Last Updated: 26 March, 2021.

Piara Bazar Bangladesh Privacy Commitment

Since 2014, Piara Bazar’s business and reputation have been built on trusted relationships with our customers, employees, and other stakeholders. The protection of information in our custody is a critical component of these trusted relationships.

As part of our ongoing commitment to fostering and maintaining trust, Piara Bazar has established a robust privacy program that is designed to protect the personal information entrusted to us.

We work hard to: Be Accountable: We have established a foundational privacy framework that sets out the structure and accountability for the treatment of personal information across the organization. Our privacy framework is overseen by a dedicated Privacy Office, led by our senior management that sets and maintains Piara Bazar’s privacy program.

Be Safe: We have implemented measures designed to protect the personal information that has been entrusted to us.

Be Respectful: We collect, use, and disclose personal information in a manner that is fair, ethical and non-discriminatory.

Be Useful: We use information to deliver value, enhance the retailing experience, and to manage our business.

Be Adaptable: We monitor privacy and data protection laws, standards and industry practices so that we can provide our products and services in a privacy-respectful manner.

Be Transparent: We explain how we handle personal information in a clear and easily accessible
manner.

The following documents describe our privacy practices:

Privacy Agreement

Our Privacy Agreement describes how we treat personal information including the types of personal information we collect, when and why we collect and use personal information, and the circumstances when we share and disclose it.
Piara Bazar Privacy Agreement
Piara Bazar recognizes the importance of your personal information and we never take for granted the trust that you – as a customer or a business partner – have placed in us to protect that information.
Piara Bazar values transparency. With this Privacy Agreement, along with our Digital Privacy and Interest-Based Advertising Policy, we are striving to provide you with a good understanding of why we collect and use your personal information, how your information is shared, retained and protected, and how you can exercise your personal choices. We will also explain how you can find out what personal information we hold about you. When you apply or sign-up for a product or service that requires further explanation about how we use your personal information, we will explain that to you.
Some of our affiliates and vendors, sellers may have their own privacy policies, but where that is not the case, this Privacy Agreement and our Digital Privacy and Interest-Based Advertising Policy apply to The Piara Bazar Inc. and the current and newly acquired members of the Piara Bazar companies or any of branch or regional office in Bangladesh (“Piara Bazar” or “we” or “us”).

Our privacy framework

We have established a privacy framework that sets out the structure and accountability for the secure and respectful treatment of personal information. Our privacy framework is overseen by our senior management committee.

You can contact our senior management committee on privacy related issue using the contact
information at the end of this Privacy Agreement.

What is personal information?

Personal information is information that identifies you or can be used to identify you. Examples of personal information include: first and last name, mother’s maiden name, mailing address, telephone number (including mobile), email address, date of birth, National Identity (NID), government-issued identification, credit history, information about your employment and education.

Why we collect and use personal information?

· We collect and use personal information to establish and manage our retail business relationship with you, provide you with personalized products and services, manage our business, and comply with legal and safety requirements. We will give you some examples to explain each one of these purposes.

· To establish and manage our retail services relationship We collect and use personal information to establish and maintain our relationship and provide you withnthe products and services you have requested.

· We need to confirm who you are and verify the information you have provided to us: We will ask for your name, address, telephone numbers (including mobile), email address, and date of birth, and may ask for other forms of identification such as a passport or a recent utility bill.

· We may also ask for certain biometric information, like a fingerprint or a voiceprint to securely verify your identity. We may ask you for your NID to confirm your identity and ensure we obtain accurate information from credit reporting agencies. Providing your NID for these identity verification purposes is optional. To withdraw your consent for the use of your NID for identity verification purposes.

· We need to communicate with you: We may communicate with you by phone, fax, mail, email, SMS text message or other electronic means to provide you with information related to the products and services you hold with us. You can also choose to sign-up to receive alerts (including push notifications) regarding your account.
To provide you with personalized products and services ,

· We collect and use personal information to provide you with personalized products and services and information about products and services that may be of interest to you.

· We collect and use information to personalize your experience with us, including: to better understand your needs and preferences including through data analytics; to personalize your experience on our websites and mobile applications; to provide you with tailored communications and offers.

· We collect and use information to provide you with marketing communications: We may contact you by phone, fax, mail, email, SMS text message or other electronic means about new products and services, offers, events and promotions. Our communications may be tailored based on information that we have about you. If you do not wish to receive these communications, you can withdraw your consent at any time by following the instructions under “How to update your marketing choices” below. If you sign-up to receive electronic messages (such as emails and SMS text messages) from Piara Bazar, we will send you communications about our products and services, offers, events, and other valuable information. We may also send you information about the products and services of Piara Bazar that may be of interest to you.

· We may also use services provided by third-party platforms (such as social networking and other websites) to serve relevant Piara Bazar advertisements on such platforms to you and others.

· We may provide a de-identified version of your email address to the platform provider for such purposes. To opt-out of the use of your information for these purposes, you can unsubscribe from receiving email marketing communications by following the instructions under “How to update your marketing choices” below.

· We collect and use information when you participate in a contest, survey, or promotion: If you participate in a contest, survey or promotion, we may collect your name, address, phone number, email address, and other information or responses you provide. We use this information to administer your participation in the contest or promotion and as otherwise described to you when you enter. The information obtained through our surveys is used in an aggregated form. We use this information to help us understand our clients and to improve our products and services. If a contest or promotion is administered by a third party (such as a loyalty program partner), we may share information with the third party as described to you at the time of entry into the contest or promotion.

· To manage our business we collect and use personal information to operate and manage our business and business relationships.

· We collect and use information to prevent and detect fraud and criminal activity and secure our premises: We may ask you for any additional information required to investigate matters, settle any claim or report a matter to the appropriate authorities.

· We collect and use information when you contact us: We record telephone calls for training and quality assurance purposes. We will tell you when we are recording a call.

· We collect and use information to collect debts, enforce obligations and to manage and assess risk.

· We collect and use information to manage our business relationships: For example, we collect personal information from employees or other representatives of our suppliers and contractors that is necessary for them to do business with us.

· We use and analyze the information we collect to better understand our clients, improve our products and services, and to prevent and detect fraud. To comply with legal and safety requirements

· We are required to collect and use personal information to meet legal and safety requirements.

· We also need to collect, use and disclose your NID for income tax reporting purposes and to fulfil other safety requirements, as required by law.

Why we share your personal information

Piara Bazar may share your personal information with third parties for the purposes described below.

Members of the Piara Bazar companies may be located outside of Bangladesh and may access and process your personal information from the United States or other jurisdictions.

We may share your personal information with other members of the Piara Bazar companies so that they may contact you for the purposes of marketing, including telemarketing, or to help you manage your credit responsibly. You can withdraw your consent to the disclosure of your personal information to other region of Piara Bazar companies for marketing at any time. See “How to update your marketing choices” for more information.

We may share information with our service providers: We may use third party service providers to process or handle personal information on our behalf. Our service providers assist us with various services such as printing, postal and electronic mail distribution, marketing (including by telephone and electronic means), advertising, analytics, customer service, and processing, authorizing and authenticating your transactions.

We also provide personal information to credit or payment card networks and associations to
administer the payment card system. We may also share information with merchants with whom you have set up pre-authorized or automatic bill payments, in which case we may provide your updated payment card number or expiry date.

When personal information is provided to our service providers, we will require them to protect the information in a manner that is consistent with Piara Bazar privacy and security policies, practices and standards.

Some of our service providers are located outside of Bangladesh and may access and process your personal information from the United States or other jurisdictions.

We may share information with our loyalty, reward or program partners: We may offer products and services with trusted business partners. In the event we collect, use and disclose personal information in connection with a partner program, we will tell you this at the time you sign-up for the program. For more information, see the terms that govern your participation in the program.

We may share information with other trusted business partners: We may share information with our partners for marketing or other servicing purposes. For example, if you sign-up to receive
communications from our trusted business partners, we share your personal information with our
trusted partners so that they may contact you for the purposes of marketing, including telemarketing.
You can withdraw your consent to the disclosure of your personal information with these partners at any time. See “How to update your marketing choices” below for more information.

We may share information with credit reporting agencies: We exchange personal information with consumer and credit reporting agencies on an ongoing basis, including information about late payments, missed payments or other defaults.

We may share information with third parties in connection with a prospective business transaction: If we sell a company or a portion of the business or assets of Piara Bazar Company, or in the event we sell,  assign or securitize your loan, mortgage or other debt, we may provide information we hold about you to the prospective purchaser or investor. The personal information we disclose in such circumstances may include financial information obtained in support of your loan, mortgage or other debt.

To other organizations for the purposes of investigating a breach of an agreement or contravention of law or to detect, suppress or prevent fraud;  To establish, exercise or defend legal claims; to protect the rights, property and safety of Piara Bazar and others; to courts, law enforcement and regulatory authorities in the jurisdictions in which we or our service providers operate, including to respond to a local or foreign court order, search warrant or other demand or request which we believe to be valid; to comply with the rules of production of a local or foreign court; and To satisfy legal and safety requirements that we believe are applicable to us, including the requirements of any self-regulatory organizations to which we belong.

We may share information relating to mortgage products: If you have a mortgage account with us, we may share information about you, including credit information and the amount of your mortgage, to mortgage insurers for the purposes of offering and administering mortgage insurance, or to a creditor where you are in default of an obligation to that creditor.

We may share information relating to insurance services: We may exchange personal information (including health information) with hospitals and health care professionals, government insurance plans, other insurance companies and insurance service bureaus.

We may share information in accordance with your requests or as you otherwise consent.

How we protect and retain personal information:

· We have implemented measures designed to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, and disclosure.

· We restrict access to personal information to employees and authorized service providers who require access to fulfil their job requirements.

· We may keep and use information about you in our records for as long as it is needed for the purposes described above, or to otherwise meet our legal obligations, even if you are no longer a customer.

How we notify you of changes to this Privacy Agreement:

· We may amend this Agreement from time to time to reflect changes in our personal information practices. We will post the revised Agreement on our website and make it available at our branches.

· We may also notify you of any changes to this Agreement in any of the following way:
A notice on the Piara Bazar website or Online portal;

· Digital Privacy and Interest-Based Advertising Policy, Our Digital Privacy and Interest-Based Advertising Policy describes how Piara Bazar uses cookies and other technologies on its websites, including to deliver more relevant advertising.

· Piara Bazar Digital Privacy and Interest-Based Advertising Policy
This Digital Privacy and Interest-Based Advertising Policy, along with the Piara Bazar Privacy Agreement, describes how Piara Bazar uses cookies and other technologies to provide our customers and business partners (“you”) with personalized products and services.

· Some of our affiliates and sellers have their own digital and interest-based advertising policies. Where that is not the case, this Policy applies to Piara Bazar and any current and newly acquired members of the Piara Bazar companies or any Piara Bazar programs (“Piara Bazar” or “we” or “us”) We collect information about the computer or device you use to access our website or one of our mobile applications, including IP (Internet Protocol) address, mobile device identification number, MAC address or other device identifier, the make and model of your device, its operating system, information about the screen size, page requests, browser type, average time spent on our website or app and date and time of your use.

· We use this information to determine which settings are appropriate for your computer or device, to provide or enhance digital functionality and options, and for security purposes including fraud prevention, internal analysis and reporting. We also may use this information to help us understand our website and mobile application activity and to monitor and improve our website and mobile applications.

Technologies we use:

We use cookies and other technologies such as pixel tags and web beacons.

A “cookie” is a piece of data that a web browser creates when you visit a website. This data is
information about how and when you use a site. It is placed on your computer, smartphone, or tablet (“online device”) in the form of a small text file.

There are two main types of cookies:

Session cookies: 

These are temporary cookies that expire when you leave the site. Session cookies allow the website to recognize you as you navigate between pages during a single browser session and allow you to use the website most efficiently.
Persistent cookies: in contrast to session cookies, persistent cookies are stored on your online device between browsing sessions until expiry or deletion. They therefore enable the website to “recognize” you on your return, remember your preferences, and personalize services to you.
We use both session cookies and persistent cookies on our website. The benefit of enabling cookies is that it will allow your use of Piara Bazar websites to be faster, easier and tailored to your interests.

Pixel tags and web beacon technologies provide information about how you interact with our websites, mobile applications, and emails. For example, pixels can be used to determine whether an e-mail has been opened or forwarded and how much of it has been viewed. These technologies may communicate with servers to obtain images and other content and to relay information about the IP address being used to access our site and information about your browser.

We may use the information we obtain through these technologies to serve you targeted ads, as described below under “What is interest-based advertising?”.

Why we use these technologies:

· To collect statistical information: We use these technologies to collect and evaluate statistical information on how you use our websites to help us improve our websites, products and services.

· To measure engagement: We use these technologies to gain a better understanding of customer behavior on our websites to develop engagement strategies to better serve you and make it easier for you to navigate our websites and find information about our products and services. This data may be matched with other information we have about you to provide you with personalized marketing communications and services that better reflect your needs.

· To advertise or make offers: We use these technologies to serve Piara Bazar advertisements and offers tailored to you or that may be of interest to you on third party websites. For more information on interest-based advertising see “What is interest-based advertising?” below.

· For analytics: We may use web analytics services such as Adobe Analytics and Google Analytics to help us analyze how visitors use our websites so that we can better understand and improve our websites. These third parties may collect your IP address or device identifier on the date you visit a site as well as the number of visitors to our site, where visitors have come to the site from and the pages they visit. For example, with Google Analytics, the information generated by the cookie about your use of the site (including your IP address) will be transmitted to and stored by a Google server. Google uses this information for the purpose of evaluating your use of the site, compiling reports on site activity for us, and providing us with other services relating to site activity and internet usage.

· For more information, see “How Google uses data when you use our partners’ sites or apps” and “Google Analytics and Privacy”.

· For instructions on how to opt-out of Google Analytics and Adobe Analytics, please see “How to control or refuse cookies” Below.

· For the Piara Bazar Online: You can select to have a cookie securely store your account with us. This allows you to access your accounts faster and more conveniently. You cannot store your passwords.

· To authenticate your computer: We use these technologies to gather information such as IP address and browser type to authenticate you and your computer and to detect and prevent fraud.

· For security and verification: We use these technologies to help us maintain security and verify your details while you navigate from page to page on our websites, which enables you to avoid having to re-enter your details each time you enter a new page.

· To personalize content: We use these technologies to remember how you have customized your use of our websites, such as your preferred currency and time zone, and to personalize your experience on our websites and mobile applications.

· To improve your user experience: We use these technologies cookies to collect information about your activity on our websites to enable us to better understand and improve your user experience when using our websites, for example, a cookie which recognizes if your browser supports specific technology features. This helps, for example, in enabling websites to be loaded more quickly when you request the download of a large file.

Why we collect information about your location:

We offer mobile applications or other products and services that use information about your location. If you choose to use such applications or services, we may, with your consent, collect information about your location to provide you with services you request or to protect you and us from fraud.

How to control or refuse cookies?

You can limit the collection of your information by disabling cookies on your browser. You may also be able to modify your browser settings to require your permission each time a website attempts to set a cookie. However, our websites (and many other websites) rely on cookies to enable certain functionality. If you choose to disable cookies, some of the services or functionality available on our websites may not work properly.

You can prevent the storage and processing of data relating to your use of the site by Google and Adobe as follows:

You can opt out of Adobe Analytics using Adobe Opt Out Settings.
You can opt out of Google Analytics by installing Google’s opt-out browser add-on.
To opt-out of interest-based advertising, please see “How to opt-out of interest-based advertising” below.

What is interest-based advertising?

Interest-based advertising allows us to deliver advertisements and offers that are more relevant to you and your interests. It works by showing you advertisements and offers that are based on your browsing patterns and the way you have interacted with our websites. We use third parties such as ad networks, advertisers and other partners who use their own technologies (including cookies and pixel tags) to collect information about your activity on our websites and on third-party websites (such as those you visit and your interaction with our advertising and other communications).

This information is used to make predictions about your preferences and deliver ads that are more relevant to your perceived interests when you are on our websites or third party websites. We may also share this information with a limited number of trusted business partners that wish to advertise to you.

If you click one of our advertisements or offers, we may also track the response rate and the website activity associated with it to evaluate the effectiveness of our online campaigns.

How to opt-out of interest-based advertising

To opt-out of the third parties collecting information for interest-based advertising on our websites, please click here for our cookie consent management tool.

As part of our commitment to fair information practices, Piara Bazar is a participant and supporter of the Digital Advertising Alliance of Bangladesh (as per BTCL guideline).

You can also opt-out of interest-based Adobe ads using Adobe Opt out Settings and from interest-based Google ads using Google’s Ads Settings.

Important notes about your opt-out:

If you opt-out of interest-based advertising by a third party, these technologies may still collect data for other purposes including analytics and you will still see ads from us across the Internet, but the ads will not be targeted based on behavioral information about you and may therefore be less relevant to you and your interests.
Interest-based advertising opt-outs work by saving cookies in your browser that tell the various ad partners that you have opted-out. Because cookies are generally browser-specific, your choice will only apply to the web browser from which you opt-out. You must opt-out from each web browser from which you do not want interest-based advertising (and this may involve different devices, if you use more than one).
If you delete or clear your browser’s cookies, you will need to opt-out again.

How to protect your security?

Browsers such as Microsoft Internet Explorer allow you to store passwords and logon IDs so you do not need to re-enter this information each time you access a web site. To prevent unauthorized use of your online access codes, Piara Bazar strongly urges you to NOT use this functionality.

How we will notify you of changes to this Policy

We may change this Policy from time to time to reflect changes in our practices. We will display the changed Policy on our website. We encourage you to visit our website frequently to stay informed.