personal information and order information with our retail partners in order to fulfil your order request.
• If you are a driver partner, we may share your Personal Data with the shopper including your name and photo.
With Pixibo partners at your request
For example, if you requested a service through a Pixibo partner or used a promotion provided by a Pixibo partner, Pixibo may share your Personal Data with that Pixibo partners. Our partners include online fashion and footwear retail partners that integrate with various Pixibo's Services.
With subsidiaries and affiliates
We share Personal Data with our subsidiaries, associated companies, jointly controlled entities and affiliates.
With Pixibo's service providers and business partners
We may provide Personal Data to our vendors, consultants, marketing partners, research firms, and other service providers or business partners. This includes:

• payment processors and facilitators;
• debt collectors;
• credit bureaus and other credit reporting agencies;
• background check and anti-money laundering service providers;
• cloud storage providers;
• marketing partners and marketing platform providers;
• data analytics providers;
• fleet and merchant partners;
• service providers who perform identity verification services; and
With our legal advisors and governmental authorities
We may share your Personal Data with our legal advisors, law enforcement officials, government authorities and other third parties. This may take place to fulfil the legal purposes (mentioned above), or any of the following circumstances:

1.where it is necessary to respond to an emergency that threatens the life, health or safety of a person; or
2.where it is necessary in the public interest (e.g. in a public health crisis, for contact tracing purposes and safeguarding our community).
IV. Retention of personal data
We retain your Personal Data for the period necessary to fulfill the Purposes outlined in this Policy unless a longer retention period is required or allowed by law. Once your Personal Data is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your Personal Data, we take steps to erase, destroy, anonymise or prevent access or use of such Personal Data for any purpose other than compliance with this Policy, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.
V. International transfers of personal data
Your Personal Data may be transferred from country, state and city ("Home Country") in which you are present while using our Services to another country, state and city ("Alternate Country").

When we transfer your Personal Data from your Home Country to the Alternate Country, we will comply with our legal and regulatory obligations in relation to your Personal Data,including having a lawful basis for transferring Personal Data and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Data. We will also ensure that the recipient in Alternate Country is obliged to protect your Personal Data at a standard of protection comparable to the protection under applicable laws.

Our lawful basis will be either consent (i.e. we may ask for your consent to transfer your Personal Data from your Home Country to the Alternate Country at the time you provide your Personal Data) or one of the safeguards permissible by laws.
VI. Cookies and advertising on third party platforms
Pixibo, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5 and Flash (sometimes called "flash cookies"), advertising identifiers (including mobile identifiers such as Apple's IDFA or Google's Advertising ID) and similar technology ("Cookies") in connection with your use of the Websites and Apps. Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit Personal Data about you and your use of the Service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.

Pixibo may allow third parties to use Cookies on the Websites and Apps to collect the same type of Personal Data for the same purposes Pixibo does for itself. Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.

Additionally, we may share non-personally identifiable Personal Data with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising on third party platforms.

If you do not wish for your Personal Data to be collected via Cookies on the Websites, you may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser.
VII. Protection of personal data
We will take reasonable legal, organisational and technical measures to ensure that your Personal Data is protected. This includes measures to prevent Personal Data from getting lost, or used or accessed in an unauthorised way. We limit access to your Personal Data to our employees on a need to know basis. Those processing your Personal Data will only do so in an authorised manner and are required to treat your information with confidentiality.

Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through any online means,therefore, any transmission remains at your own risk.
VIII. Your rights with respect to your personal data
In accordance with applicable laws and regulations, you may be entitled to:

• ask us about the processing of your Personal Data, including to be provided with a copy of your Personal Data;
• request the correction and/or (in some cases) deletion of your Personal Data;
• in some cases, request the restriction of the processing of your Personal Data, or object to that processing;
• withdraw your consent to the processing of your Personal Data (where we are processing your Personal Data based on your consent);
• request receipt or transmission to another organisation, in a machine-readable form, of the Personal Data that you have provided to us where we are using your Personal Data based on consent or performance of a contract; and
• complain to the relevant data privacy authority if your data privacy rights are violated, or if you have suffered as a result of unlawful processing of your Personal Data.

Where you are given the option to share your Personal Data with us, you can always choose not to do so. If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

However, choosing not to share your Personal Data with us or withdrawing your consent to our use of it could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in Section II (Use of Personal Data) or that you are unable to make use of the Services. After you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulations.

If you wish to make a request to exercise your rights, you can contact us via our Data Protection Officer –dpo@pixibo.com

We will screen and verify all requests beforehand. In order to verify your authority to make the request, we may require you to provide supporting information or documentation to corroborate the request.

Once verified, we will give effect to your request within the timelines prescribed by applicable laws.
IX. Amendments and updates
Pixibo shall have the right to modify, update or amend the terms of this Policy at any time by placing the updated Policy on the Websites. By continuing to use Services from Pixibo or continuing to communicate or engage with Pixibo following the modifications, updates or amendments to this Policy, you signify your acceptance of such modifications, updates or amendments.
X. How to contact us
If you have any queries about this Policy or would like to exercise your rights set out in this Policy, please contact our Data Protection Officer at:

Pixibo Data Protection Officer

c/o Pixibo Pte. Ltd

81 Ayer Rajah Crescent

#02-49, Block 81 JTC Launchpad

Singapore 133967

Email: dpo@pixibo.com

The original of this Policy is written in the English language. In the event of any conflict between the English and other language versions, the English version shall prevail.