Though only acting as an agent/middleman, we at Appleton Group LLC, its products, services, subsidiaries and affiliates ("we", "us") recognize the importance of privacy and confidentiality of personal information.
Appleton Group LLC, its products, services, subsidiaries and affiliates (the "Sites/Apps") is a Digital Transformation, Flexible Consumption, Everything as a Service (XaaS), Internet of Things (IoT) and Global Online On-Demand company providing C2C, B2B and B2C services on our Sites/Apps which connects and facilitates sales and purchases of products and/or services between customers and 3rd party sellers.
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 a customers and 3rd party sellers:
you will be asked to provide certain contact information that is necessary for the registering for a Sites/Apps account on behalf of a 3rd party user (customer, service provider) including name, address, phone number, email address, job title and department, etc.;
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 Service provider or an investor, we will also ask you to provide details about the goods and products/ investments services/package that you intend to provide to customers via the Sites/Apps and details about your sales/transactions on Appleton Group LLC, its products, services, subsidiaries and affiliates;
if you are a Buyer we will also ask you to provide details or preferences about the goods and services/ investment services/package that you may be interested in buying via the Sites/Apps and any details or preferences relevant to your transactions;
if you are successfully certified by Appleton Group LLC, its products, services, subsidiaries and affiliates as a customer, 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 Sites/Apps;
In connection with the facilitation of transactions, purchases and payments over the Sites/Apps, 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 your transactions through the Sites/Apps;
We will process any information provided to us in connection with disputes or to support complaints in connection with the Sites/Apps or goods and/or services purchased via the Sites/Apps. Please note, Customers and Service Providers may submit complaints regarding the products and services on the Sites/Apps and/or disputes between the users to the Sites/Apps and under such circumstances, we will process data provided to us by Customers and Service Providers that is relevant to the disputes or complaints submitted. This may include health data of end-users (which may include minors as applicable) of products purchased on the Sites/Apps to the extent relevant to the disputes or complaints that are being reviewed by the Sites/Apps 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 Sites/Apps for publication may be made publicly available on the Sites/Apps and therefore accessible by any internet user. You should exercise caution when deciding what information you submit to us for publication.
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 Sites/Apps 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, fax numbers and email addresses.
If you visit our Sites/Apps, we may 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, broad geographic location (e.g. country or city-level location), browsing patterns and details of how you have interacted with our Sites/Apps and the goods and services available on it. In addition, we gather statistical information about the Sites/Apps and visitors to the Sites/Apps 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 Sites/Apps, 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 Sites/Apps. Some of this information may be collected using cookies and similar tracking technology.
Information that we receive from third parties
We may receive personal information about you from social media Sites/Apps if you choose to register for a Sites/Apps account via a social media account. Exactly what information we receive will depend on your privacy settings with the applicable Sites/Apps, but it would typically include basic public profile information such as:
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. This may include your name, email address, company details and contact information.
If you choose to participate in reviewing or rating products and/or services on Appleton Group LLC, its products, services, subsidiaries and affiliates, we may receive personal information about you from third parties that work with us to conduct reviews into our services and/or rate us.
B. 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 Sites/Apps user;
setting up / administering user accounts, including providing log-in IDs and developing a Sites/Apps profile;
providing users with customer service support; responding to queries, feedback, and managing claims and/or disputes;
facilitating communication between Customers and Service Providers via the Sites/Apps, processing transactions and settlement between Customers and Service Providers made over the Sites/Apps, assessing fund withdrawal requests from service providers;
providing logistics services (including, without limitation, transportation, shipment, etc., via the Sites/Apps);
facilitating customs clearance declarations / applications via the Sites/Apps;
assessing and monitoring account security and transaction risks of users of Appleton Group LLC, its products, services, subsidiaries and affiliates, detecting and preventing fraud, money laundering and other security incidents;
personalizing our marketing and communications with you based on your browsing records, and your order history;
performing research or statistical analysis in order to improve the content and layout of the Sites/Apps, and to improve the product offerings and services of Appleton Group LLC, its products, services, subsidiaries and affiliates, 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. Where we are required by applicable law, we will seek your consent prior to sending you communications for marketing purposes;
If you are a customer or investor, we will share details of the last viewed products/services on the Sites/Apps to enable other Customers and Service Providers to contact you with details of products/services that might interest you. You can opt not to share this information on your Privacy Settings.
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.
C. DISCLOSURE OR SHARING OF PERSONAL INFORMATION
We may disclose (or provide access to) personal information to the following categories of recipients:
Other Sites/Apps Users where necessary in connection with the facilitation of transaction and communications made between you and the other users.
o our business partners (for example, in order for them to provide you with sweep sticks or offers that may interest you);
o credit risk assessment providers to conduct risk assessment on Customers and Service Providers to determine whether a user can be permitted to make a fund withdrawal;
o logistics partners for providing delivery services for Customers, including return and exchange of products, and warehousing services for service providers;
o custom agents for customs clearances purposes;
o cloud computing service providers to provide cloud storage services;
o customer service providers to provide after-sale services;
o risk control service providers to assess the security of users’ accounts and transaction risks; and
o third party rating / reviewing service providers to carry out reviews of our services with customers if you choose to participate in reviewing or rating Appleton Group LLC 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 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.
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.
What are cookies?
A cookie is a small amount of data that is sent to your browser and stored on your computer's or mobile device’s hard drive. If you do not de-activate or erase the cookie, each time you use the same browser or mobile device to access the Sites/Apps, our web servers will be notified of your visit to the Sites/Apps and in turn we may have knowledge of your visit and the pattern of your usage.
Cookies set by the website or app owner (in this case, Appleton Group LLC, its products, services, subsidiaries and affiliates) are called "first party cookies". Cookies set by parties other than the website owner are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third-party cookies can recognize your device both when it visits the website in question and also when it visits certain other websites.
Cookies can also be categorized as session cookies (which are erased once you close the browser or shut down the device) and persistent cookies (which remain even after closing the browser or shutting down the device/application and which are activated each time you visit the Sites/Apps). The session cookies use encrypted data to authenticate you. The persistent cookies do not store account numbers or passwords. We use both session cookies and persistent cookies.
We use first and third party cookies for several reasons. Some cookies are required for technical and/or security reasons in order for our Sites/Apps to operate, and we refer to these as "essential" or "strictly necessary" cookies. First party cookies are mainly served to enable basic functionality on our Sites/Apps; including web analytics cookies that help us understand how users use our web pages and how we can improve their use. For example, we use essential or strictly necessary cookies to enable us to remember goods added to your Appleton Group LLC, its products, services, subsidiaries and affiliates transaction experience and to recognize you when you sign into your Appleton Group LLC, its products, services, subsidiaries and affiliates account.
In addition, we also use social media cookies. You may register for Sites/Apps membership and "share" Sites/Apps content through social media such as Facebook and Twitter. Sometimes we embed videos from websites like YouTube. These websites have their own privacy policies which govern their use of information, which you can find on the respective websites.
Cookies we use
The specific categories of first and third party cookies served through our Sites/Apps and the purposes they perform are described in the table below (please note that the specific cookies served may vary):
Types of cookies we use on our sites/apps
Essential Cookies These cookies are strictly necessary for enabling access and use of our Sites/Apps. They provide necessary functionality to ensure the proper performance, security and functionality of our Sites/Apps. These cookies cannot be disabled.
Statistical Cookies: Statistical cookies including analytics cookies collect information in aggregate form to help us determine and understand how users interact with and use our Sites/Apps. We use this information to help us to improve and optimize our Sites/Apps and its security.
Personalization and Service Cookies: These cookies are used to remember your computer or mobile device when you visit a website. They remember your registration and login details and your settings and preferences such as language, region, currency and payment details. They are also used to ensure you don’t have to login every time you use your browser to comment on articles and to ensure interactive services work effectively. Personalization cookies are also used to recommend content we think you'll be interested in by serving and measuring relevant advertising, based on what you've looked at before.
Personalization cookies may also include social media cookies which are used to enable you to log into our Sites/Apps using your social media accounts and to share pages and content that you find interesting on our Sites/Apps through third party social networking and other websites. These cookies may also be used for advertising purposes too.
Marketing Cookies. Marketing cookies help us to ensure that provide you with more targeted and relevant marketing. We will also use marketing cookies to evaluate the effectiveness of our marketing communications by monitoring open rate and conversions.
What about other tracking technologies, like web beacons?
Cookies are not the only way to recognize or track visitors to our Sites/Apps. We may use other, similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Sites/Apps or opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Sites/Apps to another, to deliver or communicate with cookies, to understand whether you have come to our Sites/Apps from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.
How can I control cookies?
You have the right to decide whether to accept or reject cookies. If you choose to set your web browser controls to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted.
Certain features of the Sites/Apps depend on cookies. Please be aware that if you choose to block cookies, you may not be able to sign in or use those features, and preferences that are dependent on cookies may be lost.
Google Analytics (More information) Our Sites/Apps uses Google Analytics, an internet analytics service provided by Google, Inc. ("Google"). Google cookies allow us analyze use of the Sites/Apps by telling us which pages our users are viewing, which ones are most popular, what time of day our Sites/Apps are visited, if users have previously visited our Sites/Apps, from which website users are redirected to our Sites/Apps were and the like. The data generated by the cookie about your use of the Sites/Apps will be transmitted to Google and stored by Google on servers in the United States.
The Sites/Apps uses an anonymization tool of IP addresses so that the IP addresses are truncated within the territory of the Member States of the European Union and the other members of the agreement on the European Economic Area. The non-truncated IP address are only exceptionally transmitted to Google’s servers in the US and then truncated there.
Google uses the data on behalf of Appleton Group LLC, its products, services, subsidiaries and affiliates to evaluate your use of the Sites/Apps, to compile reports on website activity for the website operators and for other website activity and internet usage services. Google may disclose this information to third parties under the terms of the law or for further processing by third parties on behalf of Google. For more information about Google Analytics cookies, visit:
The IP address that your browser will pass on to Google Analytics will not be associated with any other data stored by Google. Through your browser settings, you can block cookies; however, this can lead to problems with the use of some functionalities of the website. Through the add-on "Google Analytics Opt-out" you can through your current web browser opt-out to the use of Google Analytics from then on: http://tools.google.com/dlpage/gaoptout?hl=en. More information can be found here: https://support.google.com/analytics/answer/6004245.
G. VISITORS FROM THE EUROPEAN UNION
If you are in the EEA, the data controller of your personal information is Appleton Group LLC, (incorporated in the State of Delaware, the United States of America with registration number: 36-4895934).
Legal basis for data processing
necessary for providing the services pursuant to the agreement between you and Appleton Group LLC, its products, services, subsidiaries and affiliates (for example, to provide you with the services you request and to identify and authenticate you so you may use the Sites/Apps); 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 Sites/Apps 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 Sites/Apps and our services, undertaking marketing, or for the purposes of ensuring the security of our Sites/Apps 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 Sites/Apps.
International transfers of personal information
If you are a resident of the EEA, you also have the following data protection rights, which you can exercise at any time by contacting us using our contact details on our sites/apps or through firstname.lastname@example.org:
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” or “opt-out” 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 our contact details on our sites/apps or through email@example.com:.
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.