1. Introduction

Arcadier recognizes the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy ("Privacy Policy" or "Policy") is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data. If you have any questions regarding this information or our privacy practices, please contact us at hello@arcadier.com

By using or accessing the services provided by Arcadier, registering for an account with us, visiting our website, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you consent to us collecting, using, disclosing and/or processing your personal data as described herein. We may revise this Privacy Policy but the most current version will always be at this link.

Privacy matters, and if you are a marketplace administrator, your merchants and consumers need to understand how you (and how Arcadier) collects and processes their personal information. Accordingly, if you use the services, you agree to post an up-to-date and accurate privacy policy on your marketplace that complies with the laws applicable to your business. You also agree to certain consent from your buyers for the use and access of their personal information by Arcadier and other third parties. In addition, if you are collecting any sensitive personal information from your merchants or consumers, you agree to attain affirmative, express consent from your buyers for the use and access of sensitive personal information by Arcadier and other third parties. To help you get started on creating your own privacy policy and presenting it, Arcadier has a privacy policy field within the administrator portal of the marketplace.

2. Collection of Data from Marketplace Administrators

We collect the following data about our marketplace administrators.

1. Basic information such as name, age, address, email address and phone number,
2. When you connect to us or register an account using an external third-party application, such as Facebook using an application programming interface (API), you will be granting us permission to receive information from these third-party application,
3. IP address,
4. billing information.

We use technologies such as cookies, clear gifs, log files and flash cookies for several purposes, such as to help understand how you interact with our site and services, in order to provide a better experience for all our marketplaces. The information we collect may include,

• - Your Internet Protocol (IP) address,
• - computer/mobile device operating system and browser type,
• - type of mobile device,
• - the characteristics of the mobile device,
• - the address of a referring web site (if any), and the
• - pages you visit on our website and mobile applications and the times of visit.

Arcadier may from time to time, contact you via your email to tell you about new features, solicit your feedback, or just keep you up to date with what is going on with Arcadier and our products, as well as other marketplaces built using our service.

Arcadier works with a variety of third parties and service providers to help provide our customers, marketplace administrators, with our services and we may share personal information with them to support these efforts.

We may also share their information in the following circumstances:

• - To prevent, investigate, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service or any other agreement related to the services, or as otherwise required by law.
• - To help us conduct marketing and/or advertising campaigns
• - To conform to legal requirements, or to respond to lawful court orders, subpoenas, warrants, or other requests by public authorities (including to meet national security or law enforcement requirements).
• - Personal information may also be shared with a company that acquires our business, whether through merger, acquisition, bankruptcy, dissolution, reorganization, or other similar transaction or proceeding. If this happens, we will post a notice on our home page.
• - Arcadier will always ask for your consent before sharing your personal information with third parties for uses other than those mentioned in this section.
• - Arcadier is responsible for all onward transfers of personal information to third parties in accordance with the E.U.-U.S. Privacy Shield Framework, the Swiss-U.S. Privacy Shield Framework, and Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).

3. Collection of Data from Marketplace Merchants

We collect your marketplace merchant's name(s), company name, address(es), email address(es), phone number(s) and payment details (for examples, your billing and credit card details).

We use this information to provide you with our services; for example, to confirm your identity, contact you, provide you with advertising and marketing and invoice you. We also use this information to make sure that we comply with legal requirements.

We collect data about the Arcadier websites that you visit. We also collect data about how and when you access your account and the Arcadier platform, including information about the device and browser you use, your network connection, your IP address and information about how you browse through the Arcadier interface.

We use this information to give you access to and improve the services we provide; a key example being making our interface easier to use.

We collect personal information about your merchants and consumers as they on-board onto your marketplace. This is for the purposes of providing you with our services and so that you can process transactions and better serve your merchants and consumers. Some of these information will be critical to marketplace functionality. One example would be sending confirmation emails to merchants and consumers whenever a transaction goes through your site.

We use some of the information you provide us to conduct some level of automated decision-making - for example, we use certain personal information to help us screen accounts for risk or fraud concerns.

We will also use personal information in other cases where they have given us their express permission.

We collect personal information when they sign up for a marketplace account on an Arcadier powered marketplace, when they access our services or otherwise provide us with the information.

We also partner with third parties who provide us information about merchants or prospective merchants, for example to help us screen out merchants associated with fraud.

4. Collection of Data from Marketplace Consumers

We collect the marketplace administrator's Consumer's name(s), email(s), shipping and billing address(es), payment details, company name(s), phone number(s), IP address(es), information about orders they initiate, information about the Arcadier-supported marketplaces that they visit and information about the device and browser you use.

We use this information to provide our marketplace administrators with the service, including supporting and processing transactions, authentication and payments. We also use this information to improve our services.

We collect this information when they access a marketplace that uses our services, such as when they visit a marketplace administrator's site, sign up for an account on an administrator's site, or place an order on the site.

We also partner with third parties who provide us information about consumers or prospective consumers, for example to help us screen out consumers associated with fraud.

5. Collection of Data from Partners

Partners are individuals or businesses that have agreed to abide by the respective Arcadier Partnership agreements. Partners consist of our custom coders, expert partners, affiliate partners, referral partners and others. These partners work with Arcadier to support or promote the product by (a) providing custom coding services to administrators, (b) developing marketplaces using the Arcadier Application Programing Interface (API) for administrators, (c) providing complementary services to marketplace administrators and (d) referring clients to Arcadier.

We collect your name, company name, website, social media handles, phone number(s), address, business type, email address, and relevant payment details where applicable.

We use this information to work with you, confirm your identity, contact you, pay you and to screen for risk, fraud or other similar types of issues.

Arcadier works with a variety of third parties and service providers to help provide you with our services and we may share this information with them.

Arcadier will also share the contact information you have shared with us with marketplace administrators. This is so that they can work with you, the marketplace adminstrator.

We will also use the information to conduct marketing and/or advertising campaigns.

To conform to legal requirements, or to respond to lawful court orders, subpoenas, warrants or other requests by public authorities (including to meet national security or law enforcement requirements).

Personal information may also be shared with a company that acquires our business, whether through merger, acquisition, bankruptcy, dissolution, reorganization, or other similar transaction or proceeding. If this happens, we will place a notification on our home page.

6. Collection of Data from Arcadier Website Visitors and Support Users

As you visit or browse the Arcadier websites, Arcadier collects information about the device and browser you use, your network connection, your IP address and information about how you browse through the Arcadier website. We also collect personal information by you via any ticketing feature available from any of our websites.

From support calls, Arcadier will also collect your phone number, chat messaging handles and other personal information you provide us during our call, pursuant to our terms of service, we may request additional documentation from you during our call to verify your identity.

We use this information to verify your account, to provide and enhance our Services, including supporting or servicing your account, if applicable, and answer any questions you may have.

We collect this information when you visit the Arcadier website, use services offered on our websites or engage with us either by email, web form, ticket system or post content on or through our websites. We also collect any additional information that you might provide to us.

7. Information from Cookies and Similar Tracking Technologies.

What is a cookie? A cookie is a small amount of data, which may include a unique identifier. Cookies are sent to your browser from a website and stored on your device. We assign a different cookie to each device that accesses our website.

Why does Arcadier use cookies and similar tracking technology? Arcadier uses cookies to recognize your device and provide you with a personalized experience on our websites, or otherwise through the service. We also use cookies as part of the services, for example to operate the shopping cart for our administrator's marketplaces.

We also use cookies to serve targeted ads from Google, Facebook, Bing and other third-party vendors.

Our third-party advertising partners use cookies to track your prior visits to our websites and elsewhere on the internet in order to serve you targeted ads.

To measure performance and engagement, and in communications with you, we may use web beacons, tracking technology and other automated tracking methods on our websites.

8. Third Party Apps.

Arcadier's platform allows administrators to use APIs with third party applications to alter or provide new functionalities in their marketplace. Arcadier is not responsible for and has no control over how these apps function. Merchants ultimately can control which apps they choose to use with their stores, and are responsible for making sure that they do so in compliance with relevant privacy and data protection requirements.

9. Disclosure.

Arcadier will not rent or sell personal data to anyone. We will not disclose your personal data to third parties, except as required in the course of providing our services or for internal reporting purposes as described above. Other than to contractors and affiliated organizations, we disclose personal data only in response to a subpoena, court order or other governmental request, or when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Arcadier, third parties or the public at large.

10. Protection of Data Across Borders.

Transfer of Personal Data Outside the EU/EEA

Arcadier Private Limited is a Singaporean company, we provide services to individuals and companies. Our technology processes data from users around the world. Accordingly, Arcadier might transmit your personal information outside of the country, state, or province in which you are located.

Arcadier complies with the EU GDPR (General Data Processing Regulation), regarding the collection, use and retention of personal information from data subjects in the European Economic Area (EEA). In this regard, we have adhered to the principles of notice, choice, accountability for onward transfers, security, data integrity and purpose limitation, access, recourse, enforcement and liability.

Residents of EEA

If you are located in the EEA and believe that your personal information has been used in a manner that is not consistent with the relevant privacy policies listed above, please contact us using the information below. If your complaint or dispute remains unresolved, you may also contact the International Centre for Dispute Resolution, the international division of the American Arbitration Association (ICDR/AAA). This organization provides independent dispute resolution services, at no charge to you. ICDR/AAA can be contacted at http://go.adr.org/privacyshield.html.

If, after attempting to resolve a dispute through ICDR/AAA, you feel that your concerns about the use of your personal information have not been resolved, you may seek resolution of the issue through binding arbitration. For more information about the binding arbitration process, please visit http://www.privacyshield.gov.

If you are located in the EEA, you have certain rights under European law with respect to your personal data, including the right to request access to, correct, amend, delete, or limit the use of your personal data. If you are a merchant, a partner, a visitor of Arcadier's websites, or a user of Arcadier's support services and wish to exercise these rights, please reach out to us using the contact information below. If you are a buyer and wish to exercise these rights, please contact the merchants you interacted with directly. We serve as a processor on their behalf and can only forward your request to them to allow them to respond.

Additionally, if you are located in the EEA, we note that we are generally processing your information in order to fulfill contracts we might have with you (for example if you make an order through an Arcadier site), or otherwise to pursue our legitimate business interests listed above, unless we are required by law to obtain your consent for a particular processing operation.

11. Data Retention.

In general, we will continue to store archived copies of your personal information for legitimate business purposes and to comply with the law, except when we receive a valid erasure request or, if you are a merchant, you terminate your account and your information is scrambled (anonymized) pursuant to our standard process.

We will continue to store anonymous or anonymized information, such as website visits, without identifiers, in order to hone our service standards.

12. What we do not do with your Data.

We do not and never will share, disclose, sell, rent or otherwise provide personal information to other companies (other than to specific Arcadier marketplace administrators you are interacting with, or to third party apps or service providers being used by the administrators you are interacting with) for the marketing of their own products or services.

If you are an administrator using Arcadier's services, we do not use the personal information we collect from you or your customers to independently contact or market to your customers. However, Arcadier may contact or market to your customers if we obtain their information from another source, such as from the customers themselves.

13. User rights and Controls

Arcadier understands that you have rights over your personal information, and takes reasonable steps to allow you to access, correct, amend, delete, port or limit the use of your personal information. If you are a merchant or a partner, you can update many types of personal information, such as payment or contact information, directly within your account settings. If you are unable to change your personal information within your account settings, or if you are concerned about data collected as you visit Arcadier's websites or use our support services, please contact us to make the required changes. If you are a buyer and wish to exercise these rights, please contact the merchants you interacted with directly. We serve as a processor on their behalf, and can only forward your request to them to allow them to respond. It is important to remember that if you delete or limit the use of your personal information, the Services may not function properly.

14. Security processes in place

We take security seriously, and the security of your personal data is important to us. We follow industry-standard practices to protect the data we collect and maintain, including using Transport Layer Security (TLS) to encrypt information as it travels over the internet. No method of transmission over the internet or electronic storage is completely secure, so Arcadier cannot guarantee its absolute security. Your account information is protected by a password, which you should choose carefully and keep secure. We encourage all users to enable two-factor authentication in for the open-authentication account to further protect their account.

We have a Security Incident Response Team (SIRT) and protocol in place in the event of a data breach. We encourage the responsible disclosure of vulnerabilities of our Services by emailing security@arcadier.com.

15. Data Protection Officer

If you would like to update your personal information, you can update many types of personal information, such as payment or contact information directly within your account settings. If you are a merchant or consumer on a marketplace operated on the Arcadier platform, and would like to exercise your rights to your data, please contact your marketplace administrator to allow them to respond. If you would like to extract or change information that requires Arcadier's support, you can write to hello@arcadier.com. If you would like to contact our Data Protection Officer, please email privacy@arcadier.com.

You can contact the privacy officer in writing at:

Attn: Data Protection Officer

Arcadier,

34 Boon Leat Terrace

Singapore, 271021

16. Data Protection Authority

Subject to applicable law, if you are a citizen or resident of the European Economic Area, you also have the right to (i) object to Arcadier's use of your personal information and (ii) lodge a complaint with your local data protection authority or the United Kingdom Information Commissioner's Office.

United Kingdom Information Commissioner's Office

Wycliffe House, Water Lane, Wilmslow, Cheshire

SK9 5AF, United Kingdom

Telephone: +0303 123 1113

Fax: 01625 524510

Web: https://ico.org.uk/global/contact-us/

17. Children

People under 18 (or the legal age in your jurisdiction) are not permitted to use Arcadier on their own. Arcadier does not knowingly collect any personal information from children under the age of 13 and children under 13 are not permitted to register for an account or use our Services.

If you believe that a child has provided us with personal information, please contact us at hello@arcadier.com. If we become aware that a child under age 13 has provided us with personally identifiable information, we will delete it.