Effective date: April 10, 2023

At Kerqu, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of the Kerqu Services is at all times subject to our Terms of Service <https://www.kerqu.com/pages/terms-of-service>, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

Category of Personal Data	Examples of Personal Data We Collect	Categories of Third Parties With Whom We Share this Personal Data
Account or Contact Data	First and last name Address Email Phone number	Service Providers Parties You Authorize, Access or Authenticate
Password Data	Unique identifiers such as log-in ID and passwords	Service Providers
Social Network Data	User name for third party social network account Phone number IP address Device ID	Service Providers Advertising Partners Analytics Partners Parties You Authorize, Access or Authenticate
Payment Data	Payment method	our payment processing partner
Order Data	Purchase history Order information (e.g. order time, order details, order account) Shipping/contract information Consumer profiles	Service Providers Advertising Partners Parties You Authorize, Access or Authenticate
Device Data	IP address Device ID Ad ID (IDFA, AAID) Type of device/operating system/browser used to access the Services	Service Providers Advertising Partners Parties You Authorize, Access or Authenticate
Analytics	Search inquiries Web page and application browsing, interactions, and usages data (e.g. page views, adding to cart, time of active use) Referring webpage/source through which you accessed the Services Non-identifiable request IDs Ad ID (IDFA, AAID) Statistics associated with the interaction between device or browser and the Services	Service Providers Advertising Partners Analytics Partners Parties You Authorize, Access or Authenticate
Consumer Demographic Data	Zip code Gender	Service Providers Parties You Authorize, Access or Authenticate
Geolocation Data	IP-address-based location information	Service Providers Advertising Partners Parties You Authorize, Access or Authenticate
Other Identifying Information that You Voluntarily Choose to Provide	Identifying information in emails you send us	Service Providers Parties You Authorize, Access or Authenticate

We collect Personal Data about you from the following categories of sources:

• You
• When you provide such information directly to us.
• When you create an account or use our interactive tools and Services.
• When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
• When you send us an email or otherwise contact us.
• Please note that we do NOT collect your payment detail information (i.e. Debit/Credit Card information, etc.) and all your payment are processed on SSL-secured pages, empowered by our payment partners.
• When you use the Services and such information is collected automatically.
• Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
• If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
• If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
• Third Parties
• Vendors
• We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
• We may use vendors to obtain information to generate leads and create user profiles.
• Social Networks
• If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.
• Advertising Partners
• We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.

• Creating and managing your account or other user profiles.
• Processing orders or other transactions; billing.
• Delivering and fulfilling your orders.
• Providing you with the products, services or information you request.
• Sending personalized curated feeds to you within the Kerqu application, and personalizing the Services, product listings, content and communications based on your preferences, your behaviors and usage of our Services, and your past order history through the Services. You can disable the personalized recommendation feature of the Kerqu application by adjusting your account setting.
• Meeting or fulfilling the reason you provided the information to us.
• Providing support and assistance for the Services.
• Improving the Services, including testing, research, internal analytics and product development.
• Doing fraud protection, security and debugging.
• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.

• Marketing and selling the Services.
• Showing you advertisements about our Services, including interest-based or online behavioral retargeting marketing about our Services on third-party websites or services after you visited with our Services. Please refer to the “Tracking Tools, Advertising and Opt-Out” section below for more details.

• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Kerqu or the Services.
• Sending emails and other communications according to your preferences or that display content that we think will interest you.

• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
• Protecting the rights, property or safety of you, Kerqu or another party.
• Enforcing any agreements with you.
• Responding to claims that any posting or other content violates third-party rights.
• Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
• Hosting, technology and communication providers, such as AWS that is our cloud hosting service provider.
• Support and customer service vendors.
• Product fulfillment and delivery providers. 
• Payment processors.
• Our payment processing partners, currently including Stripe, Inc., PayPal, Inc., and Worldpay (offered by Fidelity National Information Services Inc.), collects your voluntarily-provided payment card information necessary to process your payment.
• Please see our payment processing partners’ terms of service and privacy policy for information on its use and storage of your Personal Data.
•  Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
• Companies that track how users found or were referred to the Services.
• Companies that track how users interact with the Services.
• Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:
• Marketing providers (including their ad agents and ad networks).
• Business Partners. These parties partner with us in offering various services. They include:
• Companies that we partner with to offer the products you found through our Services.
• Parties You Authorize, Access or Authenticate
• Third parties you access through the services, such as our payment processing partners.
• Social media services.
• Other users.

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Using Personal Data” section above.

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

We will treat your Personal Data with most discretion: we will not list your Personal Data as a manner of profitable products; we will not use your Personal Data as the content of advertisements without notification to you.

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. These cookies do not gather information about you for marketing purposes. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region). We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services.
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.
• Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”

We may serve advertisements about the Services, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms (“Advertising Partners”), to serve advertisements about the Services on non-affiliated third-party websites and applications. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

• Web Browser Controls

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.

• Service Provider Opt-out/Opt-in

As described above, we use third-party Performance/Analytical Cookies to monitor and analyze your use of the Services. Currently, we use Google Analytics, a web analytics service offered by Google Inc. (“Google”). Google uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at http://www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/. If you are located in the EU, and the Google Analytics is structured to collect Personal Data, the cookie banner on our Services will provide you the opportunity to consent to Google Analytics.

As described above, we use third-party Retargeting/Advertising Cookies to advertise about the Services on third-party websites to you after you leave our Services. Currently, we use Google Ads for these purposes. Google Ads remarketing service is provided by Google. You can opt-out of this by visiting the Google Ads Settings page: http://www.google.com/settings/ads. If you are located in the European Countries, and the Google Ads is structured to collect Personal Information, the cookie banner on our website will provide you the opportunity to consent to Google Ads.

• Industry Opt Out Tools

Through the Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based a consumer’s online behavior across different websites and properties. Some of our Advertising Partners or providers of Cookies may participate in the NAI Opt-Out Tool ( http://www.networkadvertising.org/choices/) and/or the Digital Advertising Alliance (DAA) Consumer Choice Page ( http://www.aboutads.info/choices/).

To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, which are located at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices. Users in the European Union should visit the European Interactive Digital Advertising Alliance’s user information website http://www.youronlinechoices.eu/.

• Mobile Opt Out

Your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for Interest-Based Ads. You may also opt-out of certain Tracking Tools on mobile devices by installing the DAA’s AppChoice app on your mobile device (for iTunes, visit https://itunes.apple.com/us/app/appchoices/id894822870?mt=8, for Android, visit https://play.google.com/store/apps/details?id=com.DAA.appchoices&hl=en ). For more information, please visit http://support.apple.com/kb/HT4228, https://support.google.com/ads/answer/2662922?hl=en or http://www.applicationprivacy.org/expressing-your-behavioral-advertising-choices-on-a-mobile-device , as applicable.

• Do Not Track

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. The Service does not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Service and after you leave our Service.

Please note the following with respect to opting out of Interest-Based Ads:

• Some opt-out features are cookie-based, meaning that when you use these opt-out features, an “opt-out” cookie will be placed on your computer or other device indicating that you do not want to receive Interest-Based Ads from certain companies. If you delete your cookies, use a different browser, or use a different device, you will need to renew your opt-out choice.
• Opting-out of Interest-Based Ads does not mean that you will no longer receive online ads. It only means that such ads will no longer be tailored to your specific viewing habits or interests. You may continue to see ads on and about the Service.

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Kerqu will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at shop@kerqu.com.

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

The “Our Commercial or Business Purposes for Using Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

• Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
• Account or Contact Data
• Password Data
• Delivery Addresses
• Payment Data
• Order Data
• Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
• Social Network Data
• Payment Data
• Order Data
• Device Data
• Analytics
• Consumer Demographic Data
• Geolocation Data
• Other Identifying Information that You Voluntarily Choose to Provide
• We may also de-identify or anonymize Personal Data to further our legitimate interests.
• Examples of these legitimate interests include (as described in more detail above):
• Providing, customizing and improving the Services.
• Personalization of the Services, e.g. personalized recommendation of products (Note that you can disable the feature of personalized curated feeds within the Kerqu application by adjusting your account setting)
• Performing web analytics (subject to cookie requirements under applicable e-Privacy regulations)
• Marketing the Services (subject to applicable requirements under e-Privacy regulations)
• Corresponding with you.
• Meeting legal requirements and enforcing legal terms.
• Completing corporate transactions.
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at shop@kerqu.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about Kerqu's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

The Services are hosted in the United States (“U.S.”) through our cloud hosting service providers in the U.S., and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Kerqu and will be hosted on U.S. servers, and you authorize Kerqu to transfer, store and process your information to and in the U.S., and possibly other countries (including Singapore and China where we and our affiliates are located). You hereby consent to the transfer of your data to the U.S. pursuant to: a data processing agreement incorporating standard data protection clauses promulgated by the European Commission, a copy of which can be obtained at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087.

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at shop@kerqu.com.

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as you have an open account with us (plus 12 to 48 months thereafter depending on the types of Personal Data) or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Kerqu application, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

•  https://www.kerqu.com
•  shop@kerqu.com
• RM22 2/F FU TAO BUILDING , NO.98 ARGYLE STREET , MONGKOK , KOWLOON , HONG KONG