Echotomato Privacy Policy

Echotomato understands that our users care about their personal data and how it is collected, used, shared and safeguarded. We are committed to handling your personal data in compliance with applicable laws when you use any features or functions on our Platform via computer, mobile device, or any internet-connected device.
 

PLEASE READ THIS PRIVACY POLICY CAREFULLY

By clicking or checking "SIGN UP", "I AGREE TO ECHOTOMATO’S PRIVACY POLICY", or "I AGREE AND CONSENT TO THE COLLECTION, USE, DISCLOSURE, STORAGE, TRANSFER AND/OR PROCESSING OF MY PERSONAL DATA AS STATED IN ECHOTOMATO’S PRIVACY POLICY", you acknowledge that you have read and understood this policy and consent to the collection, use, disclosure, storage, transfer, and/or processing of your personal data as described herein.

1. Introduction to this Privacy Policy

1.1. Commitment to Privacy

Echotomato takes your privacy seriously. Depending on your location, the entity controlling your personal data is Straits Times Advisor Pte. Ltd.

1.2. Scope of Data Processing

When you use Echotomato’s applications, websites (web and mobile versions), and products, information, functions, or other services operated by Echotomato, we collect, use, disclose, store, and/or process data—including your personal data. In this policy, "Platform" refers to all relevant applications and websites, and "Services" refers to all products, information, functions, and services provided by Echotomato on the Platform.

1.3. Policy Purpose

This Privacy Policy informs you about how we collect, use, disclose, store, and/or process data during the provision of Services or your access to the Platform, whether or not you have registered as a buyer or seller. We will only process your personal data in accordance with this policy.

1.4. Related Notices

It is important to read this policy together with any other applicable notices we provide for specific applications where we collect, use, disclose, and/or process your personal data, to ensure you fully understand how and why we use your data.

1.5. Policy Updates

We may update this policy from time to time. Changes will be posted on this page, and material changes will be notified to you. Where local laws permit, your continued use of Services, access to the Platform (including placing Orders as defined in the Terms of Use), or express consent after modifications constitute your acceptance of the changes. You agree to review this policy regularly for updates.

1.6. Policy Application

This policy applies in conjunction with other notices, contractual clauses, and consent clauses regarding the collection, storage, use, disclosure, and/or processing of your personal data, and does not override them unless stated otherwise.

1.7. User Scope

These terms apply to all Echotomato users, whether or not they have created a buyer and/or seller account, unless specified otherwise for buyers or sellers only.

2. The Personal Data We Collect From You

2.1. Collection Principles

We collect the personal data described below in compliance with applicable local laws and, where required, with your consent.

2.2. Definition of Personal Data

Personal data means any information about an individual that can identify them (directly or indirectly) from the data alone or in combination with other data we have or may access, whether recorded in material form or not and regardless of accuracy.

2.3. Personal Data You May Provide

Depending on your use of our Platform and/or interaction with our Services (e.g., registering or logging in), you may be asked to provide information. While you may choose not to provide certain data, this may limit your access to many Services. The personal data you may provide includes:
  • Identity and Profile Data: Name, date of birth, gender, username, password, email, phone number, interests, and personal data in photos, videos, or audio recordings you upload to our Platform.
  • Account and Transaction Data: Credit card details, bank account information, bank statements, delivery/billing address, payments, orders, and details of products/services you supply or purchase through the Platform.
  • Usage Data: Information on how and when you use the Platform, products, and Services, content viewed, websites visited before accessing the Platform, and similar statistics.
  • Marketing and Communications Data: Interests, survey responses, marketing material preferences, communication preferences, product/service preferences, and feedback, chat, email, or call history on the Platform or with third-party service providers.
  • Location Data: E.g., when checking for nearby deals or order delivery/pick-up status.

2.4. Automated Data Collection

We automatically collect and process certain information when you use devices to access our Platform and interact with Services for the purposes stated herein.

2.5. How We Receive Your Personal Data

We may receive personal data from you in the following situations during your use of the Platform or our provision of Services:
  1. Browsing our websites (mobile and web versions).
  2. Creating an account (as buyer, seller, or otherwise).
  3. Listing products/services for sale on the Platform and/or affiliate platforms as a seller, and conducting transactions with buyers.
  4. Applying for, subscribing to, or using Services on our Platform and/or affiliate platforms.
  5. Making transactions for products available on the Platform.
  6. Activating or using payment-related functions on the Platform or provided by third-party service providers.
  7. Using features, functions, mini-apps, or mobile games on the Platform or Services.
  8. Recording user-generated content uploaded to the Platform.
  9. Using the chat function on the Platform.
  10. Subscribing to our publications or marketing materials.
  11. Entering competitions, promotions, or surveys.
  12. Participating in activities or campaigns on the Platform.
  13. Logging in via external services/applications (e.g., Facebook, Google).
  14. Other users commenting on your uploaded content or you commenting on others’ content.
  15. Third parties lodging complaints against you or your posted content.
  16. Interacting with us offline (e.g., with outsourced customer service agents).

2.6. Data Sources

We may collect personal data from you, third parties (including agents, vendors, contractors, partners, payment service providers, government sources, financial services providers, credit bureaus, delivery/marketing partners), our affiliates, or automatically when you use the Platform/Services (see Sections 2.12–2.16 for computer data collection).

2.7. Consent to Data Transfer

During your use of the Platform/Services, you consent to the transfer of your personal data from third parties and/or affiliates to Echotomato for the purposes stated in this policy or other terms.

2.8. Data Accuracy and Updates

You agree to provide accurate, non-misleading personal data and keep it updated. We reserve the right to request documentation to verify your data as part of user verification processes or legal requirements.

2.9. Impact of Non-Providing Data

We can only collect certain personal data if you voluntarily provide it or as otherwise permitted by this policy. Refusing to provide data or withdrawing consent may prevent us from providing certain Services or platform access.

2.10. Third-Party Personal Data

When providing personal data of others (e.g., family, friends, contact list) via "Find My Friends" or adding them as service recipients, you warrant that you have obtained their consent to share and transfer their data to us for processing under this policy.

2.11. Social Media Account Linking

If you sign up or link your Echotomato account to a social media account, we may access personal data you voluntarily provided to the social media provider, in accordance with their policies, and manage it under this policy.

2.12. Collection of Computer Data

We or authorised service providers may use cookies, web beacons, and similar technologies in connection with your use of Services or access to the Platform.

2.13. Automated Data Recording

When you visit the Platform via computer, mobile device, or other internet-connected device, our servers automatically record data sent by your browser, such as technical and usage data outlined in Section 2.2.

2.14. Data Collection Purposes

Collected data is analysed to improve our website, Services, and products, personalise content to match your interests, enhance Platform convenience, and provide relevant advertising for market products, services, and features.

2.15. Technology Explanations

  • Cookies: Small text files placed in your browser/device memory to recognise specific devices or browsers.
  • Web Beacons: Small graphic images on Services/Platform to count page views and understand user preferences/interests.

2.16. User Controls for Cookies

You may manage/delete cookies via browser/device settings, but note that some cookies are essential for core functions (e.g., adding items to a shopping basket). Changing/deleting cookies may affect Platform/Services functionality.

3. Use and Disclosure of Your Personal Data

3.1. Use and Disclosure Principles

We use and disclose personal data for the purposes below in compliance with applicable laws and, where required, with your consent.

3.2. General Purposes of Use

Depending on your relationship with us (e.g., buyer, seller, visitor, mobile app user), personal data collected from you or third parties may be used for:
  • Facilitating Service Use: Enabling your use of Services or access to the Platform.
  • Account Administration: Managing online accounts you set up with us.
  • Analytics, Research, and Development:
    • Understanding user experience with Services and the Platform.
    • Improving Platform page layout/content and customising for users.
    • Identifying Platform visitors.
    • Conducting surveys and research on user demographics/behaviour to improve technology (e.g., voice recognition via machine learning).
    • Deriving additional attributes to provide targeted/relevant information.
    • Analysing usage trends and developing new products/services.
  • Legal and Operational Purposes:
    • Verifying identity for fraud detection.
    • Comparing and verifying information with third parties for accuracy.
    • Processing complaints, feedback, enforcement actions, and content takedown requests.
    • Generating statistics for internal/statutory reporting and record-keeping.
    • Storing, hosting, and backing up personal data for operational, legal, or business needs.
    • Sharing data in connection with business purchases, mergers, or acquisitions (complying with data protection laws).
    • Preventing/investigating violations of Terms of Use, Privacy Policy, fraud, unlawful activity, or misconduct.
    • Performing due diligence checks.
    • Complying with legal/regulatory requirements (e.g., displaying name, contact details) and responding to law enforcement/government requests.
    • Protecting the safety of Echotomato employees, users, and the public.
  • Other Consented Purposes: Any other purpose with your consent, in compliance with applicable laws (including notifying you at the time of consent).

3.3. Additional Purposes for Buyers

If you are a buyer and/or have signed in/registered, personal data may also be used for:
  • Order Processing (Products sold by us or third-party sellers):
    • Processing orders submitted through the Platform.
    • Delivering purchased products (sharing personal information with logistics partners/regulatory authorities like customs).
    • Updating order delivery status.
    • Providing customer support for returns.
    • Verifying and processing payment transactions (credit card, bank transfers, e-wallets, etc.), which may involve transferring payment information to third-party payment service providers.
  • Providing Services:
    • Displaying your name, username, or profile on the Platform (including in reviews).
    • Facilitating mini-app use and purchases.
    • Responding to queries, feedback, claims, or disputes (directly or via third-party providers).
    • Displaying on Platform scoreboards for campaigns, mobile games, or activities.
    • Enabling user identification (e.g., "Find My Friends"), connection with other users, and social features.
    • Assessing loan applications and performing credit risk evaluations for financial services/products (e.g., loans, insurance, credit cards).
    • Integrating third-party loyalty programmes (supported by sellers/brands) with our Platform.
  • Marketing and Advertising:
    • Providing information we think you may find useful or have requested.
    • Sending marketing/promotional materials about our/third-party sellers’ products/services on the Platform.
    • Supporting our marketing and advertising efforts.
    • Promoting Services using user-generated content (e.g., videos) you choose to upload/broadcast, which may be shared publicly (beyond our control).
  • Other Purposes:
    • Gaining insights about our buyers.
    • Conducting automated decision-making processes in compliance with laws (including notifying and obtaining your consent).

3.4. Additional Purposes for Sellers

If you are a seller, personal data may also be used for:
  • Providing Services:
    • Shipping/delivering products listed/sold through the Platform (sharing information with logistics partners/affiliates/regulatory authorities).
    • Responding to your queries, feedback, claims, or disputes (directly or via third-party agents).
    • Verifying documentation for seller onboarding and testing technologies for efficient onboarding.
    • Displaying your name, username, or profile on the Platform.
    • Verifying and processing financial transactions (payments, promotions, Services used), involving transfer to third-party payment providers.
    • Assessing loan applications and performing credit risk evaluations for seller financing/products (e.g., loans, insurance, credit cards).
    • Providing ancillary logistics services to mitigate delivery/return risks.
    • Facilitating product returns to you (via logistics partners).
  • Marketing and Advertising:
    • Sending marketing/promotional materials about our/third-party sellers’ products/services on the Platform or affiliate-provided services.
    • Supporting our marketing and advertising efforts.
  • Other Purposes:
    • Gaining insights about our sellers.
    • Conducting automated decision-making processes in compliance with laws (including notifying and obtaining your consent).

3.5. Who We Disclose Your Personal Data To

We may share/transfer your personal data to third parties and/or affiliates for the purposes above. These parties (located inside or outside your jurisdiction) include but are not limited to:
  1. Service providers (e.g., payment, logistics, marketing, data analytics, customer service, IT, website hosting).
  2. Their service providers and related companies.
  3. Courts, tribunals, enforcement agencies, and governmental/regulatory authorities with jurisdiction over Echotomato.
  4. Other Platform/Services users.

3.6. Data Security in Disclosure

When disclosing your personal data, we strive to ensure third parties and affiliates protect it from unauthorised access, collection, use, disclosure, processing, or loss, and retain it only as long as necessary for the stated purposes.

3.7. International Data Transfers

We may transfer your personal data outside your jurisdiction for purposes stated in this policy, but only if the transfer complies with applicable laws (e.g., notifying you and obtaining consent on transfer countries and their data protection standards).

3.8. Third-Party Services

We may share your personal data with third-party service providers/affiliates (e.g., payment providers) to enable them to offer services in conjunction with your use of the Platform/Services. Your acceptance/use of their services is subject to terms between you and them. Upon acceptance, their privacy policy (not ours) governs data collection, use, etc., and you agree to direct queries/complaints to them.

4. Withdrawal of Consent

4.1. How to Withdraw Consent

You may withdraw consent to the continued use, disclosure, storage, and/or processing of your personal data by contacting us using the details below, subject to applicable legal conditions/limitations.

4.2. Consequences of Withdrawal

If you withdraw consent or exercise other rights under local laws, we may not be able to continue providing Services or performing contracts with you, and we will not be liable for any resulting impacts. Our legal rights and remedies are reserved in such cases.

4.3. Unsubscribing from Marketing

You may unsubscribe from marketing information at any time via mobile app settings or the unsubscribe function in electronic marketing materials.

5. Updating Your Personal Data

5.1. Importance of Accuracy

It is crucial to provide accurate and complete personal data for continued Platform use and Service provision. You are responsible for notifying us of changes or inaccuracies.

5.2. How to Update Data

Update your personal data anytime by accessing your account on the Platform.

5.3. Sharing Updates with Third Parties

We may share updates with third parties and affiliates with whom we have shared your data if the data remains necessary for the stated purposes.

6. Accessing and Correcting Your Data

6.1. Requesting Access or Correction

Request access to your personal data or enquire about its use/disclosure/storage/processing via your Platform account settings or by contacting us (see Section 11). You may also request corrections in the same way. We may request additional information to process your request and may refuse vexatious/unreasonable correction requests where permitted by law.

6.2. Administrative Fees

Where allowed by data protection laws, we reserve the right to charge a reasonable administrative fee for retrieving your personal data records, which we will notify you of before processing.

7. Security of Your Personal Data

7.1. Security Measures

To protect your personal data from unauthorised access, use, disclosure, etc., we have implemented appropriate administrative, physical, and technical measures, including:
  • Restricting access to authorised individuals.
  • Maintaining technology to prevent unauthorised computer access.
  • Using 128-bit SSL encryption for financial details.
  • Implementing other security measures as required by law.

7.2. Limitations of Security

While we strive to protect your data, no internet transmission or electronic storage is completely secure. We continuously review and enhance security measures but advise you to exercise caution when sharing personal data or authentication details outside our Platform/Services.

8. Retention of Personal Data

8.1. Retention Periods

We retain your personal data only as long as required/permitted by law or relevant to the purposes for which it was collected.

8.2. Disposal of Data

When retention is no longer necessary for stated purposes or legal/business needs, we will securely dispose of your data or anonymise it to remove associations with you.

9. Minors

9.1. No Service to Minors

Echotomato does not sell products to minors (as defined by applicable law) or intend to provide Services/Platform access to them. We do not knowingly collect personal data from minors.

9.2. Age Confirmation

You confirm that you are of legal age and capable of understanding this policy. Minors may use our Platform only with parental/guardian supervision.

9.3. Parental Responsibility

As a parent/guardian, do not allow minors under your care to submit personal data to Echotomato. If minor data is disclosed, you consent to its processing and agree to be bound by this policy and responsible for their actions.

9.4. Unauthorised Use

We are not responsible for unauthorised use of Services by you, agents, or unauthorised users. You are responsible for making informed decisions about Platform use and preventing misuse.

10. Third-Party Sites

10.1. Links to Other Websites

The Platform may contain links to third-party websites (e.g., affiliates, merchants, payment gateways). We are not responsible for their privacy practices; check their privacy policies to understand how they handle your information.

10.2. Lack of Control Over Third-Party Sites

Even if affiliated, we cannot control third-party websites, which have independent privacy/data collection practices. We are not liable for their content, security, or activities. Links are provided for convenience, and you access them at your own risk. We welcome feedback about broken links or other issues.