Fanno – Privacy Policy

Last updated: 2021-10-21

1. Introduction

Fanno is a marketplace platform which enables traders ("Merchants") to promote and sell goods ("Products") to users of the Fanno website and app ("Buyers"). We are committed to protecting and respecting your privacy and this privacy policy ("Privacy Policy") sets out the basis on which we process any personal data we collect from you, or that you provide to us, if you use the Fanno website and app as a Merchant or Buyer.

Where we refer to “Fanno”, “we”, “us” or "our" in this Privacy Policy, we mean Perceiver Pte. Ltd, a Singapore company with its registered office at 8 Robinson Road, #03-00, Aso Building Singapore (048544). We are the controller of any information processed in connection with this Privacy Policy.

This Privacy Policy does not apply to any processing of your personal data by any Merchants who promote and sell Products via Fanno. Please see the section 'How we share your personal data' for more information.

2. Summary

In this section, we provide a summary of the personal data we collect about you via the Fanno website and app; how we use your personal data; and who we share your personal data with. Please refer to the corresponding sections of this Privacy Policy linked to above for full details.

2.1 What personal data do we collect about you via the Fanno website and app and how do we use it?

If you are a Buyer:

We collect certain personal data needed to facilitate your purchase of Products, the delivery of Products to you by Merchants, and the provision of support to you regarding your order. This includes, for example, your name and address, your card payment details, your purchase history, and any additional information we process when you contact us or the Merchant for support via our website and app or contact us by telephone. We will also collect personal data about your visit and behaviour on our website and app.
We use your personal data to perform our obligations to you, and exercise our rights, under the Fanno Terms of Use for Buyers and to perform our obligations to Merchants under the agreements that we have in place with them. We also use your personal data for our legitimate interests for the purposes of our due diligence, identity verification, fraud prevention and operation of the Fanno website and app.
We also combine and use information that you submit to us, information about how you use the website and app and information that we infer about you to make suggestions and provide a customised experience such as recommending certain products or making promotional offers available to you which we think will be of interest.

If you are a Merchant:

We collect certain personal data about you and your representatives necessary for you to register with and make use of the Fanno website and app, as well as any additional information we process when you chat with us or a Buyer via our website and app or with us by telephone or email. We will also collect personal data about your visit and behaviour on our website and app.
We use your personal data to perform our obligations to you and exercise our rights under the agreement that we have in place with you. We also use your personal data for the purposes of our due diligence, identity verification, fraud prevention and operation of the Fanno website and app.

If you are a Merchant or Buyer, we will process your personal data to optimize and improve the features and functionality of the Fanno website and app.

2.2 Who do we share your personal data with if you use the Fanno website and app?

If you are a Buyer, we will share your personal data with the Merchant you have ordered a Product from, as well as any third party logistics provider to deliver your ordered Products, and payment providers to facilitate your payment of the Product.

If you are a Merchant, we may share your personal data with third party logistics providers and payment providers necessary to facilitate orders from Buyers.

If you are a Merchant or Buyer, we will share your personal data with our affiliates, service providers, and with other third parties in limited scenarios such as in the event of a corporate transaction or to enforce our rights.

3. The types of personal data we collect

3.1 If you are a Buyer, we collect the following information:

Your name, address, post code, telephone number and email address;
Payment details, such as your credit or debit card information or other third-party payment information (such as PayPal), payment authentication code and billing address;
Purchase and transaction history in relation to Products that you purchase from Merchants via the website and app;
Feedback or comments that you provide in relation to a Product or order;
Logistics information in relation to delivery of your Product by a third-party logistics provider on behalf of the Merchant;
Products that you place in your shopping cart and other usage information including content you view and search for in the website and app, how long and how often you use the website and app;
Technical information such as your IP address; app region, language and version; device ID, platform, type, brand, OS version, resolution and carrier; time zone; approximate location (including city, region); and language settings. We use this personal data to administer our website, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our website and app;
Information that we process when you contact us or the Merchant for support through the chat function provided by us via the website and app or by telephone, such as images of a Product or order, enquiries about a Product or order, or your evaluation of our support service;
Information you provide if you choose to participate in one of our surveys, promotions or marketing campaigns;
We infer your attributes (such as age-range and gender) based on the information we have about you;
Information about your visit and your behaviour on our website and app (for example, the pages that you click on). This may include time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or download; and
Information from other sources. If you choose to create or sign-in to your Fanno account using a third party platform (such as Facebook or Google), the third party platform will share information such as your email address and user ID.

3.2 If you are a Merchant, we collect the following information:

The name of your shop, shop logo, your name, whether you are a personal seller, the country your shop is located in, your phone number, your email address and category of Product (for example, clothes, toys etc.), your warehouse information and related business information;
If you are a company, we collect contact details (such as name and phone number) of your legal representative(s) or contact person and identification documents (such as passport or national ID card);
If you are a personal seller, your identification information such as a copy or photo of your government-issued ID card or passport and your bank account information;
Purchase and transaction history information and information on refunds and complaints;
Logistics information regarding shipment and delivery of Products, including by third party logistics providers;
Technical information such as your IP address, device ID, time zone and language settings; and
Information that we process when you contact us or when you interact with a Buyer regarding support through the chat function provided by us via the Platform.

3.3 A word about cookies

Some pages on our website and app use cookies or other tracking technology. We use cookies or other tracking technology in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.
Where we use cookies or other tracking technology on our website and app, we will ask you for your prior consent unless these cookies or technologies are strictly necessary to provide the services you have requested. If you use your browser settings to block all cookies (including essential cookies), or other tracking technology you may not be able to access all or parts of our website and app or to use all the functionality provided through our website and app.
For detailed information on the cookies or other tracking technology we use and the purposes for which we use them, please refer to our cookies policy here: Fanno Cookie Policy.

4. How we use your personal data

4.1 If you are a Buyer, we collect, use and store your personal data listed above for the following reasons:

To provide and administer the Fanno website and app;
To perform our obligations, and exercise our rights, under the Fanno Terms of Use for Buyers and to perform our obligations under the agreements that we have in place with Merchants, where you order Products promoted and/or sold by Merchants via the Fanno website and app. This includes sharing your additional information with Merchants and third-party payment providers for the purposes of fulfilling your order, and sharing your information with third party logistics providers for the purposes of delivery of your Product(s) on behalf of the Merchant;
To provide you with user support regarding your order when you contact us via our website, app or by email, which may include responding to or processing your queries, feedback, claims or disputes;
To maintain and enhance the safety, security, and stability of our website and app by identifying and addressing technical or security issues or problems (such as technical bugs), for risk management purposes and to prevent and respond to abuse, fraud, illegal activity and other potentially harmful content;
To optimize and improve the features and functionality of the website and app, including by monitoring interactions and usage across your devices, analysing how people are using our website and app, and informing our algorithms;
To promote our website and app or third party services through marketing communications or promotions;
To make suggestions and provide a customised experience such as recommending certain products and/or making promotional offers available to you which we think will be of interest (for example, coupons or reductions on courier fees). In order to do this we will process the content viewed on the website and app, including preferences you set (such as choice of language). We also collect information regarding your use of the website and app, e.g. how you engage with the website and app, including how often you use the website and app and how you interact with products we show you, and problems encountered, the products that you like and the words you search. We infer your interests, gender and age for the purpose of personalising our recommendations to you and to send you the promotional offers that may interest you. You can exercise your rights in respect of such profiling as set out in section 9 below; and
To process your messages sent to or received from Merchants to provide the Fanno website and app messaging functionality to perform our contract with you and to investigate and resolve complaints or disputes between Merchants and Buyers. We process such personal data for the purposes of our legitimate interests in investigating and resolving such complaints or disputes between Merchants and Buyers.

4.2 If you are a Merchant, we collect, use and store your personal data listed above for the following reasons:

To provide and administer the Fanno website and app;
To verify your identity for risk management and anti-fraud purposes;
To enable you to manage your Fanno store (including to open or close your store);
To perform our obligations, and exercise our rights, under the agreement that we have in place with you in relation to the Fanno website and app;
To contact you with a view to improving and developing your business on the Fanno website and app;
To maintain and enhance the safety, security, and stability of our website and app by identifying and addressing technical or security issues or problems (such as technical bugs), for risk management purposes and to prevent and respond to abuse, fraud, illegal activity and other potentially harmful content; and
To process your messages sent to or received from Buyers to provide the Fanno website and app messaging functionality to perform our contract with you and to investigate and resolve complaints or disputes between Merchants and Buyers. We process such personal data for the purposes of our legitimate interests in investigating and resolving such complaints or disputes between Merchants and Buyers.

4.3 If you are a Merchant or a third party that uses the Fanno API platform, we collect, use and store your personal data listed above in order to provide and administer the Fanno API platform.

5. Our legal bases and how we process your personal data

We may only use your information when we have a “legal basis” to do so. We use different legal bases depending on why we use your information (in other words, the “purpose” of our processing). These legal bases involve contractual necessity, legitimate interests (ours, yours or those of another party), consent, and compliance with a legal obligation. We consider that the legal bases for using your personal data as set out in this privacy policy are as follows:

Our use of your personal data is necessary to perform our obligations under the Fanno Terms of Use (if you are a Buyer) or our agreement with you (if you are a Merchant). For example, this includes providing and administering the Fanno website and app, and, if you are a Buyer, sharing your information with Merchants and third-party payment providers for the purposes of fulfilling your order.
Our use of your personal data is necessary for complying with our legal obligations. This includes situations where we have obligations to comply with a valid legal request such as an order from law enforcement agencies or courts.
We will also use your personal data where it is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website and app), provided these interests are not outweighed by your interests or fundamental rights and freedoms. Our legitimate interests are:

to provide and administer the Fanno website and app, and to review, optimize and improve the features and functionality of the website and app;
to run, grow and develop our business;
to ensure the security and stability of our website and app, and to prevent and respond to abuse, fraud, illegal activity and other potentially harmful content;
to investigate and resolve complaints or disputes between Merchants and Buyers;
to make suggestions and provide a customised experience such as recommending certain products and/or making promotional offers available to you which we think will be of interest (for example, coupons or reductions on courier fees); and
to carry out marketing, market research and business development.

Whenever we use your information on the basis that it is necessary for legitimate interests, you can object to, and request restriction of, such usage.

We may send you direct marketing messages about features of the website and app and third party Products that we think will interest you. We may also send you promotions or marketing campaigns or events. If required by applicable law, we will process your personal data for direct marketing messages based on your consent. Whenever we use your information based on your consent, you can withdraw your consent at any time with future effect.

6.1 If you are a Buyer, we share your information with Merchants (and service providers acting on behalf of the Merchant such as platform providers who manage orders for a Merchant) and third-party logistics providers to facilitate your order and delivery of a Product from Merchants. Merchants are controllers of this data and their use of it is subject to their own privacy policy. Merchants and logistics providers may be located outside of the European Economic Area, Switzerland and the UK (the "European Region") or the country you usually reside in.

To process your payment, we also share your information with payment providers.

We partner with third party platforms (such as Facebook or Google) to offer you a seamless log-in experience. We share information with these third party platforms when you want to use this feature. For example, if you choose to sign-up or log-in to your Fanno account or store using your account details from a third party platform, we will share certain technical information to facilitate this.

We may also share your information with our affiliates to provide user support to you, as well as with Merchants to the extent necessary to allow the Merchant to initiate communications with you to provide you with user support under limited circumstances regarding your order, including the necessary steps to be taken in a situation when the Product is out of stock.

6.2 If you are a Merchant, we may share your information with payment providers, logistics providers and your independent software vendor as communicated to us, to the extent necessary to facilitate orders of Products from Buyers.

6.3 If you are a Buyer or a Merchant, we will also disclose your personal information to the following third parties or categories of third parties:

We will share your personal data with third party vendors and other service providers that perform services for us or on our behalf, which may include providing professional services, such as legal and accounting services, mailing, email or chat services, fraud prevention, hosting or providing analytics services; and
Our Corporate Group. As a global company, our Services are supported by a number of affiliated entities within our corporate group (“Corporate Group”). We share information with our Corporate Group as necessary to enable them to provide important functions such as cloud hosting, content delivery, security, research and development, analytics, online payments, customer and technical support, and content moderation.

6.4 If you are a Buyer or Merchant, we also share your information in other limited scenarios as follows:

Corporate transactions. Your information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control, or acquisition of all or a portion of our business.
Legal obligations and rights. We may access, preserve, and share your personal data with law enforcement agencies, public authorities, copyright holders, or other third parties if we have good faith belief that it is necessary to:

comply with applicable law, legal process or government requests, as consistent with internationally recognised standards;
investigate potential violations of and enforce our Fanno Terms of Use, agreements with Merchants or any other applicable terms, policies or standards;
to protect the rights, property, and safety of Buyers, Merchants, staff, our business and others, including to protect life or prevent imminent bodily harm. For example, we may provide information (such as your IP address) to law enforcement in the event of an emergency where someone’s life or safety is at risk; or
detect, investigate, prevent, or address misleading activity, copyright infringement, or other illegal activity.

7. Data security and retention

7.1 The security of your information is important to us. We maintain appropriate technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods.

7.2 We retain information for as long as necessary to provide our website and app service and for the purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing our website and app service, and enhancing the safety, security and stability of our website and app service), and for the exercise or defence of legal claims.

7.3 The retention periods will be different depending on the type of information and the purposes for which we use the information. For example, when we process your information to provide you with the website and app service, we keep this information for as long as you have a Fanno account. Where you are a Buyer, this information includes your name, email address, telephone number and purchase history.

8. Our Global Operations and Data Transfers

8.1 We operate a global service. As such, we will need to transfer and store your personal data in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including Singapore where we are based. We have taken appropriate safeguards to ensure that your personal data will remain protected and require our third-party service providers and partners if applicable to have appropriate safeguards as well.

8.2 When we make onward transfers of your information outside of the European Region, we ensure it benefits from an adequate level of data protection by:

relying on European Commission adequacy decisions made under Article 45 of the GDPR (or an adequacy decision made by the Secretary of State in the UK, if applicable), finding that the third country to which the information is being transferred offers an adequate level of data protection; or
using European Commission approved (or ICO approved in respect of transfers outside the UK) standard contractual clauses under Article 46(2) of the GDPR for the transfer of information to all other third countries. For a copy of these standard contractual clauses, please contact us via the details provided in the “Contact us” section below.

9. Your rights

9.1 You have rights and choices (free of charge) when it comes to your personal data. Some of these rights apply generally, while others will only apply in certain circumstances. Depending on the scenario, these rights may be subject to some limitations.

9.2 Access your information. You can ask us to confirm what information we process about you, to provide certain information about the processing, and for a copy of your information. You can exercise your right to access your data by emailing service@mail.fannoshop.com.

9.3 Delete your information. You can delete or ask us to delete some or all of your information. You can exercise your right to delete your information by emailing service@mail.wander-shops.com.

9.4 Rectify your information: You can change or ask us to change or correct your information where that information is not accurate. You can change or correct much of your information through the in-app controls and settings (such as your account or store information).

9.5 Port your information. You have the right to data portability in certain circumstances . This means that you have the right to receive your information in a structured, commonly used, and machine-readable format and to share it with a third party. You can exercise your right of portability by emailing service@mail.wander-shops.com.

9.6 Object to the processing of your information. You also have the right to object to the processing of your information in certain circumstances. The right to object applies when the processing you are objecting to is relying on legitimate interest or public interests as a legal basis. In submitting an objection request, you should explain what specific processing activity you are objecting to and why the processing should be stopped. We will stop the particular processing if we don't have compelling legitimate grounds to continue that processing or don’t need it for legal claims.

9.7 Restrict the processing of your information: You have the right to request the restriction of the processing of your information where (a) you are challenging the accuracy of the information, (b) the information has been unlawfully processed, but you are opposing the deletion of that information, (c) where you need the information to be retained for the pursuit or defence of a legal claim, or (d) you have objected to processing and you are awaiting the outcome of that objection request.

9.8 If you are a resident of France (or French data protection law applies to you), you also have the right to provide us with instructions on the use of your personal data after your death. You have the right to provide instructions on the use (retention, erasure and communication) of your personal data after your death. Those instructions can be general or specific. You can amend or revoke these instructions at any time

9.9 Exercising your rights: To exercise any of the above rights, please contact us by emailing service@mail.wander-shops.com. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details or provide additional information so that we can understand the issue. If you exercise your rights, we will process the personal data provided by you to the extent necessary to deal with your request and to ensure proper documentation.

9.10 We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with a supervisory authority.

10. Contact Us

If you have any questions or complaints regarding this Privacy Policy, you can contact us by emailing service@mail.fannoshop.com. You can also reach Fanno's Data Protection Officer using the same details.

You can also contact us at the following postal address.

If you are based in the United Kingdom, our designated GDPR representative is:

Cosmo Technology Private Limited

2 Temple Back East

Temple Quay

Bristol BS1 6EG

United Kingdom

If you are based in the European Region (other than the United Kingdom), our designated representative is:

Mikros Information Technology Ireland Limited

Mespil Business Centre

Mespil House

Sussex Road

Dublin 4

Ireland

11. Privacy Policy updates

We will notify you of any material changes to this Privacy Policy through a notice provided via the Fanno website and app or by other means. The “Last Updated” date at the top of this policy reflects the effective date of such policy changes.