Snuggle - Marketplace

PRIVACY NOTICE

Please read this Privacy Policy carefully. This Privacy Policy informs you about our policy and practices on data privacy matters which you may concerned with before you provide your personal data to JYH. This Privacy Policy applies when you visit or use jyh5g.com website and/or the JYH mobile app (“the Platform”) and/or any facilities, services and/or functions made available by JYH at the Platform from time to time (“the Services”).

Introduction to this Privacy Policy

In the course of providing to you with the Services and/or access to the Platform, we will be collecting, using, disclosing, storing and/or processing data, including your personal data. In this Privacy Policy, the Platform shall also refer to the relevant seller platform(s).

This Privacy Policy basically exists to let you know about: -

Whatare the personal data we collect from the users;
Thepurpose of our collection of your personal data;
How we collect, use, disclose, store and/or process the data we collect and receive during the course of providing the Services and/or access to the Platform to you, our user, whether you are using the Platform as a buyer or a seller;
Whomyour personal data may be disclosed to;
Howlong does JYH keep your personal

It is important that you read this Privacy Policy together with any other applicable notices we may provide from time to time when we are 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.

This Privacy Policy may be amended, updated, improved, altered, added, revised and/or modified from time to time. We will post notice of material changes on JYH’s website. Please re-visit this Privacy Notice from time to time to learn of any such changes. Where permissible under the laws, your continued use of the Services, access to the Platform or use of the Services, including placing orders on the Platform, or express consent thereto, shall constitute your acknowledgment and acceptance of the changes we make to this Privacy Policy.

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 expressly state otherwise.

All of these terms apply to JYH's users, whether buyers or sellers, unless stated specifically to apply only to buyers or only to sellers.

The Personal Data We Collect From You

Personal data means any information about an individual or that can be connected to the 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. During the course of your use of the Platform and/or the provision of the Services, we may collect personal data about you, as follows:

Where you are a buyer:

Identitydata, such as your name, gender, profile picture, and date of birth;
Contact data, such as billing address, delivery address, email address, social media handle and phone numbers;
Biometricdata, such as voice files when you use our voice search function, and facial and other bodily features and voice of yourself and/or another person featured in your video when you upload videos onto the Platform;
Account data, such as bank account details, bank statements, credit / debit card information and payment details (such account data may also be collecteddirectly by our affiliates and/or third party payment service providers);
Transaction data, such as details about orders and payments, and other details of products and Services related to you;
Technical data, such as Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, international mobile equipment identity, device identifier, IMEI, MAC address, cookies (where applicable) and other information and technology on the devices you use to access the Platform;
Profiledata, such as your username and password, password hint, security information, orders related to you, your interests, preferences, feedback and survey responses;
Usagedata, such as information on how you use the Platform, products and Services or view any content on the Platform, including the time spent on the Platform, items and data searched for on the Platform, access times and dates, as well as websites you were visiting before you came to the Platform and other similar statistics;
Location data, such as when you capture and share your location with us in the form of photographs or videos and upload such content to the Platform;
Marketingand communications data, such as your preferences in receiving marketing from us and our third parties, your communication preferences, preferred language and your post, chat, comment, email or call history on the Platform or with third party customer service providers; and
Additional information we may request you to submit for due diligence checks as required for identity verification (such as copies of government issued identification, e.g. passport, ID cards, etc.) or if we believe you are violating our policy.

Where you are a seller:

Identityand contact data, such as your name, date of birth or incorporation, company name, address, email address, phone number and other business-related information (e.g. company registration number, business licence, tax information, shareholder and/or director information, etc.);
Account data, such as bank account details, bank statements, credit/debit card information and paymentdetails (such account data may also be collected directly by our affiliates and/or third party payment service providers);
Transaction data, such as details about orders and payments, and other details of products and Services related to you;
Technical data, such as Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, international mobile equipment identity, device identifier, IMEI, MAC address, cookies (where applicable) and other information and technology on the devices you use to access the Platform;
Profiledata, such as your username and password, password hint, security information and/or orders related to you, your interests, preferences, feedback and survey responses;

Usagedata, such as information on how you use the Platform, products and Services or view any content on the Platform, including the time spent on the Platform, items and data searched for on the Platform, access times and dates, as well as websites you were visiting before you came to the Platform and other similar statistics;
Location data, such as when you capture and share your location with us in the form of photographs or videos and upload such content to the Platform;
Marketingand communications data, such as your preferences in receiving marketing from us and our third parties and your communication preferences and your post, chat, comment, email or call history on the Platform or with our third party seller service providers; and
Additionalinformation we may request you to submit for authentication (such as copies of government issued identification, e.g. passport, ID cards, etc.) or if we believe you are violating our policy.

Use and Disclosure of Your Personal Data

Purpose of Use

The personal data we collect from you or via third parties may be used for certain purposes, including but not limiting to the following:

Where you are a buyer:

Toprovide, activate, facilitate and manage your use of the Services or access to the Platform;
Toprocess your order for products (whether sold by us or a third party seller);
To process and fulfil request, order, download, subscription or other transaction through the Platform;
To deliver the products you have purchased through the Platform. We may disclose your personal data to a third party (e.g. our logistics partner) or relevant regulatory authority (e.g. customs) in order to make delivery of the product(s) to you;
Toinform and update you on the delivery of the product(s);
Tonotify you on the changes, updates and other announcement related to the Platform and/or the Services;
Toprovide customer support for your orders;
To provide technical, product and other support and to help keep the Platform and/or the Services working, safe and secure;
Tofurther develop, improve and enhance the Platform and/or the Services;
Toverify 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 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;
Toadminister your account (if any) with us;
To display your name, username or profile on the Platform (including on any reviews you may post);
Tofacilitate the use of the services available on the Platform and purchases made via these services;
To respond to your queries, feedback, comments, concerns, claims or disputes, whether directly or through our third party service providers;
To allow other users to identify you (via the "Find my friends" or any other similar function)as a user of the Platform and/or the Services, to allow you to find other users and to connect with them on the Platform and/or the Services and to support the socialising function of the Platform and/or the Services (where applicable);

To offer or facilitate the integration of third party’s loyalty membership programmes (includingthose supported by sellers or brands) with our Platform, referral programme, reward programmes etc;
To provide you with information we think you may find useful or which you have requested from us or which are more relevant to your interests and geography;
Tosend to you marketing advertisement or promotional information about our or third- party sellers’ products and services on the Platform from time to time;
To promote the Platform and/or the Services and use information that you give to us, such as user-generated content (including video content) that you can choose to uploador broadcast on the 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 and/or the Services;
Toascertain your identity in connection with fraud detection purposes;
Tocompare information, and verify with third parties in order to ensure that the information is accurate;
To process any complaints, investigation, review, feedback, enforcement action and take-down requests in relation to any content you have uploaded to the Platform;
To produce statistics and research for internal and statutory reporting and/or record- keeping requirements;
Tostore, host, back up your personal data;
Toprevent, detect or investigate any actual or suspected violations of our policy, fraud, unlawful activity, omission or misconduct, whether relating to your use of the Platform and/or the Services or any other matter arising from your relationship with us;
Toperform due diligence checks;
To comply with legal and regulatory requirements (including, where applicable, the display of your name, contact details and company details), including any law enforcementrequests, in connection with any legal proceedings, or otherwise deemed necessary by us, both within and outside Malaysia;
Wherenecessary to prevent a threat to life, health or safety;
Tounderstand your user experience with the Platform and/or the Services;
To improvethe layout or content of the pages of the Platform and customise them for users;
Toidentify visitors on the Platform and/or the users of the Services;
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;
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 more targeted and/or relevant information;
Toknow our buyers better;
Forinternal record keeping and internal functions such as evaluating the effectiveness of marketing, market research, statistical analysis and modelling, reporting, audit and risk management;
Anyother purpose to which your consent has been

Where you are a seller:

To provide, activate, facilitate and manage your use of the Services and/or access to the Platform;
To ship or deliver the products you have listed or sold through the Platform. We may discloseyour personal data to a third party (e.g. our logistics partners) or relevant

regulatory authority (e.g. customs) in order to carry out shipping or delivery of the products listed or sold by you;

To respond to your queries, feedback, claims or disputes, whether directly or through our third party service agents;
Toverify your documentation submitted to us facilitate your subscription as a seller on the Platform, including the testing of technologies to enable faster and more efficient subscription;
Toadminister your account (if any) with us;
Todisplay your name, username or profile on the Platform;
Toverify and carry out financial transactions (including any credit card payments, bank transfers, offline payments, remittances, or e-wallet transactions) in relation to payments related to 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;
To provide you with ancillary freightforwarding or logistics services to protect against risks of failed deliveries or customer returns;
Tofacilitate the return of products to you (which may be through our designated freight forwarder or logistics partner);
To send to you marketing or promotional materials about our or third-party sellers’ products and services on the Platform from time to time;
Tohelp us conduct marketing and advertising;
To produce statistics and research for internal and statutory reporting and/or record- keeping requirements;
Tostore, host, back up your personal data;
Toprevent, detect or investigate any actual or suspected violations of our policy, fraud, unlawful activity, omission or misconduct, whether relating to your use of the Platform and/or the Services or any other matter arising from your relationship with us;
To comply with legal and regulatory requirements (including, where applicable, the display of your name, contact details and company details), including any law enforcementrequests, in connection with any legal proceedings or otherwise deemed necessary by us, both within and outside Malaysia;
Wherenecessary to prevent a threat to life, health or safety;
To process any complaints, investigation, review, feedback, enforcement action and take-down requests in relation to any content you have uploaded to the Platform;
Tocompare information, and verify with third parties in order to ensure that the information is accurate;
Toascertain your identity in connection with fraud detection purposes;
Tofacilitate the takedown of prohibited and controlled items from the Platform;
Analytics,research, business and development
Toaudit the downloading of data from the Platform;
Tounderstand the user experience with the Services and/or the Platform;
To improvethe layout or content of the pages of the Platform and customise them for users;
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;
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 more targeted and/or relevant information;
Tofurther develop our products and services;
Toknow our sellers better;

Forinternal record keeping and internal functions such as evaluating the effectiveness of marketing, market research, statistical analysis and modelling, reporting, audit and risk management; and
Anyother purpose to which your consent has been

How we receive your personal data

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

When you browse our website (both mobile and web versions);
When you create an account with us (as buyer or seller);
When, as a seller, you list products and/or services for sale on the Platform and conducttransactions with buyers in respect of the sale and purchase of those products and/or services through the Platform;
When you apply for, subscribe to or otherwise use any of the Services;
When you make a transaction regarding the products available on the Platform;
When you activate or use any payment-related functions available on the Platform or provided by our third party service providers;
When you use any of the features, functions or mini-apps available on the Platformand/or the Services;
When you record any user-generated content which is uploaded on the Platform;
When you use the chat function on the Platform;
When you subscribe to our publications or marketing collaterals;
When you enter or participate in a competition, prize draw, promotion, referral programme or loyalty or reward programme;
When you participate in any activity or campaign on the Platform;
When you log in to your account on the Platform or otherwise interact with us via an external service or application, such as Facebook or Google;
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;
When athird party lodges a complaint against you or the content you have posted on the Platform;
When you communicate with us via email or other correspondences;
When you complete a survey that we send to you; and
When you interact with us offline, including when you interact with our outsourced customer service agents.

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, regulatory agencies, licensing authorities, government sources of data, financial providers, credit bureaus, delivery, marketing and other service partners), our affiliates, or such data may be collected automatically when you use the Platform and/or the Services, as set out in this section.

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 JYH for the purposes set out in this Privacy Policy or any other terms.

You must only submit personal data which is accurate and not misleading and you must keep it up to date and inform us of any changes to the personal data 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.

The provision of your personal data is voluntary and optional. 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 under this Privacy Policy. Nevertheless, 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.

If you provide personal data of any third party to us, you represent and warrant that you have obtained the necessary consent, license and permissions from that third party to share and transfer his/her personal data to us, and for us to access, collect, store, use and disclose that data in accordance with this Privacy Policy.

If you sign up as a user on our Platform using your social media account or link your JYH account to your social media account or use certain other JYH 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.

Who we disclose your personal data to

We may share (or permit the sharing of) your personal data with and/or transfer your personal data to third parties and/or our affiliates for the above-mentioned purposes. These third parties and affiliates, which may be located inside or outside your jurisdiction, include but are not limited to:

Our employees, related companies, affiliates, auditors, consultants, lawyers, accountants and other professional advisors;
Any person, government authority, statutory authority, industry regulator or other relevant party whom we are compelled or required to so pursuant to law;
the service providers (such as suppliers, agents, vendors, representatives and partners) in areas such as payment processors, logistics and shipping, customer support, email service, ITservice, cloud storage, insurance and financing, marketing, data analytics, market or consumer research, survey, social media, installation services, information technology and website hosting;
Theirservice providers, their employees and related companies;
Yourorganisation;
Otherusers of the Platform and/or the Services;
Asrequired by the relevant laws and

In disclosing your personal data to them, we endeavour to ensure that the third parties and our affiliates keep your personal data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain your personal data only for as long as your personal data is needed to achieve the above-mentioned purposes.

We may also 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.

International data transfer

We may transfer or permit the transfer of your personal data outside of your jurisdiction for any of the purposes set out in this Privacy Policy. However, we will not transfer or permit any of your personal data to be transferred outside of such jurisdiction unless the transfer is in compliance with applicable laws.

For legal reasons

We will share your personal data if we have a good faith belief that such disclosure is necessary to: -

meetany applicable law, regulation, legal process or other legal obligations;
detect,investigate and help prevent security, fraud or technical issues;
protectthe rights, property or safety of JYH, our users, employees or other;
as part of a corporate transaction, such as transfer of assets to or an acquisition by or merger with another company.

Third party services

We may share your personal data with our third party service providers or affiliates (e.g. payment service providers or network provider) in order for them to offer services to you other than those related to your use of the Platform and/or the Services. Your acceptance and use of the third party service provider’s or our affiliate’s services shall be subject to terms and conditions as may be agreed between you and the third party service provider or our affiliate.

Upon your acceptance of the third party service provider’s or our affiliate’s service offering, the collection, use, disclosure, storage, transfer and processing of your data (including your personal data and any data disclosed by us to such third party service provider or affiliate) shall be subject to the applicable privacy policy of the third party service provider or our affiliate, which shall be the data controller of such data. You agree that any queries or complaints relating to your acceptance or use of the third party service provider’s or our affiliate’s services shall be directed to the party named in the applicable privacy policy.

Retention of Personal Data

We will only retain your personal data for as long as we are either required or permitted to by law or as relevant for the purposes for which it was collected. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data was collected, and is no longer necessary for any legal or business purpose.

Restriction or Withdrawal of Consent to Continued Use, Disclosure, Storing and/or Processing of Personal Data

You may communicate the restriction or withdrawal of your consent to the continued use, disclosure, storing and/or processing of your personal data by contacting us using the contact details below, subject to the conditions and/or limitations imposed by applicable laws or regulations.

Please note that if you communicate your restriction or withdrawal of your consent to our use, disclosure, storing or processing of your personal data for the purposes and in the manner as stated above or exercise your other rights as available under applicable local laws, we may not be in a position to continue to provide the Services to you or perform any contract we have

with you, and we will not be liable in the event that we do not continue to provide the Services to, or perform our contract with you. Our legal rights and remedies are expressly reserved in such an event.

Marketing information

We may use your personal data to market products, services, events or promotions of ours, our partners, sponsors, vendors, sellers and advertisers. We may communicate such marketing to you via post, telephone call, email, short messaging service (SMS), social media and/or other channels. You may unsubscribe from receiving marketing information at any time in our mobile application settings or by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters from us and from our related companies.

Updating Your Personal Data

It is important that the personal data you provide to us is accurate and complete for you to continue using the Platform and for us to provide the Services. You are responsible for informing us of changes to your personal data, or in the event you believe that the personal data we have about you is inaccurate, incomplete, misleading or out of date.

You can update your personal data anytime by accessing your account on the Platform. We take steps to share the updates to your personal data with third parties and our affiliates with whom we have shared your personal data if your personal data is still necessary for the above- stated purposes.

Accessing and Correcting Your Personal Data

The Platform and/or the Services allow registered users to have direct access and review their own account information upon login at any time.

You may request information about your personal data which we have collected, or enquire about the ways in which your personal data may have been used, disclosed, stored or processed by us via the personal account information setting on the Platform or by contacting us using the contact details below.

You may also request for rectification or correction of any error or omission in your personal data which we have collected. In order to facilitate processing of your request, it may be necessary for us to request further information relating to your request. We will make appropriate rectification or correction based on the updated information provided by you. Where permissible under the law, we may refuse such rectification or correction requests if deemed vexatious or unreasonable.

You also have the right to request to erase or delete your personal data. When requested and if it is practical, we will use our commercial reasonable effort to erase or delete the identified information from the Platform. However, please note that we may be required to keep such information and not to delete it (or keep it for a certain period of time, in which case, we will comply with your deletion request only after we have fulfilled such requirements). When we delete information, it will be deleted from the active database but it may remain in our archive.

We may also retain your data for fraud prevention and detection or other purposes. Where permitted by applicable data protection laws, we reserve the right to charge a reasonable administrative fee for retrieving your personal data records. If so, we will inform you of the fee before processing your request.

Please be mindful that as deletion or erasure of certain information may impact your access to the Platform and/or use of the Services and we may decline to such erasure or deletion.

Security of Your Personal Data

We implement technical and organizational measures to seek to ensure a level of security appropriate to the risk to your personal data we collect and process.

To safeguard your personal data from unlawful and unauthorised access, collection, use, disclosure, processing, copying, modification, disposal, loss, misuse, modification or similar risks, we have introduced appropriate administrative, physical and technical measures or efforts such as:

Restrictingaccess to personal data to individuals who require access;
Storing your personal data in systems that are protected by secured networks and operating environments that are not available to public and only accessible by our employees for the purpose of performing their official duties;
Regularly monitoring our system for possible vulnerabilities and attacks and regularly review our data collection, storage and processing practices;
Maintainingtechnology products to prevent unauthorised computer access; and/or
implementingother security measures as required by applicable

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

Please remember that certain content submitted to the Platform and/or the Services or our other social media platforms may be viewed by the public and you are advised to be cautious in providing certain personal data or information. We are not responsible for any actions taken by other person if you post personal data on the Platform or our other social media platforms and we recommend that you do not share such information.

Minors

We do not sell products to minors (which is to be determined based on the applicable law), nor does it intend to provide any of the Services or the use of the Platform to minors. We do not knowingly collect any personal data relating to minors.

You hereby confirm and warrant that you are above the age of minority and you are capable of understanding and accepting the terms of this Privacy Policy. If you are a minor, you may use our Platform only with the involvement of a parent or legal guardian.

As a parent or legal guardian, please do not allow minors under your care to submit personal data to JYH. In the event that such personal data of a minor is disclosed to JYH, you hereby consent to the processing of the minor’s personal data and accept and agree to be bound by this Privacy Policy and take responsibility for his or her actions.

We will not be responsible for any unauthorised use of the Services and/or the Platform by yourself, users who act on your behalf or any unauthorised users. It is your responsibility to make your own informed decisions about the use of the Services and/or the Platform and take necessary steps to prevent any misuse of the Services and/or the Platform.

Collection of Computer Data

We or our authorised service providers may use cookies, web beacons, and other similar technologies in connection with your use of the Services and/or access of the Platform. 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 electronic graphic images that may be included on the Services and/or the Platform. They allow us to count users who have viewed these pages so that we can better understand your preference and interests.

When you visit the Platform through your computer, mobile device, or any other device with Internet connectivity, our servers will automatically record data that your browser sends whenever you visit a website. This data is collected for analysis and evaluation in order to help us improve or enhance 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/or the Platform more convenient and useful to you and to provide more relevant advertising related to market products, services and features to you.

You may be able to manage and delete cookies through your browser 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 full functionality available on the Platform or through the Services.

By continuing accessing or using the Platform, you consent to our use of cookies and other similar technologies in accordance with this Privacy Policy.

Third Party Sites

The Platform may contain links to other websites operated by other parties, such as our business affiliates, merchants or payment gateways. As we are not in control of the activities of third party, we are not responsible for the privacy practices of websites operated by these other parties. You are advised to check on the applicable privacy policies of those websites to determine how they will handle any information they collect from you.

Questions, Feedback, Concerns, Suggestions or Complaints

If you have any questions on personal data protection or data privacy or if you have any queries or complaints about this Privacy Policy or how we handle your personal data, please feel free to contact us.