Privacy Policy and Confidentiality

I. Introduction

TwinBP (App) is owned and operated by Tropcey Technologics (Private) Limited. When you use Our App, you trust us with your personal data. We're committed to keeping that trust. That starts with helping you understand our privacy practices.

This notice describes the personal data ("data") we collect, how it's used and shared, and your choices regarding this data. We recommend that you read this along with our which highlights key points about our privacy practices.

II. Overview

A. Scope

This notice applies to users of our App's services anywhere in the world, including users of our App, web, features, or other services.

• This notice describes how our App and its affiliates collect and use data. This notice applies to all our App users: as customers and suppliers via their TwinBP account.
• This Privacy Policy explains how we collect, use and (under certain conditions) disclose your personal information. This Privacy Policy also explains the steps we have taken to secure your personal information. Finally, this Privacy Policy explains your options regarding the collection, use and disclosure of your personal information. By visiting the Our App directly or through another Our App, you accept the practices described in this Policy.
• Data protection is a matter of trust, and your privacy is important to us. We shall therefore only use your name and other information which relates to you in the manner set out in this Privacy Policy. We will only collect information where it is necessary for us to do so and we will only collect information if it is relevant to our dealings with you.
• We will only keep your information for as long as we are either required to by law or as is relevant for the purposes for which it was collected.
• We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data was collected and is no longer necessary for any legal or business purpose.
• You can visit the App and browse without having to provide personal details. During your visit to the App, you remain anonymous and at no time can we identify you unless you have an account on the Our App and log on with your username and password.

B. Collection of Data

• We may collect various pieces of information if you seek to place an order for a product with us on our App.
• We collect, store and process your data for processing your purchase on the App and any possible later claims, and to provide you with our services. We may collect personal information including, but not limited to, your title, name, gender, date of birth, email address, postal address, delivery address (if different), telephone number, mobile number, fax number, payment details, payment card details or bank account details.

C. Usage of Data Collected

We will use the information you provide to enable us to process your orders and to provide you with the services and information offered through our App and which you request in the following ways:

1. If you are a buyer:

• Processing your orders for products
• Process orders you submit through our App
• To monitor quotes provided by the supplier and your acceptance of the quote for your Products and to ensure the Supplier to deliver the products you have ordered through our App for which we may pass your personal information on to a third party (e.g. delivery partner of the Supplier) in order to make delivery of the product to you
• Update you on the delivery of the products
• Provide customer support for your orders
• To verify the delivery of the Products by the Supplier to you and to verify accept payment to the Supplier by us and to make payments to the Supplier. In this regard to Verify and carry out payment transactions (including any credit card payments, bank transfers, offline payments, remittances, or e-wallet transactions) in relation to payments by you to us. In order to verify and carry out such payment transactions, payment information, which may include personal data, will be transferred to third parties such as our payment service providers
• To facilitate the return of the Products as per the return and refund policy under the Terms and Conditions stated on our App

2. If you are a seller:

• Providing Services
• To facilitate your use of Our App
• To monitor you quoting for the Buyer's orders, the acceptance of your quote by the Buyer, delivery of the Products to the Buyer and transfer the payment upon the successful delivery to the Buyer. We may agree with you to pass the Buyer's delivery address, Buyer's name and Buyer's telephone nos for the delivery of the Products to the Buyer by your delivery partner
• To respond to your queries, feedback, claims or disputes, whether directly or through our third-party service agents
• To physically verify your documentation submitted to us through the App to facilitate your onboarding with us as a seller on Our App, including the testing of technologies to enable faster and more efficient onboarding
• To administer your account (if any) with us
• To display your name, username or profile on Our App
• To verify the Products are delivered to the Buyer and accepted by the Buyer and to make payment to you for the Products and to carry out financial transactions (including any credit card payments, bank transfers, offline payments, remittances, or e-wallet transactions) in relation to payments to you. In order to verify and carry out such payment transactions, payment information, which may include personal data, will be transferred to third parties such as our payment service providers
• To monitor the return of the Products by the Buyer to you as per the Return and the Refund Policy stated on our App

3. Other uses of your Personal Information

• We may use your personal information for opinion and market research. Your details are anonymous and will only be used for statistical purposes. You can choose to opt out of this at any time. Any answers to surveys or opinion polls we may ask you to complete will not be forwarded on to third parties. Disclosing your email address is only necessary if you would like to take part in competitions. We save the answers to our surveys separately from your email address.
• We may also send you other information about us, Our App, our other web or Our Apps and our newsletters, anything relating to other companies in our group or our business partners. If you would prefer not to receive any of this additional information as detailed in this paragraph (or any part of it) please click the 'unsubscribe' link in any email that we send to you. Within 7 working days (days which are neither (i) a Sunday, nor (ii) a public holiday anywhere in Sri Lanka) of receipt of your instruction we will cease to send you information as requested. If your instruction is unclear, we will contact, you for clarification.
• We may further anonymize data about users of Our App generally and use it for various purposes, including ascertaining the general location of the users and usage of certain aspects of Our App or a link contained in an email to those registered to receive them, and supplying that anonymized data to third parties such as publishers. However, that anonymized data will not be capable of identifying you personally.

4. Competitions

• For any competition we use the data to notify winners and advertise our offers. You can find more details where applicable in our participation terms for the respective competition.

5. Third Parties and Links

• We may pass your details to other companies in our group. We may also pass your details to our agents and subcontractors to help us with any of our uses of your data set out in our Privacy Policy. For example, to analyze data and to provide us with marketing or customer service assistance. We may also exchange information with third parties for the purposes of fraud protection and credit risk reduction.
• We may share (or permit the sharing of) your personal data with and/or transfer your personal data to third parties and/or our affiliates for the above-mentioned purposes. These third parties and affiliates, which may be located inside or outside your jurisdiction, include but are not limited to:
  • Service providers (such as agents, vendors, contractors and partners) in areas such as payment services, logistics, marketing, data analytics, market or consumer research, survey, social media, customer service, installation services, information technology and web or Our App hosting
  • Their service providers and related companies

6. Other users of the Our App

• We may transfer our databases containing your personal information if we sell our business or part of it, provided that we satisfy the requirements of applicable data protection law when disclosing your personal data. Other than as set out in this Privacy Policy, we shall NOT sell or disclose your personal data to third parties without obtaining your prior consent unless this is necessary for the purposes set out in this Privacy Policy or unless we are required to do so by law. Our App may contain advertising of third parties and links to other Our Apps or frames of other Our Apps. Please be aware that we are not responsible for the privacy practices or content of those third parties or other Our Apps, nor for any third party to whom we transfer your data in accordance with our Privacy Policy. You are advised to check on the applicable privacy policies of those web or Our Apps to determine how they will handle any information they collect from you.
• In disclosing your personal data to third parties, we endeavour to ensure that the third parties and our affiliates keep your personal data secure from unauthorized access, collection, use, disclosure, processing or similar risks and retain your personal data only for as long as your personal data helps with any of the uses of your data as set out in our Privacy Policy.
• We may transfer or permit the transfer of your personal data outside of Sri Lanka for any of the purposes set out in this Privacy Policy. However, we will not transfer or permit any of your personal data to be transferred outside of Sri Lanka unless the transfer is in compliance with applicable laws and this Privacy Policy.
• We may share your personal data with our third-party service providers or affiliates (e.g. payment service providers) in order for them to offer services to you other than those related to your use of the Our App. Your acceptance and use of the third-party service provider's or our affiliate's services shall be subject to terms and conditions as may be agreed between you and the third-party service provider or our affiliate. Upon your acceptance of the third party service provider's or our affiliate's service offering, the collection, use, disclosure, storage, transfer and processing of your data (including your personal data and any data disclosed by us to such third party service provider or affiliate) shall be subject to the applicable privacy policy of the third party service provider or our affiliate, which shall be the data controller of such data. You agree that any queries or complaints relating to your acceptance or use of the third-party service provider's or our affiliate's services shall be directed to the party named in the applicable privacy policy.

7. Cookies

• We or our authorised service providers may use cookies, web beacons, and other similar technologies in connection with your use of the Our App.
• The acceptance of cookies is not a requirement for visiting the Our App. However, we would like to point out that the use of the 'basket' functionality on the Our App and ordering is only possible with the activation of cookies. Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a web or Our App or view a message. They allow us to recognise a particular device or browser. Web beacons are small graphic images that may be included on Our App. They allow us to count users who have viewed these pages so that we can better understand your preference and interests. Cookies are tiny text files which identify your computer to our server as a unique user when you visit certain pages on Our App and they are stored by your Internet browser on your computer's hard drive. Cookies can be used to recognize your Internet Protocol address, saving you time while you are on, or want to enter, Our App. We only use cookies for your convenience in using Our App (for example to remember who you are when you want to amend your shopping cart without having to re-enter your email address) and not for obtaining or using any other information about you (for example targeted advertising). However, certain cookies are required to enable core functionality (such as adding items to your shopping basket), so please note that changing and deleting cookies may affect the functionality available on the Sit. Your browser can be set to not accept cookies, but this would restrict your use of Our App. Please accept our assurance that our use of cookies does not contain any personal or private details and are free from viruses. If you want to find out more information about cookies, go to all-about-cookies or to find out about removing them from your browser, go to here.
• The web or Our App uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies, which are text files placed on your computer, to help the web or Our App analyze how users use the Our App. The information generated by the cookie about your use of the web or Our App (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the web or Our App, compiling reports on web or Our App activity for web or Our App operators and providing other services relating to web or Our App activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this web or Our App. By using this web or Our App, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

8. Security

• We have in place appropriate technical and security measures to prevent unauthorized or unlawful access to or accidental loss of or destruction or damage to your information. When we collect data through the Our App, we collect your personal details on a secure server. We use firewalls on our servers. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you. You are responsible for protecting against unauthorized access to your password and to your computer.
• You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

9. Your rights

• If you are concerned about your data, you have the right to request access to the personal data which we may hold or process about you. You have the right to require us to correct any inaccuracies in your data free of charge. At any stage you also have the right to ask us to stop using your personal data for direct marketing purposes. Where permitted by applicable data protection laws, we reserve the right to charge a reasonable administrative fee for retrieving your personal data records. If so, we will inform you of the fee before processing your request.
• You may communicate the withdrawal of your consent to the continued use, disclosure, storing and/or processing of your personal data by contacting our customer services, subject to the conditions and/or limitations imposed by applicable laws or regulations. Please note that if you communicate your withdrawal of your consent to our use, disclosure, storing or processing of your personal data for the purposes and in the manner as stated above or exercise your other rights as available under applicable local laws, we may not be in a position to continue to provide the Services to you or perform any contract we have with you, and we will not be liable in the event that we do not continue to provide the Services to, or perform our contract with you. Our legal rights and remedies are expressly reserved in such an event.
• Furthermore, you also have the right to ask us to delete your data. If you would like to have your data deleted, please contact us at [email protected].

10. Minors

• We do not permit minors, i.e. individuals below the age of 18 on board our App, and we do not knowingly collect any personal data relating to minors. You hereby confirm and warrant that you are above the age of 18 and are capable of understanding and accepting the terms of this Privacy Policy.
• If you allow a minor to access the Our App and buy products through Our App by using your account, you hereby consent to the processing of the minor's personal data and accept and agree to be bound by this Privacy Policy and take responsibility for his or her actions.
• We will not be responsible for any unauthorized use of your account on the Our App by yourself, users who act on your behalf or any unauthorized users. It is your responsibility to make your own informed decisions about the use of the Our App and take necessary steps to prevent any misuse of the Our App.

11. Data Controller and Transfer

Our App's Data protection officers are the data controllers for the data collected in connection with use of Our App's services.

12. Changes and Updates

We may occasionally update this notice. If any significant changes are made users will be notified in advance of the changes through our App or through other means, such as email. We request users to periodically review this notice for the latest information on our privacy practices.

Use of our services after an update constitutes consent to the updated notice.