Privacy and Data Protection Policy

We, Frosts Food & Beverage Pte Ltd and its affiliates (together "Frosts" or the "Company"), take your personal information seriously and use or keep it confidential. In order to protect your private information, we have established this Privacy Policy (the "Policy") in accordance with best practices in the industry and applicable laws and regulations. This Policy describes how we handle your personal information for our services on the Frosts website and its related sites, services and tools (the "Website").

By accepting this Policy in registration, you expressly consent to our collection, storage, use and disclosure of your personal information as described in this Policy. This Policy is effective immediately upon acceptance by new users.

Collection

You can browse our sites without telling us who you are or revealing any personal information about yourself. Once you give us your personal information, you are not anonymous to us. If you choose to provide us with personal information, you consent to the transfer and storage of that information on our servers located in [Where?].

We may collect and store the following personal information:

- email address, physical contact information, the date of birth and gender information, and (depending on the service used) sometimes financial information, such as credit card or bank account numbers;

- transactional information based on your activities on the Website (such as buying, selling, bidding, item and content you generate or that relates to your account);

- postage, billing and other information you provide to purchase or dispatch an item;

- community discussions, chats, dispute resolution, correspondence through our Website, and correspondence sent to us;

- other information from your interaction with our Website, services, content and advertising, including computer and connection information, statistics on page views, traffic to and from the Website, ad data, IP address and standard web log information;

- additional information we ask you to submit to authenticate yourself or if we believe you are violating site policies (for example, we may ask you to send us an ID or bill to verify your address, or to answer additional questions online to help verify your identity or ownership of an item you list);

- information from other companies, such as demographic and navigation data; and

- other supplemental information from third parties (for example, if you incur a debt to the Company, we will generally conduct a credit check by obtaining additional information about you from a credit bureau, as permitted by law).

Marketing

We don't sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalise our services, content and advertising. If you don't wish to receive marketing communications from us or participate in our ad-customisation programmes, simply indicate your preferences in My Account or by following the directions provided with the communication or advertisement.

Use

Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient and customized experience. You agree that we may use your personal information to:

- Provide the services and customer support you request;

- Resolve disputes, collect fees, and troubleshoot problems;

- Prevent potentially prohibited or illegal activities, and enforce our User Agreement;

- Customize, measure and improve our services, content and advertising;

- Tell you about our services and those of our corporate family;

- Send you targeted marketing, service updates, and promotional offers; and

- Compare information for accuracy, and verify it with third parties.

Our Disclosure of Your Information

We may disclose personal information to respond to legal requirements, enforce our policies, respond to claims that a listing or other content violates the rights of others, or protect anyone's rights, property, or safety. Such information will be disclosed in accordance with applicable laws and regulations.

Share of Your Information

We may share your personal information with:

- Third-party service providers under contract who help with our business operations: We employ other companies and individuals to perform functions on our behalf. Examples include fulfilling orders, delivering packages, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, investigating frauds and providing customer service. They have access to personal information needed to perform their functions, but may not use it for other purposes.

- Third parties giving promotional offers: Sometimes we send offers to selected groups our users on behalf of other businesses. When we do this, we do not give that business your name and address. [If you do not want to receive such offers, please adjust communication preferences in My Account].

- Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service).

- Law enforcement or other governmental officials, in response to a verified request relating to a criminal investigation or alleged illegal activity. In such events, we will disclose information relevant to the investigation, such as name, city, postal code, telephone number, email address, User ID history, IP address, fraud complaints, and purchasing and listing history;

- Other business entities, should we plan to merge with or be acquired by that business entity. (Should such a combination occur, we will require that the new combined entity follow this privacy policy with respect to your personal information. If your personal information will be used contrary to this policy, you will receive prior notice.)

For the avoidance of doubt, If Frosts has reasonable grounds to believe that any User is in breach of any of the terms of this Policy, Frosts reserves the right, in its sole and absolute discretion, to cooperate fully with governmental authorities, private investigators, all the rightful owner(s) or interest holder(s) and/or injured third parties in the investigation of any potential or ongoing criminal or civil wrongdoing. Further, Frosts may disclose the User's identify and contact information, or such other transaction-related data, if requested by a government or law enforcement body, private investigator, rightful owner or interest holder and/or any injured third party or as a result of a subpoena or other legal action, or if Frosts is of the view, in its sole and absolute discretion, that it would be in its best interest to do so. Frosts shall not be liable for damages or results arising from such disclosure, and the User(s) agrees not to bring action or claim against Frosts for such disclosure.

Using Information from this Website

We enable you to share personal information to complete transactions. When users are involved in a transaction, they may have access to each other's name, user ID, email address and other contact and postage information. In all cases, you must comply with data protection laws, and give other users a chance to remove themselves from your database and a chance to review what information you have collected about them.

You agree to use user information only for:

- fulfillment of the transaction through this website and purposes related to the transaction;

- using services offered through this website (e.g. escrow, postage and fraud complaints); or

- other purposes that a user expressly chooses.

Cookies

We use "cookies" (small files placed on your hard drive) on certain of our pages to help analyse our web page flow; customise our services, content and advertising; measure promotional effectiveness, and promote trust and safety.

A few important things you should know about cookies are that:

- We offer certain features that are available only through the use of cookies. - We use cookies to help identify you and maintain your signed-in status. - Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session. - You are always free to decline our cookies if your browser permits, although doing so may interfere with your use of some of our sites or services. - You may encounter cookies from third parties on certain pages of the Website that we do not control. (For example, if you view a web page created by another user, there may be a cookie placed by that web page.)