I. Introduction


1.1 You are welcome to use the carousell Platform operated by carousell and its affiliates (individually and collectively, "carousell," "we," "us" or "our"). carousell takes seriously its responsibilities under applicable privacy laws and regulations ("Privacy Act") and is committed to respecting the privacy rights of all users of our carousell websites and mobile applications ("Platform"). ("Platform") (we refer to the Platform and the services we provide on our Platform collectively as the "Services"). Users are those who register an account with us to use the Services, including buyers and sellers (individually and collectively, "Users", "you" or "your"). We recognize the importance of the personal data you entrust to us and believe that it is our responsibility to properly manage, protect and process your personal data. This privacy policy ("Privacy Policy" or "Policy") is intended to help you understand how we collect, use, disclose and/or process the personal data you provide to us and/or that we have about you, both now and in the future, as well as to help you understand how we collect, use, disclose and/or process your personal data before providing it to us. 


1.2 "Personal Data" or "Personal Data" means data about an individual who can be identified from that data or from that data and other information to which the organization is or may be entitled to have access, whether whether or not it is genuine. Common examples of personal data may include name, ID number and contact information.


1.3 By using the Services, registering an account with us, accessing our Platform or accessing the Services, you acknowledge and agree that you accept the practices, requirements and/or policies outlined in this Privacy Policy and you hereby consent to our collection, use, disclosure and/or processing of your personal data as described herein. If you do not consent to the processing of your personal data as described in this Privacy Policy, please do not use our Services or access our Platform. If we change our Privacy Policy, we will notify you, including by posting such changes or a revised Privacy Policy on our Platform. We reserve the right to modify this Privacy Policy at any time. To the maximum extent permitted by applicable law, your continued use of the Services or the Platform, including placing any orders, will mean that you acknowledge and accept the changes made to this Privacy Policy.


1.4 This Policy applies in conjunction with, and is not intended to override, other notices, contractual terms, and consent terms that apply to our collection, storage, use, disclosure and/or processing of your personal data, unless we expressly state otherwise. 


1.5 This Policy applies to both buyers and sellers using the Services, unless expressly stated otherwise. We disclose and/or process your personal data and do not intend to override these notices or terms unless we expressly state otherwise. 


1.6 This policy applies to both buyers and sellers using the Services, unless expressly stated otherwise.


2. When does carousell collect personal data? 


2.1 We will/may collect personal data about you. 

When you register and/or use our Services or Platform, or open an account with us. 

When you submit any forms, including but not limited to application forms or other forms related to any of our products and services, whether online or through physical forms. 

When you enter into any agreement or provide other documents or information in connection with your interactions with us, or when you use our products and services. 

When you interact with us, such as by telephone (which may be recorded), mail, fax, face-to-face meetings, social media platforms and email, including when you interact with our customer service agents. 

When you use our electronic services, or interact with us through our applications or use services on our platform. This includes, but is not limited to, through cookies that we may deploy when you interact with our applications or websites. 

When you grant permissions on your device to share information with our applications or platforms.

When you associate your carousell account with your social media or other external accounts or use other social media features in accordance with the provider's policies. 

When you conduct transactions through our services. 

When you provide feedback or complaints to us. 

When you register for a contest; or 

When you submit your personal data to us for any reason 

The above is not exhaustive, but is a list of some common situations in which personal data may be collected about you. 


3. What personal data will carousell collect? 


3.1 The personal data that carousell may collect includes, but is not limited to 


Email address; 

Date of birth; 

Billing and/or shipping address. 

Bank account and payment information. 

Phone number; 

Gender ; 

Information sent by or in connection with the device used to access our services or platforms. 

Information about your network and the people and accounts with whom you interact.

Photographs or audio or video recordings.

Government-issued identification or other information necessary for our due diligence, understanding of your customers, identity verification or fraud prevention. 

Marketing and communication data, such as your preferences for receiving marketing from us and third parties, your communication preferences and the history of communications with us, our service providers and other third parties. 

Usage and transaction data, including details about your searches, orders, the advertising and content you interact with on the Platform and other products and services associated with you.

Location data.

Any other information about users when they register to use our Services or the Platform and when they use the Services or the Platform, as well as information related to how users use our Services or the Platform; and 

Aggregate data about the content in which the user engages. 


3.2 You agree not to submit any inaccurate or misleading information to us, and you agree to notify us of any inaccuracies or changes to such information. We reserve the right, in our sole discretion, to request further documentation to verify the information you provide. 


3.3 If you use your social media account ("Social Media Account") to register as a user of our Platform, link your carousell account to your social media account or use any carousell social media feature, we may access your information that has been voluntarily provided to your social media provider in accordance with that provider's policies. account provider, and we will always manage and use any such personal data in accordance with this Policy. 


3.4 If you do not want us to collect the above information/personal data, you may opt out at any time by notifying our Data Protection Officer in writing. For more information on opting out, please see the section below entitled "How can you withdraw your consent, request access or correct the information you have provided to us?" . Please note, however, that opting out or withdrawing your consent to our collection, use or processing of your personal data may affect your use of the Services and the Platform. For example, opting out of the collection of location information will result in its location-based features being disabled. 



4. Collection of Other Data 


4.1 As with most websites and mobile applications, information sent from your device may include data about you that is recorded by web servers as you browse our Platforms. This typically includes, but is not limited to, your device's Internet Protocol (IP) address, computer/mobile device operating system and browser type, mobile device type, mobile device characteristics, unique device identifier (UDID) or mobile device identifier (MEID) for your mobile device, the address of the referring website (if any), the pages you visit on our websites and mobile applications, and time of visit, and sometimes a "cookie" (which can be disabled using your browser preferences) to help the site remember your last visit. If you are logged in, this information will be associated with your personal account. 


4.2 Our mobile applications may use technologies such as GPS, Wi-Fi, etc. to collect precise information about the location of your mobile device. We collect, use, disclose and/or process this information for one or more purposes, including but not limited to location - services where you request or provide you with relevant content based on your location or allow you to share your location with other users as part of the services under our mobile applications. For most mobile devices, you can revoke your permission for us to obtain your location information through your device settings. If you have any questions about how to disable location services for your mobile device, please contact your mobile device service provider or device manufacturer. 


4.3 When you view pages on our website or mobile application, most of the same information is sent to us when you view content and ads and access other software on our platform or through the Services (including, but not limited to, IP address, operating system, etc.); however, your device does not send us content, ad views and/or software about the Services and platform installations and time of information, not page views. 



5. Cookie 


5.1 From time to time, we or our authorized service providers and advertising partners may use "cookie" or other features that allow us or third parties to collect or share information related to your use of our Services or Platform. These features help us improve our Platform and the services we offer, help us provide new services and features, and/or enable us and our advertising partners to provide you with more relevant content, including through remarketing. "Cookie" are identifiers that are stored on your computer or mobile device to record data about the computer or mobile device, how and when you use or access the Services or the Platform, how many people and other activities within our Platform. We may associate cookie information with personal data. cookies also link to information about the items you choose to purchase and the pages you view. This information is used to track your shopping cart, to provide content specific to your interests, to enable our third party advertising partners to place advertisements on websites on the Internet, to conduct data analytics and to monitor usage of the Services. 


5.2 You may refuse the use of cookies by selecting the appropriate settings on your browser or device; however, please note that if you do so, you may not be able to use the full functionality of our Platform or Services. 



6. How do we use the information you provide to us? 


6.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes. 

To consider and/or process your applications/transactions with us or your transactions or communications with third parties through the Services. 

To administer, operate, provide and/or manage your use of and/or access to our Services and our Platform (including, but not limited to, remembering your preferences) and your relationship and user account with us. 

Responding to, processing, handling or completing transactions and/or fulfilling your requests for certain products and services, and notifying you of service issues and unusual account behavior. 

To enforce our Terms of Service or any applicable end user license agreement. 

To protect the safety of persons and the rights, property or safety of others. 

For purposes of identifying, verifying, conducting due diligence or getting to know your customers. 

To evaluate and make decisions relating to your credit and risk profile and eligibility for credit products. 

To maintain and manage any software updates and/or other updates and support that may be required from time to time to ensure the smooth operation of our services. 

To process or facilitate customer service, carry out your instructions, process or respond to any inquiries made (or purported to be made) by or on behalf of you. 

To contact or communicate with you by voice call, SMS and/or fax message, email and/or postal mail or otherwise for the purpose of administering and/or managing your relationship with us or your use of our Services, such as, but not limited to, communicating administrative information to you in connection with our Services. You acknowledge and agree that we may make such communications by mailing letters, documents or notices to you, which may involve the disclosure of certain personal data about you to effect the same delivery as well as envelopes/mail packages on the outside cover. 

Allowing other users to interact with you, contact you or view some of your activities on the Platform, including notifying you when other users send you private messages, comment on the Platform for you or use social features to contact you on the Platform. 

To conduct research, analysis and development activities (including, but not limited to, data analysis, surveys, product and service development and/or analysis), to analyze how you use our Services, to recommend products and/or services that are relevant to your interests, to improve our Services or products and/or to enhance your customer experience. 

To allow for audits and surveys to verify the size and composition of the target audience and to understand their experience with carousell' services. 

For marketing and advertising purposes and, in this regard, to send you marketing and promotional information and materials related to products and/or services (including, but not limited to, possible third party products and/or services of carousell) through various media and communications in cooperation or collaboration with products or services that carousell (and/or its affiliates or related companies) may be selling, marketing or promoting, whether such products or services exists now or is created in the future. You may unsubscribe from receiving marketing communications at any time by using the unsubscribe feature in the electronic marketing materials. That we may use your contact information to send newsletters or marketing materials from us and our related companies. 

To respond to legal process or to comply with any applicable law, governmental or regulatory requirements of any relevant jurisdiction or where we have a good faith belief that such disclosure is necessary, including, without limitation, to satisfy disclosure requirements under any law binding on carousell or its related or affiliated companies (including, if applicable, displaying your name, contact information and company details). 

Generating statistical data and research for internal and statutory reporting and/or record keeping requirements. 

Conducting due diligence or other screening activities (including, but not limited to, background checks) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or that we may have in place. 

auditing our services or carousell' business. 

Preventing or investigating any actual or suspected violations of our Terms of Service, fraud, illegal activity, omissions or misconduct, whether or not in connection with your use of our Services or any other matter arising out of your relationship with us. 

Responding to any threatened or actual claims against carousell or other claims that any content violates the rights of third parties.

storing, hosting, backing up (whether for disaster recovery or otherwise) your personal data, whether in your jurisdiction or outside your jurisdiction. 

Processing and/or facilitating a business asset transaction or potential business asset transaction where such transaction involves carousell as a participant or involves only carousell' affiliates or associates as participants or involves carousell and/or any one or more of carousell' affiliates or associates as participants, and where other third party organizations may be involved in the transaction. "Business Asset Transaction" means a purchase, sale, lease, merger, consolidation or any other acquisition, disposition or financing of the organization or a portion of the organization or any business or assets of the organization; and/or 

for any other purpose that we notify you of with your consent. 

(collectively, the "Purposes"). 


6.2 You acknowledge, consent and agree that carousell may access, preserve and disclose your account information and content if required to do so by law or pursuant to a court order or order of any governmental or regulatory authority having jurisdiction over carousell or under good faith circumstances. Such access protection or disclosure is believed to be reasonably necessary to: (a) comply with legal process; (b) comply with the requirements of any governmental or regulatory authority having jurisdiction over carousell; (c) enforce the carousell Terms of Service or this Privacy Policy; (d) respond to any threatened or actual claims against carousell or other claims that any Content violates the rights of third parties; (e) respond to your s customer service requests; and (f) protect the rights, property or personal safety of carousell, its users and/or the public.


6.3 As the purposes for which we will/may collect, use, disclose or process your personal data depend on the current circumstances, the above purposes may not arise. However, we will notify you of such other purposes when we obtain your consent, unless privacy laws permit the processing of applicable data without your consent. 



7. How does carousell protect and retain customer information? 


7.1 We have implemented a variety of security measures and strive to ensure the security of your personal data on our systems. Personal user data is contained behind a secure network and is accessible only by a limited number of employees who have special access rights to such systems. Inevitably, however, absolute security cannot be guaranteed.


7.2 We will retain personal data in accordance with privacy laws and/or other applicable laws. That is, we will destroy or anonymize your personal data when we reasonably determine that (i) retention of such personal data is no longer consistent with the purposes for which such personal data was collected; (ii) retention is no longer necessary for any legal or business purposes; and (iii) there is no other legitimate interest in further retention of such personal data. If you stop using the Platform, or if your permission to use the Platform and/or Services is terminated or revoked, we may continue to store, use and/or disclose your personal data in accordance with this Privacy Policy and our obligations under the Privacy Act. In accordance with applicable law, we may process your personal data securely without prior notice to you. 



8. Does carousell disclose the information it collects from visitors to outside parties? 


8.1 In the course of conducting our business, we will/may need to use, process, disclose and/or transfer your personal data to our third party service providers, agents and/or our affiliates or related companies and/or other third parties, which may be located in the United States or outside the United States for one or more of the items listed above. Such third party service providers, agents and/or affiliates or related companies and/or other third parties will process your personal data on our behalf or otherwise for one or more of the purposes described above. We strive to ensure that third parties and our affiliates protect your personal data from unauthorized access, collection, use, disclosure, processing or similar risks and retain your personal data only for the purposes for which it is needed as described above. 

Our subsidiaries, affiliates and related companies. 

Buyers or sellers with whom you transact or interact on the Platform, or in connection with your use of the Services for the purposes described above.

Other users of our Platform for one or more of the above purposes.

Contractors, agents, service providers and other third parties that we use to support our business. These include, but are not limited to, parties that provide administrative or other services to us, such as post offices, logistics service providers, financial service providers, advertising and marketing partners, telecommunications companies, information technology companies and data centers. 

Governmental or regulatory authorities that have jurisdiction over carousell or are permitted under Section 6.2.

a buyer or other successor in the event of a merger, divestiture, reorganization, restructuring, dissolution or other sale or transfer of some or all of the assets of carousell, whether as a going concern or as part of a bankruptcy, liquidation or similar proceeding, in which personal data held by carousell about users of our services are among the transferred assets; or carousell or any of its affiliates a counterparty to a transaction involving business assets to which the company or a related company is a party; and 

Third parties to whom we disclose personal data for one or more purposes, and who in turn collect and process your personal data for one or more purposes.