Legal & privacy

WHEN WILL WE COLLECT PERSONAL DATA?
1. We will/may collect personal data about you:
A. When you register and/or use our services or platforms, or open an account with us;
B. When you submit any forms, including registration or other forms in connection with any of our products and services, online or otherwise;
C. When you enter into any agreement or provide other documents or information related to your interactions with us, or when you use our products and services;
D. When you interact with us, such as through phone calls (which may be recorded), correspondence, faxes, face-to-face meetings, social media platforms and email;
E. When you use our electronic services or interact with us through the platform, website, or services. This includes cookies, which we may deploy when you interact with our platforms or websites;
F. When you provide feedback or submit a complaint to us;
G. When you register for a contest;
H. When you submit your personal data to us for any reason.

WHAT DATA WILL WE COLLECT?
1. Personal data we may collect includes:
A. Full name;
B. Email address;
C. Date of birth;
D. Phone number;
E. Gender;
F. Information sent by or relating to the device(s) used to access our services or platforms;
G. Any other information gathered upon your logging into and using our services or platforms and how you use them; and
H. Aggregated content data.

2. You agree not to provide us with any inaccurate or misleading information, and you agree to notify us of any inaccurate or misleading information you may come across. We reserve the right in our sole discretion to request other documents necessary to verify the information you provide.

3. If you sign in to become a user of our platforms using your social media account, link your Union Square account to your social network account, or use any social networking feature, we have the right to access information about you that you have voluntarily provided to your social media account service provider per the policies of the provider(s). We will manage and use your personal data per the provisions of this policy at all times.

4. If you do not want us to collect the aforementioned personal information/data, you may opt-out at any time by notifying our data protection officer in writing. More information can be found under “How can you withdraw permission to use your name, request access, or correct information you have provided to us?”. Note, however, that refusing or revoking our permission to collect, use, or process your personal data may affect your use of the services and platform. For example, location services will not work if you do not allow the application to access your location.

ALTERNATIVE DATA COLLECTION
1. As with most websites and other mobile applications, your device sends information that may include data about you, which is recorded by a web server when you use our platform. This information includes IP address, computer/mobile device operating system, browser type, mobile device type, mobile device characteristics, uniform device identifier (UDID), or the mobile device identifier (MEID) of your mobile device, the site’s reference address (if applicable), the pages you have visited on our website or mobile application, length of visit, and sometimes “cookies” (which can be disabled using your browser preferences) to help the website remember your last visit. If you log in, this information is linked to your personal account. This information is also included in anonymous statistics to help us understand how visitors use our website.

2. Our mobile applications may collect accurate information about the address of your mobile device using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process this information for one or more purposes, including services provided based on your location, or to transmit relevant content to you based on your location, or to enable you to share your location with other users as part of the services offered by our website/mobile app.

For most mobile devices, you can withdraw your permission for us to collect this information based on your location through your device’s settings. If you have any questions about how to disable location services on your mobile device, please contact your mobile device service provider or device manufacturer.

COOKIES
1. We may sometimes use “cookies” or other features to enable third parties or ourselves to collect or share information that will help us improve our platform and the services we provide or help us roll out new services and features.

“Cookies” are identifiers we send to your computer or mobile device that allow us to identify your computer or device and let us know when the services or platforms are being used or accessed and by how many people as well as to track activities within our platforms. We may associate cookie information with personal data.

Cookies are also associated with information about the content you have selected for the shopping sites you have viewed or the games you have played. This information is used for shopping cart tracking, for example. Cookies are also used to deliver content based on your interests and to track usage of the services.

2. You can refuse the use of cookies by selecting the appropriate settings on your browser. Please note, however, if you do this, you may not be able to use the full functionality of the platform or our services.

WATCH AND DOWNLOAD CONTENT AND ADVERTISING
Because when you view pages on our website or mobile application, you view content and advertising and access other software on our platform or through the service, the majority of the same information will be sent to us (including IP address, operating system, etc.); but, instead of page views, your device sends us information about the content, advertisements viewed, and/or software installed on the services and platforms and when.

PURPOSE OF COLLECTING DATA
1. We may collect, use, disclose, and/or process your personal data for the following purposes:
A. To review and/or process your application/transaction with us or your transaction or correspondence with third parties via the services;
B. To administer, operate, provide, and/or manage your use and/or access to our services and platforms (including your preferences) and relationships and accounts you use with us;
C. To respond to, process, settle, and/or complete a transaction and/or respond to your requests for certain products and services, and to notify you of service issues and activity unusual to your account;
D. To enforce our terms of service or any applicable end-user license agreement;
E. To protect personal safety and the rights, property, or safety of others;
F. For identification and/or verification;
G. To maintain and manage any software and/or other updates and support as may be required from time to time to ensure the smooth functioning of our services;
H. To address or facilitate customer service, carry out your instructions, resolve or respond to any inquiries submitted by (or intended to be submitted by) you or on your behalf;
I. To contact you or communicate with you by telephone, text message, and/or fax message, email and/or mail or otherwise to administer and/or manage your relationship with us or your use of our services, such as, in communicating administrative information to you regarding our services. You acknowledge and agree that our such communication may be by mail, document, or notice to you, which may include disclosure of certain personal data about you to provide such documents as well as on the package/envelope;
J. To allow other users to interact with or communicate with you through the platform, including to notify you when another user has sent you a private message or posted comments to you on the platform;
K. To conduct research, analysis, and development activities (including data analysis, surveys, product and service development, and/or characterisation), to analyse how you use our services, to improve our services or products and/or to improve your customer experience;
L. To allow advertising, audits, and other surveys, among others, to verify the size and composition of the respondents and understand their experiences with the services;
M. For marketing purposes, in this case, to communicate with you through various methods of marketing and promotional information and materials relating to products and/or services (including products and/or services of third parties with whom we may cooperate or be affiliated). We may sell, market or promote to you whether such products or services exist at a given time or will be available in the future. You may unsubscribe from marketing communications at any time by using the unsubscribe function in electronic marketing materials. We may use your contact information to send newsletters from Union Square or our related companies;
N. To respond to legal proceedings or to comply with or as required by applicable law and the requirements of competent governmental authorities;
O. To compile statistics and research to meet reporting requirements and/or maintain internal or regulatory records;
P. To perform discovery and verification or other screening activities (including background checks) in compliance with our regulatory obligations or risk control procedures may be required by law or may have been applied by us;
Q. To check our services or operations;
R. To prevent or investigate any fraudulent, illegal, omission or misconduct, whether or not occurring, in connection with your use of our services. Any problems arising from your relationship with us;
S. To store, host, back up (whether for disaster recovery or other purposes) your personal data; and/or
T. Any purpose(s) for which we notify you at the time of obtaining your permission.

2. As the purposes for which we will/may collect, use, disclose, or process your personal data depend on the existing circumstances, such purposes may not appear above. However, we will notify you of such other purpose(s) when obtaining your consent, unless the applicable data processing without your consent is permitted under the provisions of the law on privacy protection of personal information.

HOW WE PROTECT AND STORE CUSTOMER INFORMATION
1. We implement various security measures and make every effort to ensure the safety of your personal data on our systems. Users’ personal data is stored behind secure networks and can only be accessed by certain employees with special permissions within our systems.

2. We will maintain personal data in accordance with applicable privacy or general laws. That is, we will destroy or remove identifying information from your personal data when we have reasonable cause to determine that (i) the retention of such personal data is no longer serving the purpose for which such personal data was originally collected; (ii) retention is no longer required for any lawful or business purposes and (iii) there is no longer any other legitimate interest to keep this personal data.

If you stop using our platform, or your right to use the platform and/or services is terminated or cancelled, we may continue to save, use, and/or your disclose data. Your personal information is subject to this Privacy Policy and our obligations under the laws on protecting the confidentiality of personal information. Subject to the law, we may securely destroy your personal data without prior notice to you.

DOES THE MALL DISCLOSE INFORMATION COLLECTED FROM ACCESSORIES?
1. In doing business, we will/may need to disclose your personal data to third-party service providers, agents, and/or affiliated companies, our related parties, and/or other third parties, for one or many of the preceding purposes, and such disclosure will be made in accordance with the order and provisions of applicable law. Such third-party service providers, agents, and/or affiliated or related companies and/or other third parties will process your personal data on our behalf or other, for one or more of the previous purposes. Such third parties include:
A. Our subsidiaries, affiliates and related companies;
B. Contractors, agents, service providers and other third parties we hire to support or supplement our business. These parties include, but are not limited to, those that provide administrative or other services to us such as postal companies, telecommunications companies, information technology companies, e-commerce operations, and data centres;
C. Third parties to whom we disclose information for one of the purposes and such third parties will, in turn, collect and process your personal data for one or more purposes.

2. This may require, among other things, sharing statistical and demographic information about the user and the user’s use of the services with advertising and programming partners. We will also share statistical and demographic information about our users and their use of the services with programming and advertising service providers. This case will not include any information that could be used to specifically identify you or disclose personal information about you.

3. For the avoidance of doubt, if privacy laws or other applicable laws permit an organisation such as us to collect, use or disclose data personally without your consent, such permission by law will continue to apply.

4. Third parties may intercept or gain unauthorised access to personal data submitted to or contained on the website, technologies may not work correctly or not as intended, or may be accessed by someone or misused through no fault of ours. However, we will implement reasonable security measures to protect your personal data in accordance with the provisions of the law on the protection of the confidentiality of personal information; however, absolute security cannot be guaranteed, such as unauthorised disclosure arising from hacker activity because of malicious intent or the complexity of malicious content through no fault of ours.

INFORMATION ABOUT CHILDREN
These services are not intended for use by children. We do not knowingly collect or store any personal data or non-personally identifiable information from children, nor does any part of our platform or other services.

Parents or guardians of children, please supervise and ensure that the personal information of children under your custody do not provide us with personal information. If the personal information of children is provided to the mall by custodial parents, the parent or guardian agrees to the processing of the children’s information and agrees to be governed by this Policy on behalf of the ward. We will lock down any accounts used solely by children and will remove and/or delete any personal data that we believe has been submitted by a child.

INFORMATION COLLECTED BY THIRD PARTIES
1. Our platform uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your device, to help the platform analyse how users use our platform. The information generated by the cookie about your use of the platform (including your IP address) will be sent to and stored by Google on servers in the United States. Google will use the information to evaluate your use of our platform, compile reports on website activity for website operators, and provide other services related to website activity and Internet usage. Google may also send this information to third parties where required by law or where such third parties process the information on behalf of Google. Google will not associate your IP address with any other data that Google holds.

2. We, and third parties, may occasionally make downloads of software applications available to you for use of the platform or through the services. These applications may privately access, and allow a third party to view, your identifying information, such as your name, user ID, your device’s IP address, or other information such as the article you are reading during any particular session, and any cookies you may have previously set or have been set for you by a software application or third-party website. In addition, these applications may ask you to provide additional information directly to third parties. Third-party products or services offered through these applications are not owned or controlled by Union Square. You should read the terms and other policies published by such third parties on their websites or elsewhere.

DISCLAIMER OF SECURITY OBLIGATIONS AND THIRD-PARTY SITES
1. WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We implement various security measures to maintain the safety of your personal data that we hold or control. Your personal data is stored behind secure networks and can only be accessed by a limited number of individuals who have special access rights to our systems and have been required to keep the data secure. When you place an order or access your personal data, we recommend using a secure server. All personal data and information you provide will be encrypted into our databases to be accessed only as described above.

2. To provide you with added value, we may choose different third-party websites, applications, or services to link to and frame within the platform. We may also enter into co-marketing and other relationships to provide our visitors with e-commerce and other services and features. These linked sites have separate and independent privacy policies and security measures. Even if such a third party is affiliated with us, we do not control these linked websites/applications/services, each of which has its own privacy protection and data collection practices or separate material independent of us. Data collected by our co-marketing partners or third-party websites/apps/services (even if made available on or through our platform) may not be accessible to us.

3. We, therefore, accept no responsibility or liability for the content and security practices (or lack thereof) of these linked websites/applications/services. These linked websites/applications/services are solely for your convenience, and you are therefore solely responsible for accessing them. However, we seek to protect the integrity of our platform and the links placed on each of those websites and we, therefore, welcome feedback on these linked sites (including if a particular site is down).

HOW CAN YOU WITHDRAW, DELETE, REQUEST ACCESS, OR ADJUST THE INFORMATION YOU PROVIDE TO US?
Withdrawal of Consent
1. You may withdraw your consent to the collection, use, and/or disclosure of your personal data that we hold or control by emailing our Personal Data Protection Department me at __(email address)__ or via <LINK>, and we will process these requests in accordance with the Privacy Policy and relevant laws.

2. However, your withdrawal of consent may mean that we will no longer be able to provide services for you, and we may need to terminate your current relationship and/or contract with us.

3. When you share YouTube Content, in addition to withdrawing your consent by emailing us, you may opt-out of Union Square’s access to your personal information through Google security at https://security.google.com/settings/security/permissions.

Request Access to or Correction of Personal Data
4. If you have registered an account with us, you may personally access and/or correct your personal data through the Account Settings page or label on the platform. If you have not registered an account with us, you can personally request to access and/or correct your personal data that we hold or control by submitting a written request to us. We will need sufficient information from you to determine your identity and the nature of your request to process it. Therefore, please submit your written request by emailing our Data Management staff <LINK>.