Outline

Welcome to Vcomerz, a platform that makes e-commerce affordable for all, whether you are tiny, small, medium or large, having a digital sales channel has become the most desired tools for businesses. We are here to help your journey in successful digital commerce. In the process we collect and use information about you, if you are a

• store Owner who created a store using Vcomerz platform to power your business
• customers who shop at a Vcomerz powered business
• partners who create stores and web portals and applications for store owners to use, refer potential entrepreneurs to Vcomerz, or otherwise help store owners operate or improve their Vcomerz built digital sales channels
• visitors to Vcomerz websites, or anyone contacting Vcomerz support

This Privacy Policy will help you better understand how we collect, use, and share your personal information. If we change our privacy practices, we may update this privacy policy. If any changes are significant, we will let you know (for example, through the admin portal of Vcomerz or by email).

Our promises

We at Vcomerz promise the following while you trust us in handling your personal information.

You are the owner of your information

We meticulously evaluate the types of information necessary to deliver our services, striving to collect only what is essential. Whenever feasible, we delete or anonymize this data once it is no longer needed. Our engineers collaborate closely with our privacy and security teams to ensure that privacy is a fundamental aspect of our product development and improvement processes. Throughout all our efforts, we adhere to the principle that your information is your property, and we aim to use it solely for your benefit.

Your information is protected from others

If a third party requests your personal information, we will decline to share it unless you provide explicit permission, or we are legally obligated to do so. In cases where we are legally required to share your personal information, we will notify you in advance, unless prohibited by law.

We help store owners and partners meet their privacy duties

We understand many store owners and partners using Vcomerz lack the resources of a dedicated privacy team, making it crucial for us to assist them in fulfilling their privacy obligations. To support this, we design our products and services to be inherently privacy-friendly. Additionally, we offer comprehensive FAQs and documentation on key privacy topics and promptly address any privacy-related inquiries we receive.

Why we process your information

We generally process your information to fulfil contractual obligations, such as processing your subscription payments for the Vcomerz platform, or when we or our partners need to use your personal information for business-related reasons, like providing a service. In the European Economic Area (EEA) and the United Kingdom (UK), these reasons are known as "legitimate interests." These legitimate interests include:

• Preventing risk and fraud
• Answering questions or providing support
• Helping Store owners to find and use our services
• Providing and improving our products and services
• Offering reporting and analytics
• Testing new features or services
• Assisting with marketing, advertising, or other communications

We only process personal information for these legitimate interests after assessing potential privacy risks and implementing measures to mitigate them. These measures include ensuring transparency in our privacy practices, giving you control over your personal information where appropriate, limiting the information we retain and how we use it, restricting who we share it with, and employing technical safeguards to protect it.

Additionally, we may process your personal information with your consent. This is particularly relevant when we cannot rely on another legal basis for processing, when you direct us to transfer information to a third party, when we receive your data from a third party with your consent, or when required by law (including for some sales and marketing activities). You have the right to withdraw your consent at any time by changing your communication preferences, opting out of our communications, or contacting us.

Depending on whether you are a store owner, customer, partner, or visitor, please refer to our supplemental privacy policies to understand our purposes for processing, categories of recipients, and legal basis for processing for each type of personal data.

Your rights over your information

We believe you should have the ability to access and control your personal information, regardless of where you live. Depending on how you use Vcomerz, you may have the right to:

• Request access to your personal information
• Correct or amend your information
• Delete your information
• Port your information to another service provider
• Restrict or object to certain uses of your information

We will not charge you more or provide a different level of service if you exercise any of these rights. Please note that some of these rights apply only in specific circumstances and may be limited by law.

If you purchase something from or provide your information to a Vcomerz-built store and wish to exercise these rights regarding your purchase or interaction, you need to contact the store owner directly. We act as a processor and handle information on their behalf. We will assist store owners in fulfilling these requests as required by law, by providing them with the necessary tools and support.

If you are a store owner, partner, customer, Vcomerz employee, website visitor, or another individual with a direct relationship with Vcomerz, please submit your data subject request to datahand@vcomerz.com . To ensure we are responding to the correct person, we may use a third party to collect and verify identification documents.

If you are dissatisfied with our response to a request, you can contact us to resolve the issue. If you are in the EEA or UK, you also have the right to lodge a complaint with your local data protection or privacy authority at any time.

Where we send your information

We are a registered company in the UK and India, but we work with and process data about individuals worldwide. To operate our business, we may transfer your personal information outside of your state, province, or country. This data may be subject to the laws of the countries where it is sent. We take steps to protect your information during these cross-border transfers.

Depending on whether you are a store owner, customer, partner, user, or visitor, please refer to our supplemental privacy policies for more details

Transfers outside of Europe and Switzerland

If you are located in the EEA, the UK, or Switzerland, your personal information is controlled by M2R2 LTD, a company registered in England. Your information is then transferred to other Vcomerz locations and service providers, which may be in different regions. When we transfer your personal information outside of the EEA, UK, or Switzerland, we comply with applicable laws.

While we strive to protect your information, there may be instances where we are legally required to disclose it (e.g., in response to a valid court order). For details on how we handle such requests, please email datahand@vcomerz.com.

How long do we retain your information

We will keep your personal data only as long as necessary to fulfill the purposes for which it was collected. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for processing the data, and whether those purposes can be achieved through other means, as well as applicable legal requirements. We will also retain and use your personal information as needed to comply with legal obligations, resolve disputes, and enforce our policies. If you stop using our services or delete your account, we will delete your information or store it in an aggregated and anonymized format.

For more details on the retention of your personal information, please refer to our supplemental privacy policies relevant to whether you are a store owner, customer, partner, or visitor.

Our use of Deep/Machine Learning

We assist store owners using Vcomerz by employing techniques like "machine/deep learning" (referred to as "automated decision-making" under certain EEA and UK laws) to enhance our services. When we use machine/deep learning, we involve a human in the process or apply machine learning in ways that do not have legal or similarly significant effects like how the product in a store is rearranged for a particular user.

How we protect your information

We at Vcomerz work diligently to protect your information and ensure the security and integrity of our platform. We also engage independent auditors to assess the security of our data storage and systems that process financial information. However, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee the absolute security of your personal information.

How we use "cookies" and other tracking technologies

We use cookies and similar tracking technologies on our website and when providing our services. For more information about how we use these technologies, including a list of other companies that place cookies on our sites, a list of cookies we place when powering a store, and an explanation of how you can opt out of certain types of cookies, please see our Cookie Policy.

How you can reach us

If you would like to ask about, make a request relating to, or complain about how we process your personal information, please contact Vcomerz Support, or mail us at one of the addresses below. If you would like to submit a legally binding request to demand someone else's personal information (for example, if you have a subpoena or court order), please review our Guidelines for Legal Requests.

If you are a store owner, partner, customer, employee, website visitor or other individual that Vcomerz has a direct relationship with and you are in the EEA or UK, M2R2 LTD. is the controller of your personal data. If you buy something from or otherwise provide your information to a Vcomerz powered store, the store owner is your data controller, and we are acting as a processor on their behalf.

If you have questions about how a store processes your personal information, you should contact the store owner or visit their privacy policy.

If you are located in the EEA, the UK, the Middle East, South America, or Africa:

If you are located in Asia, Australia, or New Zealand:

What information we collect and share about you

To provide our services to you, we must process information about you, including personal information.

We do not "sell" your personal information as that term is defined under UK GDPR.

Here is a summary of the categories of personal information we may have collected about you over the past 12 months and with whom we may have disclosed that information to, depending on how you use Vcomerz.

Why we collect and share your Personal Information

We use and share your personal information for the purposes set out in the Vcomerz Privacy Policies. For categories of sensitive personal information that we collect, we only use or disclose such information either with your specific consent when required, or as otherwise permitted by law.

Sources of Personal Information

To enable e-commerce/digital sales channel for all at Vcomerz, we collect and use personal information provided by:

• You: We collect the information you provide when you use our platform, including when you sign up for Vcomerz as a store owner, visit a Vcomerz powered store, fill in order information, visit one of Vcomerz's websites or contact Vcomerz support. We collect account and payment information you provide to us (including information about your business if you are a store owner), Vcomerz stores or items you save to favorites, purchases you make, reviews you post, and how you otherwise interact or communicate with stores or other users on our services. We also collect information about how you browse through our sites, including search terms you may enter.
• Your device(s): We collect information from and about the devices you use, including computers, phones, and other web-connected devices you use to access our services, and we combine this information across different devices you use.
• Third parties: We receive information from partners who help us provide you with our services including the following:
• Email providers. If you use the Vcomerz and you connect your third party inboxes, such as Gmail or Outlook (according to their terms and policies and as permitted by applicable law), we receive information to identify shopping-related emails and display within Shop information about specific orders you have made, stores you have engaged with in the past, and other related information.
• Service Providers. We receive information from our service providers, who help us provide services to our store owners, like reviewing accounts for fraud or other concerns.
• Marketplaces. If you use the Vcomerz stores, we receive information about purchases you have made from other marketplaces or platforms, such as Amazon, that you choose to connect through Vcomerz. This information helps us to provide and improve Vcomerz, to personalize your experience using our services, and to determine if you are eligible for specific offers or payment methods.
• Sub processors. We work with third party subprocessors for cloud hosting, content delivery, data analysis, internal logging, fulfillment services and email transmission, among others, to provide you with our services. For more information, see Vcomerz sub processors.
• Analytics and cookie providers. We receive information through our use of cookies, social plugins (such as the Facebook "like" button), pixels and tags for business purposes, such as providing information to help measure how users interact with our website content. For more information about how we use these technologies, see our Cookie Policy.

How long we keep your information

Because we need your personal information to provide Vcomerz services, we generally keep your personal information, including sensitive personal information, while you use Vcomerz products or services or until you tell us to delete your information. We may also keep personal information to comply with legal obligations or protect our or other's interests.

If you are a merchant operating a Vcomerz-powered store, and you close the store, stop paying your subscription fees, or we terminate your account, we retain store information for three years before we begin the deletion process.

When you visit or make a purchase from a store owner's Vcomerz powered store, we act as a service provider or processor for the store owner, and the store owner, not Vcomerz, decides how long your information is retained.

Your rights over your information

Depending on where you live, how you use Vcomerz, and subject to certain exceptions, you may have some or all of the following rights:

• Right to Know: The right to request that we disclose to you the personal information we collect, use, or disclose about you, and information about our data practices.
• Right to Request Correction: The right to request that we correct inaccurate personal information that we maintain about you.
• Right to Request Deletion: The right to request that we delete personal information that we have collected about you.

To exercise your rights, including the "right to know" and "right to delete," please submit a request through datahand@vcomerz.com.

If you have visited or made a purchase from a store owner's Vcomerz-powered store, please contact the specific store owner directly. If you make a request to us, we will forward your request to the relevant merchant.

Please note that to protect your information and the integrity of our products and services, we may need to verify your identity before processing your request. In some cases we may need to collect additional information to verify your identity, such as your email address or a government issued ID.

We will not discriminate against you for exercising any of these rights.

How you can reach us

If you would like to ask about or have concerns about how we process your personal information, please contact Vcomerz Support.