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                                                                             PRIVACY NOTICE

This PRIVACY NOTICE (this “Notice”) is effective from April 12, 2021.  Reference is hereby made to that certain User Agreement (the “Agreement”) by and between e-World Fashion LLC (“e-World Fashion”) and any person agreeing to the Agreement and/or using the Services (the “User”), as amended, and all other terms, conditions, policies or notices posted from time to time on e-World Fashion’s website(s) (collectively, “Policies”).  The Agreement and Policies are incorporated by        reference in this Notice as though fully set forth herein, and capitalized terms used but not defined herein shall have the meanings set forth therefor in the Agreement and the Policies.

1.   Scope and updates of this Notice

This Notice applies to the User’s use of the Services, regardless of how used or accessed, including  access via mobile devices and apps, and pertains to e-World Fashion’s handling of the User’s personal data and the User’s corresponding rights.  e-World Fashion may change this Notice at any time by posting the revised Notice on this website and indicating the effective date thereof.

2. Controller

e-World Fashion is responsible for the collection and processing of the User’s personal data in  connection with the provision of Services.  e-World Fashion’s address is published on its website.

3.  Data protection officer and contact

e-World Fashion has appointed a data protection officer to oversee the protection of the User’s  personal data. If the User has questions about this Notice or about data protection by e-World       Fashion in general, the User can contact the data protection officer at any time.  The User may ask  e-World Fashion for the contact details of the data protection officer.  Furthermore, if the User has questions or complaints regarding this Notice,        e-World Fashion’s global data protection principles or e-World Fashion’s handling of personal data, the User can also contact the controller who is responsible for the processing of the User’s personal data at any time (for further information, see Controller above).

4.  What personal data we collect and process  

e-World Fashion collects the User’s personal data when the User uses the Services, creates a new account, provides information via a web form, adds or updates information in the account,  participates in online     community discussions or otherwise interacts with e-World Fashion or on its Platform.  e-World Fashion also collects personal data from other sources (such as credit agencies or bureaus and other data brokers).               e-World Fashion collects the following personal data:

Personal data the User provides when using the Services or creating an account:

·       Data that identifies the User, such as name, address, telephone numbers, email addresses,      username and tax identification number that are provided when setting up the User’s account or at another time.

·       If processing payments through  the Platform, additional identification data (such as social       security number or date of birth), tax identification numbers (such as VAT identification number) and other information (such as bank account number) that are provided when using payment processing services.

·       Data regarding listings, bids, purchases, barters, rentals or sales that are provided in a transaction.

·       Content that the User shares with other Users through the Portals’ messaging tools.

·       Financial information (e.g. credit card and account numbers, transaction details and form of payment).

·       Shipping, billing and other information the User provides, as well as information required for customs clearance (such as tax identification numbers or other identification numbers) and relevant shipping information (such as shipment numbers and tracking information) if shipped through one of e-World Fashion’s programs.

·       In some cases: age, gender, country of birth, nationality, employment status, family status,   interests and preferences.

·       The User may provide additional information through a web form or by updating or adding  information  to an account, by participating in community discussions, member chats, inquiries,     dispute resolution or customer service calls recorded or if the User contacts e-World Fashion for any other reason regarding the Services.

·       Other data that e-World Fashion is required or entitled by applicable law to collect and process and that  e-World Fashion needs for authentication or identification, or for the verification of the data collected.

 Personal data collected automatically when the User uses the Services or creates an account:

·       Data that is generated as part of a transaction (bids, purchases, sales, exchanges, rentals) or that is linked to the User’s account as a result of a transaction, such as transaction amounts, time and    location of transactions and form of payment or payment method.

·       Data that is generated through the User’s other actions when the User uses the Services and which is linked to the User’s account, e.g. when the User places Items in a shopping cart, places Items on the watch list, saves Sellers, searches or interests or follows other Users.

·       Data regarding all other interactions with the Services, the User’s advertising preferences and the User’s communications with e-World Fashion.

·       Location data, including general location data (e.g., IP address) and the precise location data of the User’s mobile device.  Please note that for most mobile devices, the User can manage or disable the use of location services for all applications in the settings menu.

·       Computer and connection information, such as statistics regarding the User’s use of Services,  information on data traffic to and from websites, referral URL, information on advertisements, IP  address, access times, browser history data, language settings and weblog information.

Personal data collected in connection with the use of cookies and similar technologies:

·       e-World Fashion uses cookies, web beacons and similar technologies to collect data while the User uses the Services.  e-World Fashion collects this data from the devices (including mobile devices) with which the User accesses or uses the Services.

·       Data about the pages the User visits, the access time, frequency and duration of visits, the links on which the User clicks and other actions the User takes as part of using the Services and in advertising and email content.

·       Data about the User’s activities and interactions with e-World Fashion’s advertising partners including data about the advertisements the User was shown, how often they were shown, when and where they were shown, and whether the User took any action, such as clicking on an advertisement or making a purchase.

·       The user segment or category into which the User falls, for example: female, 18-34 years old, interested in watches.

·       Model or device type, operating system and version, browser type and settings, device ID or  individual device identifier, advertisement ID, individual device token, and cookie-related data (e.g. cookie ID).

Personal data from other sources:

§  e-World Fashion also collects personal data about the User from other sources and from third   parties to the extent permitted by applicable law.

§  Data from public sources (e.g. demographic data).

§  Data from credit agencies or bureaus (e.g. credit reports/checks, identity confirmation, data for risk           modeling and setting of credit limits).

§  Data from data providers (e.g. "Know Your Customer"/identity verification, demographic,  interest-based and online advertising related data).

§  e-World Fashion combines or connects the personal data collected from the User with data from these other sources.  Where personal data is disclosed to e-World Fashion by third parties, e-World Fashion requires that these third parties are legally permitted to disclose the User’s personal data to e-World Fashion.

Social network data the User shares with us

·       e-World Fashion may allow the User to use social networks (such as Facebook) or other providers of single sign-on services (such as Google or Apple) with whom the User already has an account to create an e-World Fashion account or to link the e-World Fashion account to such single sign-on services.  The User can determine the personal data that e-World Fashion can access when authorizing the connection with the single sign-on service.

·       e-World Fashion may allow the User to share personal data with social networks (such as  Facebook) or to link the User’s e-World Fashion account to a social network.  These social networks may automatically provide e-World Fashion with access to certain personal data they have stored about the User (e.g. content the User has viewed or enjoyed, information about the advertisements the User has been shown or clicked on, etc.).  The User can determine the personal data that e-World Fashion can access through the privacy settings of each social network.

·       If the User gives e-World Fashion access to video content pages, the User’s grant of access is the User’s consent that e-World Fashion may, for at least two years, or until the User withdraws consent or is no longer connected to the social network, share with and collect from social networks  information regarding the User’s viewing of videos.

·       e-World Fashion may also use plug-ins or other technologies from various social networks.  If the User clicks on a link displayed through a social network plug-in, the User voluntarily connects to that social network.

5.  Purposes and legal basis for data processing and categories of recipients

e-World Fashion processes the User’s personal data for various purposes and based on several    different legal bases that allow this processing.  For example, e-World Fashion processes the User’s personal data to provide and improve the Services, to provide the User with a personalized user     experience on this website, to contact the User about the User’s account and the Services, to provide customer service, to provide the User with personalized advertising and marketing communications, and to detect, prevent, mitigate and investigate fraudulent or illegal activity.  e-World Fashion also shares the User’s information with third parties, including service providers acting on e-World      Fashion’s behalf, for these purposes.  Below the User will find a summary of the purposes for which   e-World Fashion processes the User’s personal data, including the categories of recipients to whom  e-World Fashion transmits personal data for the purposes stated, sorted by e-World Fashion’s legal basis for this processing or sharing.

e-World Fashion processes the User’s personal data in order to fulfil the Agreement and to provide the User with the Services.  This includes the following purposes:

·       Processing of data relating to the User or the User’s company for the purpose of entering into a contract with the User and executing it.

·       Provision of the Services, including but not limited to enabling and performing transactions with other Users (including the transmission of the User’s personal data to other Users where necessary to perform the transaction, including in cases of terminated, failed or subsequently voided    transactions, e.g. by sharing the User’s return address so a Buyer may return an Item), displaying the User’s transaction and feedback history to a User, providing and enhancing features such as payment processing, ratings and account management, providing other services the User may use (as  described in connection with such services) and ensuring the functionality of the Services.  In connection with the provision of the Services, e-World Fashion will send the User notifications relating to the execution of transactions and the use of the Services in accordance with the communication    preferences in the User’s account.

·       Enabling the delivery of Items by logistics/shipping service providers including notifications in connection with the delivery (such as tracking information), the latter to the extent permitted by    applicable law without the User’s consent.

·       Providing general customer support including the solution of problems with the User’s account, arbitration of disputes, providing other services within the scope of customer service as well as  enforcement of fee claims.  For these purposes, e-World Fashion may contact the User via email,    telephone, SMS, push notification on the User’s mobile device or by mail.  If e-World Fashion contacts the User by telephone, in order to ensure efficiency, e-World Fashion may use automatically dialed calls with tape announcements or automated text messages in accordance with the Agreement, to the extent permitted by applicable law.

·       Processing of general location data (such as IP address or postal code) in order to provide the User with location-based services (such as radius search and other content that is personalized on the basis of the User’s general location data).

·       Enforcement of the Agreement and the Policies.

·       Publication and promotion of the User’s listings and related content on the websites or in the    applications, services and tools of cooperating third party operators of websites, applications,  services and tools.  When e-World Fashion shares the content of the User’s listings and any related personal data with third parties, e-World Fashion does so only on the basis of an agreement that     limits the use of such personal data by the third party to the purposes necessary to fulfil its  contractual obligations to e-World Fashion.  Third party providers are contractually obliged to take appropriate security measures with regard to this data.  Third party providers are strictly forbidden to pass on personal data contained in the User’s listings to other third parties.

·       Where necessary, e-World Fashion transmits the User’s personal data to processors and the   following recipients for one or several of the purposes described above:

o   Other Users

o   External service providers and shipping companies (such as DHL, UPS, etc.)

o   Payment service providers such as PayPal

o   External operators of websites, applications, services and tools

e-World Fashion processes the User’s personal data in order to comply with legal obligations to which e-World Fashion is subject.  This includes the following purposes:

·       Participation in investigations and proceedings (including judicial proceedings) conducted by public authorities or government agencies, in particular, for the purpose of detecting, investigating and prosecuting illegal acts.

·       Prevention, detection and mitigation of illegal activities (e.g. fraud, money laundering and terrorist financing).

·       Complying with information requests from third parties based on any statutory information rights they have against e-World Fashion (e.g. in the event of an intellectual property infringement, product piracy, or other unlawful activity).

·       Ensuring the information security of the Services.

·       Retention and storage of the User’s personal data to comply with specific legal retention requirements.

·       Where necessary, e-World Fashion transmits the User’s personal data to processors and the  following recipients for one or several of the purposes described above:

o   Law enforcement agencies, courts, government agencies or public authorities, intergovernmental or supranational bodies (including in connection with compliance with Luxembourg laws concerning FATCA dated July 7, 2015 and concerning the OECD Common Reporting Standard dated December 18, 2015).

o   Third parties based on statutory information claims against e-World Fashion

o   Third party service providers

o   Third parties who are involved in judicial proceedings, in particular, if they submit a legal order, court order or equivalent legal order to e-World Fashion

o   Credit agencies, bureaus, or associations, if required by applicable law (e.g. information on  payment 

delays, payment defaults or other irregularities that may be relevant to the User’s credit report)

E-World Fashion processes the User’s personal data in order to protect the User’s vital interests or the vital 

interests of another natural person. This includes the following purposes:

·       Prevention, detection, mitigation and investigation of unlawful activities that may result in   impairment of the User’s vital interests or the vital interests of another natural person, unless there is a statutory obligation to this effect.

·       Where necessary, e-World Fashion transmits the User’s personal data to processors and the  following    recipients for one or several of the purposes described above:

o   Law enforcement agencies, courts, government agencies or public authorities, intergovernmental or   supranational bodies

o   Third parties who are involved in judicial proceedings

o   External service providers

E-World Fashion processes the User’s personal data where necessary for the purposes of the legitimate 

interests pursued by e-World Fashion or by a third party, except where such interests are overridden by the User’s interests or fundamental rights and freedoms.  In order to reconcile e-World Fashion’s legitimate interests with the User’s rights, e-World Fashion has introduced appropriate control mechanisms. On this basis, e-World Fashion processes the User’s data for the following purposes:

·       Participation in proceedings (including judicial proceedings) conducted by courts, law  enforcement  agencies, government agencies or public authorities, intergovernmental or supranational bodies, in particular for the purpose of detecting, investigating and prosecuting illegal acts, unless there is a statutory obligation to this effect, and e-World Fashion may legitimately assume that the disclosure of the data is necessary to avert imminent disadvantages or to report a suspicion of an illegal act.  In such cases, e-World Fashion will only disclose what e-World Fashion     believes is necessary, such as the User’s name, city, zip code, telephone number, email address,     (previous) user names, IP address, fraud complaints and bidding and listing history.

·       Protection of the legitimate interests of third parties in connection with civil law disputes, unless there is a statutory obligation to this effect, if e-World Fashion may legitimately assume that it is    necessary to disclose the data to such third parties in order to avert imminent disadvantages.

·       Prevention, detection, mitigation and investigation of fraud, security breaches and other prohibited or unlawful activities, including the assessment of corresponding risks (e.g. through the use of captchas or the telephone number stored in the User’s account for two-factor authentication), unless there is a statutory obligation to this effect.

·       Monitoring and improvement of the information security of the Services, unless there is a  statutory obligation to this effect.

·       Performance of identity checks, creditworthiness and other financial standing checks, evaluation of applications and comparison of information for accuracy and verification purposes.

·       Automatic filtering and, where necessary, manual review of messages sent through the  Platform’s messaging tools to prevent fraudulent or suspicious activity or violations of the           Agreement or other rules and Policies, including enforcing the prohibition of purchases, sales and other transactions outside of the Platform.

·       Provision of functions for Users that make the processing of transactions easier or more  convenient (e.g. administration of several delivery addresses).

·       Analysis of telephone conversations with e-World Fashion’s customer service that e-World Fashion recorded.

·       Advertisements by mail (according to the User’s communication preferences in the User’s account).

·       To the extent permitted by applicable law without the User’s consent, communications with the User via electronic mail (e.g. email or text message) or telephone to offer the User vouchers,   discounts and special offers, to conduct opinion polls and surveys and to inform the User about the Services (according to the User’s communication preferences in the User’s account).  If the User does not wish to receive marketing communications from e-World Fashion, the User can also unsubscribe by clicking on the link in the email the User received.  For technical reasons, the implementation may take a few days.

·       Notifications regarding promotions and information about the Services after logging into the User’s account or in messages in the Platform (according to the User’s communication preferences in the User’s account).

·       For Users outside the European Economic Area (EEA):  personalization, measurement and improvement of e-World Fashion and third-party advertisements in e-World Fashion or third-party online offerings.

·       Customization of page content to display the Items the User may like based on the actions the User takes.

·       Evaluation of the quality and success of e-World Fashion’s email marketing campaigns (e.g. through analysis of opening and click rates).

·       Assessment of the Service status (e.g. on the basis of tracking information if Sellers use shipping labels from shipping providers via the Platform or provide tracking numbers).

·       Offering of partner and bonus programs and other co-branded marketing efforts, e.g. co-branded credit cards in collaboration with a third party credit card issuer.

·       Provision of shared content and services (such as registration for services, transaction processing and customer service) with cooperating payment service providers.

·       Initiation, preparation and execution of a company acquisition, e.g. in the event of a merger with another company or takeover by another company.  If such an event occurs, e-World Fashion will     require the merged entity to comply with this Notice with respect to the User’s personal data.  Should the User’s personal data be processed for any purpose not specified in this Notice, the User will be informed in advance of the processing of the User’s data for this new purpose.

·       Assertion of or defense against legal claims, including those asserted by one User against another User.

·       Where necessary, e-World Fashion transmits the User’s personal data to processors and the  following recipients for one or several of the purposes described above:

o   External service providers

o   Other Users

o   Law enforcement agencies, arbitrators, courts, government agencies or public authorities,  ntergovernmental or supranational bodies

o   Third parties who are involved in arbitration or judicial proceedings

o   Payment service providers including PayPal

o   Credit agencies or bureaus, data verification services, risk assessment vendors and collections agencies (e.g. information about payment delays, payment defaults or other irregularities that may be relevant to the User’s credit report, or that e-World Fashion uses to confirm the User’s identity, model risk, establish credit limits, or collect unpaid debts)

o   Other companies in the context of a company acquisition

o   Third parties in the event of an investigation for fraud, intellectual property infringement, retail crime, stolen goods, product piracy or other unlawful activity, if e-World Fashion, in its sole  discretion, deems the investigation of such incident necessary or useful.  In such cases, e-World Fashion will disclose the User's name, address, city, zip code, country, telephone number, email address and company name to the third party and bind the third party by a worldwide non-disclosure agreement to treat the data as confidential to the extent practicable.

With the User’s consent, e-World Fashion processes the User’s personal data for the following purposes:

§  For Users within the European Economic Area (EEA):  personalization, measurement and  improvement of   e-World Fashion and third-party advertisements in e-World Fashion and third-party online offerings

§  Marketing communications by telephone or electronic mail (such as email or SMS), unless these communications are permitted without the User’s consent under applicable law.  e-World Fashion may engage third parties to send marketing communications on e-World Fashion’s behalf

§  Processing of the User’s precise location data to provide location-based services

§  Provision of a single sign-on service allowing the User to register or log-in to third-party services using the User’s Platform log-in credentials

§  Processing of the User’s personal data on the basis of the User’s consent, which the User has given so that  e-World Fashion or third parties can enable the User to use certain services or make them available to the User

§  The User can find information about the User’s right to withdraw the User’s consent below under Rights as a data subject and information with regard to the use of cookies and similar technologies below under Cookies & similar technologies.

§  Where necessary, e-World Fashion transmits the User’s personal data to processors and the following        recipients for one or several of the purposes described above:

·       External service providers

·       Third parties using e-World Fashion’s single sign-on service (as authorized by the User in each single case)

·       Other third parties with whom e-World Fashion partners to offer the User specific services (as described at the collection of the respective User consent)

·       Third-party financial institutions with whom e-World Fashion partners to offer financial products to the User, for them to provide joint content and services (such as, registration, transactions and customer support).  These third-party financial institution partners will use the User’s personal data to send the User marketing communications only if the User has requested their services

Automated decision-making.  E-World Fashion uses technologies that are considered automated decision making or profiling.  e-World Fashion will not make any automated decisions about the User that would significantly affect the User unless such a decision is necessary for entering into, or the performance of, a contract with the User, e-World Fashion has obtained the User’s consent or e-World Fashion is required by applicable law to use such technology.  The User will find information on the User’s right to object to this processing of the User’s data below.

6.  International data transfers  

Some recipients of the User’s personal data are located outside the User’s country or have offices in countries where data protection laws may provide a different level of protection than the laws in the User’s country.  When transferring personal data to such recipients, e-World Fashion provides appropriate safeguards.

Data transfers (from the European Economic Area to third countries).  e-World Fashion will only transfer the User’s personal data from the European Economic Area (EEA) to third countries, i.e.     countries outside the EEA, on the basis of appropriate safeguards. Third countries providing an adequate level of data protection according to the European Commission currently include Andorra,  Argentina, Canada (for companies covered by the Personal Information Protection and Electronic Documents Act), Switzerland, the Faroe Islands, Guernsey, the State of Israel, the Isle of Man, Japan, Jersey, New Zealand and Uruguay. Recipients in the USA can be partially certified according to the        EU-U.S. Privacy Shield, so that appropriate safeguards for an international data transfer exist.  In other cases, e-World Fashion provides the necessary safeguards, e.g. through the conclusion of data     protection contracts adopted by the European Commission (e.g. standard data protection clauses) with the recipients, or through other measures provided for by law.  A copy of relevant documentation of the measures taken is available on request.

7.  Storage duration and erasure  

The User’s personal data will be stored by e-World Fashion and its service providers in accordance with applicable data protection laws to the extent necessary for the processing purposes set out in this Notice.  Subsequently, e-World Fashion will delete the User’s personal data in accordance with    e-World Fashion’s data retention and deletion policy or take steps to properly render the data anonymous, unless e-World Fashion is legally obliged to keep the User’s personal data longer (e.g. for legal compliance, tax, accounting or auditing purposes).  In Europe, the retention periods are generally   between 6 and 10 years (e.g. for contracts, notifications and business letters).  As far as legally         permissible or required, e-World Fashion restricts the processing of the User’s data instead of       deleting it (e.g. by restricting access to it).  This applies in particular to cases where e-World Fashion may still need the data for the execution of the contract or for the assertion of or defense against     legal claims, or where such retention is otherwise required or permitted by law.  In these cases, the duration of the restriction of processing depends on the respective statutory limitation or retention periods.  The data will be deleted after the relevant limitation or retention periods have expired.

The specific retention periods for personal data are documented in e-World Fashion’s data retention guidelines.  How long e-World Fashion retains personal data may vary depending on the Services  e-World Fashion provides and its legal obligations under applicable law.  The following factors typically affect the retention period:

§  Necessity for the provision of the Services.  This includes such things as executing the Agreement with the User, maintaining and improving the performance of the Services, keeping e-World  Fashion’s systems secure and maintaining appropriate business and financial records.  Most of  e-World Fashion’s retention periods are determined on the basis of this general rule.

§  Special categories of personal data.  If e-World Fashion stores special categories of personal data (i.e., personal data revealing racial or ethnic origin, political opinions, religious or philosophical      beliefs, trade union membership, genetic or biometric data which is being processed for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation), a shorter retention period is usually appropriate.

§  Consent-based processing of personal data.  If e-World Fashion processes personal data on the  basis of consent (including consent to the extended storage), e-World Fashion stores the data for as long as necessary in order to process it according to the User’s consent.

§  Statutory, contractual or other similar obligations.  Corresponding storage obligations may arise, for            example, from laws or official orders.  It may also be necessary to store personal data with regard to pending or future legal disputes.  Personal data contained in contracts, notifications and business letters may be subject to statutory storage obligations depending on applicable law.

8.  Rights as a data subject

 Subject to possible restrictions under applicable law, as a data subject, the User has the right to  access,       rectification, erasure, restriction of processing and data portability with regard to the User’s personal data.  In addition, the User can withdraw the User’s consent and object to e-World Fashion’s processing of the User’s personal data on the basis of e-World Fashion’s legitimate interests.  The User can also lodge a complaint with a supervisory authority.

The User can withdraw the User’s consent to the processing of the User’s personal data by e-World Fashion at any time.  As a result, e-World Fashion may no longer process the User’s personal data based on this consent in the future.  The withdrawal of consent has no effect on the lawfulness of processing based on consent       before its withdrawal.

The User has the right to obtain access to the User’s personal data that is being processed by e-World Fashion.  In particular, the User may request information on the purposes of the processing, the categories of personal data concerned, the categories of recipients to whom the personal data have been or will be disclosed, the envisaged period for which the personal data will be stored, the existence of the right to request rectification or erasure of personal data or restriction of processing of personal data or to object to such processing, the right to lodge a complaint with a supervisory authority, any available information as to the personal data’s source (where they are not collected from the User), the existence of automated decision-making, including profiling and, where appropriate, meaningful information on its details.  The User’s right to access may be limited by applicable law.

The User has the right to obtain from e-World Fashion without undue delay the rectification of inaccurate personal data concerning the User.  Taking into account the purposes of the processing, the User has the right to have incomplete personal data completed, including by means of providing a supplementary statement.

The User has the right to obtain from e-World Fashion the erasure of personal data concerning the User, unless processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims.  The right to erasure may be limited by applicable law.

The User has the right to obtain from e-World Fashion restriction of processing to the extent that:

§  the accuracy of the data is disputed by the User,

§  the processing is unlawful, but the User opposes the erasure of the personal data,

§  e-World Fashion no longer needs the data, but the User needs it to assert, exercise or defend legal claims or

§  the User has objected to the processing.

The User has the right to receive the personal data concerning the User, which the User has provided to            e-World Fashion, in a structured, commonly used and machine-readable format and has the right to transmit those data to another controller ("right to data portability").

The User has the right to lodge a complaint with a supervisory authority or the registered office of the controller.

If the User’s personal data is processed on the basis of e-World Fashion’s legitimate interests, the User has the right to object to the processing of the User’s personal data on grounds relating to the User’s particular          situation.  This also applies to profiling.  If the User’s personal data is processed by e-World Fashion for direct marketing purposes, the User has the right to object at any time to the processing of the User’s personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

The exercise of the above data subjects' rights (e.g. right to access or erasure) is generally free of charge.  Where requests are manifestly unfounded or excessive, in particular because of their repetitive character,         e-World Fashion may charge an appropriate fee (at most its actual costs) in accordance with the applicable statutory regulations or refuse to process the application.

Exercising the User’s rights and managing the User’s settings.  The User can exercise the User’s rights as a data subject by contacting e-World Fashion.  If the User would like to change the User’s preferences regarding       notifications (including marketing communications), the User can do so at any time by contacting e-World Fashion.  If the User does not wish to receive marketing communications from e-World Fashion, the User can also unsubscribe by clicking on the link in the email the User received.  For technical reasons, the implementation may take a few days.

9.  Cookies & similar technologies  

When the User uses the Services, e-World Fashion and selected third parties may use cookies and similar   technologies to provide the User with a better, faster and safer user experience or to show the User                 personalized advertising.  Cookies are small text files that are automatically created by the User’s browser and stored on the User’s device when the User uses the Services.  The User can find detailed information about e-World Fashion’s use of cookies and similar technologies and the User’s choices in e-World Fashion’s Cookie Notice.

e-World Fashion’s cookies and similar technologies have different functions:

§  They may be technically necessary for the provision of the Services

§  They help e-World Fashion optimize the Services technically (e.g. monitoring of error messages and loading times)

§  They help e-World Fashion improve the User’s user experience (e.g. save font size and form data entered)

§  They allow e-World Fashion to show the User more relevant advertisements

e-World Fashion uses cookies and similar technologies that remain on the User’s device only as long as the User’s browser is active (session cookies), as well as cookies and similar technologies that remain on the User’s device longer (persistent cookies).  Where possible, e-World Fashion takes appropriate security measures to prevent unauthorized access to e-World Fashion’s cookies and similar technologies.  A unique ID ensures that only e-World Fashion and/or selected third parties have access to cookie data.

The User’s choices regarding cookies.  The User is free to disable the use of cookies and similar technologies if this is supported by the User’s device.  The User can manage the User’s cookie settings in the User’s browser or device settings.  In addition, the User can decide whether e-World Fashion may use cookies and similar       technologies to show the User personalized advertisements:

·       To manage the settings regarding the use of first-party cookies (and similar technologies) for advertising-related purposes, please contact e-World Fashion

·       The User can find information about third-party cookies (and similar technologies) related to     advertising and how to prevent their use on the following websites:

o   www.youronlinechoices.eu

o   www.aboutads.info/choices (only available in English)

o   www.networkadvertising.org/choices (only available in English)

·       Users in the European Economic Area (EEA) can also use Advertising and related preferences to determine to what extent they consent to the processing of their personal data for advertising purposes via cookies (and similar technologies)

If the User decides not to have the User’s personal data processed by e-World Fashion for advertising purposes via cookies (and similar technologies), this does not mean that e-World Fashion will not show the User advertisements.  It simply means that these advertisements will not be personalized for the User using first-party or third-party cookies, web beacons, or similar technologies.

10.  Data security  

e-World Fashion protects the User’s personal data through technical and organizational security measures to minimize risks associated with data loss, misuse, unauthorized access and unauthorized disclosure and alteration.  To this end e-World Fashion uses firewalls and data encryption, for example, as well as physical access restrictions for its data centers and authorization controls for data access.  The User can find further information on e-World Fashion’s data security by contacting e-World Fashion.

11.  Other important information regarding data protection

This section contains important additional information about the protection of personal data in connection with the use of the Services, including whether the User is required to provide personal data.

What happens when the User shares the User’s personal data on the Platform(s)?

§  Other Users have access to the information the User shares on the Platform or discloses to other Users.  For example, other Users can see the User’s bids, purchases, items for sale, saved interests, sellers and searches, storefronts, feedback, ratings, product reviews and associated comments.      Other Users can also see any information the User chose to share in the User’s profile.

§  When the User uses the Services, the User’s public User ID may be displayed and available to the public and associated with all of the User’s public Platform activity.  Notices sent to other Users about suspicious activity and notice violations on e-World Fashion’s sites may refer to the User’s public User ID and specific items.  Accordingly, if the User uses a username that allows others to identify the User, these others may be able to identify the User’s Platform activities.

§  To help protect the User’s personal data, e-World Fashion allows only limited access to other Users' contact, shipping and financial information as necessary to facilitate the User’s transactions and collect payments.  However, when Users are involved in a transaction, they have access to each other's name, User ID, email address and other contact and shipping information.  For example, e-World Fashion may allow Users to exchange telephone numbers in order to contact each other prior to completing a transaction (e.g. a Seller may opt to share their telephone number with a Buyer so that the Buyer may call with questions about a listed Item).  In this case, Sellers are prohibited from using a buyer's telephone number for other purposes (e.g. completing a transaction off the Platform or adding the Buyer to a marketing list).

The User’s responsibilities over transactional information the User receives through the Platform

§  When the User completes a transaction with another User (or a transaction has been cancelled, failed or subsequently invalidated), e-World Fashion will provide the User with the other User's personal data (such as name, username, email address, contact information, shipping and billing information or return address).  Independent from e-World Fashion, the User is the controller of such data and responsible for any processing that the User perform after e-World Fashion has shared this data with the User, including compliance with any limitations imposed by this Notice and the Agreement.

§  Unless the User acts for purely personal purposes, e-World Fashion recommends that the User explain the User’s data processing activities in the User’s own privacy notice and protect the privacy of other Users.  As a Seller, the User must in any case comply with the applicable data protection laws and in particular protect the rights of other Users as data subjects, e.g. give them the opportunity to access the personal data collected by the User and demand that it be erased.

§  The User may only use the personal data that the User has access to for Platform transaction-related purposes, or for other Services offered (such as shipping, fraud complaints and member-to-member communications), and for purposes expressly consented to by the User to whom the data relates.  Using personal data of other Users that the User has access to for any other purpose, such as adding them to a mailing list without their express consent, constitutes a violation of the Agreement.

Personal data relating to third parties.  If the User provides e-World Fashion with personal data relating to another person, the User must obtain the consent of this person or the disclosure of the data to e-World Fashion must be otherwise legally permissible.  The User must inform the other person of how e-World Fashion processes personal data in accordance with the Notice.

Filtering of messages sent via the Platform’s messaging tools.  All messages sent via the Platform’s messaging tools may first be received by e-World Fashion and then forwarded to the recipient.  All messages are subject to being automatically filtered according to certain criteria.  If necessary, conspicuous messages may be checked manually by e-World Fashion’s customer service.  In the event of a violation of the Agreement (including any of e-World Fashion’s rules and Policies), e-World Fashion reserves the right to block the transmission of the message, restrict the purchase, sale and similar functions of the User’s account and/or block the User’s account.  This is to protect e-World Fashion’s legitimate interests such as protecting against fraudulent or suspicious activities (e.g. spam, viruses, phishing or other illegal activities) or enforcing the Agreement and e-World Fashion’s other rules and Policies (e.g. illegal and other prohibited content), including but not limited to enforcing the prohibition of purchases, sales and other transactions outside of the Platform.

Is the User obliged to provide the User’s personal data to e-World Fashion?  Some of the personal data that the User provides to e-World Fashion (e.g. data by which e-World Fashion can identify the User) is required to enter into the Agreement.  As described elsewhere in this Notice, e-World Fashion may share this data with service providers, including payment processors, credit agencies and bureaus.  Although the provision of any other personal data (e.g. address and shipping data) is voluntary, it may be necessary for the use of the Services, such as bidding, purchase and sales data to complete a transaction.

Children's Privacy.  The Services are not intended for the use by children.  e-World Fashion does not knowingly collect personal data from Users who are considered children under applicable laws.  Under the Agreement, children are not permitted to use the Services.

Staying Signed-in.  When the User signs into the User’s account on the Services, e-World Fashion gives the User the option to stay signed-in to the User’s account for a certain amount of time.  If the User is using a public or shared computer, e-World Fashion encourages the User to decline.  The User or any other user of the computer/browser the User signed in on will be able to view and access most parts of the User’s account and take certain specific actions during this signed-in period without any further authorization.  The specific actions and account activities that the User or any other user of this computer/browser may take include:

§  Bid, buy or make an offer on an Item

§  Check out or add Items to the User’s cart

§  Purchase an Item with stored payment methods

§  View or edit account information

§  Send messages, including to other Users

§  Conduct post-transaction activities, like leaving feedback, canceling orders, requesting returns or submitting claims

If the User attempts to change the User’s password or User ID, update any other account information or attempt other account activity beyond those listed above, the User may be required to enter the User’s password.

The User can typically end the User’s signed-in session by either signing out and/or clearing the User’s cookies.  If the User has certain browser privacy settings enabled, simply closing the User’s browser may also end the User’s signed in session.  If the User is using a public or shared computer, the User should sign out and/or clear the User’s cookies when the User is done using the Services to protect the User’s account and the User’s personal data. 

                                                                 CALIFORNIA PRIVACY NOTICE

This CALIFORNIA PRIVACY NOTICE (this “California Notice”) is effective from September 30, 2020. Reference is hereby made to that certain User Agreement (the “Agreement”), by and between e-World Fashion LLC (“e-World Fashion”) and any person agreeing to the Agreement and/or using the Services (the “User”), as amended, and all other terms, conditions, policies or notices posted from time to time on e-World Fashion’s website(s), including without limitation the Privacy Notice (collectively, “Policies”).  The Agreement and Policies are incorporated by reference in this California Notice as though fully set forth herein, and capitalized terms used but not defined herein shall have the meanings set forth therefor in the Agreement and the Policies.  This California Notice is provided as a supplement to the Privacy Notice and includes information on how the User can exercise the User’s rights pursuant to the California Consumer Privacy Act (the “CCPA”).  This California Notice applies solely to individual residents of the State of California.  This California Notice does not apply to the personal information e-World Fashion collects from employees or job applicants.

 Categories of personal information that e-World Fashion may collect about California consumers

·       Identifiers, such as name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers.

·       Customer Records, such as physical characteristics or description, telephone number, bank account number, credit card number, debit card number, or any other financial information.

·       Personal Characteristics or Traits, such as demographic data.

·       Customer Account Details/Commercial Information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

·       Internet Usage Information, such as browsing history, search history and information regarding a consumer’s interaction with any e-World Fashion website, Platform, Services or advertisement.

·       Geolocation Data, such as physical location or movements and travel patterns.

·       Sensory Data, such as audio recordings of customer service calls.

·       Inferences derived from personal information, such as information about the User’s interests or purchase preferences.

Categories of sources of personal information that e-World Fashion collects.  E-World Fashion receives personal information from a variety of sources, including from the User directly, the User’s devices or partners.  The categories of sources from which personal information is collected includes:

§  The User

§  Other Users

§  Advertising networks

§  Service providers (including Internet service providers or ISPs)

§  Data analytics providers

§  Government entities and other public sources

§  Operating systems and platforms

§  Social networks

§  Data brokers and other data providers

§  Vendors and suppliers

§  Credit agencies or bureaus

§  Other sources as listed in the Privacy Notice

Business or commercial purpose for collection.  The purposes for which e-World Fashion collects personal information are described in the Privacy Notice.

Categories of personal information disclosed for a business purpose.  e-World Fashion shares personal information with service providers and other vendors.  The following Table lists the categories of personal information disclosed for a business purpose and the categories of recipients who have received this personal information.  Not every one of the following categories may apply to the User’s personal information.

Category of Personal Information Disclosed for a Busines Purpose	Category of Recipients
1.     Identifiers 2.     Customer Records 3.     Personal Characteristics or Traits 4.     Customer Account Details/Commercial Information 5.     Internet Usage Information 6.     Geolocation Data 7.     Inferences Derived from Personal Information	·       Service providers ·       Credit agencies (when required by law) ·       Financial institutions ·       Government authorities and agencies

Categories of personal information “sold.”  The following lists the categories of personal information “sold” and the categories of recipients who have received this information.  The CCPA’s definition of “sale” is broad and includes sharing practices common among online marketplaces.  While, without the User’s consent, e-World Fashion does not sell the User’s personal information for money, e-World Fashion does share information for a variety of other purposes, such as to tailor the User’s online experience or provide more relevant advertisements to the User.

e-World Fashion identifies in the table below as a “sale” the categories of personal information that e-World Fashion disclosed to third parties for advertising purposes, which allows them to tailor the User’s online experience, provide relevant content to the User and measure its effectiveness.

Category of Personal Information “Sold”	Category of Recipients
1.     Identifiers 2.     Internet Usage Information 3.     Inferences Derived from Personal Information	·       Advertising networks

 

 

Children.  e-World Fashion does not knowingly collect, disclose or sell the personal information of consumers under 16.  According to the Agreement, children under age 18 are not permitted to use the Services.  If a parent or guardian becomes aware that a child has provided e-World Fashion with personal information, they should contact e-World Fashion, and e-World Fashion will address the issue.

CCPA Rights

The CCPA provides new rights to California consumers.  These include rights to:  access, deletion, opt-out and non-discrimination.  This section provides more information about each right and how California consumers can exercise these rights under the CCPA.

For e-World Fashion to fulfill the User’s request, the User must provide sufficient information for e-World Fashion to reasonably verify that the User is the consumer from whom e-World Fashion collected the personal information.  The information the User sends for e-World Fashion to verify the User’s identity will be used for this purpose only.  If e-World Fashion is unable to verify the User’s identity or if e-World Fashion suspects fraudulent activity, e-World Fashion may decline to comply with the User’s request. 

E-World Fashion will make commercially reasonable efforts to identify the User’s personal information that e-World Fashion collects, processes, stores, discloses and otherwise uses and to respond to the User’s requests.  e-World Fashion reserves the right to charge a reasonable fee, or decline to act upon a request, if it is excessive or overly burdensome.  In addition, e-World Fashion will not honor the User’s requests to the extent that doing so would infringe upon e-World Fashion’s or any other person or party’s rights or conflict with applicable law.  If e-World Fashion denies the User’s request, e-World Fashion will explain the reasons in its response. 

Right to access

o   The right to access (also called a “request to know”)

§  California consumers have the right to request that e-World Fashion disclose the personal information that e-World Fashion collects, uses, discloses and sells.  This includes the right to request the categories of personal information e-World Fashion has collected about them, the categories of sources of personal information, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom e-World Fashion shares or sell personal information, and the specific pieces of personal information e-World Fashion has collected.

§  e-World Fashion tries to fulfill access requests within 45 days of receiving the request.  If e-World Fashion needs more time or additional information to fulfill the User’s request, e-World Fashion will write to let the User know.

o   How to exercise the right to access

§  Registered e-World Fashion Users with accounts in good standing

·       If the User is a registered e-World Fashion User with an account in good standing, the User can request a copy of the data e-World Fashion holds about the User at any time through the User’s e-World Fashion account.  e-World Fashion will verify the User’s identity using the User’s existing username and password prior to allowing the User to make a request.

·       The User may submit the User’s request by contacting e-World Fashion

§  For non-registered e-World Fashion Users and e-World Fashion Users with suspended accounts, the User may submit the User’s request by contacting e-World Fashion.

·       e-World Fashion is required to verify the identity of everyone to whom e-World Fashion releases personal information.  Please include the User’s first name, last name, country of residence and the email address the User used for any guest transactions the User made.  Before fulfilling the User’s data request, e-World Fashion will ask the User for Proof Of Identity (POI) and Proof Of Address (POA) to ensure that e-World Fashion is only releasing personal information to authorized parties.

·       The POI/POA the User provides will be used solely for the purpose of identity verification related to this transaction (i.e. the release of personal information) and will be processed and stored in accordance with the Notice.

·       The User may also contact Customer Service to submit the User’s access request.

§  Authorized agents

·       If the User is a registered agent and wants to submit a request on behalf of a California consumer with a registered e-World Fashion account in good standing, the User should work with the registered User to submit an access request directly through his or her account.

·       If the User is submitting a request on behalf of a person without a registered e-World Fashion account, the User may submit the request by contacting e-World Fashion and disclosing, “I am a third party making a request on behalf of a data subject.”

·       The User will need to provide POI and POA for the consumer on whose behalf the User is submitting the request and proof that the User is authorized to act on their behalf.  Only after verifying both the User’s authorization to act and proof of the requestor’s identity will e-World Fashion fulfill the request.  The report containing a copy of the requestor’s personal data will be sent directly to the requestor at the email address he or she uses for e-World Fashion transactions.

·       If the name, address or email address the User provides e-World Fashion for the requestor does not match what is in e-World Fashion’s records, e-World Fashion will not be able to process the request.

Right to deletion

§  The right to deletion

·       Subject to some exceptions, California consumers have the right to request the deletion of the personal information e-World Fashion has collected from them. 

·       Deletion requests may take between 30 and 60 days to fulfill (depending on whether the User has recently transacted business through e-World Fashion.  If e-World Fashion needs more time or additional information to fulfill the User’s request, e-World Fashion will write to let the User know.

§  How to exercise the right to deletion

·       Registered e-World Fashion Users with accounts in good standing

o   If the User is a registered e-World Fashion User with an account in good standing, the User can submit a deletion request at any time through the User’s e-World Fashion account.  The User’s account will be closed as part of fulfilling the User’s deletion request.  e-World Fashion will verify the User using the User’s existing username and password prior to allowing the User to make a request.

·       Non-registered e-World Fashion Users (e.g. guest Users) or e-World Fashion Users with suspended accounts

o   For non-registered e-World Fashion Users and e-World Fashion Users with suspended accounts, the User may submit the User’s deletion request by contacting e-World Fashion. 

o   e-World Fashion is required to verify the identity of everyone to whom e-World Fashion releases personal information.  Please include the User’s first name, last name, country of residence and the email address the User used for any guest transactions the User made.  Before fulfilling the User’s request, e-World Fashion will ask the User for POI and POA to ensure that e-World Fashion is only deleting personal information for authorized parties.

o   The POI/POA the User provides will be used solely for the purpose of identity verification related to this transaction (i.e. the deletion of personal information) and will be processed and stored in accordance with the Notice.

o   The User may also contact Customer Service to submit the User’s deletion request.

·       Authorized agents

o   If the User is a registered agent and wants to submit a request on behalf of a California consumer with a registered e-World Fashion account in good standing, the User should work with the registered User to submit a deletion request directly through his or her account.

o   If the User is submitting a request on behalf of a person without a registered e-World Fashion account, the User may submit the request by contacting e-World Fashion and disclosing, “I am a third party making a request on behalf of a data subject.”

o   The User will need to provide POI/POA for the consumer on whose behalf the User is submitting the request and proof that the User is authorized to act on their behalf.  Only after verifying both the User’s authorization to act and proof of the requestor’s identity will e-World Fashion fulfill the request.

o   If the name, address or email address the User provides e-World Fashion for the requestor does not match what is in e-World Fashion’s records, e-World Fashion will not be able to process the request.

Right to opt-out

§  The right to opt-out

·       California consumers have the right to opt-out of any “sale” of their personal information.  As mentioned, the CCPA’s definition of “sale” is broad and includes sharing practices common among online marketplaces.  While, without the User’s consent, e-World Fashion does not sell personal information for money, e-World Fashion does share information for a variety of other purposes, such as to tailor the User’s online experience or provide more relevant advertisements to the User.

§  How to exercise the right to opt-out

·       Registered e-World Fashion Users with accounts in good standing

o   The User may contact e-World Fashion to make a “CCPA opt-out request.”

o   In addition, the User may contact Customer Service to submit the User’s opt-out request.

·       Non-registered e-World Fashion Users (e.g. guest Users) or e-World Fashion Users with suspended accounts

o   The User may contact e-World Fashion to make a request

o   Important note for Users without a registered e-World Fashion account:  e-World Fashion is unable to permanently opt-out consumers who do not have a registered e-World Fashion account.  When non-registered Users opt-out, the opt-out choice will only apply to the User’s use of e-World Fashion through the browser used to submit the User’s opt-out request so long as that browser’s cookies are not erased.

·       Authorized agents

o   If the User is a registered agent and want to submit an opt-out request on behalf of a registered e-World Fashion User, the User may contact e-World Fashion to make a request. 

o   A User making such request should disclose, “I am a third party making a request on behalf of a data subject.”

o   The User should include the e-World Fashion username of the consumer for whom the User is making the request and disclose, “CCPA opt-out request.”

o   As mentioned, e-World Fashion is unable to permanently opt-out consumers without a registered e-World Fashion account.  Please inform the consumer for whom the User is making the request that the opt-out choice will only apply to his or her use of e-World Fashion through the browser used to submit the request and only so long as that browser’s cookies are not erased.

Right to non-discrimination.  A business may not discriminate against a California consumer because the consumer exercised their rights under CCPA.  e-World Fashion does not use the fact that the User has exercised, or requested to exercise, any CCPA rights for any purpose other than facilitating a response to the User’s request.

Do Not Track.  California law requires e-World Fashion to let the User knows how e-World Fashion responds to web browser Do Not Track (DNT) signals.  Because there currently isn't an industry or legal standard for recognizing or honoring DNT signals, e-World Fashion doesn't respond to them at this time.

California’s “Shine the Light” Law.  If the User is a California resident, the User is entitled once a year, free of charge, to request and obtain certain information regarding e-World Fashion’s disclosure, if any, of certain categories of Personal Information to third parties for their direct marketing purposes in the preceding calendar year.  e-World Fashion does not share personal information with third parties for their own direct marketing purposes without obtaining the User’s consent or providing the ability to opt-out.

Cookies.  e-World Fashion encourages the User to manage the User’s browser-based cookies by adjusting the User’s settings.  For more detailed information about e-World Fashion’s practices related to cookies, web beacons and similar technologies, please see the Cookie Notice.

Security and Protection of Personal Information.  For more information on how e-World Fashion protects the User’s personal information from unauthorized use and access, refer to the Notice.

Changes.  e-World Fashion reserves the right to change this California Notice from time to time.  Changes shall become effective on the date they are posted.

Additional information.  If the User has any questions about this California Privacy Policy, e-World Fashion’s global privacy standards or e-World Fashion’s handling of personal data, the User can contact e-World Fashion.

COOKIE NOTICE

This COOKIE NOTICE (this “Cookie Notice”) is effective from September 30, 2020.  Reference is hereby made to that certain User Agreement (the “Agreement”), by and between e-World Fashion LLC (“e-World Fashion”) and any person agreeing to the Agreement and/or using the Services (the “User”), as amended, and all other terms, conditions, policies or notices posted from time to time on e-World Fashion’s website(s) (collectively, “Policies”).  The Agreement and Policies are incorporated by reference in this Cookie Notice as though fully set forth herein, and capitalized terms used but not defined herein shall have the meanings set forth therefor in the Agreement and the Policies.

Users can adjust the settings for the usage of first-party cookies (and similar technologies) for marketing purposes by contacting e-World Fashion.  Users in the European Economic Area (the “EEA”) can also determine whether they consent to the use of cookies and similar technologies for marketing purposes via advertising preferences.

The Cookie Notice details all relevant information regarding the use of cookies, web beacons and similar technologies in connection with the Services and options in this regard. This Cookie Notice shall be read in conjunction with the Privacy Notice and the information regarding cookies and similar technologies which the Privacy Notice contains.  This Cookie Notice is applicable regardless of how the User accesses and makes use of the Services including the access via mobile devices and apps.

1. Information regarding the technologies e-World Fashion uses

When the User uses the Services, e-World Fashion and authorized third-party providers make use of cookies and similar technologies.  e-World Fashion makes use of cookies and similar technologies which will not be saved on the User’s device or which will only be saved on the User’s device for as long as the User’s browser is active (e.g. session cookies).  Furthermore, e-World Fashion makes use of cookies and similar technologies which will be saved on the User’s device for a longer period (e.g. persistent cookies).  Where possible, e-World Fashion takes appropriate security measures to prevent unauthorized access to e-World Fashion’s cookies and similar technologies.  A unique identifier (ID) ensures that only e-World Fashion and authorized third-party providers have access to data that has been collected by means of cookies and similar technologies.

The cookies and similar technologies used by e-World Fashion have various functions:

·       They can be (technically) necessary for the provision of the Services

·       They help e-World Fashion to technically enhance the Services (e.g. monitoring of error messages and loading times)

·       They help e-World Fashion to improve the User’s user experience (e.g. by saving the font size and data entered into webforms)

·       They enable e-World Fashion to show the User more relevant ads

What are cookies, web beacons and similar technologies

§  Cookies

·       Cookies are small text files (typically made up of letters and numbers) which are placed in the memory of the User’s browser or device when the User makes use of the Services, in particular when the User visits e-World Fashion’s website or when the User opens a message.  Cookies allow for a recognition of a specific device or browser.  There are different types of cookies:

o    Session cookies (also called session-based cookies) expire at the end of the User’s session (e.g. when closing the User’s browser window) and enable the entity using them to track the User’s activities during this one session

o    Persistent cookies remain stored on the User’s device between sessions and enable e-World Fashion, for example, to track the User’s settings or activities on several websites

o    First-party cookies are set by the provider whose online service the User is using (e.g. the operator of the website the User is visiting)

o    Third-party cookies are set by a provider other than the provider whose online service the User is using (e.g. the operator of a website other than the one the User is visiting)

§  Web beacons

·       Web beacons (also known as pixel tags or clear GIFs) are small graphic images that are used in connection with the provision of the Services and which typically work in conjunction with cookies to track the use of an online service by its users.  For example, when e-World Fashion sends the User emails, web beacons may allow e-World Fashion to track if the User opened the emails and clicked links to measure campaign performance and improve features.

§  Similar technologies

·       Similar technologies are technologies which enable the entity using it to track the User’s user behavior.  This can be done by local shared objects or local storage, such as flash cookies, HTML 5 cookies and other web application software methods, all of which store information in the User’s browser or device.  Additionally, there are other technologies that function without local storage in the User’s end device and instead make use of, inter alia, browser functions.  In this context, a "fingerprint" of the User’s system is created that serves as a unique identifier.

·       These technologies may function across all the User’s browsers and in some cases are not fully managed by the User’s browser, but may need to be managed directly from the User’s installed applications or the User’s device. e-World Fashion sometimes use the terms cookies and similar technologies interchangeably.

Why these technologies are used

Some of the Services can only be offered using cookies, web beacons and similar technologies.  In general, these technologies enable e-World Fashion to track the User’s user behavior and identify the User, even across devices.  The User can find more information about the personal data that e-World Fashion collects using cookies and similar technologies in the Privacy Notice.

The cookies, web beacons and similar technologies used in connection with the Services serve the following functions:

·       Technologies which are operationally necessary.  e-World Fashion uses cookies, web beacons and similar technologies that are necessary for the operation of the Services.  This includes technologies that allow the User accesses to e-World Fashion’s sites, services, applications and tools, which are required to monitor the functioning of the site, prevent fraudulent activity and improve security or that allow the User to make use of Platform functions such as shopping carts, saved search or similar functions.

·       Technologies which are performance-related.  e-World Fashion uses cookies, web beacons or other similar technologies to assess the performance of the Services.  This happens, inter alia, to analyze how visitors use the Services, how Users use e-World Fashion’s messaging tools, if and how Items and links are viewed or how to improve the Services.

·       Technologies which are functionality-related.  e-World Fashion uses cookies, web beacons or other similar technologies that allow e-World Fashion to offer the User enhanced functionality when accessing or using the Services.  These technologies may, inter alia, identify the User when the User signs in to the Services or they may store the User’s settings or the Items viewed, so that e-World Fashion can enhance the presentation of content within the Services and facilitate it (e.g. by means of the 'stay logged in function').

·       Technologies which are advertising- or targeting-related.  e-World Fashion uses cookies, web beacons or other similar technologies to deliver content tailored to the User’s interests, including advertisements, in connection with the provision of the Services or within third-party online services (retargeting, remarketing).  This includes using technologies to determine how relevant the advertisements and contents are for the User, which ads have already been shown to the User, how often they have been shown, when and where they have been shown and if the User has reacted by carrying out an activity, such as clicking on an ad or purchasing an Item.  For this purpose, data will be combined with data already collected regarding the User’s interests.

·       Inter alia, e-World Fashion collects data regarding the User’s device (e.g. the operating system and its version) to provide a uniform service on all the User’s devices.  The User can find further information on personal data that e-World Fashion collects by the means of cookies and similar technologies in the Privacy Notice.

Which service providers do e-World Fashion cooperates with?

In regard to the usage of cookies, web beacons and similar technologies, e-World Fashion cooperates with authorized service providers.  This includes, inter alia, ad networks and ad exchanges, which enable e-World Fashion to show the User advertisements.

Authorized service providers are entitled to place web beacons and similar technologies within the Services and to place cookies on the User’s device, as far as this is permissible according to applicable law.  In this context, data for the identification of the User’s device will be tracked, for example the IP address, the device ID or the advertising ID.

This enables the service providers to help e-World Fashion deliver content and more relevant advertisements, and to produce anonymous metrics and analytics, including conversion statistics.  The processing of personal data by external service providers is subject to data protection and confidentiality agreements with e-World Fashion and applicable data protection laws.  With regard to data processing by service providers, please check the privacy notices of the respective third-party providers.

Service providers that e-World Fashion cooperates with may include Facebook and Google:

Facebook:  Provision of advertising services via Facebook's advertising and marketing platforms, e.g. Website Custom Audiences

Google:  Provision of advertising services via Google's advertising and marketing platforms, e.g. Google Ads, Google Marketing Platform, Google Ad Manager

With the exception of the use of such technologies by e-World Fashion’s service providers or other authorized third parties, e-World Fashion does not permit any third-party content on sites (such as Item listings, communication between Users, classified listings, comments, reviews, etc.) to include or utilize any cookies, web beacons, local storage or similar technologies for tracking purposes or to collect the User’s personal data for the own purposes of such third parties.  If the User suspects that an offer or third-party content within the Services collects personal data or may use tracking technologies, the User should report same to e-World Fashion.

Users in the EEA can obtain information on other service providers and their privacy notices in connection with the advertising preferences.

What security measures does e-World Fashion take to protect the User’s data?  e-World Fashion protects its cookies and similar technologies to ensure that only e-World Fashion or authorized service providers can evaluate them.  For this purpose, e-World Fashion assigns a unique identifier (ID) to them that is designed so that only e-World Fashion can process them.

2. The User’s Choices

The User can decide to what extent e-World Fashion may use cookies and similar technologies within the provision of the Services.  The User’s options will depend on the purposes for which e-World Fashion uses these technologies.

Technologies which are operationally necessary, performance-related or functionality-related

·       If the User wishes to deactivate the use of any cookies, including cookies that are operationally necessary, performance-related or functionality-related, that e-World Fashion uses within the provision of the Services, the User may do so by changing the settings in the User’s browser or device, if this is supported by the User’s browser or device.  The settings must be made separately for each browser the User uses.

·       The User may not be able to use certain Services when the User deactivates cookies and similar technologies (e.g. the 'stay logged in function').  The User may also need to enter the User’s password more frequently during the User’s browser sessions.

Technologies which are advertising- or targeting-related

·       In addition, the User can specifically decide whether e-World Fashion and third parties may use cookies and similar technologies to show the User personalized ads.  If the User uses the Services within the EEA, this will only be done with the User’s consent, which the User can withdraw at any time.

·       If the User chooses not to have the User’s personal data processed by e-World Fashion for advertising purposes using cookies (and similar technologies), this does not necessarily mean that no advertisements will be shown to the User.  It simply means that these advertisements will not be personalized for the User by means of cookies, web beacons or similar technologies.  As a result, the User will no longer receive personalized advertising in the future, but the User’s data may still be collected as described in the Privacy Notice.

All users

·       The User can determine whether the User agrees to the use of advertising-related first-party cookies (and similar technologies).

·       The User can deactivate the use of any third-party cookies, e.g. by online ad networks, within the Services by changing the settings in the User’s browser or the device settings in the User’s device, if this is supported by the User’s browser or device.

·       The User can also find information on advertising-related third-party cookies and similar technologies and how to prevent their use on the following websites:

o    www.youronlinechoices.eu

o    www.aboutads.info/choices (available in English only)

o    www.networkadvertising.org/choices (available in English only)

·       If the User deletes all cookies on the User’s device, any opt-out cookies that have already been set will also be deleted, so that the User will have to declare again any opt-outs that have already been declared.

Users in the EEA.  Users in the EEA can also use the advertising preferences to determine whether they consent to the use of cookies and similar technologies for advertising purposes.

3. Do Not Track.  California law requires e-World Fashion to let the User know how e-World Fashion responds to web browser Do Not Track (DNT) signals.  Because there currently isn't an industry or legal standard for recognizing or honoring DNT signals, e-World Fashion doesn't respond to them at this time.  e-World Fashion awaits the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.