PRIVACY NOTICE

CMG Eurospares Co.,Ltd is a company registered in Myanmar (hereinafter referred to as "we", "our" or "us").

OVERVIEW

Maintaining the security of your data is of paramount importance to us and we are committed to respecting your privacy rights.

This notice, which including without limitation applies when using the website: www.cmgeurospares.com ("our website") or our marketplaces, provides you with information about:

• How we use your data
• What personal data we collect
• Who we share your data with
• How we ensure your privacy is maintained; and
• Your rights relating to your personal data

INFORMATION WE MAY COLLECT FROM YOU AND OTHER SOURCES

Although the precise details of the personal information collected will vary according to the specific purpose for which we are collecting the information, we may collect and process the following data about you:

• Information that you provide by filling in forms on our social media pages or on our website. This includes information provided at the time of registering to use our website, subscribing to our service, purchasing goods via our website or via our marketplace listings, posting material or requesting further services. We may also ask you for information when you report a problem with our website.
• If you contact us by phone, email or otherwise and is provided voluntarily, we may keep a record of that correspondence.
• Please note that we record and monitor telephone conversations that we have with you. The sole purpose of any recording is for training and quality control purposes. Under the GDPR any personal or confidential information disclosed shall not be made available to any third party (unless required by law to do so) or used for marketing purposes. Recorded conversations are deleted within three months after the recording was made.
• We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
• Details of transactions you carry out through our website or our marketplace listings and for the fulfilment of your orders.
• Details of your visits to our website including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
• We also collect behavioural and browsing data from you for the purposes of offering you a tailored or personalised online shopping experience.
• We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual. We collect some of this information using Cookies. We may also collect any personal information which you allow to be shared that is part of your public profile on a third party social network.
• We obtain certain personal information about you from sources outside our business which may include our group of companies (further defined below). We may receive your personal information from other sources, such as: public databases, our retail and supplier partners, referrals from insurance and accident management companies, joint marketing partners; social media platforms; from people with whom you are friends or otherwise connected on social media platforms, as well as from other third parties. For example, this other personal data helps us to:
• Provide the relevant services in an accurate manner;
• review and improve the accuracy of the data we hold; and
• improve and measure the effectiveness of our marketing communications, including online advertising.

USES MADE OF THE INFORMATION

We use information held about you in the following ways:

• To ensure that content from our website is presented in the most effective manner for you and for your computer.
• To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
• To carry out our obligations arising from any contracts entered into between you and us. For example, we pass your contact details to our courier company (eg, DHL and Royal Mail) who may contact you via email, text message or a telephone call to confirm delivery of your order. Where you use our Click and Collect service, we will notify you via text message or a telephone call to advise you when your order is ready to be collected by our branch. We may notify our suppliers of your details for any warranty purposes.
• To allow you to participate in interactive features of our service, when you choose to do so.
• To enhance your experience whilst using our website.
• To notify you about changes to our service.
• If you are an existing customer, we will only contact you by electronic means (email or telephone) with information about goods and services that we offer. We will not contact you by email if you have unsubscribed from our mailing list, or by phone if you are registered with the Telephone Preference Service (and have not expressly indicated that we may continue to call you notwithstanding your registration).
• If you are a new customer, we will only contact you by electronic means if you have consented to this.
• Whether you are a new or existing customer, if you have consented to being contacted electronically we will contact you in accordance with your consents.
• We may use your personal information to contact you if there are any urgent safety or product recall notices to communicate to you where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any personal harm to you. It is in your vital interests for us to use your personal information in this way.

Third-party links

Our website or marketplace listings may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

COOKIES

For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our website and to deliver a better and more personalised service. They enable us:

• To estimate our audience size and usage pattern.
• To store information about your preferences, and so allow us to customise our website according to your individual interests.
• To speed up your searches.

• To recognise you when you return to our website.

  You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our website.

  Please note that our advertisers may also use cookies, over which we have no control.

  Our website saves the contents of your basket when you haven’t completed a transaction. If you quit our website without placing an order the system will remember the items you added to your basket and send you an email with a reminder. We do this to make sure your shopping experience is as hassle free as possible. If you do not want to receive these emails in the future, please click on the unsubscribe link at the bottom of the email you have received.

DISCLOSURE OF YOUR INFORMATION

In order to make certain services available to you, we may need to share your personal data with third parties.

• We may disclose your personal information to:
• our trusted service providers acting on our behalf who provide services such as: web hosting, web analytics and integration, customer service web chat and ticketing, order fulfilment, data analysis including data personalisation, infrastructure provision, email marketing data, review sites of our services, auditing services and other services to enable them to provide services;
• our courier company who delivers your orders (such as DHL);
• selected third parties if you are a new customer and you have consented to this;
• our affiliate websites that may use your personal information in the ways set out in the "how we use your information section" above or in connection with products and services that complement our own range of products and services; and
• third party suppliers who manage our secure payment platform and credit card processing (such as PayPal or Ingenico).
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If CMG Eurospares Co.,Ltd substantially sell all of its assets or are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of CMG Eurospares Co.,Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

HOW DO WE PROTECT YOUR DATA

We are committed to keeping your personal data safe and secure and employ a number of security measures such as:

• We ensure our website and data is supported with TLS 1.2 technology using RSA 2048 bit security standard and/or other appropriate standards from time to time;
• Monitoring and auditing our service providers to ensure they have an adequate level of protection as required under the PCI DSS;
• All credit and debit card payment transactions are initiated on our website via our online shopping basket;
• All information you provide to us is stored on our secure servers. For registered users, where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
• We use reasonable, organisational, technical and administrative measures to protect personal information under our control. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

The personal data that you provide to us in order to purchase goods and other personal data generated for transactional agreements is processed as it is necessary for the performance of a contract with you.

We are committed to keeping your personal data safe and secure and employ a number of security measures such as:

All other personal data is processed for our legitimate interests (as set out below) and to comply with our legal obligations.

In general, we only rely on opt-in consent as a legal basis to contact (and allow for selected third parties to contact) new customers by electronic means and/or send direct marketing communications via email or text message to new customers.

You have the right to withdraw your consent at any time.

Our legitimate interests

The normal legal basis for processing customer data, is that it is necessary for our legitimate interests including:-

• selling and supplying goods and services to our customers;
• protecting customers, employees and other individuals and maintaining their safety, health and welfare;
• promoting, marketing and advertising our products and services;
• sending promotional communications which are relevant and tailored to individual customers;
• understanding our customers’ behaviour, activities, preferences, and needs;
• complying with our legal and regulatory obligations;
• preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
• handling customer contacts, queries, complaints or disputes;
• managing insurance claims by customers;
• protecting us and our employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us;
• effectively handling any legal claims or regulatory enforcement actions taken against us; and
• fulfilling our duties to our customers, colleagues, shareholders and other stakeholders.

HOW LONG DO WE KEEP YOUR DATA?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Our procedures to manage data retention is to retain customer data for 7 years to support some of our parts warranty.

The email marketing unsubscribe function will remove your details from marketing lists and confirmation of your removal will be sent to your email address.

Data back-ups can take up to 60 days to remove specific data from the system.

CHANGES TO OUR PRIVACY NOTICE

Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail.

CONTACT

If you have any questions about how we use your personal data that are not answered here, or if you want to exercise your rights regarding your personal data, please contact us by any of the following means:

• Email us on: customersupport@cmgeurospares.com
• Write to use at:

  CMG Europe Car Spare Parts
  No.235, Ngu Wah Street, Ahlone Township, Yangon, Myanmar.
  Telephone
  09 7755 9 7711
  09 26325 0374

• Issue Date: [30 October 2018]