Welcome to Empon (the “App” or “Platform”). Empon is a multi‑vendor marketplace with an internal advertising system (“Ads System”). This Privacy Policy explains how we collect, use, disclose, and protect your information when you use Empon as a buyer, seller (vendor), or visitor.
If you do not agree with this policy, please do not access or use Empon. If you have questions, contact us at privacy@empon.app.
Quick Links
1) Who We Are
Controller / Operator: [Company Legal Name]
Registered Address
[Street, City, Country]
Contact
Email: privacy@empon.app
Phone: [+XX XXX XXX XXXX]
Data Protection Officer
[Name, if applicable] – dpo@empon.app
2) Information We Collect
A. You provide to us
- Account & Profile: name, username, password, email, phone, address, photo, language, preferences.
- Vendor Details: store name, description, branding, business registration, tax/VAT IDs, payout details.
- Listings & Content: product info, pricing, inventory, photos/videos, FAQs, policies, messages.
- Communications: messages with buyers/sellers, support requests, reviews, and ratings.
- Verification: identity/KYC information (e.g., ID number, date of birth) where required by law.
B. Collected automatically
- Usage & Logs: device identifiers, app version, IP address, timestamps, pages/screens viewed, clicks, referring/exit pages.
- Device & Network: OS, browser, mobile device model, network type, crash and performance diagnostics.
- Location: IP‑based geolocation; with consent we may collect precise location.
C. From third parties
- Payment Processors: confirmation of payment status, limited card/bank metadata (no full card numbers stored by us).
- Identity/Compliance Providers: KYC/AML checks, sanctions screening results.
- Analytics / Anti‑Fraud: risk scores, device fingerprint signals, chargeback data.
3) How We Use Information
- Provide, operate, and improve the App and marketplace features.
- Enable account creation, authentication, vendor onboarding, and payouts.
- Facilitate product listing, search, cart, orders, shipping, and returns.
- Offer and measure our internal ads (see Section 4).
- Recommend content, vendors, and products (personalization).
- Communicate with you about orders, changes, and promotions (you can opt out of marketing).
- Detect, investigate, and prevent fraud, abuse, and security incidents.
- Comply with legal obligations and enforce our Terms.
4) Internal Ads System
Empon includes an internal advertising system where vendors can promote listings across the Platform. We do not rely on third‑party ad networks for delivery (unless expressly stated within a campaign). We process the following for ad delivery and measurement:
- Ad Delivery & Frequency Capping: anonymous identifiers, device/app data, pages viewed, and campaign parameters.
- Measurement & Attribution: impressions, clicks, conversions, and revenue attribution to campaigns.
- Targeting: non‑sensitive signals such as category interests, on‑platform activity, and location at a general level (e.g., city/country). We do not use sensitive categories (e.g., health status, religion, sexual orientation).
Your choices: You may manage ad personalization in Settings → Privacy → Ads. Disabling personalization means you will still see ads, but they will be less relevant. We honor applicable opt‑out rights where required by law.
5) Cookies & Tracking Technologies
We use cookies and similar technologies (local storage, device identifiers) to keep you signed in, remember preferences, provide security, measure performance, and support our internal ads system. You can control cookies in your browser or app settings; some features may not function without essential cookies.
6) How We Share Information
- With Vendors & Buyers: we share order‑related details necessary to fulfill purchases (e.g., shipping info, product details, messages).
- Service Providers: hosting, storage, analytics, customer support, email/SMS, identity verification, and anti‑fraud providers under contracts that protect your data.
- Payment & Payout Partners: to process customer payments and vendor payouts.
- Legal & Safety: to comply with law, court orders, or to protect rights, safety, and property of Empon, users, or the public.
- Business Transfers: in connection with a merger, acquisition, or asset sale with appropriate safeguards.
We do not sell your personal information for money. Where applicable law defines “sale” or “sharing” to include certain ad/analytics disclosures, we provide the required opt‑out mechanisms.
7) Payments
Payments on Empon are processed by third‑party payment processors (e.g., Stripe, PayPal, or local providers). We receive tokens or confirmations but do not store full payment card numbers. Vendors may need to provide payout information to our payout partner(s).
8) Data Retention
- Account data: kept while your account is active and for up to [X years] after closure for recordkeeping, disputes, and legal compliance.
- Order records: retained for [X years] to meet tax, accounting, and consumer protection laws.
- Ads & analytics logs: typically [3–24 months], unless we need longer retention for security, fraud prevention, or legal requirements.
9) Security
We implement administrative, technical, and physical safeguards designed to protect your information, including encryption in transit (HTTPS), role‑based access, and monitoring. No method of transmission or storage is 100% secure.
10) Your Rights & Choices
Your rights depend on your location. Subject to applicable law, you may have the right to:
- Access, correct, or delete your personal information.
- Object to or restrict certain processing, including personalized ads.
- Port your data to another service.
- Withdraw consent where processing is based on consent.
To exercise rights, use Settings → Privacy or contact privacy@empon.app. We may verify your request. Authorized agents may submit requests where permitted by law.
Regional Information (Summary)
- EEA/UK (GDPR): lawful bases include contract, legitimate interests, legal obligation, and consent. You can contact our DPO and lodge a complaint with your local supervisory authority.
- US (CCPA/CPRA): California residents can request disclosures, deletion, correction, and opt‑out of sale/sharing. We do not knowingly sell the personal information of minors.
- Other Regions: We honor local privacy rights as required by applicable laws.
11) Children’s Privacy
Empon is not intended for children under the age of 13 (or the minimum age required by your country). We do not knowingly collect personal information from children. If you believe a child has provided personal information, contact us to delete it.
12) International Data Transfers
We may transfer, store, and process information in countries other than your own. Where required, we use appropriate safeguards (e.g., Standard Contractual Clauses) to protect your data.
13) Changes to This Policy
We may update this Privacy Policy from time to time. The “Last updated” date at the top will reflect the latest version. Material changes will be communicated through the App or by email.
14) Contact Us
Questions or concerns? Contact: privacy@empon.app or write to [Company Legal Name], [Street, City, Country].
- Last updated date
- Company legal name, address, contact details
- Retention periods
- Payment/payout providers used in your region
- Supervisory authority info (EEA/UK) if applicable