Privacy Policy
PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CLICKING OR CHECKING “SIGN UP”, “I AGREE TO GORILLA’S PRIVACY POLICY”, “I AGREE AND CONSENT TO THE COLLECTION, USE, DISCLOSURE, STORAGE, TRANSFER AND/OR PROCESSING OF MY PERSONAL DATA FOR THE PURPOSE STATED IN, AND UNDER THE TERMS OF, GORILLA’S PRIVACY POLICY” OR SIMILAR STATEMENTS AVAILABLE AT THE GORILLA REGISTRATION PAGE, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THE TERMS OF THIS PRIVACY POLICY AND THAT YOU HAVE AGREED AND CONSENTED TO THE COLLECTION, USE, DISCLOSURE, STORAGE, TRANSFER AND/OR PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED AND UNDER THE TERMS HEREIN.
1. Introduction to this Privacy Policy
1.1. Gorilla and its affiliates (collectively or individually, “Gorilla”, “we” or “us”) take your privacy seriously.
1.2. In the course of providing you with the Services (as defined in the Terms of Use) or access to the Gorilla Platform (as defined in the Terms of Use), we will be collecting, using, disclosing, storing and/or processing data, including your personal data. In this Privacy Policy, Gorilla Platform shall also refer to the platform(s) of the relevant Seller (as defined in the Operation Regulations).
1.3. This Privacy Policy exists to keep you in the know about how we collect, use, disclose, store and/or process the data we collect and receive during the course of providing the Services or access to the Gorilla Platform to you, our user, whether you are using our Gorilla Platform as a Customer (as defined in the Operation Regulations) or a Seller. We will only collect, use, disclose, store and/or process your personal data in accordance with this Privacy Policy.
1.4. It is important that you read this Privacy Policy together with any other applicable notices we may provide on specific occasions when we are collecting, using, disclosing and/or processing personal data about you, so that you are fully aware of how and why we are using your personal data.
1.5. We may update this Privacy Policy from time to time. Any changes we make to this Privacy Policy in the future will be reflected on this page and material changes will be notified to you. Where permissible under local laws, your continued use of the Services, access to the Gorilla Platform or use of the Services, including placing Orders (as defined in the Terms of Use) on the Gorilla Platform, or express consent thereto, shall constitute your acknowledgment and acceptance of the changes we make to this Privacy Policy. You agree that it is your responsibility to check back frequently to see any updates or changes to this Privacy Policy.
1.6. This Privacy Policy applies in conjunction with other notices, contractual clauses and consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override them unless we state expressly otherwise.
1.7. All of these terms apply to Gorilla’s users, whether Customers or Sellers.
2. The Personal Data We Collect From You
2.1. Personal data means any information about an individual, whether recorded in a material form or not and whether true or not, who can be identified from that data (whether directly or indirectly), or from that data and other data to which we have or are likely to have access.
2.2. During the course of your use of the Gorilla Platform and the provision of the Services, we may collect personal data about you, as follows:
(a) Where you are a Customer:
(i) Identity data, such as your name, gender, profile picture, and date of birth;
(ii) Contact data, such as billing address, delivery address, email address and phone numbers;
(v) Transaction data, such as details about orders and payments, and other details of products and Services related to you;
(vi) Technical data, such as Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and Gorilla Platform, international mobile equipment identity, device identifier, IMEI, MAC address, cookies (where applicable) and other information and technology on the devices you use to access the Gorilla Platform;
(vii) Profile data, such as your username and password, orders related to you, your interests, preferences, feedback and survey responses;
(viii) Usage data, such as information on how you use the Gorilla Platform, products and Services or view any content on the Gorilla Platform, including the time spent on the Gorilla Platform, items and data searched for on the Gorilla Platform, access times and dates, as well as websites you were visiting before you came to the Gorilla Platform and other similar statistics;
2.3. During the course of your use of the Gorilla Platform and our provision of the Services, we may receive personal data from you in the situations, as follows:
(a) When you browse our website (both mobile and web versions);
(b) When you create an account with us (as Customer or Seller);
(c) When, as a Seller, you list products and/or services for sale on the Gorilla Platform and conduct transactions with Customers in respect of the sale and purchase of those products and/or services through the Gorilla Platform;
(d) When you apply for, subscribe to or otherwise use any of the Services;
(e) When you make a transaction regarding the products available on the Gorilla Platform;
(f) When you activate or use any payment-related functions available on the Gorilla Platform or provided by our third party service providers;
(g) When you use any of the features, functions, mini-apps or mobile games available on the Gorilla Platform or Services;
(i) When you use the chat function on the Gorilla Platform;
(j) When you subscribe to our publications or marketing collaterals;
(k) When you enter a competition, promotion or survey;
(l) When you participate in any activity or campaign on the Gorilla Platform;
(m) When you log in to your account on the Gorilla Platform or otherwise interact with us via an external service or application, such as Facebook or Google;
2.4. We may collect personal data from you when you use the Gorilla Platform or the Services our
2.5. Where we collect personal data from third parties and/or our affiliates, we will only collect your personal data, where permitted by law, for or in connection with the purposes for which those third parties or our affiliates are engaged, for the purposes of our collaboration with the third parties or affiliates, or for the requirement to carry out verification or due diligence checks. During the course of your use of the Gorilla Platform and our provision of the Services, you agree that you have provided your consent (whether to us, the third party or our affiliates) to the transfer of your personal data from third parties and/or our affiliates to Gorilla for the purposes set out in this Privacy Policy or any other terms.
2.6. You must only submit personal data which is accurate and not misleading and you must keep it up to date and inform us of any changes to the personal data you have provided to us. We shall have the right to request for documentation and carry out the necessary checks to verify the personal data provided by you as part of our user verification processes or as required under law.
2.7. We will only be able to collect certain categories of personal data if you voluntarily provide the personal data to us or as otherwise provided for under this Privacy Policy. If you choose not to provide your personal data to us or subsequently withdraw your consent to our use of your personal data, we may not be able to provide you with certain features or functionality on the Services or access to the Gorilla Platform.
2.8. If you provide personal data of any third party to us, you represent and warrant that you have obtained the necessary consent, license and permissions from that third party to share and transfer his/her personal data to us, and for us to collect, store, use and disclose that data in accordance with this Privacy Policy.
2.9. If you sign up to be a user on our Gorilla Platform using your social media account or link your Gorilla account to your social media account or use certain other Gorilla social media features, we may access personal data about you which you have voluntarily provided to your social media provider in accordance with the provider’s policies and we will manage your personal data in accordance with this Privacy Policy.
3. Purpose of Collecting Personal Information
3.1. The personal data we collect (as defined in section 2 above) from you or via third parties may be used for certain purposes, as follows:
(a) Where you are a Customer:
(i) Processing your order for products (whether sold by Gorilla or a third party Seller)
- To process orders you submit through the Gorilla Platform;
- To deliver the products you have purchased through the Gorilla Platform. We may pass your personal information on to a third party (e.g. our logistics partner) or relevant regulatory authority (e.g. customs) in order to make delivery of the product to you;
- To update you on the delivery of the products;
- To provide customer support for your orders; and
- To verify and carry out payment transactions (including any credit card payments, bank transfers, offline payments, remittances, or e-wallet transactions) in relation to payments related to you and/or Services used by you. In order to verify and carry out such payment transactions, payment information, which may include personal data, will be transferred to third parties such as our payment service providers.
(ii) Providing Services
- To facilitate your use of the Services or access to the Gorilla Platform;
- To administer your account (if any) with us;
- To display your name, username or profile on the Gorilla Platform (including on any reviews you may post);
- To facilitate the use of the mini-apps available on the Gorilla Platform;
- To respond to your queries, feedback, claims or disputes, whether directly or through our third party service providers;
- To display on scoreboards on the Gorilla Platform in relation to campaigns, mobile games or any other activity;
- To allow other users to identify you (via the “Find my friends” or any other similar function) as a user of the Service, to allow you to find other users and to connect with them on the Gorilla Platform, and to support the socialising function of the Services (where applicable);
- To assess your application for loan facilities and/or to perform credit risk assessments in relation to application for financing services (where applicable); and
- To facilitate the integration of third party’s loyalty membership programmes (including those supported by Sellers or brands) with our Gorilla Platform.
(iii) Marketing and advertising
- To provide you with information we think you may find useful or which you have requested from us (provided you have opted to receive such information);
- To send you marketing or promotional information about our or third-party Sellers’ products and services on our Gorilla Platform from time to time (provided you have opted to receive such information);
- To help us conduct marketing and advertising; and
- To promote the Services and use information that you give to us, such as user-generated content (including video content) that you can choose to upload or broadcast on our Gorilla Platform and will be accessible on the Internet and may be shared by the public (the latter of which is not within our control), as part of our advertising and marketing campaigns to promote the Gorilla Platform.
(iv) Legal and operational purposes
- To ascertain your identity in connection with fraud detection purposes;
- To compare information, and verify with third parties in order to ensure that the information is accurate;
- To process any complaints, feedback, enforcement action and take-down requests in relation to any content you have uploaded to the Gorilla Platform;
- To produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
- To store, host, back up your personal data;
- To prevent or investigate any actual or suspected violations of our Terms of Use, Privacy Policy, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
- To perform due diligence checks;
- To comply with legal and regulatory requirements (including, where applicable, the display of your name, contact details and company details), including any law enforcement requests, in connection with any legal proceedings, or otherwise deemed necessary by us; and
- Where necessary to prevent a threat to life, health or safety.
(v) Analytics, research, business and development
- To understand your user experience with the Services and the Gorilla Platform;
- To improve the layout or content of the pages of the Gorilla Platform and customise them for users;
- To identify visitors on the Gorilla Platform;
- To conduct surveys, including carrying out research on our users’ demographics and behaviour;
- To improve our current technology (e.g. voice recognition tech, etc) via machine learning or other means;
- To derive further attributes relating to you based on personal data provided by you (whether to us or third parties), in order to provide you with more targeted and/or relevant information;
- To conduct data analysis, testing and research, monitoring and analysing usage and activity trends;
- To further develop our products and services; and
- To know our Customers better.
(vi) Other
- Any other purpose to which your consent has been obtained; and
- To conduct automated decision-making processes in accordance with any of the above purposes.
(b) Where you are a Seller:
(i) Providing Services
- To facilitate your use of the Services or access to the Gorilla Platform;
- To ship or deliver the products you have listed or sold through the Gorilla Platform. We may pass your personal information on to a third party (e.g. our logistics partners) or relevant regulatory authority (e.g. customs) in order to carry out shipping or delivery of the products listed or sold by you;
- To respond to your queries, feedback, claims or disputes, whether directly or through our third party service agents;
- To verify your documentation submitted to us facilitate your onboarding with us as a Seller on the Gorilla Platform, including the testing of technologies to enable faster and more efficient onboarding;
- To administer your account (if any) with us;
- To display your name, username or profile on the Gorilla Platform;
- To verify and carry out financial transactions (including any credit card payments, bank transfers, offline payments, remittances, or e-wallet transactions) in relation to payments related to you and/or Services used by you. In order to verify and carry out such payment transactions, payment information, which may include personal data, will be transferred to third parties such as our payment service providers;
- To assess your application for loan facilities and/or to perform credit risk assessments in relation to your application for Seller financing (where applicable);
- To provide you with ancillary logistics services to protect against risks of failed deliveries or Customer returns; and
- To facilitate the return of products to you (which may be through our logistics partner).
(ii) Marketing and advertising
- To send you marketing or promotional materials about our or third-party Sellers’ products and services on our Gorilla Platform from time to time (provided you have opted to receive such information); and
- To help us conduct marketing and advertising.
(iii) Legal and operational purposes
- To produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
- To store, host, back up your personal data;
- To prevent or investigate any actual or suspected violations of our Terms of Use, Privacy Policy, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
- To comply with legal and regulatory requirements (including, where applicable, the display of your name, contact details and company details), including any law enforcement requests, in connection with any legal proceedings or otherwise deemed necessary by us;
- Where necessary to prevent a threat to life, health or safety;
- To process any complaints, feedback, enforcement action and take-down requests in relation to any content you have uploaded to the Gorilla Platform;
- To compare information, and verify with third parties in order to ensure that the information is accurate;
- To ascertain your identity in connection with fraud detection purposes; and
- To facilitate the takedown of prohibited and controlled items from our Gorilla Platform.
(iv) Analytics, research, business and development
- To audit the downloading of data from the Gorilla Platform;
- To understand the user experience with the Services and the Gorilla Platform;
- To improve the layout or content of the pages of the Gorilla Platform and customise them for users;
- To conduct surveys, including carrying out research on our users’ demographics and behaviour to improve our current technology (e.g. voice recognition tech, etc) via machine learning or other means;
- To derive further attributes relating to you based on personal data provided by you (whether to us or third parties), in order to provide you with more targeted and/or relevant information;
- To conduct data analysis, testing and research, monitoring and analysing usage and activity trends;
- To further develop our products and services; and
- To know our Sellers better.
(v) Other
- Any other purpose to which your consent has been obtained; and
- To conduct automated decision-making processes in accordance with any of these purposes.
4. Scope of Information Usage
The personal data we collect will be used domestically or transferred to overseas to serve the purposes as stated in this Privacy Policy.
5. Information Retaining Period
5.1. We will only retain your personal data for as long as permitted by law or as relevant for the purposes for which it was collected.
5.2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data was collected, and is no longer necessary for any legal or business purpose.
5.3. Without prejudice to the other terms and conditions provided hereunder, your personal data shall be retained until your request to delete your personal data and/or deactivate your Gorilla user account with us.
6. Persons or organizations who can approach such information
6.1. In Vietnam, the Gorilla entity controlling your personal data will be Gorilla South East Asia Pte. Ltd. and/or Recess Company Limited.
6.2. We may share (or permit the sharing of) your personal data with and/or transfer your personal data to third parties and/or our affiliates for the usage purposes mentioned in this Privacy Policy. These third parties and affiliates, which may be located inside or outside Vietnam, include but are not limited to:
(a) Service providers (such as agents, vendors, contractors and partners) in areas such as payment services, logistics and shipping, marketing, data analytics, market or consumer research, survey, social media, customer service, installation services, information technology and website hosting;
(b) Their service providers and related companies; and
(c) Other users of the Gorilla Platform or Services.
6.3. In disclosing your personal data to them, we endeavour to ensure that the third parties and our affiliates keep your personal data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain your personal data only for as long as your personal data is needed to achieve the above-mentioned purposes.
6.4. We may also share personal data in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we satisfy the requirements of applicable data protection law when disclosing your personal data.
6.5. We may transfer or permit the transfer of your personal data outside Vietnam for any of the purposes set out in this Privacy Policy. However, we will not transfer or permit any of your personal data to be transferred outside Vietnam unless the transfer is in compliance with applicable laws.
6.6. We may share your personal data with our third party service providers or affiliates (e.g. payment service providers) in order for them to offer services to you other than those related to your use of the Gorilla Platform or our Services. Your acceptance and use of the third party service provider’s or our affiliate’s services shall be subject to terms and conditions as may be agreed between you and the third party service provider or our affiliate. Upon your acceptance of the third party service provider’s or our affiliate’s service offering, the collection, use, disclosure, storage, transfer and processing of your data (including your personal data and any data disclosed by us to such third party service provider or affiliate) shall be subject to the applicable privacy policy of the third party service provider or our affiliate, which shall be the data controller of such data. You agree that any queries or complaints relating to your acceptance or use of the third party service provider’s or our affiliate’s services shall be directed to the party named in the applicable privacy policy.
7. Address of entity collecting and managing data, including contact method for consumers to inquire about the collection, process activities of information related to the consumer
7.1. If you have any questions on personal data protection or data privacy, please refer to our list of frequently asked questions on data protection/ privacy.
7.2. If your queries are not covered in our FAQs, or if you have any queries or complaints about this Privacy Policy or how we handle your personal data, please feel free to contact us via our online chat service or as follows:
Gorilla Glue Vietnam Company Limited
Address: 139 Phố Kim Hoa, Đống Đa, Hà Nội