Privacy Policy

Privacy Policy

Effective as of: 2 September 2024

1. Who we are

MEMIDOS is a platform that allow businesses to offer, sell and buy all kinds of new materials, products, parts, tools and machinery. The actual contract for sale is directly between the seller and buyer.

Our website address is: https://www.memidos.com.

This Privacy Policy sets out the ways in which MEMIDOS collect, use and disclose information in connection with its operation of the Platform including personal information about Platform visitors and representatives and employees of Buyers and Sellers (“you”). This Privacy Policy also applies to use of our Platform via a mobile device, either through mobile applications or mobile-optimized websites.

If you have any questions or concerns about the use of your personal information, then please contact us using the contact details provided at section 13 “How to contact us” at the bottom of this Privacy Policy.

2. Collection of information

The personal information that we may collect about you broadly falls into the following categories:

Information you provide to us

If you are a representative or employee of any Buyer or Seller or a sole trader Buyer or Seller:

• you will be asked to provide certain contact information that is necessary for the registering for a Platform account on behalf of a Buyer or Seller, including name, address, phone number, email address, job title and department;
• you will be asked to provide certain identity information, tax registration and/or related information about your business, such as your company name, business type and industry, corporate registration details and information about your business license;
• if you are a Seller we will also ask you to provide details about the goods and products that you intend to sell via the Platform and details about your sales/transactions on www.memidos.com;
• if you are a Buyer we will also ask you to provide details or preferences about the goods and products that you may be interested in buying via the Platform and any details or preferences relevant to your purchases;
• if you are certified by MEMIDOS as an affiliate, a blogger or an influencer, in addition to the information mentioned above, we may also collect your live stream videos, your social media account names and profile photos, and posts or comments made by other users of the Platform;
• in connection with the facilitation of transactions, purchases and payments over the Platform, you will be asked to provide certain payment information. This might include bank account numbers, billing and delivery information, credit/debit card numbers, expiration dates and security code and tracking information from cheques or money orders to facilitate the sale and purchase as well as the settlement of purchase price of the products or services transacted on or procured through the Platform;
• we will process any information provided to us in connection with disputes or to support complaints in connection with the Platform or goods and/or services purchased via the Platform. Please note, Buyers and/or Sellers may submit complaints regarding the products and services on the Platform and/or disputes between the Buyers and Sellers to the Platform and under such circumstances, we will process data provided to us by Buyers and/or Sellers that is relevant to the disputes or complaints submitted. This may include health data of end-users of products purchased on the Platform to the extent relevant to the disputes or complaints that are being reviewed by the Platform and to the extent that the individual(s) has provided their explicit consent to their data being shared with us for the purposes of handling the complaints and/or settling the disputes.
• Information you submit to the Platform for publication may be made publicly available on the Platform and therefore accessible by any internet user. You should exercise caution when deciding what information you submit to us for publication.
• in order to facilitate your use of the services available on the Platform (including on websites and/or mobile applications), we may request for access to, and you may provide us with, contents stored in your devices including but not limited to contacts in address book, photos, videos and/or other files. If you are using our communication tools on the Platform (particularly in case of voice communication), we may require access to your camera and/or microphone, and may conduct voice recordings.

Information that we collect automatically

• If you contact us (such as via our customer services department chat service, telephone or email), we may record a copy of your correspondence and may ask for additional information to verify your identity.
• We will collect contact details and other information of users from publicly available sources for the purposes of verifying the users and performing due diligence on the users.
• We will collect details of user activities, transactions and interactions on the Platform including information relating to the types and specifications of the products and services purchased, pricing and delivery information, dispute and complaint records, communications between users and any information disclosed in any discussion forum.
• From time to time, we may also collect information about the existing and prospective users, during or in connection with trade shows, industry events and/or other functions. Including representative contact names, addresses, phone numbers and email addresses.
• If you visit our Platform, we will automatically collect certain information from your device. In some countries, including countries in the European Economic Area, this information may be considered as personal information under applicable data protection laws. Specifically this information may include IP addresses, device type, unique device identification numbers, browser type, geographic location, browsing patterns and details of how you have interacted with our Platform and the goods and services available on it. In addition, we gather statistical information about the Platform and visitors to the Platform including, browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors. Collecting this information enables us to better understand the visitors who come to our Platform, where they come from, and what content is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Platform. Some of this information may be collected using cookies and similar tracking technology, as explained further under the section 6 “Cookies” below.

Information that we receive from third parties

• We may receive personal information about you from social media platforms if you choose to register for a Platform account via a social media account. Exactly what information we receive will depend on your privacy settings with the applicable platform, but it would typically include basic public profile information such as:
  • Your username or nickname
  • Your profile picture
  • Country
  • Company name
  • Contact details
• We may receive personal information about you from third parties that are engaged by us to assist with providing verification services, and conducting suitable money laundering and KYC (know-your-customer) checks on users, and to improve our marketing efforts. This may include your name, email address, company details and contact information for company representatives.
• If you choose to participate in reviewing or rating products and/or services on www.memidos.com, we may receive personal information about you from third parties that work with us to conduct reviews into our services and/or rate us.

3 Use of Personal Information

We collect and use your personal information for the following purposes:

• verifying your identity and conducting security, KYC (know-your-customer) and anti-money laundering diligence and background checks in order to set up user accounts;
• verifying your eligibility to register as a member or user on MEMIDOS;
• setting up / administering user accounts, including providing log-in IDs and developing a Platform profile;
• providing users with customer service support; responding to queries, feedback, and managing claims and/or disputes;
• facilitating communication between Buyers and Sellers via the Platform, processing transactions and settlement between Buyers and Sellers made over the Platform, assessing fund withdrawal requests from Sellers;
• providing logistics and warehousing services (including, without limitation, customs clearance declarations via the Platform);
• facilitating customs clearance declarations / applications via the Platform;
• facilitating Financing of a purchase via the Platform;
• assessing and monitoring account security and transaction risks of users of www.memidos.com, detecting and preventing fraud, money laundering and other security incidents;
• sending and serving tailored marketing and advertising that we believe will be of interest to you based on the ways in which you use the Platform, your browsing records, and order history;
• performing research or statistical analysis in order to improve the content and layout of the Platform, and to improve the product offerings and services from MEMIDOS, including, for example, using anonymized data for machine learning purposes;
• identifying, developing and marketing and advertising products and services that we believe you will value, including across browsers and devices, in accordance with applicable laws. Cookies or other similar technologies may be used to provide you with advertising based upon your browsing activities and interests (see section 6 “Cookies” below). Where we are required by applicable law, we will seek your consent prior to sending you communications for marketing purposes;
• if you are a Buyer, we will share details of the last viewed products on the Platform to enable Sellers, their respective affiliates and/or their third-party services provider to contact you with details of products and/or services that might interest you.
• When you use services that require access to contents stored in and/or functions on your devices (including but not limited to contacts in address book, photos, videos, microphone and/or camera), we use your photos, videos, contact information in your address book, and other personal information to respond to your requests, provide the requested services to you, and improve our services.
• We may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

4 Disclosure of Sharing of Personal Information

We may disclose (or provide access to) personal information to the following categories of recipients:

• Other Platform Users where necessary in connection with the facilitation of purchases and communications made between you and the other users.
• Third party business partners, service providers and/or affiliates of MEMIDOS engaged by us or working with us to assist us to provide services to you or who otherwise process personal information for purposes described in this Privacy Policy or notified to you when we collect your personal information. Categories of these partners or service providers include:
  • our business partners (for example, in order for them to provide you with discounts or offers that may interest you);
  • marketing and advertising platforms, such as Google, Twitter, LinkedIn, Facebook and Instagram, and providers of analytics services relating to users’ behaviour, in order to tailor the content you see when visiting our Platform. These platforms may combine information they collect on our Platform with data on their platforms and data they collect from other websites or through other sources in order to conduct targeted advertising. The processing activities of these third party marketing platforms are governed by their own privacy policies, not this Privacy Policy;
  • payment service providers who collect and process personal information to assist with settling the payments for transactions or process withdrawal requests for Sellers. The activities of payment service providers may be governed by their own privacy policies, not this Privacy Policy;
  • credit risk assessment providers to conduct risk assessment on Buyers to determine whether a Buyer can be permitted to have their equipment purchase financed;
  • logistics partners for providing delivery services for Buyers, including return and exchange of products, and warehousing services for Sellers;
  • custom agents for customs clearances purposes;
  • cloud computing service providers to provide cloud storage services;
  • customer service providers to provide after-sale services;
  • risk control service providers to assess the security of users’ accounts and transaction risks; and
  • third party rating / reviewing service providers to carry out reviews of our services with customers if you choose to participate in reviewing or rating MEMIDOS products and/or services;
• To our professional advisers, law enforcement agencies, insurers, government and regulatory and other organizations where we believe it is necessary to comply with applicable laws or to exercise, establish or defend our legal rights or protect your vital interests or those of any other person, we may also disclose and transfer your personal information or as otherwise required or permitted by applicable laws.
• To an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy.
• To any other person with your consent to the disclosure.

We may provide aggregated or anonymized data to third parties, but when we do so, the information we share is in a de-identified format that does not personally identify you.

5 Retention

We retain your personal information as long as we have an ongoing legitimate business need to do so for example to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6 Cookies

Our website uses cookies. For more information about cookies, please refer to our Cookie Policy.

7 Minors

The Site and the content are not targeted to minors (those under the age of 18) and we do not intend to sell any of our products or services to minors. If a minor has provided us with Personal Data without parental or guardian consent, the parent or guardian should contact us to have the content removed. Se 13 “How to contact us” at the bottom of this Privacy Policy.

8 Security Measures

We employ commercially reasonable security methods to prevent unauthorized access to the Sites, to maintain data accuracy and to ensure the correct use of the information we hold.

For registered users of the Sites, some of your information can be viewed and edited through your account, which is protected by a password. We recommend that you do not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited email. If you share a computer with others, you should not choose to save your log-in information (e.g., user ID and password) on that shared computer. Remember to sign out of your account and close your browser window when you have finished your session.

No data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect the information we hold for you, we cannot guarantee the security of any information you transmit to us and you do so at your own risk.

9 Changes to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

Any changes to this Privacy Policy will be communicated by us posting an amended Privacy Policy on the Platform. Once posted on the Platform, the new Privacy Policy will be effective immediately. You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

10 Legal basis for data processing

We process personal information for the purposes set out in this Privacy Policy, as described above. Our legal basis for processing personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect and process personal information about you only where it is:

• necessary for providing the services pursuant to the agreement between you and MEMIDOS and/or our affiliates (for example, to provide you with the services you request and to identify and authenticate you so you may use the Platform);
• necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement);
• necessary for our legitimate interests and not overridden by your rights; and/or
• where it is based on your consent.

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Platform and services, manage our relationship with you and communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our Platform and our services, undertaking marketing, or for the purposes of ensuring the security of our Platform and services and detecting or preventing illegal activities such as fraud. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If we ask you to provide personal information to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time. We will advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). In some instances, you may be required to provide us with personal information for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Platform.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under section 13 “How to contact us” below.

11 International transfers of personal information

In connection with our provision of the Platform and its connected services, we may transfer your personal information to countries outside of the EU, including to countries that may not provide the same level of data protection as your home country such as the United States and China. We take appropriate steps to ensure that recipients of your personal information are bound to duties of confidentiality and we implement appropriate measures to ensure your personal information will remain protected in accordance with this Privacy Policy.

12 Your rights

As a member or user of MEMIDOS you also have the following data protection rights, which you can exercise at any time by contacting us using the contact details provided under section 13 “How to contact us” below:

• The right to access, correct, update or request deletion of your personal information.
• The right to object to processing of your personal information when it is based on our legitimate interests, and separately the right to object to direct marketing.
• The right to ask us, in some situations, to restrict processing of your personal information or request portability of your personal information.
• The right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under section 13 “How to contact us” below.
• If we have collected and process your personal information with your consent, then you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected.

13 How to contact us

If you have any requests, questions or concerns about our use of your personal information and this Privacy Policy, please contact us at contact@memidos.com.