1. INTRODUCTION

1.1 This data protection and privacy policy (the “Policy”) describes how Moscord Pte. Ltd. (“us”, ”we” or ”our”) collects personal data. Furthermore it descirbes how personal data in our possession is being used, processed or otherwise treated, your obligations to us when you transact with us and what you agree to consent to when you transact with us.

1.2 The Policy is prepared and made available to comply with the general data protection regulation (2016/679 of 27 April 2016) (the ”GDPR”) and the rules included herein on information to be provided to you.

2. Collecting personal data with cookies

2.1 By visiting and using our website(s), cookies are collected and used on the basis of consent. Information in these cookies include browser type, search terms on our website(s), IP address. (hereinafter "Cookiedata").

2.2 Cookiedata is used for improvement of the website(s) and the user experience, to deliver our products, services or goods.

2.3 Use of cookies for the purpose of collecting personal data is in accordance with the Cookie Order (No. 1148 of 9 December 2011), section 3.

2.4 If you wish to limit or decline the cookies placed on your computer when visiting our website you can do so at any time by changing your browser settings. However, you should be aware that if you decline or reject cookies it will impact the functionality of the website which means that there are features on the website that you will not be able to see. Any browser allows that you delete cookies collectively or individually. How this is done depends on the used browser. Remember to delete the cookies in all browsers, if you use several different browsers.

2.5 We disclose and/or share Cookie Data with information collected with cookies is passed on to Google LLC, as these cookies are placed by Google LLC (Google Analytics).

3. Types of personal data processed

3.1 We process personal data about you when this is necessary and in accordance with the applicable legislation. Depending on the specific circumstances, the processed personal data include the following types of personal data: name, address, telephone number, email, IP addresses You consent to the use of personal data being used in accordance with our provision of an internet platform (“Trading Platform”) to you. Under the Trading Platform, products are aggregated by a variety of suppliers (“Suppliers”) and offered to potential buyers (“Customers”) under the terms and conditions applicable. We may offer or provide various services to Customers, Suppliers and other entities as we may deem appropriate.

3.2 If we need to collect more personal data than what is specified above, we will inform about this. Such information may be provided by our updating of this Policy.

4. Purposes for processing the personal data

4.1 We only process personal data for legitimate purposes in accordance with the GDPR. Depending on the circumstances, the personal data is processed for the following purposes:

a) To deliver products or services to a user, customer or member.
b) To facilitate a sales process.
c) To improve our products, services or website.
d) To provide service messages and information to users, customers or members.
e) To send newsletters on e-mail.

5. Legal basis for processing personal data

5.1 We only process your personal data when we have a legal basis to do so in accordance with the GDPR. Depending on the specific circumstances, the processing of personal data is done on the following legal basis: a) If we have asked for a consent for the processing of specific personal data, the legal basis for such personal data is a consent, cf. article 6(1)

(a) of the GDPR, as the consent can always be withdrawn by contacting us via the contact details provided at the end of this Policy, and, if the consent is withdrawn, the personal data processed on the basis of consent is deleted, unless it can or must be processed, for example, in order to comply with legal obligations.
b) The processing is necessary for the purposes of the legitimate interests where such interests are not overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, cf. the GDPR, article 6(1)(f).

6. Disclosure and transfer of personal data

6.1 We only pass on personal data to others when the law allows it or requires it. Our company is part of a concern/company group where personal data is shared between the group companies depending on the circumstances.

6.2 We transfer personal data to the following recipients from the EU/EEA: a) Suppliers b) Data processors

6.3 From time to time we use external companies as suppliers to assist us in delivering our services. The external suppliers will not receive or process personal data unless the applicable law allows for such transfer and processing. Where the external parties are data processors, the processing is always performed on the basis of a data processor agreement in accordance with the requirements hereto under GDPR. Where the external parties are data controllers, the processing of personal data will be performed based on said external parties’ own data privacy policy and legal basis which the external parties are obligated to inform about unless the applicable legislation allows otherwise.

6.4 We do not transfer personal data to countries or international organisations outside the EU/EEA unless it is necessary on your specific request.

7. Erasure and retention of personal data

7.1 We ensure that the personal data is deleted when it is no longer relevant for the processing purposes as described above. We also retain personal data to the extent that it is an obligation from applicable law, as is the case with for example accounting and bookkeeping materials and records. If you have any questions about our retention of personal data, please contact the email mentioned in section 10 of this Policy.

8. Data subject rights

8.1 Data subjects have a number of rights that we can assist with. If a data subject wants to make use of his or her rights, he or she can contact us. The rights include the following:

8.1.1 The right of access: Data subjects have a right to ask for copies of the information that we process about them, including relevant additional information.

8.1.2 The right to rectification: Data subjects have a right to ask for rectification of inaccurate personal data concerning him or her.

8.1.3 The right to erasure: In certain circumstances data subjects have a right to obtain the erasure of personal data concerning him or her before the time when erasure would normally occur.

8.1.4 The right to restrict processing: Data subjects have, in certain situations, a right to have the processing of his or her personal data restricted. If a data subject has the right to have the processing of his or her personal data restricted, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest in the European Union or of a European member state.

8.1.5 The right to object: Data subjects have, in certain situations, a right to object to the legal processing of his or her personal data.

8.1.6 The right to data portability: Data subjects have, in certain situations, a right to receive his or her personal data in a structured, commonly used and machinereadable format and have the right to transmit those data to another data controller without hindrance from the data controller to which the personal data has been provided.

8.2 More information about data subject rights can be found in the guidelines of the national data protection authorities. If a data subject wishes to make use of his or her rights as described above, the data subject is asked to use the contact details provided at the end of this Policy. We strive to do everything to meet wishes regarding our processing of personal data and the rights of data subjects. If you or others despite our endeavours wish to file a complaint, this can be done by contacting the national data protection authorities.

9. Changes to this Policy

9.1 We reserve the right to update and amend this Policy. If we do, we correct the date and the version at the bottom of this Policy. In case of significant changes, we will provide notification in the form of a visible notice, for example on our website or by direct message.

10. Contact

10.1 If you have questions or comments to this Policy or if you would like to invoke one or more data subject rights, please contact us at info@moscord.com.

1. This AUR is intended to protect Customer, Supplier, Moscord and the Internet community from the inappropriate use of Moscord’s computing/network services and the internet.

2. You shall not perform any of the following actions and also procure that its end users or any third party that uses its services (“Users”), shall not perform any of the following actions:

(a) Use the Services or Trading Platform to accept, transmit or distribute unsolicited bulk data (which includes, without limitation, e-mail, bulletin boards, newsgroups, software, files) or otherwise send, or facilitate the sending of unsolicited commercial email (“UCE”) and mail bombs to any person or system in a way that could be expected to adversely impact Moscord’s network or facilities, or may potentially encroach on a third party’s intellectual property rights or any rights of publicity or privacy; The only circumstances in which the Services may be used to send unsolicited data of an advertising or promotional nature is where the unsolicited data is sent to persons with whom the sender has a pre-existing business, professional or personal relationship or to persons who have previously indicated their consent to receive data from the sender from time to time, for example by ticking a box to that effect on the sender’s web site. Unless these requirements are met, Users must not send unsolicited bulk data through the Services. If these requirements are met, the User must also provide an unsubscribe function on their web site (and make this function known to recipients in the relevant data) which allows those recipients to be removed from that mailing list.

(b) Attempt to connect to any third party systems without prior permission or arrangement;

(c) Use the Services or Trading Platform in a manner which is intended to abuse or to violate the property rights of others, including, without limitation, activities which result in the distribution of viruses, worms, time bombs, Trojan horses, cancelbots, or other destructive activities like Denial of Services (“DOS”) attacks, or scanning or any form of probing / automated network status polls / information collection of a third party’s network / system without prior permission, intentional or otherwise;

(d) Use the Services or Trading Platform to conduct any other activities, which in Moscord’s view are detrimental to its Users and/or its own operations.

(e) Use the Services or Trading Platform to:-

(i) send data, or cause data to be sent, that hides or obscures the source of the data, that contains invalid or forged headers or domain names or deceptive addressing; and

(ii) relay data from a third party’s mail server without permission or which employs similar techniques to hide or obscure the source of the data; and

(f) Violate or attempt to violate the security of the Services, including without limitation, attempting to interfere with, disrupt or disable services to any user, host or network, including but not limited to via means of overloading, “flooding”, “mail bombing” or “crashing”.

3. Users shall immediately notify Moscord of any unauthorised access or attempted breach of security.

4. Users are responsible for ensuring that its equipment are configured in a secure manner. Users should not, through action or inaction, allow others to use its network for illegal or inappropriate activities.

5. Moscord may, at its sole discretion remove or disable Users’ network connections, block network addresses, or suspend all Services to Users with or without prior notice to Users. Service suspension by Moscord due to breach of this AUR shall not prejudice any of Moscord’s rights under the Trading Platform Agreement.

6. Moscord shall not be liable for any loss, expense, costs or damages of any nature suffered by any User resulting in whole or in part from Moscord’s exercise of its rights under this AUR. By using the Services, Supplier agrees to waive and hold harmless Moscord from any claims relating to any action taken by Moscord under this AUR including conduct of investigation, issuing of warnings, refusal to post materials, removal of material, or suspension or termination of services, or other appropriate action.

1. INTRODUCTION

1.1 These Rules may be updated from time to time without notification to you. You are required to re-visit this page every time you visit or use our website (“Website”), use any service provided by Moscord, or transact in any other way with Moscord Pte Ltd (“Moscord”, “we”, “us” or “our”, as the case may be) (the abovementioned acts referred to as “transacting with us”). You are required to fully comprehend these Rules in its entirety and before transacting with us. If you have any questions about this statement or your personal information that we may collect from you, please contact us at our web site www.moscord.com and consult your legal counsel.

1.2 Amongst other things, these Rules explain: (a) how Moscord collects personal data; (b) how personal data in our possession is used, processed or otherwise treated; (c) your obligations to us when you transact with us; and (d) what you agree to consent to when you transact with us.

1.3 These Rules applies to you, a natural person, even though you may be acting on behalf of another. You expressly, irrevocably and unreservedly agree with the terms of these Rules. In these Rules, the term “personal data” refers to the personal data as defined by the various data protection laws applicable to Moscord (the “Relevant Data Protection Laws”).

1.4 We are regulated by the Relevant Data Protection Laws. This includes the United Kingdom Data Protection Act and the Singapore Personal Data Protection Act and subsidiary legislations, rules, regulations, guidelines, policies and any other directions.

1.5 In the event of any conflict between these Rules and the terms of a contract you have with Moscord, the relevant provision of that contract shall prevail to the extent of any inconsistency.

1.6 You consent to the use of personal data being used in accordance with our provision of an internet platform (“Trading Platform”) to you. Under the Trading Platform, products are aggregated by a variety of suppliers (“Suppliers”) and offered to potential buyers (“Customers”) under the terms and conditions applicable. We may offer or provide various services to Customers, Suppliers and other entities as we may deem appropriate.

2. WHAT PERSONAL INFORMATION DOES MOSCORD COLLECT, AND HOW IS THAT INFORMATION THEN USED?

2.1 THE INFORMATION WE COLLECT MAY INCLUDE:

(a) any information and personal details you provide us with through forms on the Website, email, physical correspondence and forms, and via any other means, and may include information such as your name, address, telephone number and job title;

(b) your preferences and use of email and physical correspondence updates, as recorded by emails that we send you (if you elect to receive email updates on our products and offers); and

(c) the IP Address used by you in the course of you accessing the Website, the IP Address being a string of numbers unique to the device used by you when you request any page or component of the Website, that is recorded by our web server. This information may be used to monitor your usage of the Website.

2.2 YOU CONSENT THAT YOUR PERSONAL DATA THAT WE POSSESS:

(a) will be handled in accordance with Relevant Data Protection Laws, without limitation to: the sharing of such personal data with service entities that may or may not operate within the EEA or Singapore or in any case within the legal jurisdiction of which such personal data is collected, and you expressly consent to the transfer of personal data to such service entities;

(b) may be used to deal with you, your employer, your business, your employer’s or businesses’ employees, officers, agents, consultants and other representatives (collectively referred to as the “Relevant Parties”);

(c) may be used to making sales to and contracts with the Relevant Parties and providing after-sales service to the Relevant Parties;

(d) may be made available to current and potential users of the Website, in addition to information about the web pages on the Website that you have visited;

(e) may be used to send to you information on our products and services;

(f) may be forwarded to third parties for administrative purposes. We use third parties to carry out certain activities, such as processing and sorting data, monitoring how customers use the Website and issuing our emails. For these purposes your personal data may be transferred to a jurisdiction outside your residence or place of business. For example, your personal data may not be stored in either the EEA or Singapore and may not be processed within the EEA or Singapore; and

(g) may be used to enhance the website experience for other users of the Website.

2.3 Any personal data collected by us may be used in accordance with the Relevant Data Protection Laws.

2.4 You must update, correct or delete your personal data as may be necessary such that the personal data that we maintain is accurate and complete.

3. HOW DOES MOSCORD PROTECT YOUR PERSONAL INFORMATION?

We regard security with priority and will make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, or disposal to protect your personal data.

4. COOKIES

4.1 Your Internet browser has a feature called “cookies” which store small amounts of data on your device about your visit to the Website. You do not need to have cookies turned on to visit most of the Website. Therefore, if you have not supplied us with any personal information, you can still browse our Website anonymously.

4.2 Cookies may be required to allow you to access and participate in certain areas of the Website. Like all cookies, you are able to remove or block particular cookies at any time.

4.3 The majority of browsers will allow you to alter the settings used for cookies and to disable and enable them as you require. If you do not want cookies then please refer to the help menu on your browser for instructions on disabling them. For further general information on cookies and more detailed advice on how to disable and enable them please go to http://www.allaboutcookies.org and consult an IT consultant.

5. DEFINITIONS

In these Rules, where the context so allows, words importing the singular shall include the plural and vice versa.

6. DATA PROTECTION OFFICER

Our Data Protection Officer may be contacted via email at info@moscord.com.

1. This AUR is intended to protect Customer, Supplier, Moscord and the Internet community from the inappropriate use of Moscord’s computing/network services and the internet.

2. You shall not perform any of the following actions and also procure that its end users or any third party that uses its services (“Users”), shall not perform any of the following actions:

(a) Use the Services or Trading Platform to accept, transmit or distribute unsolicited bulk data (which includes, without limitation, e-mail, bulletin boards, newsgroups, software, files) or otherwise send, or facilitate the sending of unsolicited commercial email (“UCE”) and mail bombs to any person or system in a way that could be expected to adversely impact Moscord’s network or facilities, or may potentially encroach on a third party’s intellectual property rights or any rights of publicity or privacy; The only circumstances in which the Services may be used to send unsolicited data of an advertising or promotional nature is where the unsolicited data is sent to persons with whom the sender has a pre-existing business, professional or personal relationship or to persons who have previously indicated their consent to receive data from the sender from time to time, for example by ticking a box to that effect on the sender’s web site. Unless these requirements are met, Users must not send unsolicited bulk data through the Services. If these requirements are met, the User must also provide an unsubscribe function on their web site (and make this function known to recipients in the relevant data) which allows those recipients to be removed from that mailing list.

(b) Attempt to connect to any third party systems without prior permission or arrangement;

(c) Use the Services or Trading Platform in a manner which is intended to abuse or to violate the property rights of others, including, without limitation, activities which result in the distribution of viruses, worms, time bombs, Trojan horses, cancelbots, or other destructive activities like Denial of Services (“DOS”) attacks, or scanning or any form of probing / automated network status polls / information collection of a third party’s network / system without prior permission, intentional or otherwise;

(d) Use the Services or Trading Platform to conduct any other activities, which in Moscord’s view are detrimental to its Users and/or its own operations.

(e) Use the Services or Trading Platform to:-

(i) send data, or cause data to be sent, that hides or obscures the source of the data, that contains invalid or forged headers or domain names or deceptive addressing; and

(ii) relay data from a third party’s mail server without permission or which employs similar techniques to hide or obscure the source of the data; and

(f) Violate or attempt to violate the security of the Services, including without limitation, attempting to interfere with, disrupt or disable services to any user, host or network, including but not limited to via means of overloading, “flooding”, “mail bombing” or “crashing”.

3. Users shall immediately notify Moscord of any unauthorised access or attempted breach of security.

4. Users are responsible for ensuring that its equipment are configured in a secure manner. Users should not, through action or inaction, allow others to use its network for illegal or inappropriate activities.

5. Moscord may, at its sole discretion remove or disable Users’ network connections, block network addresses, or suspend all Services to Users with or without prior notice to Users. Service suspension by Moscord due to breach of this AUR shall not prejudice any of Moscord’s rights under the Trading Platform Agreement.

6. Moscord shall not be liable for any loss, expense, costs or damages of any nature suffered by any User resulting in whole or in part from Moscord’s exercise of its rights under this AUR. By using the Services, Supplier agrees to waive and hold harmless Moscord from any claims relating to any action taken by Moscord under this AUR including conduct of investigation, issuing of warnings, refusal to post materials, removal of material, or suspension or termination of services, or other appropriate action.