Privacy policy

Shoovia User Privacy Policy

Effective Date: November 24, 2022

I. Introduction
II. Privacy Policy

I. Introduction

Shoovia (hereinafter referred to as "We") attaches great importance to the protection of users' personal privacy and personal information security. We will take corresponding management and security protection measures in accordance with current laws and policies, and formulate this Privacy Policy (hereinafter referred to as "This Policy") and remind you that:

This privacy policy is applicable to the products or services provided by Shoovia, including services provided by Shoovia when you visit Shoovia website and / or log in to relevant apps.

Please note that this policy does not apply to the services provided to you by other third parties, and the privacy policies stated by the third parties shall apply to such services.

Before you use Shoovia products and/or services, please read and confirm that you have fully understood this policy. Using the products and/or services provided by Shoovia indicates you have fully understood and agreed to this policy. If you have any questions, comments or suggestions, please contact us by sending an email to: contact@shoovia.one or making a phone call to our customer service.

II. Privacy Policy

1. This part will walk you through: (1) When Shoovia collects your personal information (Section 2); (2) What personal information Shoovia collects (Section 3 - 6); (3) Why Shoovia uses your personal information, and how it uses and protects such information (Section 7 - 12); (4) Withdrawal / correction of personal information or handling of questions regarding the Privacy Policy (Section 13 - 15);

2. When Shoovia collects your personal information?

2.1 We will / may collect your personal information:

a) When you register as a seller and / or use the Service or Platform, or open an account on the Platform;

b) When you submit forms online or in writing, including but not limited to application forms or other forms related to our products or services;

c) When you sign an agreement or provide other documents or information for interaction with us, or when you use our products and services;

d) When you communicate with us via telephone (which may be recorded), instant messaging applications or software, letters, faxes, email, face-to-face meetings, social media platforms, etc.;

e) When you ask questions or answer questions from other users in our forum;

f) When you use our e-services, or communicate with us through our apps or services on our website. This includes, but is not limited to, collection through cookies (which we may set up when you come into contact with our apps or website);

g) When you trade via our services;

h) When you provide opinions or complaints to us;

i) When you register for competitions and other marketing activities;

j) When you submit personal information to us for any reason. The above are just some of the situations under which we may collect your personal information.

3. What personal information Shoovia collects?

3.1 The personal information that Shoovia collects includes but is not limited to:

a) Basic information (including your name, age, birthday, gender, nationality, address, billing address, phone number, email address, etc.);

b) Identity information (including ID card, officer card, passport, driver's license, other identity documents, etc.);

c) Facial features;

d) Network identity information (including system account, IP address, email address and password related to the above);

e) Financial information (transaction, bank account and points, coupons, Shoovia account balance, etc.);

f) Records of internet access (including computer IP address, operating system, website browsing records, software usage records, click records, etc.); equipment information (including hardware model, device MAC address, operating system type, software list, Unique Device Identifier such as IMEI/android ID/IDFA/OPENUDID/GUID, SIM card's IMSI, etc.); location information (including travel information, accurate positioning information, accommodation information, longitude and latitude, etc.);

g) Information of account opened by third party service provider;

h) Any other information provided by users when they register to use our services or websites and how they use our services or websites;

i) Information that can provide summary of user interaction.

3.2 You undertake not to submit any incorrect or misleading information to us and agree to inform us of any inaccuracy or change in such information. Shoovia reserves the right to unilaterally request further documentation to verify the information you have provided.

3.3 If you do not want us to collect the above information / personal information, you can inform the Personal Information Security Officer in writing at any time and choose to opt out. For more information about opting out, see the section below entitled "How to withdraw consent to, delete, request access to, or correct the information you provided?" However, please note that opting out or withdrawing your authorization for us to collect, use or process your personal information will affect your use of our services and platform. For example, if you opt out of collecting location information, the location-based features will be disabled.

4. Collection of other information

4.1 As with most websites and mobile applications, the information your device sends may include data about you recorded by the web server when you browse our platform. The information we collect may include, but is not limited to: your Internet communication protocol (IP) address, type of computer / mobile device operating system and browser, type of mobile device, mobile device characteristics, mobile device unique device identifier (UDID) or mobile device identifier (MEID), the address of the reference website (if any), as well as the pages you visit on our website and mobile applications and the time of your visit. Sometimes, it also includes "cookie" (which can be disabled by the browser) which help the website record the time of your last visit. If you are already logged in, such information will be associated with your account. It is also included in anonymous statistics to help us understand how visitors use our website.

4.2 Our mobile applications may use GPS, Wi-Fi, and other technologies to gather accurate information about the location of your mobile device. We may collect, use, disclose and/or process such data for one or more "purposes," including, but not limited to: location-based service requests, delivering relevant content to you based on your location, and allowing you to share your location with other users through services included in our mobile applications. For most mobile devices, you can disable our access to your location information via settings. If you have any questions about how to disable the location service of mobile device, please contact the service provider or manufacturer of your device.

5. COOKIES

5.1 What are Cookies?

"Cookies" are identifiers that we send to your computer or mobile device. They allow websites to remember your actions and preferences (e.g. login info and region selection) to improve your browsing experience, which means you don't have to re-enter such info every time you return to the website or when you browse from one page to another. At the same time, Cookies allow us to identify your computer or device, tell us how and when our service or website is used or accessed as well as the number of visitors, and track your activities on our website.

5.2 Why we use Cookies?

We use Cookies for reasons as follows: 1) For technical requirements, we need some Cookies to run our website, and we refer to these as basic website Cookies; 2) Cookies that are provided by third parties through our website for website data analysis and other purposes, which we refer to as systematic analysis-specific Cookies.

The table below describes the specific types of first and third party Cookies provided through our website and what they are used for:

Cookie Types Used for Term

Basic Website Cookies:
The information collected by these Cookies is used when we provide you with services of our website and use some of its functions, e.g. when we need to know your current login status to determine whether you are a member. User login Permanent
Notification Permanent

Systematic Analysis-specific Cookies:
These Cookies collect information to help us, in multiple ways, understand how our website is accessed, or to help us customize our website for you. Analysis of website data:
Google Tag, Manager, Facebook pixel, Reddit Pixel Permanent

5.3 How to manage Cookies?

You can set or modify your web browser controls to accept or reject Cookies. If you choose to reject Cookies, you can still use our website, but you may have limited access to some features and sections. How you reject Cookies will vary from browser to browser, and you can set your Cookies preferences for major browsers by clicking on the links below.

a) Chrome: https://support.google.com/chrome/answer/95647?hl=en

b) Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer?redirectslug=Cookies&redirectlocale=en-US

c) InternetExplorer: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

d) Safari: https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac

6. Browse and download content and advertisements

6.1 When you view content, ads and access other software on our website or through our services, the system will send us information that is substantially the same as that you send when browsing our webpages or mobile applications (including but not limited to IP addresses, operating systems, etc.); However, unlike web browsing, your device will transmit to us information related to the content and advertising you view, and/or information related to our services and the software installed on our website and the time of access.

7. How Shoovia uses the information provided by you?

7.1 We may collect, use, disclose and/or process your personal information for one or more of the following purposes:

a) Consider and/or process your applications/transactions with us or your transactions or communications with third parties through the Service;

b) Manage, operate, provide and/or handle your use and/or access to the Service and the Platform (including but not limited to recording your preferences), as well as your relationship with us and the user accounts you open;

c) Respond to, process or complete transactions and/or satisfy your requirements for specific products and services, and inform you of service problems and abnormal account operations;

d) Enforce our Terms of Service or any applicable end-user license agreement in each territory;

e) Protect personal safety, rights, property or the safety of others;

f) Identification and/or verification;

g) Maintain and manage occasional software updates and/or other updates and support required to ensure smooth operation of the Service;

h) Process or facilitate customer service, carry out your instructions, process or respond to all inquiries made by or on behalf of you (or claiming to be made by or on behalf of you);

i) Contact or communicate with you by phone call, text message and/or fax, E-mail and/or mail or other means for the purpose of executing and/or managing your relationship with us or your use of the Service, but not limited to conveying to you management information relating to the Service. You acknowledge and agree that we may communicate with you by mailing letters, documents and notices, and that your specific personal information may be disclosed outside the envelope / mail package during delivery;

j) Allow other users to interact with or contact you on the Platform, including notifying you when a user sends you a text message or publishes a comment about you on the Platform;

k) Conduct research, analysis and development activities (including but not limited to data analysis, questionnaire survey, product and service development and/or analysis) to analyze your use of our services, improve our services or products and/or enhance your customer experience;

l) Allow audits and surveys to identify the size and composition of the target audience and learn about their experience with Shoovia services;

m) For marketing and related purposes, send you products and / or services that Shoovia (and / or its affiliated enterprises or affiliated companies) may be selling, marketing or promoting (including but not limited to products and / or services of third parties that may cooperate with Shoovia or those jointly provided by third parties and Shoovia) through various communication methods. You can unsubscribe to receive marketing information at any time through the unsubscribe function in e-marketing materials. We may send you news about us and our affiliated companies via your contact information;

n) Respond to legal proceedings or comply with any applicable law, government or regulatory requirements in the relevant jurisdiction, including, without limitation, compliance with disclosure requirements under any legal provisions binding on Shoovia or its affiliates or associated enterprises;

o) Produce statistical data or conduct research for internal and statutory reporting needs and/or record keeping;

p) Conduct due diligence or other screening activities (including but not limited to background checks) in accordance with legal or regulatory obligations or in accordance with legal requirements or risk management procedures established by us;

q) Audit the Service or the business of Shoovia;

r) Prevent or investigate any real or suspected Shoovia policy violation, fraud, illegal activity, negligence or misconduct, whether related to your use of the Service or arising out of your relationship with us;

s) Store, host, and backup your personal information (whether for post-disaster data recovery or other purposes) within or outside your jurisdiction;

t) Process and / facilitate the transaction of business assets or the possible transaction of enterprise assets in which the participants include Shoovia, or only affiliates or affiliated enterprises of Shoovia, or any or more affiliates or affiliated enterprises of Shoovia and / or Shoovia, and there may be other third party organizations involved in the transaction. "Business Asset Transaction" means the acquisition, sale, lease, integration, merger or any other acquisition, disposal or financing of any business or asset of the organization or a part of the organization; and/or

u) Use the information for purposes not expressly stated in this Policy and for any other purpose to which we have communicated to you at the time of obtaining your consent. (Collectively, the "Purpose").

7.2 As the purpose for which we will / may collect, use, disclose or process your personal information depends on what happens in real time, such purpose may not be included in what has mentioned above. However, we will inform you of such purpose at the time of obtaining your consent, unless the relevant law allows us to process the applicable information without your consent.

8. How Shoovia protects your personal information?

8.1 We will take all kinds of reasonable and necessary security measures for which existing technology allows to ensure that your personal information is safe and secure on our system, including but not limited to physical, technical and administrative measures, so as to minimize the risk of loss, misuse, unauthorized access, disclosure and change. Due to various malicious means and continuous breakthroughs in science and technology, you understand and agree that even if we try our best to take the above measures, your personal information may still be leaked, damaged or lost. Shoovia shall assume no commitment or guarantee whatsoever.

8.2 We do not recommend our services to minors. Unless permitted by the local law and agreed by their guardians, minors are not allowed to register an account or send their personal information such as name, address, telephone number and email address to us. If we accidentally collect information about minors, we will delete it as soon as we know it. If you think we may have improperly held information from or about minors, please contact us.

8.3 We will retain your personal information in accordance with the relevant laws and regulations on privacy protection and / or other applicable laws, that is, we will destroy or anonymize your personal information if we reasonably believe that: (I) the retention of such personal information is no longer in line with the purpose of collecting personal information; (II) there is no longer a need to retain personal information for any legal or business purpose; and (III) further retention of such personal information is not guaranteed by any other legitimate interest. If you stop using our platform or your right to use the platform and / or the service is terminated, we will continue to process your personal information in accordance with the requirements of applicable laws in line with the obligations stipulated in this Privacy Policy and relevant privacy laws.

9. Will Shoovia disclose the information it collects from visitors to third parties?

9.1 In conducting our business, we will / may need to disclose your processed personal information to third party service providers, agents and / or our affiliates or affiliated enterprises and / or other third parties (whether located in China or not) for one or more purposes. Such third party service providers, agents and / or affiliates or affiliated enterprises and / or other third parties may process your personal information on our behalf or in other ways for one or more of the above purposes. The third party includes but is not limited to:

a) Our subsidiaries, affiliates and affiliated enterprises;

b) Users who use our website for one or more of the above purposes;

c) Contractors, agents, service providers and other third-party service providers that we use to support our business ("Authorized Partners"). These include, but are not limited to, organizations that provide us with management or other services, such as mailing companies, payment service providers, telecommunications companies, information technology companies and data centers; we will only share your information for the legal, legitimate, necessary, specific and explicit purposes of this Privacy Policy. Authorized partners can only access the information they need to perform their duties and shall not use such information for any other purpose.

d) Consolidate, divest, restructure, reorganize, dissolve, or otherwise sell or transfer (whether in the form of a going concern, or as part of a bankruptcy, liquidation, or similar procedure) part or all of the assets of Shoovia, or any other successor to Shoovia, in which personal information about the seller of the Service held by Shoovia is also in the transferred assets; Or a counter party to the business assets transaction in which Shoovia or any of its affiliates or affiliated enterprises participates;

e) A third party to whom we disclose personal information for one or more purposes, which may in turn collect and process your personal information for one or more purposes.

9.2 Among other things, statistics on the number of users and their usage of services may need to be shared with advertising and project providers. This information will not include any personal information that can be used to identify or find you.

9.3 For the avoidance of doubt, this authority shall continue to apply in cases where companies (i.e. Shoovia) are permitted under privacy laws and regulations to collect, use, or disclose your personal information without your consent.

9.4 Third parties may, without our fault, illegally intercept or access the personal information transmitted to our website or the personal information contained therein, the technology may malfunction or not operate as expected, or others may access, abuse or misuse the personal information. We will deploy reasonable security measures to protect your personal information in accordance with the relevant provisions of the privacy law, but inevitably cannot guarantee the absolute security, including but not limited to unauthorized disclosure caused by malicious and sophisticated hackers, instead of due to our fault.

10. Information collected by third parties

10.1 In order to provide better customer service and user experience, the Platform USES web page analysis services provided by Google, Inc. (hereinafter referred to as "Google") - Google Analytics. For example, Google Analytics uses cookies (text files on your computer) to assist websites in analyzing users' use of the platform. Information generated by cookies about your website usage (including your IP address) is sent and stored on Google's servers. Google will use this information to assess your website usage, compile activity reports for website operators, and provide other services related to website activity and Internet usage. Google may also be required by law to transmit this information to third parties or to third parties that process the information on Google's behalf. Google does not associate your IP address with other data held by Google.

10.2 We and third parties may download software applications for your use from time to time in or through the Service. These applications may individually access and allow third parties to view your identity information (i.e. your name, user ID, computer IP address, or other information), such as cookies that you previously installed or that were installed for you by third party software applications or websites. In addition, these applications may require you to provide additional information directly to third parties. Shoovia does not own or control third-party products or services provided through these applications. We recommend that you review the terms and other policies of such third parties posted on their websites or elsewhere.

11. Disclaimer on security and third party websites

11.1 We do not guarantee the security of your personal information and/or other information provided on third party websites. In order to maintain the security of the personal information we have or control about you, we do put in place various security measures. Your personal information is stored in a protected network accessible only to limited persons who have special access to the network and who are required to keep such personal information confidential. When you use the Service or submit personal information to the Platform, we will provide a secure server. All personal information provided by you will be stored in our database in an encrypted manner and accessible only in the manner set forth in the above terms.

11.2 In order to provide higher-valued services, we may choose to link various third-party websites to the Platform and put the third-party websites in the framework of this Platform. We may also participate in co-branding activities or establishing similar relationships to provide e-commerce and other services and functions for visitors. Such linked websites have independent privacy policies and security measures. Even if the third party is associated with us, we have no control over such linked websites, and each linked website has independent privacy rights and information collection practices that are not subject to us. We do not collect information collected by our partner brands or third party websites (even if provided on our website or through our website).

11.3 Therefore, we are not responsible for the content, security measures (or lack of such security measures) and activities of such linked websites. Such linked sites are only available for convenience and therefore should be at their own risk. Nevertheless, we still try to protect the integrity of the Platform and links placed on it. Therefore, you are more than welcome to provide us with your opinions on such linked websites (including but not limited to the cases where specific links cannot function).

12. Will Shoovia transfer your personal information abroad?

12.1 Your personal data and / or information may be transferred to a place outside your country / region for storage or processing. In most cases, your personal information is processed in the United States, where our server is located and we run our central database. Shoovia will only transfer your information abroad in compliance with relevant privacy laws and regulations.

13. How to withdraw consent to, delete, request access to or correct the information you provide?

13.1 Opt out and withdraw consent.

13.1.1 You may opt out by sending an email to support@shoovia.one to the Personal Information Security Officer, and no longer agree that we collect, use and/or disclose your personal information that is owned or controlled by us. We will act in accordance with this Privacy Policy and the relevant obligations under the privacy laws and other applicable laws. However, by opting out / withdrawing your consent, you indicate that we will be unable to continue to provide you with the our services and may require you to terminate your existing relationship and/or the contract on related services between us.

13.2 Request access to and/or correct your personal information.

13.2.1 If you have signed up with us, you may access and/or correct your personal information currently owned or controlled by us through your Account Manager or the corresponding page of the Platform. If you do not have an account, you may request access to and/or correct personal information currently owned or controlled by us by submitting a written request. You must provide sufficient information for us to ascertain your identity and the nature of your request in order to facilitate processing of your request. Please submit your written request by sending an email to contact@shoovia.one ("Personal Information Security Officer").

13.2.2 In some cases, we will/may charge you a reasonable fee to process your request for access to personal Information. If a fee will be charged, we will provide you with the items and prices in writing (including by email). Please note that we do not have to respond to or process your access request unless you agree to pay.

13.2.3 In accordance with the provisions of the privacy law, enterprises have the right to refuse to correct your personal information when requested and/or authorized under established circumstances, and we reserve the right to refuse to correct your personal information.

14. Contact us in case of questions, concerns or complaints

14.1 If you have any questions or concerns about our privacy practices or your transactions related to the Service, please feel free to contact us: contact@shoovia.one.

15. Our Privacy Policy is subject to change

15.1 We will update this Privacy Policy to provide you with better services and as the business of Shoovia develops. However, your rights under this policy will not be restricted without your express consent. We will post any changes to our Privacy Policy on Shoovia website.

15.2 For major changes, we will also notify you in more significant ways (we will explain the specific changes of the Privacy Policy by means including but not limited to e-mail, SMS, or displaying special alerts on the webpage).

15.3 Major changes referred to in this Privacy Policy include but are not limited to:

a) Where our service model has changed significantly (i.e. the purpose of personal information processing, the type of personal information processing, the use of personal information, etc.);

b) Major changes in our control and so on (i.e. the change of information controller due to merger, acquisition and reorganization);

c) The main subjects to which the personal information is going to share, transfer or publicly disclose have changed;

d) Significant change in your right to participate in the processing of personal information and the way you exercise it;

e) Changes in our departments and contact information as well as the channels for handling personal information security;

f) High risks indicated by the Impact Assessment Report for the Personal Information security. We will also archive an older version of this Privacy Policy on Shoovia for your reference.

Company Name: Starit Group Limited
Company Number: 66620028
Company Address: UNIT D, 11/F, TWO CHINACHEM PLAZA, 68 CONNAUGHT ROAD CENTRAL, CENTRAL, HONG KONG