Privacy Policy

Privacy and Confidentiality

AmPortugal (we) are committed to the highest standards of privacy and data protection compliance. This Privacy Policy sets out how and why we collect, store, use, transfer and disclose your personal information and how you may access your personal information and correct it. This Privacy Policy also explains the use of cookies on our website AmPortugal.com (our site)..

Information we collect, and how we do it

We collect information, both general and personal, in a number of ways, as detailed in this Privacy Policy.
1. Data protection is a matter of trust and your privacy is important to us. We shall therefore only use your name and other information which relates to you in the manner set out in this Privacy Policy. We will only collect information where it is necessary for us to do so and we will only collect information if it is relevant to our dealings with you.
2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data was collected, and is no longer necessary for any legal or business purpose.
3. We will only keep your information for as long as we are either required to by law or as is relevant for the purposes for which it was collected.
4. You can visit the Site and browse without having to provide personal details. During your visit to the Site you remain anonymous and at no time can we identify you unless you have an account on the Site and log on with your user name and password.
5. We may collect various pieces of information if you seek to place an order for a product with us on the Site. We collect, store and process your data for processing your purchase on the Site and any possible later claims, and to provide you with our services. We may collect personal information including, but not limited to, your title, name, gender, date of birth, email address, postal address, delivery address (if different), telephone number, mobile number, fax number, payment details, payment card details or bank account details.

AmPortugal shall collect the following information where you are a buyer:

1. Identity data, such as your name, gender, profile picture, and date of birth;
2. Contact data, such as billing address, delivery address/location, email address and phone numbers;
3. Biometric data, such as voice files and face recognition when you use our voice search function, and your facial features of when you use the Site;
4. Billing account information: bank account details, credit card account and payment information (such account data may also be collected directly by our affiliates and/or third party payment service providers);
5. Transaction records/data, such as details about orders and payments, user clicks, and other details of products and Services related to you;
6. Technical data, such as Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, device information, browser plug-in types and versions, operating system and platform, international mobile equipment identity, device identifier, IMEI, MAC address, cookies (where applicable) and other information and technology on the devices you use to access the Site;
7. Profile data, such as your username and password, account settings, orders related to you, user research, your interests, preferences, feedback and survey responses;
8. Usage data, such as information on how you use the Site, products and Services or view any content on the Site, including the time spent on the Site, items and data searched for on the Site, access times and dates, as well as websites you were visiting before you came to the Site and other similar statistics;
9. Location data, such as when you capture and share your location with us in the form of photographs or videos and upload such content to the Site;
10. Marketing and communications data, such as your preferences in receiving marketing from us and our third parties, your communication preferences and your chat, email or call history on the Site or with third party customer service providers; and
11. Additional information we may request you to submit for due diligence checks or required by relevant authorities as required for identity verification (such as copies of government issued identification, e.g. passport, ID cards, etc.) or if we believe you are violating our Privacy Policy or our Customer Terms and Conditions.

AmPortugal shall collect the following information where you are a seller:

1. Identity and contact data, such as your name, date of birth or incorporation, company name, address, email address, phone number and other business-related information (e.g. company registration number, business licence, tax information, shareholder and director information, etc.);
2. Account data, such as bank account details, bank statements, credit card details and payment details (such account data may also be collected directly by our affiliates and/or third party payment service providers);
3. Transaction data, such as details about orders and payments, and other details of products and Services related to you;
4. Technical data, such as Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, international mobile equipment identity, device identifier, IMEI, MAC address, cookies (where applicable) and other information and technology on the devices you use to access the Site;
5. Profile data, such as your username and password, orders related to you, your interests, preferences, feedback and survey responses;
6. Usage data, such as information on how you use the Site, products and Services or view any content on the Site, including the time spent on the Site, items and data searched for on the Site, access times and dates, as well as websites you were visiting before you came to the Site and other similar statistics;
7. Location data, such as when you capture and share your location with us in the form of photographs or videos and upload such content to the Site;
8. Marketing and communications data, such as your preferences in receiving marketing from us and our third parties and your communication preferences and your chat, email or call history on the Site or with our third party seller service providers; and
9. Additional information we may request you to submit for authentication (such as copies of government issued identification, e.g. passport, ID cards, etc.) or if we believe you are violating our Privacy Policy or our Terms of Use.

Information:

We will use the information you provide to enable us to process your orders and to provide you with the services and information offered through our website and which you request in the following ways:.
If you are a buyer:
Processing your orders for products:

1. Process orders you submit through the Site;
2. Deliver the products you have purchased through the Site for which we may pass your personal information on to a third party (e.g. our logistics partner) in order to make delivery of the product to you;
3. Update you on the delivery of the products;
4. Provide customer support for your orders;
5. Verify and carry out payment transactions (including any credit card payments, bank transfers, offline payments, remittances, or e-wallet transactions) in relation to payments related to you and/or services used by you. In order to verify and carry out such payment transactions, payment information, which may include personal data, will be transferred to third parties such as our payment service providers;
Providing services
1. Facilitate your use of the services or access to the Site;
2. Administer your account with us;
3. Display your name, username or profile on the Site (including on any reviews you may post);
4. Respond to your queries, feedback, claims or disputes, whether directly or through our third party service providers; and
5. Display on scoreboards on the Site in relation to campaigns, mobile games or any other activity;
Marketing and advertising:
1. Provide you with information we think you may find useful or which you have requested from us (provided you have opted to receive such information);
2. Send you marketing or promotional information about \ products and services on the Site from time to time (provided you have opted to receive such information); and
3. Help us conduct marketing and advertising;
Legal and operational purposes:
1. Ascertain your identity in connection with fraud detection purposes;
2. Compare information, and verify with third parties in order to ensure that the information is accurate;
3. Process any complaints, feedback, enforcement action you may have lodged with us;
4. Produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
5. Store, host, back up your personal data;
6. Prevent or investigate any actual or suspected violations of our Terms of Use, Privacy Policy, fraud, unlawful activity, omission or misconduct, whether relating to your use of Site or any other matter arising from your relationship with us;
7. Perform due diligence checks;
8. Comply with legal and regulatory requirements (including, where applicable, the display of your name, contact details and company details), including any law enforcement requests, in connection with any legal proceedings, or otherwise deemed necessary by us; and
9. Where necessary to prevent a threat to life, health or safety.
Analytics, research, business and development:
1. Understand your user experience on the Site;
2. Improve the layout or content of the pages of the Site and customize them for users;
3. Identify visitors on the Site;
4. Conduct surveys, including carrying out research on our users’ demographics and behavior;
5. Derive further attributes relating to you based on personal data provided by you (whether to us or third parties), in order to provide you with more targeted and/or relevant information;
6. Conduct data analysis, testing and research, monitoring and analyzing usage and activity trends;
7. Further develop our products and services; and
Other
1. Any other purpose to which your consent has been obtained; and
2. Conduct automated decision-making processes in accordance with any of the above purposes.
If you are a seller:
Providing Services
1. To facilitate your use of the Site;
2. To ship or deliver the products you have listed or sold through the Site. We may pass your personal information on to a third party (e.g. our logistics partners) or relevant regulatory authority (e.g. customs) in order to carry out shipping or delivery of the products listed or sold by you;
3. To respond to your queries, feedback, claims or disputes, whether directly or through our third party service agents;
4. To verify your documentation submitted to us facilitate your onboarding with us as a seller on the Site, including the testing of technologies to enable faster and more efficient onboarding;
5. To administer your account (if any) with us;
6. To display your name, username or profile on the Site;
7. To verify and carry out financial transactions (including any credit card payments, bank transfers, offline payments, remittances, or e-wallet transactions) in relation to payments related to you and/or Services used by you. In order to verify and carry out such payment transactions, payment information, which may include personal data, will be transferred to third parties such as our payment service providers;
8. To assess your application for loan facilities and/or to perform credit risk assessments in relation to your application for seller financing (where applicable); 9. To provide you with ancillary logistics services to protect against risks of failed deliveries or customer returns; and
10. To facilitate the return of products to you (which may be through our logistics partner).
Marketing and advertising
1. To send you marketing or promotional materials about our or third-party sellers’ products and services on our Site from time to time (provided you have opted to receive such information); and
2. To help us conduct marketing and advertising.
Legal and operational purposes
1. To produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
2. To store, host, back up your personal data;
3. To prevent or investigate any actual or suspected violations of our Terms of Use, Privacy Policy, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
4. To comply with legal and regulatory requirements (including, where applicable, the display of your name, contact details and company details), including any law enforcement requests, in connection with any legal proceedings or otherwise deemed necessary by us;
5. Where necessary to prevent a threat to life, health or safety;
6. To process any complaints, feedback, enforcement action and take-down requests in relation to any content you have uploaded to the Site;
7. To compare information, and verify with third parties in order to ensure that the information is accurate;
8. To ascertain your identity in connection with fraud detection purposes; and
9. To facilitate the takedown of prohibited and controlled items from our Site.
Analytics, research, business and development
1. To audit the downloading of data from the Site;
2. To understand the user experience with the Services and the Site;
3. To improve the layout or content of the pages of the Site and customise them for users;
4. To conduct surveys, including carrying out research on our users’ demographics and behaviour to improve our current technology (e.g. voice recognition tech, etc) via machine learning or other means;
5. To derive further attributes relating to you based on personal data provided by you (whether to us or third parties), in order to provide you with more targeted and/or relevant information;
6. To conduct data analysis, testing and research, monitoring and analysing usage and activity trends;
7. To further develop our products and services; and
8. To know our sellers better.
Other
1. Any other purpose to which your consent has been obtained; and 2. To conduct automated decision-making processes in accordance with any of these purposes.

When we share your personal information with others

Personal information we collect stays within the AmPortugal family, other than in the following circumstances: when you give us explicit consent to share your data; when we share it with the greater Innovor family (i.e. with our affiliated and group companies); when we share it with our affiliates, partners, and other trusted organisations we work with to provide products and services to you; when we share it with trusted external service providers and data processors such as data centres, web hosts, cloud storage and cloud software providers, customer support providers, payment processors, debt collectors, accountants, and insurers; when we share it with prospective sellers or buyers of our business or assets; or when we share it with regulators and other relevant parties for the purpose of legal or contractual compliance, reporting purposes, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or the rights of third parties or the public at large.

Cookies

To make this site work properly, we sometimes place small data files called cookies on your device. Most big websites do this too. A cookie is a small text file that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another. Our site uses cookies to help us identify you from other users, track your usage of our site, and your website access preferences. We do or may use the following cookies: Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site, or make use of e-billing services. Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily. Functionality cookies. These are used to recognise you when you return to our site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). Targeting cookies. These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can control and/or delete cookies as you wish—for details. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.


Third Parties and Links

We may pass your details to other companies in our group. We may also pass your details to our agents and subcontractors to help us with any of our uses of your data set out in our Privacy Policy. For example, we may use third parties to assist us with delivering products to you, to help us to collect payments from you, to analyze data and to provide us with marketing or customer service assistance. We may also exchange information with third parties for the purposes of fraud protection and credit risk reduction. We may share (or permit the sharing of) your personal data with and/or transfer your personal data to third parties and/or our affiliates for the above-mentioned purposes. These third parties and affiliates, which may be located inside or outside your jurisdiction, include but are not limited to: Service providers (such as agents, vendors, contractors and partners) in areas such as payment services, logistics and shipping, marketing, data analytics, market or consumer research, survey, social media, customer service, installation services, information technology and website hosting; Their service providers and related companies; and Other users of the Site. We may transfer our databases containing your personal information if we sell our business or part of it, provided that we satisfy the requirements of applicable data protection law when disclosing your personal data. Other than as set out in this Privacy Policy, we shall NOT sell or disclose your personal data to third parties without obtaining your prior consent unless this is necessary for the purposes set out in this Privacy Policy or unless we are required to do so by law. The Site may contain advertising of third parties and links to other sites or frames of other sites. Please be aware that we are not responsible for the privacy practices or content of those third parties or other sites, nor for any third party to whom we transfer your data in accordance with our Privacy Policy. You are advised to check on the applicable privacy policies of those websites to determine how they will handle any information they collect from you. In disclosing your personal data to third parties, we endeavor to ensure that the third parties and our affiliates keep your personal data secure from unauthorized access, collection, use, disclosure, processing or similar risks and retain your personal data only for as long as your personal data helps with any of the uses of your data as set out in our Privacy Policy. We may transfer or permit the transfer of your personal data outside of Pakistan for any of the purposes set out in this Privacy Policy. However, we will not transfer or permit any of your personal data to be transferred outside of Pakistan unless the transfer is in compliance with applicable laws and this Privacy Policy. We may share your personal data with our third party service providers or affiliates (e.g. payment service providers) in order for them to offer services to you other than those related to your use of the Site. Your acceptance and use of the third party service provider’s or our affiliate’s services shall be subject to terms and conditions as may be agreed between you and the third party service provider or our affiliate. Upon your acceptance of the third party service provider’s or our affiliate’s service offering, the collection, use, disclosure, storage, transfer and processing of your data (including your personal data and any data disclosed by us to such third party service provider or affiliate) shall be subject to the applicable privacy policy of the third party service provider or our affiliate, which shall be the data controller of such data. You agree that any queries or complaints relating to your acceptance or use of the third party service provider’s or our affiliate’s services shall be directed to the party named in the applicable privacy policy.

Competitions

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

Security

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

Minors

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

Privacy complaints

If you believe that we have breached your privacy rights in any way, or you would like to discuss any issues about our Privacy Policy please contact us at [email protected]. All such enquiries or complaints will be taken seriously and will be handled as soon as reasonably practicable.

AmPortugal

Privacy Policy changes

We may change our Privacy Policy from time to time, and in our sole discretion. We encourage you to frequently check our site for any changes to our Privacy Policy. We will not reduce or diminish your rights under this Privacy Policy without your explicit consent. If any changes do not reduce or diminish your rights, your continued use of our site, services, requesting our assistance or the provision of further personal information to us (directly or via an authorized person) after any change in this Privacy Policy will constitute your acceptance of such change. If we make significant changes to this Privacy Policy, we will provide a more prominent notice of the changes, such as by emailing you.