This VinVino Market Privacy Policy applies to the collection, use and disclosure of information in connection with the products and services offered by VinVino Market.

We at VinVino Market ("we", "us") recognize the importance of privacy and the confidentiality of personal information.  VinVino Market ("Platform") is a B2B platform that connects and facilitates the sale and purchase of products and/or services between suppliers (or "Sellers") and buyers (or "Buyers"). The Platform is intended for business transactions and, therefore, is provided only for use by legal entities and individual entrepreneurs, and not for individual or personal use. This Privacy Policy sets out the ways in which VinVino Market collects, uses and discloses information in connection with its use of the platform, including personal information about platform visitors and representatives and employees of Buyers and Sellers ("You"). This Privacy Policy also applies to use of our Platform through a mobile device, either through mobile apps or optimized mobile websites.

If you have any questions or concerns about the use of your personal information, please contact us using the contact details provided in Section 13.«HOW TO CONTACT US» at the bottom of this Privacy Policy. All terms not defined in this document have the meanings assigned to them in the Terms of Use for the Platform, which can be found here.

1. COLLECTION OF INFORMATION

The personal information we may collect about you generally falls into the following categories:

Information you provide to us

If you are a representative or employee of any Buyer or Seller or the sole Buyer or Seller:

• You will be asked to provide certain contact information that is required to register for a platform account on behalf of a buyer or seller, including name, address, phone number, email address, job title, and department;
• You will be asked to provide certain information about your identity, a copy of your corporate or sole trader passport, tax registration, and/or related information about your business, such as your company name, type of business, corporate registration details, and information about your business license;
• If you are a Seller, we will also ask you to provide details of the goods and products you intend to sell through the platform and details of your sales/transactions on VinVino Market;
• If you are a Buyer, we will also ask you to provide details or preferences about goods and products that you may be interested in on the platform and any data or preferences related to your purchases;
• If you are successfully certified by VinVino Market as a blogger or influencer, in addition to the information mentioned above, we may also collect your live videos, your social media account names, and posts or comments made by other users of the platform ;
• In connection with facilitating transactions, purchases and payments on the platform, you will be asked to provide certain payment information. This may include bank account numbers, billing and shipping information, credit/debit card numbers, expiration dates, and security code and tracking information with checks or money orders to facilitate selling and buying, and settling the price of purchasing products or services. that is made or purchased through the platform;
• We will process any information provided to us in connection with disputes or respond to complaints regarding the platform or goods and/or services purchased through the platform. Please note that buyers and/or sellers may submit complaints about products and services on the platform and/or disputes between buyers and sellers to the platform, and in such circumstances we will process the data provided to us by buyers and/or sellers that is relevant to the submitted disputes or complaints. This may include end-user health data (which may include minors, as applicable) of products purchased on the Platform, to the extent that it relates to disputes or complaints that are handled on the Platform, and to the extent that the individual(s) have, provided that their explicit consent to their data is shared with us for the purposes of handling complaints and/or resolving disputes.
• The information you submit to the platform for publication may be made public on the platform and therefore available to any internet user. You must exercise care in deciding what information you provide to us for publication.
• To facilitate your use of the services available on the Platform (including websites and/or mobile applications), we may request access to and you may provide us with content stored on your devices, including, but not limited to, address book contacts, photos, video and/or other files. If you use our communications tools on the Platform (especially in the case of voice communications), we may need to access your camera and/or microphone and may make voice recordings.

Information we collect automatically

• If you contact us (for example, through our customer support chat, phone or email), we may record a copy of your correspondence and may request additional information to verify your identity.
• We will collect contact details and other user information from publicly available sources for the purposes of user verification and user due diligence.
• We will collect detailed information about user activities, transactions, and interactions on the platform, including information relating to the types and specifications of products and services purchased, pricing and shipping information, disputes and complaint records, communication between users, and any information disclosed in any forum discussion or chat.
• From time to time, we may also collect information about existing and potential users, during or in connection with trade shows, industry events and/or other functions, including representative contact names, addresses, phone numbers, fax numbers and email addresses.
• If you visit our platform, we automatically collect certain information from your device. In some countries, including countries in the European Economic Area, this information may be treated as personal information under applicable data protection laws. In particular, this information may include IP addresses, device type, unique device identification numbers, browser type, geographic location, browsing patterns, and details of how you interacted with our platform and the products and services available on it. In addition, we collect statistical information about the platform and platform visitors, including browser software, operating system, software and hardware attributes, pages viewed, number of sessions, and unique visitors. Collecting this information allows us to better understand the visitors who come to our platform, where they come from, and what content is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our platform. Some of this information may be collected using cookies and similar tracking technology, as explained further in Section E.«cookie» below.

Information we receive from third parties

• We may receive personal information about you from social media platforms if you choose to register for a platform account through a social media account. What information we receive will depend on your privacy settings with the applicable platform, but will typically include basic public profile information such as:
• Your username or nickname
• Your profile picture
• Country
• Name of Company
• Contact Information. We may receive personal information about you from third parties who interact with us to assist us in providing verification services, as well as verifying suitable marketing activities and KYC ((know-your-customer) and improve our marketing capabilities. This may include your name, email address, company details and contact information for company representatives.
• If you choose to participate in reviewing or rating products and/or services on VinVino Market, we may receive personal information about you from third parties who work with us to review our services and/or rate us.

2. USE OF PERSONAL INFORMATION

We collect and use your personal information for the following purposes:

• verifying your identity and conducting security, KYC (know-your-customer) anti-money laundering and data verification for setting up user accounts;
• verifying your eligibility to register as a user of the platform in accordance with our Terms of Use here;
• setting up/administering user accounts, including providing login IDs and developing a platform profile;
• providing users with customer service support; respond to inquiries, feedback and manage claims and/or disputes;
• facilitating communication between buyers and sellers through the platform, transaction processing and settlement between buyers and sellers made on the platform, evaluating withdrawal requests from sellers;
• provision of logistics and warehousing services (including, without limitation, announcement of a customs clearance through the platform);
• facilitating customs clearance announcements/applications through the Platform;
• assessment and monitoring of account security and transaction risks of VinVino Market users, detection and prevention of fraud, money laundering and other types of security;
• sending and serving customized marketing and advertising that we think will be of interest to you based on the ways you use the platform, your browsing records and order history;
• performing research or statistical analysis to improve the content and layout of the platform, as well as to improve the offers and services of products on VinVino Market, including, for example, the use of anonymous data for machine learning purposes;
• identifying, developing, marketing and advertising products and services that we think you will value, including across browsers and devices, in accordance with applicable laws. Cookies or other similar technologies may be used to provide you with advertising based on your activities and interests (see section E. «Cookie» below). Where we require applicable law, we will seek your consent prior to sending you communications for marketing purposes;
• if you are a buyer, we will share details of recently viewed products on the platform to enable sellers, their respective affiliates and/or their third party service providers to contact you with details of products and/or services that may be of interest to you.
• when you use services that require access to content stored on and/or features on your devices (including but not limited to address book contacts, photos, videos, microphone and/or camera), we use your photos, videos, contact information in your address book and other personal information to respond to your inquiries, provide you with the services you have requested, and improve our services.

We may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (for example, for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes), if and where permitted by applicable law on data protection.

3. DISCLOSURE OR SHARING OF PERSONAL INFORMATION

We may disclose (or make available) personal information to the following categories of recipients:

• Other users of the platform, where appropriate, in connection with the promotion of purchases and communications made between you and other users.
• Third party business partners, service providers and/or VinVino Market affiliates engaged by us or working with us to help us provide services to you, or who otherwise process personal information for the purposes described in this Privacy Policy or notify you when we we collect your personal information.

The categories of these partners or service providers include:

• VinVino Market members and their respective affiliates and/or their designated service providers who work with us to provide processing services such as software, tools, systems and messaging services for the purposes described in this Privacy Policy;
• Our business partners (for example, to provide you with discounts or offers that may be of interest to you);
• Marketing and advertising platforms such as Google, Twitter, Facebook and Instagram and user behavior analytics providers to tailor the content you see when you visit our platform. These platforms may combine the information they collect on our platform with data on their platforms and data they collect on other websites or through other sources to deliver targeted advertising. The processing of these third party marketing platforms is governed by their own privacy policies and not by this privacy policy;
• Payment service providers who collect and process personal information to assist in the settlement of transaction fees or withdrawal requests for merchants. Payment service providers may be governed by their own privacy policies and not by this privacy policy;
• Credit risk assessment providers to conduct risk assessments on merchants to determine whether a merchant may be allowed to make a withdrawal;
• Logistics partners to provide shipping services to buyers, including product returns and exchanges, and warehouse services for sellers;
• Agents for the purposes of customs procedures
• Cloud computing service providers to provide cloud storage services;
• Customer Service Providers to provide after-sales services;
• Risk control service providers to assess the security of user accounts and transaction risks;
• Third party rating/review service providers to conduct reviews of our services with customers if you choose to participate in the review or evaluation of VinVino Market products and/or services;
• To our professional advisors, law enforcement, insurers, governmental, regulatory and other entities where we believe it is necessary to comply with applicable laws or to exercise, establish or defend our legal rights or protect our vital interests or any other person, We may also disclose and share your personal information or as otherwise required or permitted by applicable laws.
• To an actual or potential buyer (and its agents and consultants) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer that it shall only use your personal information for the purposes disclosed in this Policy privacy.
• To any other person with consent to disclosure.

We may provide aggregated or anonymous data to third parties, but when we do so, the information we share is in a segregated format that does not personally identify you.

We have established relationships with third parties and websites to offer you products and services that we do not offer, and such third parties and websites include the following VinVino Market affiliated platforms or their operators. We offer you access to these other parties and their websites, either through the use of hyperlinks to those sites from our platform, or through the "co-branding" offer. Sites where we and other parties share the same Uniform Resource Locator (URL), Domain Name or pages in an Internet domain name. In some cases, you may be required to provide personal information in order to register or apply for products or services provided by such third parties or brand partners. This privacy policy does not apply to these third party sites or collaborative sites. The privacy practices of other parties may differ from ours and we do not control the information you provide to these third parties. You should read the respective privacy policies for these third party and co-brand sites before responding to any offers, products or services advertised by those parties.

4. RETANTION

We retain your personal information when we have an ongoing legitimate business need, such as to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws.

When there is no ongoing legitimate business need for us to process your personal information, we will either delete or anonymize it, or if this is not possible (for example, because your personal information is stored in backup archives), then we will securely store your Personal Data, isolating them from any further processing until removal is possible.

5. COOKIE

This section explains how we use cookies and similar technologies (collectively referred to as «cookie»), to recognize you when you visit our platform. It explains what these technologies are, why we use them, and your rights to control them.

What is cookie?

A cookie is a small amount of data that is sent to your browser and stored on the hard drive of your computer or mobile device. Unless you deactivate and delete the cookie, each time you use the same browser or mobile device to access the platform, our web servers will be notified of your visit to the platform and in turn we may know about your visit and your usage pattern.

Cookies set by the website or application owner (in this case, VinVino Market) are called «First hand cookies». Cookies set by parties other than the website owner are called «third party cookies». Third Party Cookies allow the provision of third party features or functionality on or through the Website (such as advertising, interactive content and analytics). The parties that set these third party cookies may recognize your device both when you visit the website in question and when it visits certain other websites.

Cookies can also be classified as session cookies (which are erased when the browser is closed or the device is closed) and persistent cookies (which remain even after the browser is closed or the device/application is turned off and which are activated each time you visit the Platform). Session cookies use encrypted data for authentication. Persistent cookies do not store account numbers or passwords. We use both session and persistent cookies.

Why do we use cookies?

We use first and third party cookies for several reasons. Some cookies are required for technical and/or security reasons in order to use our platform and we refer to them as «essential » or «strictly necessary» files cookie. The first part of the cookie is mainly provided to provide basic functionality on our platform; including Web Analytics cookies that help us understand how users use our web pages and how we can improve their experience. For example, we use necessary or strictly necessary cookies so that we can remember items added to your VinVino Market shopping cart and recognize you when you log into your VinVino Market account.

In addition, we also use social media cookies. You can register for a platform membership and «to share» platform content through social networks such as Facebook and Twitter. Sometimes we embed videos from sites like YouTube. These websites have their own privacy policy which governs their use of the information you can find on their respective websites.

We also use cookies to enable us to track and target the interests of platform visitors to improve our platform experience by learning visitation patterns and deliver interest-based advertising; help our partners track visits of platform users; and track progress and participation in promotions. We use first and third party cookies for these purposes.

Cookie we use

The specific categories of first and third party cookies served through our platform and the purposes they serve are described in the table below (please note that the special cookies served may vary):

What about other tracking technologies, like web beacons?

Cookies are not the only way to recognise or track visitors to our Platform. We may use other, similar technologies from time to time, like web beacons (sometimes called «tracking pixels» or «clear gifs»). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Platform or opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Platform to another, to deliver or communicate with cookies, to understand whether you have come to our Platform from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

 How can I control cookies?

You can determine if and how a cookie will be accepted by configuring the privacy setting of the browser you are using to access the Platform or the «privacy setting» of your device. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser's help menu for more information. If you adjust the privacy setting in the browser, your device will continue collecting data unless you adjust the privacy setting of the device, and vice versa.

You have the right to decide whether to accept or reject cookies. If you choose to set your web browser controls to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted.

Certain features of the platform depend on cookies. Please be aware that if you choose to block cookies, you may not be able to log in or use these features, and preferences that rely on cookies may be lost.

Google Analytics (more information) which our platform uses is a web analytics service provided by Google, Inc. («Google»). Google cookies allow us to analyze the use of the platform by telling us which pages our users are viewing, which are the most popular, what time of day our platform is visited, if users have previously visited our platform, from which website users are redirected to our Platform and the like. The data generated by the cookie about how you use the platform will be transmitted to Google and stored by Google on its servers.

The platform uses an IP anonymization tool so that IP addresses are truncated within the territory of the Member States of the European Union and other members of the Agreement on the European Economic Area. The raw IP address is exclusively transmitted to Google's servers and then truncated there.

Google uses the data on behalf of VinVino Market to evaluate the use of the platform, to compile reports on the website for the website operators and for other websites and services on the use of the Internet. Google may disclose this information to third parties as required by law or for further processing by third parties on Google's behalf. For more information about Google Analytics cookies, visit:

• Google Help Policy and Privacy Policy: Google Privacy Policy: and
• Google Analytics Help Center: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

The IP address that your browser transmits to Google Analytics will not be associated with any other data stored by Google. Through your browser settings you can block cookies; However, this may result in problems using some of the website's features. Thanks to the addition «Google Analytics Off-Out» you can use your current web browser to use Google Analytics since then: http://tools.google.com/dlpage/gaoptout?hl=en. get more information, which can also be found here:https://support.google.com/analytics/answer/6004245

6. MINORS

The Sites and their content are not intended for minors (under the age of 18) and we do not intend to sell any of our products or services to minors. If a minor has provided us with personal information without the consent of a parent or guardian, the parent or guardian must contact VinVino Market to delete the information.

7. SECURITY MEASURES

We use commercially reasonable security practices to prevent unauthorized access to the Sites, to maintain data accuracy, and to ensure that the information we provide is used correctly.

For registered users of the site, some of your information can be viewed and edited through your account, which is password protected. We recommend that you do not disclose your password to anyone. Our staff will never ask you for your password in an unsolicited phone call or in an unsolicited email. If you share a computer with others, you should not store your login information (such as user ID and password) on that shared computer. Remember to log out of your account and close your browser window when you end your session.

No data transmission over the Internet or any wireless network can be guaranteed to be secure. As a result, while we attempt to protect the information we hold for you, we cannot guarantee the security of any information you transmit to us and you do so at your own risk.

8. CHANGES TO THIS PRIVACY POLICY

We may update this privacy policy from time to time in response to changes in legal, technical or business regulations. When we update our Privacy Policy, we take appropriate steps to notify you of the significance of the changes we make. We will obtain your consent to any material changes to the privacy policy if and where required by applicable data protection laws. Any changes to this Privacy Policy will be communicated by us through the posting of the amended privacy policy on the Platform. Once posted on the platform, the new privacy policy will take effect immediately. You can see when this privacy notice was last seen and updated by checking«Last update», date displayed at the top of this Privacy Notice.

9. VISITORS FROM THE EUROPEAN UNION

If you are using our platform or services covered by this Privacy Policy from a country that is a member state of the European Union or from the United Kingdom, FN Fusion B.V. is the data controller of your personal information. For contact information, see Section 13.«HOW TO CONTACT US»; below.

10. LEGAL BASIS FOR DATA PROCESSING

We process personal information for the purposes set out in this Privacy Policy as described above. Our legal basis for processing personal information will depend on the relevant personal information and the specific context in which we collect it. However, we generally collect and process personal information about you only where it exists:

• necessary for the provision of services in accordance with the agreement between you and VinVino Market FN Fusion B.V. and/or its affiliates (for example, providing you with the services you request and identifying and verifying you so that you can use the platform);
• legal requirements must be met (for example, to comply with applicable accounting rules and for mandatory disclosure to law enforcement authorities);
• necessary for our legitimate interests and not overridden by your rights; and/or
• where it is based on your consent.

Where we collect and use your personal information based on our legitimate interests (or those of any third party), that interest will generally be to use our platform and services, manage our relationship with you, and we will communicate with you as necessary to provide our services for you and for our legitimate business interest, such as responding to your inquiries, improving our platform and our services, marketing, or for the purposes of securing our platform and services and detecting or preventing illegal activities such as fraud with questionnaires. We may have other legitimate interests and, if necessary, we will notify you at the appropriate time.

If we ask you to provide personal information to comply with legal requirements or enter into a contract with you, we will clarify this at the appropriate time. We will tell you if providing your personal information is mandatory or not (as well as the possible consequences if you do not provide your personal information). In some cases, you may be required to provide us with personal information for processing as described above in order for us to provide you with all of our services and to use all of the features of our platform.

If you have questions or additional information regarding the legal basis for which we collect and use your personal information, please contact us using the contact details provided in section 13.«HOW TO CONTACT US»; below.

11. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

In connection with our provision of the Platform and its connected services, we may transfer your personal information to countries outside of your country. We take appropriate steps to ensure that the recipients of your personal information are bound by confidentiality obligations and we take appropriate measures to ensure that your personal information is protected in accordance with this Privacy Policy, such as standard contractual clauses. A copy of these clauses can be requested at info@vinvino.market.

12. YOUR RIGHTS

As a user of the platform, you have the following data protection rights, which you can exercise at any time by contacting us using the contact details provided in section 13.«HOW TO CONTACT US»; below:

• The right to access, correct, update or request deletion of your personal information.
• The right to object to the processing of your personal information where it is based on our legitimate interests, and separately the right to object to direct marketing.
• The right to ask us, in certain situations, to restrict the processing of your personal information or to request the portability of your personal information.
• If we have collected and processed your personal information with your consent, then you have the right to withdraw your consent at any time. Changing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

We respond to all requests we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws.

If you are aware of changes or inaccuracies in your information, you must notify us of such changes so that our records can be updated or corrected.

13. HOW TO CONTACT US

If you have any queries, questions or concerns about our use of your personal information and this privacy policy, please contact us at info@vinvino.market.