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This Privacy Policy (“Privacy Policy”) describes how SawaUp and its related companies (“us”, “we”, “our” and/or “SawaUp”) collect, use and share Personal Data (as described below) of you (“you”) as the user of our website and of our Services. Terms used in this Privacy Policy not defined herein, shall have the same meanings ascribed to them in our Terms and Conditions. This Privacy Policy also applies to any of our other websites that post this Privacy Policy and shall be read in conjunction with our Terms and Conditions.

By using our Services and/or accessing our website, you are accepting the terms of this Privacy Policy and are consenting to our collection, use, disclosure, retention and protection of your Personal Data, but as described in more detail herein. We reserve the right to amend this Privacy Policy at any time without prior notice to you. It shall be your sole responsibility to review this Privacy Policy periodically and update yourself of any changes that might be made. By continuing to access our website and/or use the Services, you are accepting the terms of this Privacy Policy in full. Should you not agree to the any of the terms in this Privacy Policy, you should stop accessing our website and/or using the Services immediately.

Personal Data that we collect

We may collect Personal Data about you and any devices you use when you use the Services, correspond with us regarding the website or the services provided through it, and otherwise generally access our website for any reason whatsoever. We may also receive Personal Data about you from third party sources which Personal Data we may add to the data we get from your use of our website. “Personal Data” includes any data which may be used to identify or contact you, including but not limited to, your name, address, telephone number, email address, gender, date of birth, nationality, occupation, username and/or other data which may be necessary to create an account with us or use the Services. Personal Data shall not include aggregated data or data that, by itself, does not permit the identification of individual persons. We may automatically collect Personal Data about you and the device you use to access our website, generally whenever you use our website, and when you decide to use the Services.

Personal Data that is transmitted to us may include but is not limited to:

Information which can identify you such as your name, address, telephone number and email address;

Financial data (such as credit card or bank account numbers) when you pay us for the Services;

Postage, billing and other Personal Data used to purchase Services;

Data through a web form or when you correspond with us regarding the Services; and

Additional data required by applicable laws to collect and process an order to authenticate or identify you or to verify the data that we have collected is correct

We will only gather Personal Data that is relevant for the purposes for which it will be used and will not gather excessive or unnecessary personal data and/or Personal Data about you. We will take reasonable steps to ensure that the data that we collect is reliable, accurate, complete, and current, always bearing in mind its intended purpose. You have a responsibility to keep the data that you provide to us updated and we will take reasonable steps to facilitate this.

We may use cookies, web beacons, unique identifiers and similar technologies to collect data about the pages that you view, the links that you click and other actions you may take on our Website, within our advertising or e-mail content.

Our use of your Personal Data

We may use the Personal Data we collect about you to provide you with continuity in services, a personalized experience when you visit our website, to contact you about our website or the Services we provide through it, provide you customer service, a personalized advertising and marketing experience, and detect, prevent, mitigate and investigate fraudulent or illegal activities.

We may therefore use and retain your Personal Data as previously stated and as follows:

to give you access to our website;

operate, maintain, and improve our website and the Services;

to send data including confirmations, invoices, technical notices, updates, security alerts, support and administrative messages;

to communicate about promotions, upcoming events, and other news about goods and services offered by us and our selected partners;

to link or combine user data with other Personal Data;

customize, measure and improve our services; and

to provide you with location-based services (such as advertising, search results and other personalized content using your GPS).

Your Personal Data may be transferred to other group companies or persons acting as our agents (which may be located in a country outside of your country of origin). We will require that any such agree to keep your Personal Data secure and confidential, use it only for the purposes for which your Personal Data is transferred and use it only in accordance with our directions subject always to the provisions of this Privacy Policy.

Your Personal Data may be transferred to any government authority, agency and institution if and as required or permitted by applicable laws and regulations.

We take precautions to protect your Personal Data. We have or may implement policies that forbid our employees or anyone having access to your Personal Data from using or disclosing your Personal Data in an inappropriate or unlawful manner and maintain security measures to safeguard the personal data that it maintains from unauthorized access, misuse, alteration, loss or destruction. We shall not collect, use, disclose or transfer your Personal Data except as described in this Privacy Policy unless you give us your permission to collect, use, disclose or transfer it for other purposes.

Supplemental Personal Data

We may supplement the data we collect about you with data from third parties (such as additional contact data, credit check data and data from credit bureaus, always subject to applicable laws).

Social Media

We may allow you to share data with social media sites. These social media sites may give us automatically access to Personal Data retained by them about you (e.g., content viewed by you, content liked by you and data about the advertisements you have been shown or may have clicked on). You control the Personal Data you allow us to have access to through the privacy settings on the applicable social media site and the permissions you give us when you grant us access to your Personal Data from that social media site. By associating an account managed by a social media site with SawaUp, you are authorizing us to have access to this data, you agree that we may collect, use and retain the data provided by these social media sites in accordance with this Privacy Policy.

Third Party Personal Data

If you give us Personal Data about someone else, you must do so only with their explicit and prior consent. You have to inform them how we collect, use, disclose and retain their personal data according to this Privacy Policy.

Sharing of Personal Data

We may disclose your Personal Data to third parties. This disclosure may be required for us to provide and to provide you access to our Website and the Services, to comply with our legal obligations, to enforce our Terms and Conditions, to facilitate our marketing and advertising activities, or to prevent, detect, mitigate and investigate fraudulent or illegal activities related to our Website. We minimize the amount of personal data we disclose to what is directly relevant and necessary to accomplish the specified purpose. As stated above, we do not disclose your Personal Data to third parties for their marketing and advertising purposes without your explicit consent.

We may disclose your Personal Data for the following purposes:

To help detect and prevent potentially fraudulent and illegal acts, violations of our terms of use and data security breaches and third party service providers who help us to provide the Services through our Website, payment processing services, assist us in providing customized advertising, to assist us with the prevention, detection, mitigation and investigation of potentially illegal acts, violations of our Terms and Conditions of Use, fraud and/or security breaches, bill collection, affiliate and rewards programs, co-branded credit cards and other business operations;

We may share Personal Data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding;

We may share Personal Data for legal, protection, and safety purposes;

to comply with our legal requirements, enforce our Terms and Conditions of Use, respond to claims that a listing or other content violates the rights of others, or protect anyone’s rights, property or safety;

law enforcement or governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability. We will only disclose data we deem relevant to the investigation or inquiry, such as name, city, state, postcode, telephone number, email address, User ID history, IP address, fraud complaints, bidding and listing history;

to credit agencies or bureaus as authorized by applicable national laws (e.g. data on late or missed payments or other defaults on your account that may be reflected in your credit report or file)

We may share data to respond to lawful requests and legal processes. We may share data to protect the rights and property of SawaUp, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use. We may share data in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person. We may share data with those who need it to do work for us. We may also share aggregated and/or anonymized data with others for their own uses. We may disclose your Personal Data to alternative payment providers and its corporate family for the following purposes:

to prevent, detect, mitigate and investigate potentially illegal acts, fraud and/or security breaches, and to assess and manage risk, including to alert you if fraudulent activities have been detected on your PayPal or alternative payment accounts;

to provide customer services or resolve disputes (e.g., billing or transactional disputes); and

to facilitate the processing of payment cards when you pay within our services with a payment card and we use PayPal to process your payment.

If we were to merge with or be acquired by another company, we may share your Personal Data with them in accordance with our global privacy standards. Should such an event occur, we will require that the new combined entity follow this Privacy Notice with respect to your Personal Data. If your personal Data will be collected, used, disclosed or retained for any purposes not covered in this Privacy Notice, you will receive prior notification of the processing of your Personal Data for the new purposes.

Updated Data

We take steps to ensure that the Personal Data we collect from you is accurate and up to date, and that you have the ability to access and make corrections to it which includes reviewing and updating your Personal Data upon request and honoring any statutory right you might have to access, modify or erase your Personal Data. Where you have a statutory right to request access or request the modification or erasure of your Personal Data, we can still withhold that access or decline to modify or erase your Personal Data in some cases in accordance with applicable national laws but will give you reasons if we do so.

Data choices

Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about the services we are providing you and our business dealings with you.

You may send requests about Personal Data to our Contact Data below. You can request to change contact choices, opt-out of our sharing with others, and update your Personal Data.

You can typically remove and reject cookies from our Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Site works for you.

You may sign-up to receive email or newsletter from us. If you would like to discontinue receiving this data, you may update your email preferences by replying to the email or clicking the “unsubscribe” link found in emails we send to you.

Note that if you choose to ‘opt-out’, withhold, block or request that we delete your personal data, you may not be able to receive the benefit of our goods or services.

Contact Data

We welcome your comments or questions about this Privacy Policy. You may also contact us on support@sawaup.com.