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1. Who We Are and What We Do
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TospinoMall is an localized integrated shopping mall focusing on emerging markets in Africa, equipping with such online functions as product searching, browsing, collection, buying, payment, order inquiry, logistics tracking and return/exchange. By convenient cross-border direct mail, it converges huge global good products to meet people’s needs on daily consumption and online shopping, bringing consumers an easy, happy shopping experience.
This Privacy Policy explains our information practices, the kinds of information we collect, how we use and share that information, and your options.
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2. Scope
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This Privacy Policy applies to any information relating to an identified or identifiable natural person (“Personal Information”) Processed by us in our business, including on our website (the “Site”), mobile application and other online or offline offerings (collectively, the “Services”). “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction. All Individuals whose responsibilities include Processing Personal Information for us are expected to protect it by following this Privacy Policy.
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3. Transparency/Notice
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3.1 Personal Information We Collect and How We Use It
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The types of Personal Information we collect and our privacy practices depend on whether you are a customer, user or visitor (together, “Individuals”) and the requirements of applicable law.
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  • Account Creation. When creating an account on our Site, you may be asked to enter your name, email address, and phone number or other details to allow us to provide you with the Services.
 
  • Purchase and Use History. We may maintain your purchase and bid history by linking this information to your Account. This information does not include financial information related to your payment method.
 
  • Beta User Information. If you sign up to join a Beta on our Site, we will collect your email, first name and username. We will also add your email to our mailing list.
 
  • Communications with Us. We may collect Personal Information from you such as email address, phone number, or mailing address when you request information about our Services, make a purchase,  request customer or technical support, or otherwise communicate with us.
 
  • Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.
 
  • Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings,   cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
 
  • Information from Other Sources. We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an App Store, a third-party login service, or a Social Networking Site (“SNS”), we may collect information about you from that third-party application that you have made available via your privacy settings. Information we collect through these services may include your name, your user identification number, your user name, email, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with the Services.
 
3.2 How We Use Your Information
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We Process Personal Information about Individuals for a variety of business purposes, including:
  • To personalize your experience and allow us to deliver the type of services and product offerings in which you are most interested.
  • To allow us to better service you in responding to your customer service requests.
  • To quickly process your transactions.
  • To send periodic emails regarding your order or other products and services.
  • To market and provide our products and services.
  • To create de-identified and aggregated information which we may then use for internal analysis and analytics.
  • Other Uses: TospinoMall may use Personal Information to pursue legitimate interests, such as direct marketing, research (including marketing research), network and information security, fraud prevention, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
 
3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
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We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us to record certain pieces of information whenever you visit or interact with our Site and Services.
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  • Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you turn cookies off, some of the features that make your site experience more efficient may not function properly.
 
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
 
  • Analytics. We may also use Google Analytics to collect information regarding visitor behavior and visitor demographics on our Site and Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
 
Google Firebase. We may use Google Firebase analytics to collect usage statistics and to improve our Services. Information collected by Google Firebase can be accessed here: https://support.google.com/firebase/answer/6318039. Information related to the security and privacy of Google Firebase is available here: https://firebase.google.com/support/privacy/
 
  • Advertising. We use Google AdSense Advertising to serve ads to our users based on previous visits to our Site and other sites on the Internet. Users may opt-out by visiting the Google Ad and Content Network privacy policy at https://policies.google.com/privacy?hl=en-US.
 
Our uses of such Technologies fall into the following general categories:
 
  • Operationally Necessary. This includes Technologies that allow you access to our Site, Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;        
  • Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our users use the Services and save user’s preferences for future visits. We compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf;
  • Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Site and Services. This may include identifying you when you sign into our Site or Services or keeping track of your specified preferences, interests, or past items viewed;
  • Advertising or Targeting Related. We may use first party or third party Technologies to deliver content, including ads relevant to your interests, on our Site and Services or on Third Party sites.
 
3.4 Third Party Websites, Social Media Platforms and Software Development Kits
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We include or offer third-party products or services on our Site. The Services may include publicly accessible forums and access to third parties’ sites. By using the Services you assume the risk that the Personal Information provided by you may be viewed and used by Third Parties for any number of purposes.
We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including advertising partners to collect your Personal Information to provide content that is more relevant to you. TospinoMall uses the following SDKs: Facebook, Google. For more information about our use of APIs and SDKs, please contact us as set forth below.
 
4. Onward Transfer—How We May Disclose Your Information
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4.1 Information We Share
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We may share your information as described in this Privacy Policy:
 
  • We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) the provision of the Site and Services.
 
  • Business Partners. We may provide Personal Information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.
 
  • Marketing – Interest-Based Advertising and Third Party Marketing.  Through our Services, TospinoMall may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site and Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with third party advertising partners, you may follow the instructions below.
 
  • Disclosures to Protect Us or Others. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) to enforce our policies or contracts; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
 
  • Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.
 
4.2 The Data We Collect About You?

Personal data means any information that can be used to identify directly or indirectly a specific individual. We collect your personal data in order to provide tailored products and services and in order to analyse and continually improve our products and services. We may collect, use, store and transfer different kinds of personal data for marketing and personal data optimization purposes. TospinoMall also uses Google Digital Marketing to propose targeted offers for certain products and services to our customers.
You provide us with your personal data when you register your personal details on our website and mobile platforms and transact with the same.
The personal data we collect includes:
A. Information you provide to us: We receive and store the information you provide to us including your identity data, contact data, biometric data, delivery address and financial data. These types of personal data may include:
contact details (such as your name, postal addresses, phone numbers and email addresses),
demographic information (such as your date of birth, age or age range and gender),
online registration information (such as your password and other authentication information),
payment information (such as your credit card information and billing address),
information provided as part of online questionnaires (such as responses to any customer satisfaction surveys or market research),
competition entries/submissions, and
in certain cases your marketing preferences.
B. Information we automatically collect/generate or obtain from third parties: We automatically collect and store certain types of information regarding your use of the TospinoMall marketplace including information about your searches, views, downloads and purchases. In addition, we may receive information about you from third parties including our carriers; payment service providers; merchants/brands; and advertising service providers.

These types of personal data may relate to your device (such as your PC, tablet or other mobile device), your use of our websites and apps (as well as certain third party websites with whom we have partnered), and/or your personal preferences, interests, or geographic location. Examples of these types of information include:
name and age (or predicted age range),
information about your device, operating system, browser and IP address,
unique identifiers associated with your device,
details of web pages that you have visited,
which products you have looked at online (including information about products you have searched for or viewed, purchased or added to an online shopping basket),
how long you spend on certain areas of a website or app together with the date and time of your visit/usage,
personal data contained within user-generated content (such as blogs and social media postings),
social media user name or ID, and
social media profile photo and other social media profile information (such as number of followers).
We strive to provide you with choices regarding the personal data you provide to us. If required by law, if you would like TospinoMall to use your personal data to provide you with a personalized experience/targeted advertising and content, you can indicate this through the registration page. If you decide that you no longer wish to benefit from this personalization, you can opt-out or adjust your preferences at any time by closing your account or sending an email to service@tospino.com.gh. Once your account is closed, all products and services that you have accessed through your account will no longer be available.

5. Your Choices:  Right to Object to Processing
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5.1 General
You have the right to object to or opt out of certain uses of your Personal Information. Where you have consented to the Processing of your Personal Information, you may withdraw that consent at any time and prevent further Processing by contacting us as described below. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Site, Services and/or information from the advertisements on third party websites for other legal purposes as described above.
 
5.2 Email and Telephone Communications
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy).
 
5.3 Mobile Devices
We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device.TospinoMall may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
 
5.4 “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
 
5.5 Cookies and Interest-Based Advertising
You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/,https://youradchoices.ca/choices/,and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA's AppChoices application from your device's app store. Alternatively, for some devices you may use your device's platform controls in your settings to exercise choice.
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
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6.Rights of Access, Rectification, Erasure, and Restriction
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly Processed Personal Information; and (vi) request erasure of Personal Information held about you by TospinoMall, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below. 
We will process such requests in accordance with applicable laws. To protect your privacy, TospinoMall will take steps to verify your identity before fulfilling your request.
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7.Data Retention
TospinoMall retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
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8.Security of Your Information
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.
By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.
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9.Children’s Information
The Site and Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect Personal Information from children. If you learn that your child has provided us with Personal Information without your consent, you may contact us as set forth below. If we learn that we have collected any Personal Information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
 
10.Changes to Our Privacy Policy
We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.
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11.Terms of Service
This Privacy Policy is incorporated by reference into the TospinoMall Terms of Service (the “Terms”). All other terms not defined in this Privacy Policy will have the meanings set forth in the Terms. The terms “TospinoMall,” “we,” “us” and our affiliates and subsidiaries.
 
12. Contact Us
 
If you have any questions about our privacy practices or this Privacy Policy, please contact us at service@tospino.com.gh