Shopstar PTY LTD (we, us, our, flick, flick live) understand that your privacy is important and we are committed to safeguarding personal information about individuals that we handle. This Privacy Policy describes generally how we manage your personal information and protect your privacy.

This Privacy Policy is intended to provide a general overview of our policies in respect of the handling of your personal information (whether you are a merchant, end user that uses our products, technology, platforms, applications or services (together the Services), a customer of a store or entity that uses our technology, a participant in our ‘Partner’ programs or whether you are simply visiting our websites). “Personal information” is essentially information or an opinion about an identified or reasonably identifiable individual.

By using any of our Services, or by dealing with a merchant or other entity using our Services, you are agreeing to the terms of this Privacy Policy and, as applicable, our Contract and Terms of Use.

Other policies may override or complement this Privacy Policy in certain circumstances. For example, when we collect personal information from you, we may advise a specific purpose for collecting that personal information, in which case we will handle your personal information in accordance with that purpose.

This Privacy Policy is intended to cover most personal information handled by us, but is not exhaustive. If you have any queries about our handling of your personal information, please contact us for further information using the details below.

We may update this Privacy Policy from time to time including in relation to changes to our privacy practices or for other operational, legal, or regulatory reasons. If material changes are made to this Privacy Policy, we will give you notice by posting the revised policy on our website, and where appropriate, by other means. By continuing to use our website or Services after any changes are posted, you agree to the revised policy.

We may collect your personal information throughout the course of your interaction with us (for example, if you obtain products or services from us, subscribe to our mailing list, fill out an online contact form, engage with our online marketing or submit an enquiry to us). The personal information that we may collect and hold about you depends on your dealings with us. Generally, we may collect:your name and address, email address, telephone number; payment details; business details; and other personal information that we require or that you volunteer to us (such as your resume, details of your qualifications, skills, education provider, work history and residency status in the event that you apply for employment or a position with us).

Generally speaking, we collect personal information so that we can provide better services to you and ensure that you have convenient access to our services.

We will collect your personal information directly from you unless it is unreasonable or impracticable to do so. If circumstances require, we may collect personal information about you from third parties (such as your employees, representatives or personal referees) or publicly available resources. All personal information we collect is limited to that which is reasonably necessary for our functions or activities.

We receive any personal information that you provide to us from third parties (for example, an employee of your business or a referee) on the understanding that we have that individual’s consent for us to collect and handle their personal information in accordance with this Privacy Policy.

When collecting your personal information, we will take reasonable steps to make you aware of the purposes for which we are collecting it, the types of organisations to which we would usually disclose it, whether we are likely to disclose it to overseas recipients (and where practicable the countries in which they are located), whether there are laws or court/tribunal orders which require or authorise us to collect it, and the main consequences for you if you fail to provide it to us. This Privacy Policy provides these details as they typically apply in most cases, however different details may apply depending on our specific interaction with you. If we do not notify you of such other details, the information in this Privacy Policy applies.

If you fail to provide personal information requested by us, or if the personal information you supply is incorrect or incomplete, there may be a range of consequences, for example we may be unable to process or respond to your request. There will not usually be South African laws or court/tribunal orders which require or authorise us to collect your personal information.

We do not generally collect sensitive information. If we do collect sensitive information about you (which may include your race, ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships or details of health or disability), we will only do so with your consent and if the information is reasonably necessary for one of our functions or activities. We will assume you have consented to us collecting, using and disclosing (in accordance with this Privacy Policy) all information that you provide to us, including any sensitive information, unless you tell us otherwise at the time of collection.

The type of personal information we collect will depend on your dealings with us and your use of the Services. For example:

Personal and contact details (for example vendor’s name, email address, home address, telephone number, date of birth, gender) to enable the provision of services and to facilitate our and any other users’ relationship with you, including relevant marketing; personal and contact details you give us when subscribing to receive emails, newsletters or marketing information from us; payment details; purchase and business history; additional information which you provide voluntarily and/or which we may ask from you to better understand you and your interests; data about your use of our Services, including when you access your account and our platform(s), including information about the device and browser you use, your network connection, your IP address, and information about how you browse through the our interface and platform; personal information about your customers that you share with us or that customers provide while shopping or during checkout;

If we need to verify your identity (for example, if there are concerns around identity theft, or if you call into support and we need to authenticate your account), we may request that you provide us with government-issued identification information as well as business information;

We may use some of the personal information you provide us to conduct some level of automated decision-making – for example, we use certain personal information to help us screen accounts for risk or fraud concerns; Information required to perform KYC and AML checks prior to enabling the Vendor’s access to the platform and prior to making disbursements to the Vendor. Vendor business address or other such contact information in order to facilitate shipments from the Vendor.

‍Customers

We collect Vendors’ and any other users’ customers’ name, email, shipping and billing address, payment details, company name, phone number, IP address, information about orders you initiate, information about our supported vendor stores that you visit, and information about the device and browser you use; and we use some of the personal information you provide us to conduct some level of automated decision-making — for example, we use certain personal information (for example, IP addresses or payment information) to automatically block certain potentially fraudulent transactions for a short period of time.

‍Suppliers

Contact details to enable the provision of your services to us and the fulfilment of our contract obligations, this may include names, email addresses and telephone numbers; and bank details and any other details required to enable payment for the services supplied.

‍Clients

Your contact details or those of individuals at your organisation (such as names, telephone numbers and email addresses) to enable the provision of services and to facilitate our relationship with you, including relevant marketing.

We will generally only use your personal information for the purpose for which we collected it, and for related purposes we consider would be within your reasonable expectations.

We generally use personal information for the following purposes (as applicable in the circumstances):

to provide products or services to you or for your benefit;

to provide information that you request, to respond to your enquiries, or otherwise achieve the purpose for which you have contacted us;

to handle payments;

to provide you with marketing and promotional material regarding our or users of our Services’ products or services, including newsletters or other materials;

to seek feedback from you and perform market research, so that we can gauge your satisfaction with our products or services;

onboard and manage vendors on our platform;

collect specific information from vendors to determine if the vendor qualifies to join the platform;

attributes for vendors that can be used to search, filter, find and engage that vendor on the platform;

enable and assist to:

facilitate sign up of customers to the platform;

facilitate transactions between customers and vendors on the platform;

enable transactions and fulfilment of services between vendors and customers on the platform;

enable collection of payment information and processing of payment information on behalf of customers on the platform;

facilitate payments, payouts and disbursements to the vendors on the platform;

facilitate support, triage and other help services for both vendors and customers on the platform;

for our general business operations (such as maintenance of our business records and compliance with our legal and insurance obligations); and

to engage in other activities where required or permitted by law.

By providing us with your personal information, you consent to us using your personal information for these purposes.

You agree that we may send you marketing or promotional communications by post or by electronic means (including email and SMS and push notification). You may request not to receive such material from us by contacting us via the details below or by using the opt-out function provided for in those communications. If you do not opt-out in either of these ways you will be taken to have consented to receiving such communications from us.

There are no consequences of opting-out of receiving our marketing and promotional communications except that you will no longer receive them, and you may elect to re-join our marketing list at a later stage if you wish.

Where we propose to use your personal information for a purpose other than as outlined above, we will seek your permission (unless we are required or permitted by law to do so without seeking consent).

We take reasonable steps to protect your personal information from misuse, interference and loss as well as unauthorised access, modification or disclosure.

For example, information stored on our computer network is protected by security features and procedures. We undertake regular monitoring of our practices and systems to ensure the effectiveness our security policies and identify and implement improvements where appropriate.

We make use of cloud-based services for our business systems. Our data may be stored with these cloud providers in locations outside of South Africa, including Europe and the Americas, depending on where the specific infrastructure is located.

Generally, we will take reasonable steps to destroy or permanently de-identify your personal information as soon as it is no longer required by us or another user of the Services, for example vendors. We may retain your personal information where we are required or permitted to do so by law, such as for insurance, legal or corporate governance purposes and for the prevention of fraud. Your personal information may also be retained in our IT system back-up records.

We acknowledge and respect the importance of your privacy rights and are committed to providing mechanisms for you to exercise those rights. In compliance with the applicable laws and regulations, we have instituted processes to allow you to request deletion of your personal data we process.

If you would like to request deletion of your personal data, you can do so in the following ways:

Through the application: Navigate to the ‘Profile’ section of the app, then select ‘Account’. Here you will find the ‘Delete Account’ button. By clicking on it, you can initiate a request to delete your data. Please note, upon confirmation, this action is not reversible.

Via Email: If you prefer, you may also request deletion of your data by contacting us directly at our designated email address, support@flick.live. In your email, please include your full name, the email address associated with your account, and a clear statement that you want to delete your personal data. Upon receiving your request, we will verify your identity before processing the deletion.

Upon receiving your deletion request, we will process it in accordance with applicable laws and regulations. It’s important to note that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

We are Processing your data to provide you with the best possible experience when using our application. The primary uses of your data include personalising your user experience, improving our services, communicating with you about the application and our other services, and providing customer support.

Please remember that if you choose to delete your data, some or all parts of the application may not function as intended.

This policy is part of our commitment to ensuring that we process your personal data transparently and in accordance with applicable law. Please review this privacy policy regularly to stay informed about how we are protecting the personal data we collect. If you have any queries regarding the deletion of your data, please contact us at support@flick.live.

We will generally only disclose your personal information for the purpose for which we collected it, and for related purposes we consider would be within your reasonable expectations.

We may disclose your personal information to the following third parties (as applicable in the circumstances):

certain suppliers that provide services to us (for example, subcontract product manufacturers, market research companies or other service providers). We generally ensure such organisations are contractually required to ensure that information we disclose is used only for the limited purposes for which we provide it;

contractors that we engage as part of providing services to you; or

members of our corporate group.

service providers such as payments and B2B software solutions we make use of.

We are not generally likely to disclose personal information to overseas recipients, except with your consent or where we are required to or authorised to do so by law. Please see part 9 below for further information.

You may contact us to request access to or correction of the personal information we hold about you. We may refuse to allow access or to amend your personal information if we are legally required or entitled to do so. If we do so, we will provide you with written reasons for the refusal (unless it is unreasonable to do so) together with information about the options available to complain about the refusal.

We may require you to pay certain costs in order to access your personal information held by us. We will advise the amount payable (if any) once we have assessed your application for access. We will not however charge a fee for you to lodge a request for access to or correction of your personal information.

If you lodge a request for access to your personal information, we may fulfil that request in any of a range of ways (for example, by supplying you with a copy of that personal information or providing you with the opportunity to inspect our records). We may require you to comply with certain procedures before we allow access to or amendment of your personal information to ensure the integrity and security of information that we hold. Depending on the nature of your request, this may include completing a personal information request form or otherwise verifying your identity to our satisfaction.

We will take reasonable steps to ensure that the personal information that we collect is accurate, up-to-date and complete and the personal information we use and disclose is accurate, up-to-date, complete and relevant. If we are satisfied that any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will amend our records accordingly.

Please notify us if your personal details change so that we may keep our records current.

This section of our Privacy Policy sets how we handle your personal information in respect of online services provided by us (which includes any services provided by us via the Internet, such as our website, and also includes email communications between us).

7.1 Automatic server logs

Our servers automatically collect various details when you use our website and platform, including:

your IP (Internet Protocol) address (generally, an identifier assigned to your computer when it is connected to the Internet);

the operating system and Internet browser software you are currently using; and

the data you access (such as web pages or other document files or software), and the time that you access it.

We do not attempt to identify individuals using this information, and only use it for statistical analysis, system administration, and similar related purposes. This information is available to vendors who use Flick’s platform as a service solution and its associated applications and services.

7.2 Cookies and similar technologies

Our website uses “cookies”, which identify your computer to our servers when you visit our website. We have also collect personal and other information using cookies. A web cookie is a small string of text sent from a website and placed on user’s hard drive by the user’s web browser during data exchange that happens when a browser visits a website.

Cookies allow a website to store information on your machine or mobile device and retrieve it later. Some cookies are managed by us (first-party cookies), while others are managed by third parties that we do not control (third-party cookies), such as Google Analytics. Personal information may also be collected or identified by other data collection or tracking technologies, such as web beacons, which imbed graphic files into our websites and online services which can be used to identify when someone visits our websites or online services, or in the case of web beacons, when an email is read or forwarded.

These small data files, cookies, and graphic files that may be on our websites, platform or systems serve various functions including:

delivery of our Services;

enhancement of our Services;

targeted ads (e.g. from Google or Facebook);

tracking performance and engagement across our website and Services;

creation of user statistics and analytics for our website, platform or systems;

management of transactions across multiple pages;

authenticating you to systems and keeping you logged into those systems; and

remembering your preferences.

Our website may store cookies on your computer in order to improve and customise your future visits to the website. By using cookies, our site can provide customised content to you. If you do not want information collected through the use of cookies, you may be able to configure your Internet browser to disable cookies.

We do not attempt to specifically identify and track individuals using cookies.

You may choose not to accept cookies in connection with your use of our website or Services by deleting, blocking or disabling cookies via your browser settings (however, this may affect the use or functionality of some webpages or online services).

7.3 Google AdWords Remarketing

We use a Google AdWords advertising feature called Remarketing, as well as Google Analytics services. These services make use of cookies and similar technologies, analytics and other identifiers to collect data about website traffic. For more information about Google Analytics and how it collects and processes data, see here.

These features also allow our advertisements to be displayed to individuals that access our website or platform when they subsequently visit other websites across the Google Display Network, and allow us to better understand how individuals interact with those advertisements and our website and platforms generally. For example, third-party vendors may use cookies to select advertisements based on an individual’s browsing history including previous visits to our website and platform. Our use of Google services (and in particular, Remarketing) assists us in identifying and providing services to current and potential customers.

Users can usually block cookies, or remove cookies, by editing the privacy and security settings of their web browser or mobile device. Some features of our website may require cookies to function properly. If cookies are disabled or deleted, then depending on the particular cookie that is deleted or disabled, users may not be able to use such features of our website, or previous opt-outs may be undone.

By using our website, individuals consent to the storing and accessing of cookies or other information on their device for the purposes of Google AdWords and Analytics, unless they have opted out. It is possible to opt out of Google AdWords and Analytics advertising features, such as interest based advertising served by Google on its products or across the Google Display Network, as well as prevent the collection of certain data, by visiting the Google Ads Settings website or through other available means. The Google opt-outs do not stop all advertising. Google may still serve advertising that is not interest based, and the user may still receive interest based advertising that is not served by Google.

7.4 Email and messages

We may collect personal information from you (such as your name and email address, and any other personal information you volunteer) if you send us an email. We will use this to contact you to respond to your message, to send you information that you request, and for other related purposes we consider are within your reasonable expectations. We will not use or disclose any such personal information for any other purpose without your consent.

7.5 Storage and transmission of personal information online

If you provide any personal information to us via our online services (including email) or if we provide such information to you by such means, the privacy, security and integrity of this information cannot be guaranteed during its transmission unless we have indicated beforehand that a particular transaction or transmission of information will be protected (for example, by encryption).=

7.6 Other online services

If any of our online services (including any email messages we send to you) contain links to other online services that are not maintained by us, or if other services link to our online services, we are not responsible for the privacy practices of the organisations that operate those other services, and by providing such links we do not endorse or approve the other services. This Privacy Policy applies only in respect of our Services.

Our platform allows vendors and other third parties to connect stores with third party applications, including, for example, to alter their store or provide new functionalities. We are not responsible for and have no control over how these applications function. Vendors ultimately can control which applications they choose to use with their stores, and are responsible for making sure that they do so in compliance with relevant privacy and data protection requirements.

We are committed to ensuring that your personal information is secure, accurate, current and up-to-date. We communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within our company.

If a data breach or suspected data breach occurs, we will undertake a prompt investigation, which will include an assessment of whether the incident is likely to result in serious harm to any individuals. In such a situation we will comply with the requirements of the Protection of Personal Information Act, which may require notification to the Information Regulator, and relevant authorities and affected individuals. Please contact us if you have reason to believe or suspect that a data breach may have occurred, so that we can investigate and, if necessary, undertake appropriate containment, risk mitigation and notification activities as required.

If you have a complaint about the way in which we handle your personal information, or you believe that a breach of your privacy has occurred, please contact us using the details below.

Your complaint will be considered and dealt with by our nominated representative, who may escalate the complaint internally within our organisation if the matter is serious or if necessary to resolve it.

Please allow us a reasonable time to respond to your compliant.

From time to time, it may be necessary for us to review our Privacy Policy. We will notify you of any changes by posting an updated version on our Websites.

If you would like further information about the ways we manage your personal information, please contact us by email on support@flick.live

Shopstar Pty Ltd

Attn: Privacy Officer, 2 Darters Road, Cape Town, South Africa, 8001