PRIVACY POLICY

Daraz understands that our users care about their personal data and how it is collected, used, shared, protected and cared for. We are committed to handling your personal data in accordance with the applicable laws when you use any of the features and functions available on our Platform or Services, interact with us via an external service, application or through our customer service agents, or access our Services or our Platform through your computer, mobile device, or any other device with Internet connectivity.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CLICKING “SIGN UP” ,”LOGIN”, “I AGREE/CONSENT TO DARAZ’S PRIVACY POLICY”, “I AGREE AND CONSENT TO THE COLLECTION, USE, DISCLOSURE, STORAGE, TRANSFER AND/OR PROCESSING OF MY PERSONAL DATA FOR THE PURPOSE STATED IN, AND UNDER THE TERMS OF THIS PRIVACY POLICY” OR SIMILAR STATEMENTS AVAILABLE AT THE DARAZ REGISTRATION PAGE OR IN THE COURSE OF PROVIDING YOU WITH THE SERVICES OR ACCESS TO THE PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THE TERMS OF THIS PRIVACY POLICY AND THAT YOU HAVE AGREED AND CONSENTED TO THE COLLECTION, USE, DISCLOSURE, STORAGE, TRANSFERAND/OR PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED AND UNDER THE TERMS HEREIN.

1. INTRODUCTION TO THIS PRIVACY POLICY

1.1. Data protection is a matter of trust and your privacy is important to us. This Privacy Policy explains how Daraz, collects, uses, shares, and protects information in connection with the Services or use of the Platform. This Privacy Policy applies regardless of the type of device you use to access our Services.

Depending on your location the Daraz entity controlling your personal data will be;

Sri Lanka – KAYMU LANKA (PRIVATE) LIMITED

Pakistan – JADE E-SERVICES PAKISTAN (PRIVATE) LIMITED

Bangladesh – DARAZ BANGLADESH LIMITED

Nepal – DARAZ KAYMU PRIVATE LIMITED

Myanmar – DARAZ MYANMAR COMPANY LIMITED

(collectively or individually, "Daraz", "we" or "us")

1.2. Where applicable, this Privacy Policy should be read in conjunction with the Country -Specific Riders for your jurisdiction as set out in Section 12 below.

1.3 In the course of you using Daraz's applications and websites (both web and mobile versions), as well as products, information, functions and other services operated by Daraz, we will be collecting, using, disclosing, storing and/or processing data, including your personal data. In this Privacy Policy, Platform shall refer to all relevant applications and websites (both web and mobile versions), and Services shall refer to all products, information, functions and services provided by Daraz from time to time on the Platform(s).

1.4. This Privacy Policy exists to keep you informed of how we collect, use, disclose, store and/or process the data we collect and receive during the co urse of providing the Services or access to the Platform to you, our user, whether or not you have registered to use our Platform as a buyer or a seller. We will only collect, use, disclose, store and/or process your personal data in accordance with this Privacy Policy.

1.5. It is important that you read this Privacy Policy together with any other applicable notices we may provide for special applications, when collecting, using, disclosing and/or processing personal data about you, so that you are fully aware of how and why we are using your personal data.

1.6. We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make and as required by applicable law, such as by posting an amended Privacy Policy on the Platform. Where permissible under local laws, your continued use of the Services or access to the Platform, i ncluding placing Orders (as defined in the Terms of Conditions (for users) and/or Marketplace Agreement (for sellers) on the Platform, or express consent thereto, following the modifications, updates or amendments to this Privacy Policy (whether or not you have reviewed such document) shall constitute your acknowledgment and acceptance of the changes we make to this Privacy Policy. You agree that it is your responsibility to review and check the Privacy Policy frequently to see if any updates or changes have been made to this Privacy Policy.

1.7. This Privacy Policy applies in conjunction with other notices, contractual clauses and consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override them unless we state expressly otherwise.

1.8. All of these terms apply to Daraz's users, whether or not the users have created an account as buyers and/or sellers, unless otherwise stated specifically to apply only to buyers or only to sellers.

2. THE PERSONAL DATA WE COLLECT

2.1. We collect the personal data described below in accordance with applicable local laws and, if and where required, upon obtaining your consent.

2.2. Personal data means any information about an individual, whether recorded in a material form or not and whether true or not, who can be identified from that data (whether directly or indirectly), or from that data and other data to which we have or are likely to have access.

2.3. Depending on your use of our Platform and/or your interaction with our Services (such as when registering for our Services and/or logging into our Platform), you may be asked to provide us with certain information. While you can choose not to provide us with certain information, you might not be able to take advantage of many of our Services and Platform that are provided to you.

The personal data that you may opt to provide to us are as follows:

(a) Identity and Profile Data, which may include your name, date of birth, gender, username and password, email address, telephone number, your interests, and any personal data in any photographs or videos or audio recordings that you upload onto our Platform.

Where you are a seller, we may also collect your company name, address, date of incorporation, and other business-related information (e.g. company registration number, business license, tax information, shareholder and director information etc.).

(b) Account and Transaction Data, which may include your credit card details, bank account details, bank statements, delivery/ billing address, payments and orders to and from you, and other details of products and services that you have supplied to or purchased through the Platform.

(c) Usage Data, such as information about how and when you use the Platform, products and Services or view any content on the Platform, as well as websites you were visit ing before you came to the Platform and other similar statistics.

(d)Marketing and Communications Data, which may include your interests, survey responses, preferences in receiving marketing materials from us and your communication preferences, your preferences for particular products or services, as well as your feedback, chat, email or call history on the Platform or with third party service providers.

(e) Location data, such as when you check for deals near you or the delivery / pick -up status of orders.

(f) Additional information we may request you to submit for due diligence checks or required by relevant authorities as required for identity verification or if we believe you are violating our Privacy Policy or any other terms and conditions.

2.4. We automatically collect and process certain types of information when you use your devices to access our Platform and interact with our Services for the purposes set out herein (Please see section on Collection of Computer Data).

How We Receive Your Personal Data

2.5 During the course of your use of the Platform and our provision of the Services, we may receive personal data from you in the following situations:

(a) When you browse our websites (both mobile and web versions);

(b) When you create an account with us (as buyer or seller or otherwise);

(c) When, as a seller, you list products and/or services for sale on the Platform and conduct transactions with buyers in respect of the sale and purchase of those products and/or services;

(d) When you apply for, subscribe to or otherwise use any of the Services on our Platform;

(e) When you make a transaction regarding the products available on the Platform;

(f) When you activate or use any payment-related functions available on the Platform or provided by our third-party service providers;

(g) When you use any of the features, functions, mini-apps or mobile games available on the Platform or Services;

(h) When you record any user-generated content which is uploaded on the Platform;

(i) When you use the chat function on the Platform;

(j) When you subscribe to our publications or marketing material;

(k) When you enter a competition, promotion or survey;

(l) When you participate in any activity or campaign on the Platform;

(m) When you log in to your account on the Pl atform or otherwise interact with us via an external service or application, such as Facebook or Google;

(n) When any other user of the Platform posts any comments on the content you have uploaded on the Platform or when you post any comments on other users’ content uploaded to the Platform;

(o) When a third-party lodge a complaint against you or the content you have posted on the Platform; and

(p) When you interact with us offline, including when you interact with our outsourced customer service agents.

2.6. We may collect personal data from you, third parties (including but not limited to agents, vendors, contractors, partners and any others who provide services to us, who collect your personal information and/or perform functions on our behalf, or with whom we collaborate, including but not limited to payment service providers, government sources of data, financial services providers, credit bureaus, delivery, marketing and other service partners), our affiliates, or such data may be collected automatically when you use the Platform or the Services, as set out in this section. Please see also Sections 2.12 to 2.16 on the collection of computer data.

2.7. During the course of your use of the Platform and our provision of the Services, you agree that you have provided your consent (whether to us, the third party or our affiliates) to the transfer of your personal data from third parties and/or our affiliates to Daraz for the purposes set out in this Privacy Policy.

2.8. You agree to only submit personal data which is accurate, up-to date and not misleading and to keep it up to date and inform us of any changes to the personal data that you have provided to us. We shall have the right to request for documentation and carry out the necessary checks to verify the personal data provided by you as part of our user verification processes or as required under law.

2.9. We will only be able to collect certain categories of personal data if you voluntarily provide the personal data to us or as otherwise provided for un der this Privacy Policy. If you choose not to provide your personal data to us or subsequently withdraw your consent to our use of your personal data, we may not be able to provide you with certain features or functionality on the Services or access to the Platform.

2.10. In some situations, you may provide personal data of other individuals to us (such as your family members or friends or persons in your contact list), when you use the "Find My Friends" or similar function, or when you add them as recipients or beneficiaries of any use of our Services. You represent and warrant that you have obtained the necessary consent, license and permissions from such individuals to share and transfer his/her personal data to us, and for us to collect, store, use, disclose or otherwise process that data in accordance with this Privacy Policy.

2.11. If you sign up to be a user on our Platform using your social media account or link your Daraz account to your social media account or use certain other social media features, we may access personal data about you which you have voluntarily provided to your social media provider in accordance with the provider's policies and we will manage your personal data in accordance with this Privacy Policy.

Collection of Computer Data

2.12. We or our authorised service providers may use cookies, web beacons, and other similar technologies in connection with your use of the Services or access of the Platform.

2.13. When you visit the Platform through your computer, mobile device, or any o ther device with Internet connectivity, our company servers will automatically record data that your browser sends whenever you visit a website, such as the technical data and usage data . In some Daraz jurisdictions, this information may be considered as personal information under applicable data protection laws. Specifically, this collected information may include IP addresses, date and time of access to the Platform, device type, unique device identification numbers, browser type, broad geographic location (e.g. country or city-level location), browsing patterns and details of how you have interacted with our Platform and Services. In addition, we gather information about the Platform and visitors to the Platform including browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors. Some of this information may be collected using cookies and similar tracking technology, as explained further below. Where we are required by applicable law, we will seek your prior consent to the collection of information using cookies and similar tracking technologies. We also may derive or collect inferences about you based on your buying and browsing activity information and other information we ha ve collected about you.

2.14. This data is collected for analysis and evaluation in order to help us improve our website and the services and products we provide, as well as to help us to personalise the content to match your preferred interests more quickly. The data is also collected to make the Services and the Platform more convenient and useful to you, and to provide more relevant advertising related to market products, services and features to you.

2.15. Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. They allow us to recognise a particular device or browser. Web beacons are small gr aphic images that may be included on our Services and the Platform. They allow us to count users who have viewed these pages so that we can better understand your preference and interests.

2.16. You may be able to manage and delete cookies through your bro wser or device settings. However, certain cookies are required to enable core functionality (such as adding items to your shopping basket), so please note that changing and deleting cookies may affect the functionality available on the Platform or through our Services.

3. USE AND DISCLOSURE OF YOUR PERSONAL DATA

Purpose of Use

3.1. We use and disclose personal data for the purposes described below in accordance with applicable local laws and this Privacy Policy, if required, upon obtaining your consent.

3.2. Depending on your relationship with us (for example, whether you are a buyer, a seller, a visitor to our websites, or a user of our mobile applications), the personal data which we collect from you or via third parties may be used for one or more purposes, as follows:

a) To facilitate your use of the Services or access to the Platform.

b) To administer the online account that you may have set up with us.

c) To conduct analytics, research, business and development:

d) To better understand user experience with the Ser vices and the Platform;

e) To improve the layout or content of the pages of the Platform and customise them for users;

f) To identify visitors on the Platform;

g) To conduct surveys, including carrying out research on our users' demographics and behaviour to improve our current technology (e.g. voice recognition tech, etc) via machine learning or other means;

h) To derive further attributes relating to you based on personal data provided by you (whether to us or third parties), in order to provide you with mo re targeted and/or relevant information;

i) To conduct data analysis, testing and research, monitoring and analysing usage and activity trends; and

j) To further develop our products and services.

k) Legal and operational purposes

l) To ascertain your identity in connection with fraud detection purposes;

m) To compare information, and verify with third parties in order to ensure that the information is accurate;

n) To process any complaints, feedback, enforcement action and take -down requests in relation to any content you have uploaded to the Platform;

o) To produce statistics and research for internal and statutory reporting and/or record -keeping requirements;

p) To store, host, back up your personal data for operational, legal or business purposes;

q) To share personal data in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we satisfy the requirements of applicable data protection law when disclosing your personal data;

r) To prevent or investigate any actual or suspected viol ations of our Terms of Use, Privacy Policy or any of our policies, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us.

s) To perform due diligence checks;

t) To comply with legal and regulatory requirements (including, where applicable, the display of your name, contact details and company details), including any law enforcement requests, requests by any governmental or regulatory authority having jurisdiction over Daraz, in connection with any legal proceedings, or as otherwise deemed necessary by us; and

u) To protect the life, health or personal safety of Daraz's employees, its users and/or the public.

v) Any other purpose to which your consent has been obtained, in compliance with our obligations under applicable laws, including to notify you at the time of obtaining your consent.

3.3. Where you are a buyer and/or you have signed in or registered with us, the personal data which we collect from you or via third parties may be used for other purposes, as follows:

i. Processing your order for products (whether sold by us or a third party seller)

a) To process orders, you submit through the Platform;

b) To deliver the products you have purchased through the Platform. We may pass your personal information on to a third party (e.g. our logistics partner) or relevant regulatory authority, where applicable (e.g. customs) in order to make delivery of the product to you;

c) To update you on the delivery of the products;

d) To provide customer support for your orders, for example, to return products that you have purchased through the Platform; and

e) To verify and carry out payment transactions (including any credit card payments, bank transfers, offline payments, remittances, or e -wallet transactions) in relation to payments related to you, promotions participated in by you and/or Services used by you. In order to verify and carry out such payment transactions, payment information, which may include personal data, will be transferred to third parties such as our payment service providers.

ii. Providing Services

a) To display your name, username or profile on the Platform (including on any reviews you may post);

b) To facilitate the use of the mini-apps available on the Platform and purchases made via these mini-apps;

c) To respond to your queries, feedback, claims or disputes, whether directly or through our third-party service providers;

d) To display on scoreboards on the Platform in relation to campaigns, mobile games or any other activity;

e) To allow other users to identify you (via the "Find my friends" or any other similar function) as a user of the Service, to allow you to find other users and to connect with them on the Platform, and to support the socialising function of the Services (where applicable);

f) To assess your application for loan facilities and/or to perform credit risk assessments in relation to applications for financial services and products, such as credit or loan facilities, insurance or credit cards (where applicable); and

g) To facilitate the integration of third party's loyalty membership programmes (including those supported by sellers or brands) with our Platform.

(iii) Marketing and Advertising

a) To provide you with information we think you may find useful or which you have requested from us;

b) To send you marketing or promotional information about our or third -party sellers’ products and services on our Platform from time to time;

c) To help us conduct marketing and advertising; and

d) To promote the Services and use the information that you give to us, such as user-generated content (including video content) that you can choose to upload or broadcast on our Platform and will be accessible on the Internet and may be shared by the public (the latter of which is not within our control), as part of our advertising and marketing campaigns to promote the Platform.

(iv) Other

a) To know our buyers better; and

b) To conduct automated decision-making processes in accordance with any of the above purposes, which will be carried out in compliance wit h our obligations under applicable laws.