PRIVACY POLICY

1. Introduction

Thanks for visiting shoppaas!

• Shoppaas (shoppaas, "we") values the privacy of its users. In order to provide better operational services, we will collect and use your relevant information, including:
• Merchants - operate stores using Shoppaas services;
• Consumers - shop at stores powered by Shoppaas;
• Partners - develop applications for merchants to use, create stores on behalf of merchants, recommend potential merchants to Shoppaas, or otherwise help merchants operate or improve their Shoppaas-powered stores;
• Users of Shoppaas applications;
• Visitors - anyone who browses the Shoppaas website or contacts Shoppaas customer service.

This Privacy Policy (this Policy) will explain to you how we collect, use and share this information. If our privacy practices change, we may update this Privacy Policy. If there are any major changes, we will notify you (for example, through the shoppaas backend or email). Your use of shoppaas services or transactions with merchants using shoppaas services means that you accept and agree to this Privacy Policy or our Terms of Service (if applicable).

Generally, we process your information where we need to perform a contractual obligation (for example, to process your payment for a shoppaas platform subscription) or where we or our partners need to use your personal information for business-related reasons (for example, to provide you with services).

We may process your personal information with your consent, in particular where: we are unable to rely on other legal grounds for processing; we have collected your data and your consent has been obtained; or we are required by law to obtain your consent for certain sales and marketing activities. You have the right to withdraw your consent at any time by changing your choices in our communications, unsubscribing from our communications or contacting us.

We believe that you should be able to access and control your personal information, no matter where you are. Depending on how you use our services, you may have the right to request access, correction, amendment, deletion, transfer to other service providers, restriction or object to the use of your personal information (such as direct marketing). If you exercise any of these rights, we will not charge you more or provide you with a different level of service.

If you purchase products from a store powered by Shoppaas and wish to exercise these rights to your purchase information, you will need to contact the relevant merchant directly. We are only a processor that processes information on behalf of the merchant and cannot determine how the information is processed. We will provide merchants with relevant tools and answers to their questions to help them meet your requests.

If you are a merchant, partner, employee or other individual with whom shoppaas has a direct relationship, please submit your data subject request through our online portal (in English). Please note that if you send us a request related to your personal information, we must ensure that it is you before we respond. To do this, we may use third parties to collect and verify identity documents.

If you are not satisfied with our response to your request, you may contact us to resolve the issue. You also have the right to contact your local data protection authority or privacy department at any time. For information on how we respond to such requests, please see the Responding to Data Requests guide.

Finally, because there is no common understanding of the meaning of “Do Not Track” signals, we do not respond to these signals in any particular way.

2. Information from merchants

• If you are a merchant using shoppaas to power your business, we collect and use your personal information to provide you with the use of our platform and its services, and generally to help you better manage your business and your relationship with your customers. We may also use third party service providers to help us review accounts for fraud or other concerns.

What information we collect about you and why

• We collect personal information when you sign up for shoppaas, when you use our platform, or when you otherwise provide us information. In general we need this information for you to be able to use our platform.

What we collect	How we use it
Information you provide us about you and your business, like your name, the name of your staff or other individuals associated with your business, company name, address, email address, and phone number，wechat number.	To provide you with the use of our platform and other related services (e.g., to confirm your identity, to contact you about issues with the platform, to invoice you) To advertise and market products or features to you To comply with legal requirements To prevent fraudulent use of our services
Payment information you provide us, such as your credit or debit card number or your bank account number or other financial information (such as your Paypal account).	To provide you with the use of our platform and other related services To charge for our services to provide you access to third-party payment service
Information about how you access shoppaas websites, your account, and our platform, including information about the device and browser you use, your network connection, your IP address, and details about how you browse our websites and platform. We collect some of this information by using “cookies” or other similar technologies directly from your device.	To provide you use of, and to improve, our platform and other related services (e.g., identifying ways to make our platform easier to use or navigate) To personalize the platform for you (e.g., by showing you apps in our app store that we believe may be useful to you) To advertise and market products or features to you To prevent fraudulent use of our services
If you participate Fast Onboarding Program which a separate agreement will be entered, we collect more specific information you provide us about your business, including your business address, business type, business ID number, bank account information, date of birth (if you are an individual business owner), and in some circumstances, government-issued identification (such as your Social Security Number, Social Information Number, Employer Identification Number or Tax Identification Number) on behalf of our payment partners.	To determine if you are eligible for specific payment methods To help you create your Payments account with third party service providers (such as Payoneer) To conduct fraud and risk monitoring To comply with legal requirements (such as “know your customer”, anti-money laundering, or anti-terrorism laws)
Copies of government-issued and/or a picture of yourself holding your identification that you provide us（such as your business ID Number, Social Security Number, Social Information Number, Employer Identification Number or Tax Identification Number, your personal ID Number if you are an individual business owner）.	If we need to verify your identity (e.g., to protect you against identity theft or fraud) To verify that we are speaking with you if you contact us To help us determine or verify account ownership To comply with legal requirements To provide tax documentation

We also work with companies that provide us with information about merchants or prospective merchants, where permitted by law (for example, to protect against fraud or if we are engaged in marketing activities).

When and why we share your information with others

• In order to better help and support your business, we work with a variety of companies to provide a range of services to support your business. We sometimes share personal information with them to help us provide you with shoppaas services.
• We also share your personal information with others:
• to prevent or investigate suspected fraud, threats to physical safety, illegal activity, or violations of a contract (like our Terms of Service) or our policies (like our Acceptable Use Policy)
• to help us conduct marketing and advertising
• to comply with legal requirements, or to respond to court orders, or other similar government demands
• if we merge with or are acquired by another company
• Additionally, almost every merchant using the shoppaas platform also uses non-shoppaas services to support their business (for example, apps from our app store, sales channels, payment gateways, or shipping providers).
• shoppaas doesn’t control how these services use your personal information, and you should review any other service you use to make sure it meets your privacy expectations. When you choose to use non-shoppaas services, we will tell you what information we will share with that service at your direction, so you can decide whether you want to use the service. You can review what access any app has to your information or your store’s information on the “Apps → click three dots → about” page in the shoppaas admin.

Your rights over your information

• You can review and correct much of your personal information directly through the shoppaas backend. If you are unable to review or correct certain information in the shoppaas backend, please submit a data subject request to our Support Team.
• Because we need your personal information to provide you with our services, we usually save your information while you use shoppaas products or services. If you close your store, stop paying subscription fees or we terminate your account, we will retain the information for three years before initiating the personal information removal process. We do not remove this information immediately because we consider that you may reactivate your account, or there may be litigation or audit needs related to your business. If you contact us and request to delete your store information, we will start the removal process after 90 days unless we are required by law to retain specific information. If you have any questions about this process, please contact our Support Team. Please note that after we anonymize your information, we may use non-identifiable information to improve our services.
• Finally, we do not and will not “sell” your personal information, as that term is used in California law.

Your customers’ information

• In order to power your business, we collect and use personal information about your customers. In general, we only collect and use this personal information as directed by you, and as further described in our Data Processing Addendum. Legally speaking, we are a “data processor” and a “service provider” as these terms are used in European, California and China privacy law. We will never use your customers’ information to independently market or advertise to your customers unless they are also using one of our applications or services directly. We also do not and will not “sell” your customers’ information, as that term is used in California law.
• Because you decide how the personal information of your customers will be used, you need to make sure your customers understand how you (and how we on your behalf) collect and process their personal information. You should do this by, at a minimum, posting a privacy policy on your store that describes the information you collect, how you use it, and who you share it with.
• To help get you started with this, you can check out our privacy policy template through your shoppaas admin. If you are collecting any “sensitive” personal information from your customers (for example, information about health, race, ethnicity, genetics, biometrics, trade union membership, political opinions, philosophical or religious beliefs, criminal history, or sexual interests), you should get the affirmative, express consent from your customers to use and process this information.

3. Information from customers

• shoppaas provides software used by our merchants to run their businesses. If you have visited or made a purchase from a merchant’s shoppaas-powered store, we collect and use information about you on behalf of that particular merchant. We only use this information at the direction of our merchants—they ultimately choose how and why to use your information. If you have questions about how a specific merchant or store uses your information, please visit their privacy policy.

What information we collect about you and why

• Please note that shoppaas will never use your personal information to independently market or advertise to you, unless you are using one of our apps or services directly.

What we collect	What we collect
Information you provide about yourself like your name, billing address, shipping address, email address, phone number, and payment information.	To provide merchants with our services, and enable them to operate their business—e.g., to allow them to complete a transaction, screen orders for fraud and risk, fulfill orders, and contact you with new products or offers
Information about how you access our websites, your account, and our platform, including information about the device and browser you use, your network connection, your IP address, and details about how you browse through our websites and platform. We collect some of this information by using “cookies” or other similar technologies directly from your device.	To provide merchants with our services, and enable them to operate their business (e.g., to provide them with analytics about how many people visit their store, and to help them troubleshoot and improve their store)

When and why we share your information with others

• We use service providers to help us provide services to our merchants. Outside of these service providers, we will only share your information if we are legally required to do so (for example, if we receive a legally binding court order or subpoena), or where a shoppaas merchant instructs us to share information on their behalf. If you have questions about how a merchant or store shares your personal information, you should contact the merchant or visit their privacy policy.

Your rights over your information

• When you visit or make a purchase from a merchant’s shoppaas-powered store, the merchant you're visiting or buying from legally controls your information. As a result, shoppaas doesn’t, for example, decide how long your information is retained because that decision is made by the merchant. This means shoppaas can't help you access, correct, erase, or port your information without being directed to by the merchant. To make a request about your personal information, contact the specific merchant directly. If you make a request to us, we will forward your request to the relevant merchant and help them fulfill your request. If the merchant no longer exists, however, we may be able to assist you directly. We also do not and will not “sell”  customers’ information of merchants, as that term is used in California law.

4. Information from partners

• If you participate in Partner Program (for example, by developing apps or themes for use by shoppaas merchants, by serving as an affiliate that refers potential merchants to us, by helping merchants build or manage their stores, or by providing your service to help our merchants run their business through our Platform ), we collect and use your personal information to provide you with the use of our platform and its services, and generally to help you work with our merchants.

What information we collect about you and why

• We collect the following personal information about you when you sign up as a shoppaas partner or affiliate, or when you otherwise provide us with this information.

What we collect	What we collect
Information you provide about yourself and your business, like your name, company name, address, email address, and phone number.	To provide you with the use of our platform and other related services (e.g., to confirm your identity, to contact you about issues with the platform, to invoice you) To advertise and market products or features to you To comply with legal requirements
Payment information you provide, such as your credit or debit card number or your bank account number, or other financial information (such as your Paypal account).	To process payments from you, or to remit payments to you
Information about how you access shoppaas websites, your account, and our platform, including information about the device and browser you use, your network connection, your IP address, communication with Merchants, and details about how you browse our websites and platform. We collect some of this information by using “cookies” or other similar technologies directly from your device.	To provide you use of, and to improve, our platform and other related services (e.g., identifying ways to make our platform easier to use or navigate) To personalize the platform for you (e.g., by showing you apps in our app store that we believe may be useful to you) To advertise and market products or features to you
Copies you provide of government-issued identification you provide us.	If we need to verify your identity (e.g., to protect you against identity theft or fraud) To verify that we are speaking with you if you contact us To comply with legal requirements

When and why we share your information with others

• We need to share your personal information with companies who help us provide you with our services, and to connect you with merchants that we believe may be interested in your services. We also share your personal information with others:
• to prevent or investigate suspected fraud, threats to physical safety, illegal activity, or violations of a contract (like our Terms of Service) or our policies (like our Acceptable Use Policy)
• to help us conduct marketing and advertising
• to process payments from you, or to remit payments to you
• to comply with legal requirements, or to respond to court orders, subpoenas, warrants, or other similar government demands
• if we merge with or are acquired by another company

Your rights over your information

• You can access and correct a lot of your personal information directly through the shoppaas admin. For information you are not able to access or correct directly within the shoppaas admin, please submit a data subject request through our online portal.
• When you sign up for the partner program you remain in the program until you tell us otherwise. Please submit a data subject request through our online portal if you would like us to delete your personal information. Please keep in mind that after we anonymize your personal information, we will continue to use non-identifiable information to improve our services.
• Finally, we do not and will not “sell” your personal information, as that term is used in California law.

Merchants that use your services

• shoppaas Partners provide a range of critical services to our merchants. When merchants sign up to use your services (for example, when they install an app you have developed), we will provide you with their personal information on the merchant’s instructions. When we do this, we are acting on behalf of our merchants. It is your responsibility to protect our merchant’s personal information and process it safely and securely in accordance with applicable law, our Partner Program Agreement, API License & Terms of Use, any other terms governing other shoppaas services you may use. shoppaas also requires you to provide merchants with a clear and transparent privacy policy to help them understand your privacy practices, and how you use the personal information they provide you. If you develop an app that you would like to list on shoppaas’s App Store, that app will also require a privacy policy before it could be listed. 

5. Information from shoppaas website visitors and support users

• If you visit one of shoppaas’s websites or contact shoppaas support, we generally use your personal information to provide you with the specific service you are using.

What information we collect about you and why

• We collect the following personal information about you when you visit one of our websites or contact shoppaas support:

What we collect	How we use it
Information you provide about yourself, like your name, address, email address, and phone number.	To provide you use of, and to improve, the app or service you are trying to use (e.g., to confirm your identity, to contact you about issues with the platform, to invoice you) To verify that we are speaking with you To advertise and market products or features to you To comply with legal requirements
Payment information you provide, such as your credit or debit card number or your bank account number.	To enable you to make a payment
Information about how you access and use shoppaas apps, websites, and other services, including information about the device and browser you use, your network connection, your IP address, and details about how you browse through our apps and sites, including search terms you may enter. We collect some of this information by using “cookies” or other similar technologies directly from your device.	To provide you use of, and to improve, our websites and related services (e.g., identifying ways to make our platform easier to use or navigate) To personalize your experience using our websites (e.g., by changing the layout of our webpages) To advertise and market products or features to you To provide app developers aggregated analytics relating to their app listing on shoppaas's App Store
Copies of your government-issued identification.	To verify that we are speaking with you if you contact us To comply with other legal requirements

When and why we share your information with others

• We need to share your personal information with companies who help us provide you with our services. We also share your personal information with others:
• to prevent or investigate suspected fraud, threats to physical safety, illegal activity, or violations of a contract (like our Terms of Service) or our policies (like our Acceptable Use Policy)
• to help us conduct marketing and advertising
• to comply with legal requirements, or to respond to court orders, or other similar government demands
• if we merge with or are acquired by another company

Your rights over your information

• You can access and correct a lot of your personal information directly through the shoppaas admin. For information you are not able to access or correct directly within the shoppaas admin, please submit a data subject request through our online portal .
• We believe that you should have the right to access and control your own personal information, no matter where you live. We retain your personal information until you tell us to delete it. Please submit a data subject request through our online portal if you would like to access or request that we delete your personal information. Please keep in mind that after we anonymize your information, we will continue to use non-identifiable information to improve our services. Finally, we do not and will not “sell” your personal information, as that term is used in California law.

6. Where we send your information

• We are a Canadian company, but we work with and process data about individuals across the world. To operate our business, we may send your personal information outside of your state, province, or country, including to the United States and China. This data may be subject to the laws of the countries where we send it. When we send your information across borders, we take steps to protect your information, and we try to only send your information to countries that have strong data protection laws.

Transfers outside of Europe and Switzerland

• If you are in Europe, the UK or Switzerland, your personal information is controlled by our Canadian entity shoppaas Inc. Your information is then sent to other shoppaas locations and to service providers who may be located in other regions, including Canada (where we are based), United States and China. When we send your personal information outside of Europe, we do so in accordance with European law.
• If you are in Europe, the UK or Switzerland, when we send your personal information to Canada it is protected under Canadian law, which the European Commission has found will adequately protect your information. If we then send this personal information outside of Canada (such as to our Subprocessors), this information is protected by contractual commitments that are comparable to those provided in Standard Contractual Clauses.
• If you are in China, your personal information is controlled and processed by our Hong Kong entity, shoppaas Hongkong Limited and may be processed by shoppaas in countries outside of China mainland. When this occurs, it will be done in compliance with the Personal Information Protection Law and local laws. As outlined in this Privacy Policy, shoppaas may also transfer such personal data to third parties (for example, to our Subprocessor), who may in turn store or transfer the data outside of China mainland.
• Finally, while we do what we can to protect your information, we may at times be legally required to disclose your personal information (for example, if we receive a valid court order). 

7. How we protect your information

• Our teams work tirelessly to protect your information, and to ensure the security and integrity of our platform. We follow industry standards on information security management to safeguard sensitive information, such as financial information, intellectual property, employee details and any other personal information entrusted to us. Our information security systems apply to people, processes and information technology systems on a risk management basis.
• We perform annual audits to ensure our handling of your credit card information aligns with industry guidelines. We are certified as a PCI DSS Level 1 compliant service provider, which is the highest level of compliance available, and our platform is audited annually by a third-party qualified security assessor.
• No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of your personal information.
• In the event of any actual or suspected breach or compromise of personal information (a "Data Breach"), we will provide notice by email, posting a notice in shoppaas Admin or in the Partner Dashboard or any reasonably effective communication method in a timely manner, which contains information about: the basic situation and possible impact of the Data Breach, any reasonable actions have been taken or will be taken, any reasonable preventions to mitigate any future Data Breach risk, in accordance with the requirements of laws and regulations. At the same time, we will report the Data Breach to the relevant regulatory authorities whereas it is required in accordance with the requirements of the regulatory authorities.

8. How we use “cookies” and other tracking technologies

We use cookies and similar tracking technologies on our website and when providing our services. 

• Opting out: You can opt out of targeted ads served via specific third party vendors by visiting the Digital Advertising Alliance’s Opt-Out page or the Network Advertising Initiative’s Opt-Out page.

9. For how long do we retain your personal information?

• In general, we keep your personal information throughout your relationship with us. For different types of users (merchants, customers, partners and visitors), please refer to above specified sections.
• In general, we purge personal information 90 days after receiving a merchant or partner deletion request. We also purge personal information from merchant stores 90 days after three years of inactivity.

10. How you can reach us

• If you would like to ask about, make a request relating to, complain about how we process your personal information, please contact shoppaas Support or mail us at one of the addresses below. If you would like to submit a legally binding request to demand someone else’s personal information (for example, if you have a subpoena or court order), please contact legal@shoppaas.com.

If you are located in Mainland China: