1. WHAT PERSONAL DATA WE COLLECT AND HOLD, AND HOW WE COLLECT IT
Seobli collects, processes, and stores Personal Data via your use of the Service or where you have given your consent. To understand how Seobli protects the data it collects from its users, please see Section 14 (“Information Security”) below. We collect information you provide during a Seobli platform on-boarding process, which may be a completed, incomplete, or abandoned process. We also collect Personal Data when you communicate with us through customer support, subscribe to marketing communications, correspond with us by phone, email, or other communication channels, or when you conduct a transaction on a Seobli Platform. We may actively or automatically collect, use, store, or transfer your Personal Data, which may include, without limitation, the following: Personal identification information such as name, email, phone number, nationality, date of birth, address, and government identification information; Institutional details such as corporate legal name, corporate registration information, government identification number, proof of identity and legal existence, address, business description, and beneficial owner information; Commercial information such as data related to transactions conducted on a Seobli Platform; Financial information such as credit/debit card numbers and bank account information; Correspondence Information such as communication with our Customer Support team and response to user surveys, chat logs; Information required by regulatory agencies such as state and federal licensing authorities and consumer protection agencies; and Other identifiers such as device fingerprint data, IP address, MAC number geolocation information, signals relating to user behavior and device interactions, unique device identifiers and session information for the devices used to access a Seobli Platform. Information about applications installed on your device and your device settings, to better protect you against interference with your use of our Services by verifying and alerting you if you have any suspicious or malicious applications on your device or if your device may have been jailbroken. Sampling rate sensors and external storage device information and activities. Certain optional information which you may choose to submit or share, such as an avatar, nickname, or “handle”. We may also collect Personal Data about you from third parties, such as electronic verification Services, referrers, marketing agencies or liquidity providers. If so, we will take reasonable steps to ensure that they are made aware of applicable privacy laws. We may also use third parties to analyze traffic on our website, which may involve the use of cookies. Information collected through such analysis is not anonymous. We will not collect Sensitive Information about you without your consent, unless an exemption or exception applies. These exemptions or exceptions include if the collection is required or authorized by law, or if it is necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct. If the Personal Data we request is not provided by you, we may not be able to provide you with the benefit of our Services or meet your needs appropriately. Accordingly, we do not give you the option of dealing with us anonymously or under a pseudonym. Furthermore, we conduct business and collect Personal Data from individuals and entities located in various jurisdictions in accordance with data protection laws. Where applicable, we are required to protect Personal Data processed in such jurisdictions in accordance with the applicable data protection laws. To understand more about how we protect the data collected from individuals and entities located within such jurisdictions, please see Sections 18 and the sections that follow.
2. UNSOLICITED PERSONAL DATA
We may receive unsolicited Personal Data about you. We destroy or de-identify all unsolicited Personal Data we receive, unless it is relevant to the purposes stated in this Privacy Notice for collecting Personal Data. We may retain additional information we receive about you if it is combined with other information we are required or entitled to collect. If we do this, we will retain the information in the same way we hold your other Personal Data.
3. WHO WE COLLECT PERSONAL DATA ABOUT
The Personal Data we may collect, and hold includes (but is not limited to) Personal Data about users, potential users, service providers or suppliers of a Seobli platform or our Services, prospective employees, employees and contractors and other third parties with whom we come into contact.
4. HOW WE USE YOUR PERSONAL DATA
Seobli uses Personal Data to administer, deliver, improve, and personalize the Services for you and to comply with our legal and regulatory obligations. We also may use such data to communicate with you in relation to other products or Services offered by Seobli and/or its partners to consider any concerns or complaints you may have. We may use and disclose your Personal Data for any of these purposes. We may also use and disclose Personal Data for secondary purposes which are related to the primary purposes set out in this section, or in other circumstances authorized by the law. Sensitive Information will be used and disclosed for the purpose for which it was provided (or a directly related secondary purpose), unless you explicitly consent otherwise, or an exemption under law applies. Furthermore, third-party payment processors may be used by us to process payments to, receive payments from, initiate a purchase, or carry out other transactions with you. Your information will be received and stored by the payment processors. To safeguard your financial information, we may be provided with a unique token and/or partial payment information for reference. Additionally, these payment processors may collect information about how you use their Services for analytics purposes; this is controlled by your Service settings and their privacy notices. In addition, for us to improve the quality, efficiency, and personalization of our services, we utilize artificial intelligence, machine learning, and other automated systems ("AI Systems"). This helps us to provide better customer support and make recommendations, automate certain processes, and enhance your overall experience. While we deploy these AI Systems to improve our Services and security, Seobli makes no guarantees, representations, or warranties regarding the continuous, uninterrupted, or error-free operation of such systems. Seobli does not warrant the accuracy, completeness, or reliability of any information generated by such AI Systems. All rights, responsibilities, and limitations of liability applicable to our Services as outlined in these Terms of Service also extend to our use of AI Systems.
5. HOW WE STORE YOUR PERSONAL DATA
We recognize the importance of securing the Personal Data of our users. We take steps to ensure your Personal Data is protected from misuse, interference or loss, and unauthorized access, modification or disclosure. Your Personal Data is generally stored in our or our affiliates ‘computer databases and/or with third party storage providers. In relation to information that is held on our computer database, we apply data security guidelines to ensure that your Personal Data is managed securely. The data that we collect from you may be transferred to, and stored at, a destination outside of the country of your residence. It may also be processed by staff operating outside of your residence who work for us or for one of our Service providers. By submitting your Personal Data, you expressly consent to this transfer, storing or processing, except users located in certain jurisdictions, as detailed in Sections 18 and the sections that follow. We retain your Personal Data for as long as is reasonably necessary to provide Services to you, for our legitimate business purposes, and to comply with our legal and regulatory obligations. If you close your account on a Seobli Platform, we will continue to retain your Personal Data as necessary to comply with our legal and regulatory obligations. For example, we are subject to certain anti-money laundering laws which require us to retain records we used to comply with our client identification and due diligence obligations for an additional period after our business relationship with you has ended.
6. SENDING INFORMATION TO OTHER COUNTRIES
The Seobli group operates a global business and Personal Data may be stored and processed in any country where we are licensed and have a physical presence, or where we have operations and where we may engage service providers, including Malaysia, Vietnam, and Argentina. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected. Those other countries may have data protection or privacy rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Notice. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data. By communicating electronically with Seobli, you acknowledge and agree to your Personal Data being processed in this way.
7. ACCESS, CORRECTION, AND DELETION OF YOUR PERSONAL DATA
Subject to exceptions set out in the law, you have the right to obtain a copy of your Personal Data upon request and ascertain whether the information we hold about you is accurate and up-to-date. We will provide access within 30 days of your request. If we refuse to provide the information, we will provide reasons for the refusal. We will require identity verification and specification of what information is required before providing you with access. If any of your Personal Data is inaccurate, you may request to update your information. Where we are satisfied that the request to update the information is accurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. If you are entitled by law, you may request to delete your Personal Data, with the exception that we may refuse your deletion request in certain circumstances, such as compliance with law or legal purposes. To request withdrawal of your previously provided consent, please send an email with your request to the relevant email address with the subject “DATA INQUIRY REQUEST”.
8. CHILDRENS’ PERSONAL DATA
Seobli does not knowingly offer Services to or collect the Personal Data of anyone under the age of 18. If we learn that we have collected Personal Data of anyone under the age of 18, we will promptly delete it from our systems. If you are aware of anyone under the age of 18 using our Services, please notify us so we can take prompt action to prevent access to our Services.
9. COMMUNICATIONS
We may only use Personal Data we collect from you for the purposes of direct marketing with your consent, where we provide a simple way of opting out of direct marketing, and you have not requested to opt out of receiving direct marketing from us. If we collect Personal Data about you from a third party, we will only use that information for the purposes of direct marketing if you have consented (or it is impracticable to obtain your consent) and we will provide a simple means by which you can easily request not to receive direct marketing communications from us. We will draw your attention to the fact you may make such a request in our direct marketing communications. We may communicate company news, promotions, and information relating to our products and Services provided by Seobli. We may share Personal Data with third parties to help us with our marketing and promotional projects or sending marketing communications. Users can opt out from these marketing communications at any time by following the unsubscribe link within any marketing communications sent to you or by contacting our Customer Service. For Services related communications, such as surveys, policy/terms updates and operational notifications, you will not be able to opt out of receiving such information.
10. COOKIE USAGE
While you access our website, i.e., www.seobli.com, we may use the industry practice of placing a small amount of data that will be saved by your browser (“Cookies”). This information can be placed on your computer or other devices used to visit our Site. We use Cookies to enhance your experience of using our Site. The information is used to identify users, remember user preferences and allow users to complete tasks without having to re-enter information when browsing from one webpage to another or when re-visiting our website at a later date. We also use Cookies to collect and analyze website usage data, related to user use and patterns. This data is used to improve our website and enhance users ‘experience. We may also use the information collected to ensure compliance with our regulatory and Anti-Money Laundering (“AML”) requirements, and to ensure your account security has not been compromised by detecting irregular, suspicious, or potentially fraudulent account activities. Set up, you can set your browser to block or alert you about these Cookies, but this may affect the functionality of the Services or your user experience. Session Cookies are added when a user starts to browse our website or interacts with a specific feature and are deleted when the browser is closed. Persistent Cookies are added when a user starts to browse our website or interacts with a specific feature but may remain stored on your device until a certain termination date is reached.
11. INFORMATION SECURITY
We endeavor to protect our Site and you from unauthorized access, alteration, disclosure, or destruction (or other similar risks) of Personal Data we collect and store. We take various measures to ensure information security, including: encryption of our Site communications; required two-factor authentication for all sessions; periodic review of our Personal Data collection, storage, and processing practices; and restricted access to your Personal Data on a need-to-know basis for our employees and Service providers who are subject to strict contractual confidentiality obligations.
12. CHANGES TO OUR PRIVACY NOTICE
We may update this Privacy Notice at any time by posting the amended version on the Seobli Platform including the effective date of the amended version, so please check frequently to see if there are any updates and changes. Your continued access to or use of a Seobli Platform and/or the Services constitutes your acknowledgment and acceptance of such changes to this Privacy Notice.