Privacy Policy

Last updated 25 October 2023

This Privacy Policy describes how NV Digital Solutions (the “Licensor”) collects and uses the Approved Users’ [i.e. any of Sellercraft Solutions (“SaaS Product”) user’s employees, staff, clients, agents and contractors (including freelancers and collaborators] who are authorised by you as the SaaS Product user (the “Customer”) to use the SaaS Product and if the Customer is a natural person, the Customer. personal data when the Approved Users access and use the SaaS Product.

Collection

When the Customer or Approved Users completes the User Onboarding Steps or otherwise accesses or uses the SaaS Product, the Approved Users provide the Licensor with personal data which the Licensor uses to facilitate the Approved Users’ use of the SaaS Product.

Depending on the nature and use of the SaaS Product, the Approved User may provide information to the Licensor, such as: Approved Users’ name, username, email address, phone number, location, physical address, company name, and payment information such as bank account information or credit card details.

The Licensor may also collect information passively via cookies, such as: authentication and security credential information, device location, device information such as browser type and version, operating system, or time zone setting, network and connection information such as Internet Protocol (IP) address used to connect the device to the internet for authentication and security purposes, to recognise a browser, device, or location, to keep track of any specified preferences, or to conduct research and diagnostic purposes.

Where the Approved Users provide the Licensor with any personal data that does not belong to the Approved Users, the Approved Users warrant that it has obtained the consent of the owner of the personal data before collecting, using, or disclosing such personal data, notified the owner of the personal data that their personal data will be used by the Licensor or similar provider for the purposes of the Approved Users’ use of the SaaS Product, and that such personal data collected is accurate and complete.

Where the Approved Users provide the Licensor with any personal data that does not belong to the Approved Users, the Approved Users warrant that it has obtained the consent of the owner of the personal data before collecting, using, or disclosing such personal data, notified the owner of the personal data that their personal data will be used by the Licensor or similar provider for the purposes of the Approved Users’ use of the SaaS Product, and that such personal data collected is accurate and complete.

Use

The Licensor uses personal data provided by the Approved Users for the purpose of facilitating the Customer’s and/or Approved Users’ use of the SaaS Product. Such purposes include providing the SaaS Product in accordance with the terms of the Licensing Agreement, using the personal data to verify the Approved Users’ login credentials, communication with the Approved Users about the SaaS Product, addressing service or technical issues, providing technical support to the Approved Users, responding to the Approved Users’ queries or instructions, analysis and improvement of the SaaS Product, disputes arising from the use of the SaaS Product, or for keeping such records as may be permitted under any

applicable law.

Sharing

The Licensor will not sell personal data provided by the Approved Users to any third party. Any third parties that the Licensor shares the Approved Users’ personal data with may be located in a different jurisdiction from the Licensor or the Approved Users. The Approved Users acknowledge and agree that their personal data shared with such third parties may be transferred overseas. The Licensor shares personal data provided by the Approved Users for the purposes below. Such personal data is shared in accordance with the terms of this Privacy Policy and as permitted by the applicable data protection laws.

Where the Licensor shares personal data with third parties, such third parties are either subject to corresponding contractual obligations and/or following standards of protection similar to those described herein.

Affiliates: The Licensor may share the Approved Users’ personal data with its affiliates to facilitate the services provided by the SaaS Product, depending on the location in which the Approved Users are located.

Third parties: The Licensor may engage other companies or individuals for its business purposes or operational support in the provision of the SaaS Product. For example, other SaaS product providers, and providers who assist in processing payments, analysing data. Such third parties may be given access to the Approved Users’ personal data for the limited purposes of carrying out the functions which the Licensor engages them for.

Authorities: The Licensor may be required to share the Approved Users’ personal data at the request of relevant authorities or law enforcement agencies to comply with any legal or regulatory requirements which the Licensor may be subject to.

Others: The Licensor may also share the Approved Users’ personal data with any other party to whom the Approved User has provided its consent for disclosure.

Storage and Security

The Licensor is located in Singapore and its affiliates are located in various jurisdictions in the region. The SaaS Product is hosted in the cloud, as provided by the Licensor’s supplier which may be changed from time-to-time in the Licensor’s absolute discretion, and the Approved Users’ personal data is sent to and stored in Singapore when the Approved User uses the SaaS Product. Depending on the scope of the SaaS Product and the Approved User’s interactions with the SaaS Product, the Approved User’s personal data may be accessed from multiple countries.

The Licensor takes all reasonable steps to secure the Approved Users’ personal data against unauthorised access and disclosure. Licensor’s security systems are designed according to the legal and regulatory requirements which the Licensor is subject to. Such systems include physical, electronic, and procedural safeguards. Notwithstanding the aforesaid, Licensor makes no representation or warranty towards the Customer and Approved Users that the personal data stored on its computer systems is secure.

Retention

The Licensor will retain the Approved Users’ personal data for as long as it is necessary in order to provide the SaaS Product to the Approved Users, or as long as it is necessary for the Licensor to retain it for business or record purposes as permitted by law. Personal data will be retained in accordance with the requirements of the applicable law.

Access, Correction, Erasure & Withdrawal

The Approved Users may request the Licensor to gain access to their personal data in the Licensor’s systems, to amend, correct or erase personal data in the Licensor’s systems, withdraw consent to the Licensor’s use of their personal data, and to raise concerns on the use of their personal data. Such requests or concerns can be directed to the Licensor’s Data Protection Officer at [email protected].