INTRODUCTION

We recognize the importance of privacy as well as the importance of maintaining the confidentiality of personal information. This Privacy Policy describes and gives you clear and comprehensive information about the data that is collected from you, and provides an explanation of how and why we collect, use and  disclose information in relation to users of the Sites. This also applies to use of our services and products via a mobile device, ...

INTRODUCTION

We recognize the importance of privacy as well as the importance of maintaining the confidentiality of personal information. This Privacy Policy describes and gives you clear and comprehensive information about the data that is collected from you, and provides an explanation of how and why we collect, use and  disclose information in relation to users of the Sites. This also applies to use of our services and products via a mobile device, either through mobile applications or mobile-optimized websites.

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. Please refer to the "Last Updated" date at the bottom of this page to see when this Policy was last revised. Any changes to this Privacy Policy will be communicated by us posting an amended Privacy Policy on the Sites. Once posted on the Sites, the new Privacy Policy will be effective immediately. We may also notify you about significant changes by email, using the address you last provided or by posting an alert which will be displayed when you access our systems. This Policy is not intended to override the terms of any contract that you have with us or between buyers and suppliers (or any rights you might have available under applicable data protection laws).

COLLECTION OF INFORMATION

"Personal data" means any information relating to an identified or identifiable person. This includes, for example, contact data such as name, telephone number, address or email address; as well as other information that you provide to us for example, during registration, as part of an inquiry or when participating in competitions or surveys and the like.
Any handling of personal data, including in particular, the collection, storage, administration, use, transmission, disclosure or deletion of your data, is considered "processing".
Your data will only be used for the respective purposes which are communicated to you in this data protection Privacy Policy declaration. We take the necessary precautions to protect your personal data from loss, theft and misuse.

Personal Data We Collect:

• Contact and Communication Details
• This includes your name, addresses, telephone numbers, email addresses, and social media contact details will be collected at the time of user registration on the Sites.
• If you are registering through social media platforms such as Facebook or Twitter, we may collect your account name and profile photo at those platforms
• If you choose to answer our supplemental questionnaires, we may also collect marital status, nationality, gender, date and/or year of birth, annual income, monthly spending and user preferences. If you prefer not to provide such information, the use of our services and products will not be affected.
• Job title, role, company name, and company demographics, i.e., number of employees, turnover, etc. Please note that contact details typically are work related since our mission is to facilitate B2B trade.
• If you are registered as a seller or service provider, in addition to the information mentioned above, we may also collect your identity information, tax registration number and information about your business, such as the information about your business license.

In the course of the registration process, request forms or the downloading of files, registration for a newsletter and participation in a competition or prize drawing, we collect personal data from you such as first and last name, address, email address; and other data such as telephone numbers or date of birth, as well as all data voluntarily entered by the registered user in his user profile. 
We use this data to process the inquiries received, to enable and check your access, as well as to notify and/or publish the winners of competitions and prize drawings. As a basis for access to online products, data on individual usage behaviour is also collected and evaluated in order to improve our

• products. Your data will also be used for customer care, and for personalised marketing purposes (e.g. pop-ups).
• Preferences
• Marketing preferences inferred from subscriptions to product/supplier alerts, print and eMagazines and Trade Show news.
• Display and language preferences
• Communications
• Details of calls/messaging made between:
• Customer service team members and visitors and advertisers/exhibitors
• Sales Team members and advertisers/exhibitors or prospects
• Advertisers/exhibitors and online visitors sent through Message Center
• Advertisers/Exhibitors and online visitors
• Buying & Payment History
• What sample requests or other orders placed between advertisers and site visitors
• What seminars/events booked at Trade Shows
• What print and eMagazinessubscribed to
• In connection with any transaction and payment services, or services under our buyer protection schemes, information, including but not limited to, bank account numbers, billing and delivery information, credit/debit card numbers, expiration dates and security code and tracking information from cheques or money orders may be collected to facilitate the sale and purchase as well as the settlement of purchase price of the products or services transacted on or procured through the Sites
• Device and Log Information
• The internet domain and IP address from where you access our websites and apps.
• The type of browser software and operating system used to access our websites and apps.
• The date and time you access our websites and apps
• If you linked into our websites and apps from another website, the address of that website (referrer URL), and:
• The pages you enter, visit and exit our websites and apps from
• Your account log-in/online identifier
• Unique device identifiers (such as the address of the device's wireless network interface (MAC Address), or mobile phone number used by the device)
• Online Behavioral Data
• We use Cookies and other tracking technologies to capture activity on our sites, such as:
• Session frequency
• Search terms used
• Pages visited and how they were accessed (for path analysis)
• Products /suppliers inquired on or profiles viewed
• Whitepapers downloaded
• Apps downloaded
• We record details of users’ activities on the Sites. Information relating to such transactions (including, but not limited to, the types and specifications of the goods, pricing and delivery information, any dispute records and any information disclosed in any discussion forum)  may be collected when transactions are conducted on or facilitated through the Sites.
• While this information itself does not hold personal identifiers, it may be linked to profile data and used for behavioral profiling (see our Cookie Policy for further details about cookies).
• Offline Behavioral Data
• Trade shows, exhibitions, and conferences visitors attended
• Exhibitors visited (captured through Global Sources Buyer App)
• Summits/seminars/events attended
• The information we may collect at these events includes, but not limits to, user name, address, phone number, fax number and email address.
• Certain data we collect may be defined as personal data under applicable data protection law (“Personal Data”). 

Means of Data Collection

At Trade Shows, Roadshows, Seminars and Conferences

• Registration Forms
• We ask visitors to register their attendance by completing a form which we then enter into our systems.
• Check-In updates
• We ask visitors to update/complete data retrieved from previous registrations held in our system.
• Business Cards
• We scan and store details of visitors’ business cards.
• Booth Visit History
• Exhibitors use App to scan visitors’ badges when visitors call at their booths. Visit data is then uploaded to our servers.

Through Website Forms

• Registration & Inquiry Forms
• We ask visitors to our online sites to register in order to personalize and use the site’s messaging functions. We support both a full and a lite registration mode that captures minimal data. Additionally, we have a self-registration function for suppliers who wish to register as an advertiser on our site.
• Subscription Forms
• We capture details of site visitors’ subscriptions and preferences to services such as Notifications, Product/Supplier Alerts, Print Magazines, and eMagazines.
• Sample/Small Order Forms
• We capture details of sample and small orders placed by visitors to advertisers on the site.
• Private Sourcing Events
• We capture basic details of buyers interested in applying for our Private Sourcing service.

Call Center Activities

• Telemarketing
• We periodically contact people and seek information for market surveys and research questionnaires or to qualify prospects for our services or those of our advertiser community, e.g., to qualify potential:
• visitors to our shows and/or online sites, or
• advertisers/exhibitors to our shows and/or online sites
• Customer Service
• Online users, and Trade Show visitors and potential advertisers contact us for enquiries, complaints, suggestions or feedback through our Customer Service Team via online chat system, hotline, fax or email.
• Additionally, there are small numbers of potential advertisers who call in. Their details are qualified and entered into our systems.

Systems Tracking Functions

We use Cookies and other related technologies on our sites. To the extent that information collected through Cookies and similar technologies constitutes personal information, the provisions in our Cookie Policy apply and complement this Privacy Policy.

Other Sources - (Show directories, Association Membership Data, etc)

We collect data from other sources, such as public databases, joint marketing partners and other third parties including third party software applications and social media platforms. The data collected through these third party sources will be combined with information we collect through our services where this is necessary to help manage our relationship with you.

USE OF PERSONAL DATA

We use the data to provide you with our products and services, to develop new offerings and to protect our visitors, exhibitors, buyers, suppliers and advertisers as detailed below. In some instances, we will request that you provide data to us directly. If you do not provide the data that we request, or prohibit us from collecting such data, we may not be able to provide the requested products and services.

We use the data for our legitimate business interests, including the following:

• Verifying your identity;
• Processing your registration as a user, and maintaining and managing your registration;
• Providing you with customer service and responding to your queries, feedback, claims or disputes;
• Facilitating communication between buyers and sellers on the Sites, processing transactions and payments, assessing advance withdrawal requests from sellers and providing delivery services;
• Assessing account security and transaction risks of members, detecting and preventing fraud and other security incidents;
• Personalizing our communication with you based on your browsing records, equipment information we collected and your order history, and performing research or statistical analysis in order to improve the content and layout of the Sites, and to improve our product offerings and services;
• Identifying, developing and marketing products and services that we believe you will value, including across browsers and devices, in accordance with applicable laws. Cookies or other similar technologies may be used to provide you with advertising based upon your browsing activities and interests.  Where we are required by applicable law, we will seek your consent prior to sending you communications for marketing purposes;
• To create personalized product recommendations on behalf of online advertisers to present to online visitors by email or phone.
• To market relevant online services (e.g., Product/Supplier Alerts, Magazines) by print DMs, eDMs, telemarketing calls, SMS or other platforms including Facebook, LinkedIn or through third party agencies.
• To market relevant Tradeshowsand services (e.g., Buyer apps, Summits, Start Up Launchpad) by print DMs, eDMs, telemarketing calls, SMS or through other platforms including Facebook, LinkedIn or through 3rd party agencies
• To create contact lists of Online and/or Trade Show visitors who have opted in to third party marketing. These lists are segmented based on visitor preferences, behaviors or demographics and can be rented/sold to verified third party vendor for direct marketing on behalf of their clients.
• Using third party marketing materials from our partners (advertisers or service providers) to market to Online and Trade Show visitors who have opted in to third party marketing. These visitors are segmented based on preferences, behavior or demographics, by print DMs, eDMs, telemarketing calls, SMS or through other platforms including Facebook, LinkedIn or through third party agencies.
• Create contact lists for surveys and similar market research activities.
• To facilitate Advertisers and Exhibitors who have received Requests for Information or similar from visitors to Online site or Tradeshows, through our Messaging Service to review visitor details for qualification purposes and to facilitate communication between parties by email/phone/chat in relation to such requests.
• Our Customer Services team may use your personal data when responding to your comments, feedback, inquiries, questions, to give you appropriate support to fulfil your needs and requests
• Our team may use your personal data to (i) facilitate internal purposes such as auditing, data analysis, and research to improve our products, services and improve your user experience, including providing more relevant customized content to you; (ii) detect, investigate and prevent fraudulent transactions and other illegal activities and protect your rights and property as well as ours.
• Use the data for purposes associated with our legal and regulatory obligations.
• We may use your personal information to send you direct marketing communications about our products and services or our related services according to your preferences either with your consent or because we have a legitimate interest to do so, including our latest product announcements and upcoming events. This may be in the form of emails, SMS, telephone calls or targeted online advertisement. We limit direct marketing to a reasonable proportionate level, and to send you communications which we think will be interesting and relevant to you, based on the information we have about you.
• Profilingbased on information we have collected about you and your viewing habits and analytics about performance of our content, offers and ad. We personalize the content, offers and ads made available to you to make your experience more relevant.
• We may also use your Personal Data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

We will only use your personal data for those purposes set out above and only where we are satisfied that it is necessary and that its use falls under one or more of the following legal grounds, i.e.:

• To comply with a relevant legal or regulatory obligation that we are subject to
• To fulfill obligations under a contract signed between you and us, or
• To support 'legitimate interests' that we have as a business provided it is always carried out in a way that is proportionate and that respects your privacy rights
• Or exceptionally for clearly defined and limited cases, where you have freely given consent

DISCLOSURE OF PERSONAL DATA

 Personal Data Shared With:

• our business partners (for example, in order for them to provide you with discounts or offers that may interest you);
• marketing platforms, such as Google, Twitter, Facebook, Instagram, and providers of analytics services relating to users’ behavior, in order to tailor the content you see when visiting our Sites.  These marketing platforms may combine information they collect on our Sites with data on their platforms and data they collect from other websites or through other sources in order to conduct targeted advertising.  The activities of these third party marketing platforms are governed by their own privacy policies, not this Privacy Policy;
• Service providers, who perform functions on our behalf such as fulfilling orders, who help manage our IT and back office systems, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), and providing customer services.
• payment service providers to assist with payment for transactions or providing withdrawing service for sellers.  The activities of payment service providers may be governed by their own privacy policies, not this Privacy Policy;
• credit risk assessment providers to conduct risk assessment on sellers to determine whether a seller can be permitted to make an advance withdrawal;
• logistics partners for providing delivery services for buyers, including return and exchange of products, and warehousing services for sellers;
• custom agents for customs clearances purposes;
• cloud computing service providers to provide cloud storage services;
• warranty service providers to provide warranty services;
• customer service providers to provide after-sale services;
• risk control service providers to assess the security of members’ accounts and transaction risks;
• other third parties, for the purpose of detecting, preventing or otherwise addressing fraud, security or technical issues, protecting against harm to the rights, property or safety of our users or the public.

We may disclose or transfer your data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Global Sources business, assets or stock (including any bankruptcy or similar proceedings).

Transfer to other countries

If necessary and appropriate for the data processing described in this Privacy Policy declaration, we may also transfer your personal data to third parties abroad.

We do not disclose personal data to third parties unless required to do so by law or ordered to do so by a court order. 
This does not include the disclosure of personal data to third parties:
a) for the legal protection of users;
b) to meet legal requirements;
c) to defend and protect the rights of the provider;
d) to comply with the terms of use or the data protection regulations;
e) to solve technical problems of the products;
f) to process your enquiries from the companies you have selected who require the transmission of data in order to process your enquiry or order. In these cases, the transmission of data is limited to the minimum necessary for the fulfillment of the order. 
g) to cooperate with service partners of the provider, who support us especially in the marketing area, for the analysis of certain technical data and for functions of the processing and/or storage of data. We work with a limited number of trusted external service partners who have been carefully selected by us and meet high data protection and security standards. Data is only disclosed to service partners to the extent that it is necessary for the provision of the services offered.

We may also disclose your Personal Data to any other person with your consent to the disclosure

These Service Providers must abide by our data privacy and security requirements and are only permitted to use your Personal Data in connection with the purposes specified above, and not for their own purposes.

We may disclose your Personal Data to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your Personal Data only for the purposes disclosed in this Privacy Policy.

When we believe it is necessary to comply with applicable laws or to exercise, establish or defend our legal rights or protect your vital interests or those of any other person, we may also disclose and transfer your Personal Data to our professional advisers, law enforcement agencies, insurers, government and regulatory and other organizations, or as otherwise required or permitted by applicable laws.

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for these notices. Please check these notices before you submit any personal information to these websites.

RIGHTS REGARDING PERSONAL DATA

Under the applicable laws, you may have the rights of access to Personal Data held by us and other rights. 

You have a number of rights in relation to your personal information. Specifically, you have the right to request:

• Access to Your Data - You can ask us to:
• Confirm whether we are processing your personal information
• Give you a copy of that data
• Provide you with other information about your personal information, such as what data we have, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out automated decision making or profiling, to the extent that information has not already been provided to you in this notice.
• Rectification
• You can ask us to rectify inaccurate personal information in our files. We may seek to verify the accuracy of the data before rectifying it.
• Erasure (Right to be Forgotten) - You can ask us to erase your personal information, but only where:
• It is no longer needed for the purposes for which it was collected; or
• You have withdrawn your consent (where the data processing was based on consent); or
• It follows a successful right to object; or
• It has been processed unlawfully; or
• It is necessary to comply with a legal obligation.

We are not required to comply with your request to erase your personal information if the processing of your personal information is necessary:

• For compliance with a legal obligation; or
• For the establishment, exercise or defence of legal claims.
• Restriction - You can ask us to restrict (i.e. keep but not use) your personal information, but only where:
• Its accuracy is contested, to allow us to verify its accuracy; or
• The processing is unlawful, but you do not want it erased; or
• It is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
• You have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personal information following a request for restriction, where:

• We have your consent; or
• To establish, exercise or defend legal claims; or
• To protect the rights of another natural or legal person.
• Objection
• You can object to any processing of your personal information which has our 'legitimate interests' as its legal basis, if you believe your fundamental rights and freedoms outweigh our Legitimate Interests. Once you have objected, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights, however, this does not apply as far as the objections refers to the use of personal information for direct marketing purposes.
• Data Portability
• You can askus to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another Data Controller.
• Information about any automated processing e.g. segmentation or profiling using your data. You can ask not to be subject to such processing.
• Information about International Transfers.
• You can request details about international transfers of your data
• Withdrawal of consent
• You can revoke your consent to data processing at any time, with effect to the future. In the event of revocation, we may no longer be able to provide you with personalised use of free and/or paid products.

To exercise your rights, you can contact us. Please note the following if you do wish to exercise these rights:

• Identity - We take the confidentiality of all records containing personal information seriously and reserve the right to ask you for proof of your identity if you make a request.
• Fees - We will not ask for a fee to exercise any of your rights in relation to your personal information, unless your request for access to information is unfounded, repetitive or excessive, in which case we will charge a reasonable amount in the circumstances.
• Timescales - We aim to respond to any valid requests within a reasonable timeframe.
• Exemptions - Local laws provide for additional exemptions, in particular to the right of access, whereby personal information can be withheld from you in certain circumstances, for example where it is subject to legal privilege.

COOKIES

A "cookie" is a small amount of data that is sent to your browser and stored on your computer's or mobile device’s hard drive. If you do not de-activate or erase the cookie, each time you use the same browser or mobile device to access the Sites, our web servers will be notified of your visit to the Sites and in turn we may have knowledge of your visit and the pattern of your usage.  The cookies will enable us to remember your information so you do not have to re-enter it every time you use the Site

In addition, we use cookies to manage the security of our Sites, to gather information about usage by users; to research visiting patterns and conduct interest-based advertising; to assist our partners to track user visits to the Sites and process orders; and to track progress and participation in promotions.

For these additional purposes identified above, you can determine if and how a cookie will be accepted by configuring the privacy setting of the browser you are using to access the Sites or the privacy setting of your mobile device. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser's help menu for more information. If you adjust the privacy setting in the browser, your mobile device will continue collecting data unless you adjust the privacy setting of the device, and vice versa.

 You have the right to decide whether to accept or reject cookies. If you choose to set your web browser controls to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. Certain features of the Site depend on cookies. Please be aware that if you choose to block cookies, you may not be able to sign in or use those features, and preferences that are dependent on cookies may be lost.  

SECURITY MEASURES

We employ commercially reasonable security methods to prevent unauthorized access to the Sites, to maintain data accuracy and to ensure the correct use of the information we hold.We restrict access to personal information to our employees, contractors and agents who need access to the relevant personal information in order for them to process it for us and who are subject to strict contractual confidentiality obligations.

On your part, we encourage you to use a unique and strong password to protect your account, limit access to your computer and log out after using our services. In addition, you should make sure your computer is updated with the latest security patches and protected with an anti-malware product at all times.

Please note that you are responsible for the personal information that you choose to share, disclose or submit voluntarily while using our website and which can be viewed by members of third party applications or messengers.

No data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect the information we hold for you, we cannot guarantee the security of any information you transmit to us and you do so at your own risk.

LEGAL BASIS FOR DATA PROCESSING

We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process Personal Data will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect and process Personal Data about you only where it is: necessary for the performance of any contract (for example, to provide you with the services you request and to identify and authenticate you so you may use the Sites); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests and not overridden by your rights; and/or where it is based on your consent .

If we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Sites and services, manage our relationship with you and communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our Sites and our services, undertaking marketing, or for the purposes of ensuring the security of our Sites and services and detecting or preventing illegal activities such as fraud. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If we ask you to provide Personal Data to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data). In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Sites.

For further processing, we rely on our primary interest. For example, to adapt and continuously improve our services to the needs of our customers; and to carry out marketing activities in order to offer you suitable products or services and display advertisements that are relevant to you. However, we have taken measures to reduce the impact of data processing on our users. We have compared our interest with the interest of our users and have concluded our data processing does not unduly affect the interests or basic rights of our users and that our interest in this data processing outweighs the others accordingly. Should you disagree with this, you have the right to object to such data processing at any time withinthe legally permissible framework. In cases where we obtain consent for the processing of data, this is regarded as the legal basis.

DATA RETENTION

We retain your Personal Data as long as we have an ongoing legitimate business need to do so for example to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws. When your personal information is no longer required, we will ensure it is either securely deleted or stored in a way which means it will no longer be used by the business.

In some circumstances we may retain your personal information for longer periods of time, for example, where we are required to do so to meet legal, regulatory, tax or accounting requirements or in the event of any complaint or challenge, or if we reasonably believe there is a possibility of legal action relating to your personal information or dealings.

Please send requests to access or correct data, to cease communications, and questions or complaints to:

GaGuAsia.com
Moim Global Sdn Bhd
Unit 19-01, Tower A, Vertical Business Suite,
8 Jalan Kerinchi, Bangsar South, 59200 Kuala Lumpur.
Tel: +6017 3377123  
E-mail: info@gaguasia.com

Note that to exercise your right to access and/or correct your personal information you must submit a request in writing to the contact details above.