PRIVACY POLICY

1. Introduction

Protecting the personal privacy of every customer, vendor, and employee is a crucial part of gaining and keeping your trust in BHINER. (the “Company”, “we”, “us”). We strive to provide a high level of privacy protection across all of our businesses and services and to deploy consistent, rigorous policies and procedures.

This privacy notice applies to the collection and processing of your personal information in relation to

• Your use of our websites, provided under www.bhiner.com, and its fellow subdomain ending with bhiner.com , www.cosplaybhiner.com.
• Your use of our products and other commercial services such as buying agent services , business consulting, dropshipping, and others.
• Your use of our other commercial services, such as interacting with us in relation to our services and products
• Your use of mobile application provided by BHINER.
• Your use of participated in our sponsorship program.

This privacy policy also describes your data protection rights, your rights, and how to exercise them, is set out in below.

2. What information do we collect

We collect your personal data either directly from you while you using our website or application , placing a purchase order, or from our authorized customer services repsentivties, browser through our websites, mobile services, and other channels including our third-party live chat services, such us e.g. Facebook Messenger , Chatra.

This includes

• Basic Personal information e.g., name, delivery address, home country.
• Contact information e.g., address, phone number, email address , social network contacts.
• Payment information e.g., Paypal payment account, bank transfer payslip.
• Membership information e.g., purchase records, rewards points
• Feedback information e.g., feedback, complaint, survey
• Social Network information e.g., Facebook, Twitter, Instagram
• Log data and device information e.g., IP address, cookies
• Tracking information e.g., cookies and similar technologies , Google Analytics, Facebook Pixel

3. How do we use this information, and what is the legal basis for this use?

We process your personal data according to the purposes and limited to what is necessary for the following purposes:

• To fulfil our buying agent services, or take steps linked to the services: this is relevant where you make a purchase on any other products or services from us. This includes:
  • Verifying your identity;
  • Taking payments;
  • Providing customer services, including arrangement of package delivery, processing your delivery arrangements, and arranging the delivery of other products, benefits or services;
  • Processing your enrolment to our VIP program and managing your account;
  • Complying with international courier/customs regulations.
• As required to conduct our business and pursue our legitimate interests, in particular:
  • We will use your information to provide products and services you have requested, and respond to any comments, queries or complaints you may send us;
  • We will monitor use of our websites and online services, and use your information to help us monitor, improve and protect our products, content, services and websites, both online and offline;
  • We will use information you provide to personalise our websites, products or services for you;
  • If you provide a Payapl Account or Bank Transfer Slip as payment, we will also use third parties to check the validity of infromation in order to prevent fraud;
  • We will trace back customer activities to prevent, investigate and/or report fraud;
  • We will use information you provide to investigate any complaints received from you or from others, about our website or our products or services;
  • We will use data of some individuals to invite them to take part in market research;
  • We will process your data for purposes such as accounting, billing and auditing;
  • In some cases, we will also use your data for internal statistical research and analytic purposes;
  • In some cases, we will contact you for product or customer satisfaction surveys.
• Where you give us consent:
  • We will send you newsletters containing news concerning our company and our products, services and special offers.
  • We will send you direct marketing in relation to our relevant products and services, or other products and services provided by us.
  • We will place cookies and use similar technologies in accordance with our Cookies Policy (Section 5) and the information provided to you when those technologies are used.
  • We create your profile for marketing purposes in order to deliver advertisements that match your interests.
  • On other occasions we ask you for consent, we use the data for the purpose which we explain at that time.
  • We will use your feedback on our services/product, include both text and image for social network promotion.
  • We will use profile or image for promotional activities either in our website , application and social network media, e.g Facebook , Instagram.
• For purposes which are required by law:
  • In response to requests by government or law enforcement authorities conducting an investigation.

4. Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your personal data for other purposes, such as those set out above.

You have an unconditional right to opt-out of direct marketing at any time. You can do this by following the instructions in the communications we send you, or by contacting us using the contact details we provided below .

5. Cookies and Other Tracking Services

We also receive and store certain types of data whenever you interact with us. For example, we use "cookies," which are unique identifiers that we transfer to your device to enable our systems to provide features of our services such as personalized advertisements on other websites, provide remote access for you, allow you to visit our website without re-entering your username and/or password, verify that you have the authorization needed for the services to process your requests, personalize and improve your experience, record your preferences, customize functionalities for your devices, and to improve the functionality and user-friendliness of our services. It also helps us to better understand how you interact with our services and to monitor aggregate usage and web traffic routing on our website. Most of the cookies used by us are so-called "session cookies", which will be deleted after your visit. Cookies do not cause any damage on your computer and do not contain any viruses. Most browsers automatically accept cookies as the default setting. You can modify your browser setting by editing your browser options to reject our cookies or to prompt you before accepting a cookie. However, if a browser does not accept cookies or if you reject a cookie, some portions of our services may not function properly.

We obtain certain types of data when your web browser accesses us or advertisements and other content served by us or on our behalf on other websites, such as the Internet protocol (IP) address used to connect your computer to the internet, device ID or token, unique identifier, device type, ID for advertising, referral URL, computer and connection data such as the type of operating system you use, your device information, your software information, browser type, browser language and version, ad data, access times, your browsing history, and your web log information. Our website automatically receives and records your IP address which your browser sent us on our server when you login to our website. We will store your IP address in our user registration databases. We will use your IP address for the following purposes:

• send the most appropriate banners based on geographic area or information derived from your IP address.
• estimate the total number of visitors from specific countries or regions all over the world.
• help to identify customers.

Use of Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies or IP-adress to help the website analyze how users use the site, to monitor and analyze use of our services. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. In case IP-anonymization is activated on this website, your IP-address will be truncated within the area of the member states of the European Union. Only in exceptional cases the whole IP-address will be first transferred to a Google server in the USA and truncated there. The IP-anonymization is active on this website. Google will use this information on our behalf for the purpose of evaluating your use of the website, compiling reports on website activity, and providing us other services relating to website activity and internet usage. The IP-address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also opt-out from being tracked by Google Analytics with effect for the future by downloading and installing: https://tools.google.com/dlpage/gaoptout?hl=en.

Use of Facebook Pixel

Facebook pixel is code that we used on our website. It helps us track conversions from Facebook ads, optimize ads based on collected data, build targeted audiences for future ads, and remarket to qualified leads—people who have already taken some kind of action on our website. It works by placing and triggering cookies to track users as users interact with our website and our Facebook ads. You can opt-out from being tracked by Facebook Pixel in Facebook ads setting page: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.

Use of Mailchimp EDM

Mailchimp is email direct marketing vendor that we used on our website. It works by placing and triggering cookies to track users as users interact with our website or the marketing email we send to you. You can opt-out from being tracked by Mailchimp by clicking the Unsubscribes button provided by Mailchimp every time the maketing email delivered to you. More about mailchimp https://mailchimp.com/

Use of Hotjar

Hotjar is a analysis tool that help us reveals the online behavior and voice of the website users. It works by placing and triggering cookies to track users as users interact with our website. https://hotjar.com/

7. Use of your data for soical network and website contents

With your consent on belows cases, we may use of your data for enriching our website or social network contents:

• Your social network account mentioned/tagged or posted any text or image that directly related to our social network account , included but not limited to e.g. Facebook, Instagram, Twitter
• You have participated in our sponsorship program, with your agreement to provided us product/services review, included but not limited to e.g. Photo, Video, Text
• Your direct review/comment posted on our website, authorized communication channel, including but not limited to e.g. Photo, Video, Text

You have the right to ask us for removing those contact, we will need a short period to implement your requests.

8. Who will we share your personal data with , where and when?

If necessary for the provision of services to you, we will share your data with other service providers who take part in the provision of the respective services to you. This may include:

• Marketing agency / vendor only if you consent us
• International courier/customs upon regulations required
• Government agencies where requested by the respective applicable law

We process your data mainly within Singapore data center. In case of movement of data, we will issue "Data Processing and Transfer Agreement" in advance for your acknowledgement.

Personal data will also be shared with third-party service providers who will process it on behalf of BHINER for the purposes identified above. Such third parties include data processors that we use for the provision of certain services such as enabling our customers to makeing payments, recieve our contact email, etc.

9. What rights do you have?

You have the right to ask us for information about our data processing or for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required to keep by law or when we have compelling legitimate interests in retaining the data.

We will provide you with a copy of your personal data when you (or, in case of children under 16, your parents or representatives) request to do. Please contact us with the contact details below directly.

We shall inform you without delay within 30 days after receiving of the request. This period may be prolonged for a further month, if several data subjects exercise their rights and their cooperation is necessary to a reasonable extent. If we refuse to take action on the request of the data subject, we shall inform you of the reasons for the refusal.

When you are under GDPR regulation (The General Data Protection Regulation of EU), to exercise any of these rights you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.

10. When is it mandatory to provide data to us?

In some cases it may be necessary that you provide us with data, in order for us to enter into a contract with you and to provide you with the services that you request. In such cases we will not be able to submit these services to you without the data.

11. How long will BHINER retain your data?

In general, BHINER will retain your personal data as long as it is needed for the respective purpose of data processing and applicable law then, thereafter, to comply with any applicable recordkeeping provisions. Personal data may also be contained in backup files which we keep for information security purposes and regularly delete when the backup period is over.

Where we process registration data, we do this for as long as you are an active user of our services.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.

12. Privacy of data subjects under the age of 16

Our products and services are not targeted to persons under the age of 16. We do not knowingly collect or process personal data from persons under the age of 16. Please note that if you are under the age of 16, you should not buy or use our product or services and we will not be liable for any lost or damage incurred by the unauthorized disclosure or processing of personal data under the age of 16.

Where we process registration data, we do this for as long as you are an active user of our services.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.

Whom should I contact?

If you have any question about this Policy, or if you would like to exercise any of your rights, or if you have any complaints that you would like to discuss with us, please in the first instance send us your signed and dated request, together with a copy of your identity card. Please be as accurate as possible:

by post to
BHINER
TOS and Privacy
1711 , DongFang GuangChang
JianSheLu Nanhu JieDao , Shenzhen , China

or

by e-mail to privacy@bhiner.com

Contact Us

cs@bhiner.com