Privacy Policy

I. Introduction

1.1 Welcome to the Tokishop platform operated by Tokishop Southeast Asia Limited and its affiliates (individually and collectively, "Tokishop", "we", "us" or "our"). Tokishop takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all users of our Tokishop website and mobile application ("Platform") (we refer to the Platform and the services we provide on our Platform as the "Services"). Users refer to 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 designed to help you understand how we collect, use, disclose and/or process the personal data you provide to us and/or we have about you, whether now or in the future, and to help you make an informed decision before providing us with any of your personal data. 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 an organization has or may have access, whether true or not. Common examples of Personal Data may include name, identification number and contact details. 1.3 By using the Services, registering an account with us, accessing our Platform or accessing the Services, you acknowledge and agree that you are accepting 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 agree 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 those changes or the revised Privacy Policy on our Platform. We reserve the right to amend this Privacy Policy at any time. To the maximum extent permitted by applicable law, your continued use of the Services or Platform, including placing any orders, constitutes your acknowledgement and acceptance of the changes to this Privacy Policy. 1.4 This Policy applies together with other notices, contractual terms, consent terms that apply to our collection, storage, use, disclosure and/or processing of your Personal Data, and is not intended to override those notices or terms unless we expressly state otherwise. 1.5 This policy applies to both buyers and sellers who use 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. 1.5 This policy applies to both buyers and sellers who use 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. 1.5 This policy applies to both buyers and sellers who use the Services, unless expressly stated otherwise.

2. When does Tokishop 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 form, including but not limited to an application form or other forms related to any of our products and services, whether online or in physical form;

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

When you interact with us, such as by telephone (which may be recorded), letter, 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 the services on our platform. This includes, but is not limited to, through cookies we may deploy when you interact with our applications or websites;

When you grant permission on your device to share information with our applications or platforms;

When you connect your Tokishop 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 us with feedback or complaints;

When you register for a competition; or

When you submit your personal data to us for any reason

The above is not exhaustive but lists some common situations where personal data about you may be collected.

3. What personal data will Tokishop collect?

3.1 Personal data that Tokishop may collect includes, but is not limited to:

Name;

Email address;

Date of birth;

Billing and/or shipping address;

Bank account and payment information;

Phone number;

Gender;

Information sent by or associated with the device used to access our services or platform;

Information about your network and the people and accounts you interact with;

Photos or audio or video recordings;

Government-issued identification or other information we need for due diligence, knowing your customers, identity verification, or fraud prevention;

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

Usage and transaction data, including details about your searches, orders, ads and content you interact with on the platform, and other products and services relevant to you;

Location data;

Any other information about users when they register to use our services or platform and while they use the services or platform, and information related to how they use our services or platform; and

Aggregate data about the content that users engage with.

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 to request further documentation at our sole discretion to verify the information you provide.

3.3 If you register as a user of our Platform using your social media account (“Social Media Account”), link your Tokishop account to your Social Media Account or use any Tokishop Social Media Features, we may have access to information you have voluntarily provided to your Social Media Account provider in accordance with the policies of that 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 titled “How can you withdraw consent, request access to or correct information you have provided to us?”. . Please note, however, that opting out or withdrawing your consent for us to collect, use or process your Personal Data may affect your use of the Services and Platform. For example, opting out of collecting location information will result in its location-based features being disabled.

4. Collection of Other Data

4.1 Like most websites and mobile applications, the information sent by your device may include data about you that is logged by web servers when you browse our Platform. 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 available), the pages you visit on our websites and mobile applications and the time of your visit, and sometimes a "cookie" (which can be disabled using your browser preferences) that helps the website remember your last visit. If you are logged in, this information will be associated with your personal account.

4.2 Our mobile applications may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process this information for one or more purposes, including but not limited to location-based services that 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 websites or mobile applications, when you view content and ads and access other software on our platform or through the Services, much of the same information is sent to us (including but not limited to IP address, operating system, etc.); however, your device will not send us information about the content installed on the Services and Platforms, ads viewed and/or software and when, other than page views.

5. Cookies

5.1 From time to time, we or our authorized service providers and advertising partners may use "cookies" or other features that allow us or third parties to collect or share information related to your use of our Services or Platforms. These features help us improve our Platforms and the Services we offer, help us offer new services and features, and/or enable us and our advertising partners to provide you with more relevant content, including through remarketing. "Cookies" are identifiers stored on your computer or mobile device that are used to record data about your computer or mobile device, how and when you use or access the Services or Platforms, how many people, and other activities within our Platforms. We may associate cookie information with personal data. Cookies are also linked to information about the items you choose to purchase and the web pages you view. This information is used to keep track of your shopping cart, deliver content specific to your interests, enable our third-party advertising partners to advertise on sites across the Internet, perform data analysis and 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 this, 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:

Considering and/or processing your application/transaction with us or your transactions or communications with third parties through the Services;

Managing, operating, providing and/or managing your use and/or access to our Services and our Platform (including but not limited to remembering your preferences), as well as your relationship with us and user account;

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;

Enforcing our Terms of Service or any applicable end user license agreement;

Protecting personal safety and the rights, property or safety of others;

For the purpose of identifying, verifying, due diligence or understanding your customers;

Assessing and making decisions related to your credit and risk profile and eligibility for credit products;

Maintaining and managing 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;

Processing or facilitating customer service, executing your instructions, processing or responding to any queries made by (or purportedly made by) you or on your behalf;

To contact or communicate with you by voice call, SMS and/or fax message, email and/or postal mail or other means in order to manage and/or administer your relationship with us or your use of our Services, such as but not limited to conveying to you administrative information relating to our Services. You acknowledge and agree that we may make such communications by posting letters, documents or notices to you, which may involve the disclosure of certain personal data about you to enable delivery of the same and on the outer cover of envelopes/mail packages;

To allow other users to interact with you, contact you or view some of your activities on the Platform, including notifying you on the Platform when other users send you private messages, post comments for you on the Platform or contact you using social features;

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

To allow audits and surveys to verify the size and composition of the target audience and understand their experience with Tokishop Services;

For marketing and advertising and in this regard, to send you marketing and promotional information and materials through various media and methods of communication relating to products and/or services (including but not limited to third-party products and/or services that Tokishop may collaborate or cooperate with) that cgwlcms (and/or its affiliates or related companies) may be selling, marketing or promoting, whether such products or services exist now or are created in the future. You may unsubscribe from receiving marketing information at any time by using the unsubscribe function in the electronic marketing materials. We may use your contact information to send newsletters or marketing materials from us and our related companies;

To respond to legal process or comply with any applicable law, governmental or regulatory request in any relevant jurisdiction or where we have good reason to believe that such disclosure is necessary, including but not limited to meeting disclosure requirements under any law binding on Tokishop or its related companies or affiliates (including, where applicable, to display your name, contact details and company details);

To generate statistics and research for internal and statutory reporting and/or record keeping requirements;

To conduct due diligence or other screening activities (including but not limited to background checks) in accordance with legal or regulatory obligations or as may be required by law or as part of our risk management procedures that we may have implemented;

To audit our services or Tokishop’s business;

To prevent or investigate any actual or suspected breach of our Terms of Service, fraud, illegal activity, omissions or misconduct, whether in connection with your use of our services or any other matter arising out of your relationship with us;

To respond to any threatened or actual claim against Tokishop or other claim that any content infringes the rights of a third party;

To store, host, back up (whether fordisaster recovery or otherwise) your personal data, whether in or outside of your jurisdiction;

Processing and/or facilitating a business asset transaction or potential business asset transaction where such transaction involves Tokishop as a participant or involves only Tokishop’s affiliates or affiliates as participants or involves Tokishop and/or any one or more of Tokishop’s affiliates or affiliates as participants, and there may be other third-party organizations involved in the transaction. “Business Asset Transaction” means the purchase, sale, lease, merger, consolidation or any other acquisition, disposal or financing of an organization or part of an organization or any business or assets of an organization; and/or

Any other purpose we notify you of when we obtain your consent.

(collectively, the “Purposes”).

6.2 You acknowledge, consent and agree that Tokishop may access, preserve and disclose your account information and content if required by law or pursuant to a court order or order of any government or regulatory authority with jurisdiction over Tokishop or in good faith. We believe that such access, protection or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with the request of any government or regulatory authority with jurisdiction over Tokishop; (c) enforce the Tokishop Terms of Service or this Privacy Policy; (d) respond to any threatened or actual claim against Tokishop or other claim that any content violates the rights of a third party; (e) respond to your customer service requests; (f) protect the rights, property or personal safety of Tokishop, its users and/or the public.

6.3 Since the purpose for which we will/may collect, use, disclose or process your personal data depends on the circumstances at hand, the above purposes may not appear. 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 Tokishop 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. User personal data is contained behind secure networks and is only accessible by a limited number of employees who have special access rights to such systems. However, it is inevitable that absolute security cannot be guaranteed.

7.2 We will retain personal data in accordance with the Privacy Act 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 no longer serves the purpose for which it was collected; (ii) retention is no longer necessary for any legal or business purpose; and (iii) there is no other legitimate interest in further retaining such personal data. If you stop using the Platform, or your license to use the Platform and/or the 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. Subject to applicable law, we may dispose of your personal data securely without prior notice to you.

8. Will Tokishop disclose the information it collects from its visitors to external parties?

8.1 In 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, who may be located in or outside Malaysia for one or more of the above purposes. 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 listed 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 as long as your personal data is needed for the purposes listed 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 listed above;

Other users who use our Platform for one or more of the purposes listed above;

Contractors, agents, service providers and other third parties we use to support our business. These include, but are not limited to, parties who 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 with jurisdiction over Tokishop or as permitted by Section 6.2;

A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Tokishop's assets (whether as a going concern or as part of bankruptcy, liquidation or similar proceedings), in which personal data held by Tokishop about users of our services is among the assets transferred; or the counterparty in a transaction involving business assets of Tokishop or any of its affiliates or related companies; and

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