Privacy Policy

1.General

This App is owned and operated by Spirit Age Technology Limited.

In this Privacy Policy, references to 'we', 'us' or 'our' are references to Spirit Age, and any reference to 'you', 'your' and 'yourself' is a reference to you as an individual who has a relationship with us or is in contact with us.

This Privacy Policy applies to you whenever you provide your personal data to us, including when you access this App (the "App"),or online or access our social media platforms.

Personal data includes any information allowing us to identify you as an individual, for example, your name, your email address or your telephone number. This Privacy Policy provides details in accordance with applicable data protection laws about how we collect, store, use and protect your personal data.

2.Your Privacy

Spirit Age respect your privacy and are committed to protecting your personal data. We will use your personal data in accordance with all applicable laws and regulations that relate to data protection and privacy.

Unless otherwise stated, for the purposes of the applicable data protection laws, Spirit Age are controllers in respect of your personal data collected via this App.

Please note, our supply of products (whether in store or online), our App, our social media and other services we provide are not intended for use by anyone under the age of 18 years old and we do not knowingly collect personal data relating to anyone under the age of 18 years old.

If you are under the age of 18, you are not permitted to use our App.

3.What personal data we collect about you

In order to work closely with you and increase the quality of the sales process, we collect the following types of personal data about you:

• your name and username
• your email address
• your telephone number
• The address of your store(including country, city and specific address)
• Your delivery address (including country, city and specific address)
• Photo of your store
• Photo of your work card
• The type and name of your store
• Your financial information

4.How we obtain your personal data

We may collect or receive your personal data in the following ways:

• when you register an account with us;
• where you provide it to us directly, for example contact us or subscribe to receive our newsletter.

5.How we use your personal data

We will only use your personal data where we are permitted to do so by applicable data protection laws.

We have set out below the purposes for which we may process your personal data, and the legal basis that we rely on to do so:

Where we process information on the basis that it is in our legitimate interests as a business to do so, we will consider your interests also. We will weigh up our business interests with your interests to ensure they are fairly balanced.

6.How long we keep your personal data

We will retain your personal data only for as long as is necessary to fulfil the purposes for which we are using it and where the respective legal basis applies, in accordance with our retention policy.

The period for which we keep your personal data will be determined by a number of criteria, including the purposes for which we are using it, the amount and sensitivity of the information, the potential risk of any unauthorised use or disclosure of the information, and whether we have a legal and/or regulatory obligation to retain it.

7.How we secure your information

We take great care in maintaining the security of our App and your personal data. To ensure that we keep your information secure we use technical security measures such as encryption, access controls, firewalls and logging, and we have organisational security controls in place such as security policies and procedures and third-party supplier risk assessments. To take full advantage of all security features available to you, you should use an up-to-date browser.

8.Who we share your personal data with

We may share your personal data with other members of the Spirit Age group on a need-to-know basis when required for our business to function. Where a legal basis exists to do so, members of the Spirit Age group may also use the personal data we share with them to improve their Apps, for analysis purposes.

We may need to share certain personal data if we receive a request for information from a government department, the police or other enforcement agency. If this happens, we will ensure that there is a proper legal basis for providing your personal information to the organisation asking for it before doing so.

We may also disclose your personal data to certain third-party service providers to carry out certain activities on our behalf. We require any such third parties to treat your personal data as confidential and to fully comply with all applicable data protection laws, and we conduct a full assessment of these third parties' processes and procedures prior to sharing any data. Examples of our third-party service providers include:

• Cloud service providers such [Amazon Web Services (AWS)]. When using our App, we share certain personal data with our cloud service providers to ensure that your data is kept secure.
• IT service providers. We share certain personal data with our IT service providers to keep our systems secure. Each of the external companies we work with has been selected by us for their ability to provide what we need to our required specification, including their ability to handle data (including your personal data) securely and appropriately.
• Email service providers: We share your email to Alibaba email to send verification codeand some events or product push to your email.
• Map service providers [Google Map and Yandex.Maps]. we share store name and store location with our above mentioned map service providers.
• Bonus remitter We share your financial information with the bonus remitter to transfer the bonus to you.

These third-party service providers have access to the personal data needed to perform their functions but may not use it for other purposes. We may use the information we receive from third parties to supplement, improve and add to our database of customer details, for purposes such as fraud prevention.

We may also share your information with other partners when we have your express consent to do so.

9.Where your personal data will be processed

Your personal data may be transferred to, and stored and processed in, one or more countries, including countries which do not provide equivalent protection for personal data.

In these circumstances, we will take reasonable steps and implement appropriate measures to ensure that your personal data is adequately protected in accordance with applicable data protection laws.

These measures generally include:

• where the transfer is to a country that has been deemed to provide an adequate level of protection under applicable data protection laws; or
• where the transfer is otherwise permitted by applicable data protection laws.

10.Your Rights

Under certain circumstances and in accordance with the applicable data protection laws, you may have the right to ask us to:

• Confirm what personal data we hold about you and provide you with a copy of that data.
• Correct any personal data that is inaccurate.
• Remove your personal data where there is no good reason for us to continue to hold it.
• Temporarily stop using your personal data where you are questioning or objecting to our right to use that data (and in other limited circumstances where that right is applicable) based on legitimate interests.
• Stop using your personal data (unless we can demonstrate a valid reason why we need to continue to use that data, for example, in respect of a product warranty).
• Provide you with the personal data that you have provided to us, in a structured and commonly-used electronic format, or transmit that information directly to another company if that is technically feasible. This applies where we are using your personal data on the basis of your consent or because it is necessary to perform a contract with you.

If you have any questions about our use of your personal data, please contact us using the details provided in section 11 below. Please note, our security procedures mean that we may request proof of identity before we are able to disclose your personal data to you or comply with other requests.

11.Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you also have the right to make a complaint to the supervisory authority if you’re not happy with how we’ve handled your personal information.

12.How to contact us

If you have any questions about this Privacy Policy or how we process your personal data, please contact us via the contact details listed below:

13.Changes to this Privacy Policy

The LAST UPDATED text at the top of this Privacy Policy indicates when it was last revised.

Any changes will become effective when we post the revised Privacy Policy on this App’s home page. We recommend that you re-visit this policy from time to time to learn of any such changes.