PRIVACY POLICY
Effective Date: [Insert Date]
This Privacy Policy (“Policy”) explains how Yarbo International Inc. and its affiliated company (“we,” “us,” or “our”) collects, uses, discloses, and protects personal data of authorized distributors, resellers, and dealer (“you” or “Partner”) in connection with your use of our Partner Portal and participation in our partner program.
This Policy applies only to business representatives acting in their professional capacity, not to end consumers.
1. What Personal Data We Collect
We collect the following categories of personal data about You and your representatives:
| Category | Information |
| Business Contact Information | Full name, job title, company name, business email, business address |
| Account Data | Username, password (hashed), IP address, login timestamps |
| Transaction Data | Order history, payment terms, credit limit, invoice records, warranty claims |
| Compliance & Verification Data | Business registration number, tax ID, bank details (for payouts), proof of incorporation |
| Communication Records | Emails, support tickets, meeting notes with our sales/partner team |
2. How We Use Your Personal Data
We process your data for the following legitimate business purposes:
-
Onboarding & Account Management: Verify your company’s eligibility and activate your Partner Portal account.
-
Order Fulfillment: Process product orders, manage inventory allocation, and coordinate logistics.
-
Program Administration: Marketing and User Preference Analysis
-
Compliance & Risk Management: Conduct KYC, anti-fraud checks, sanctions screening (e.g., OFAC), and audit trails.
-
Communication: Send operational updates (e.g., price changes, EOL notices), training invitations, or policy changes.
-
Portal Improvement: Analyze usage patterns to enhance user experience (via anonymized analytics).
Our legal basis for processing is primarily performance of a contract (e.g., fulfilling your order) and legitimate interests (e.g., fraud prevention).
3. Who We Share Your Data With
We may disclose your personal data to:
| Recipient | Purpose |
| Internal Teams | Sales, finance, logistics, and partner success teams (on a need-to-know basis) |
| Affiliated Companies | Group entities involved in global supply chain or billing |
| Service Providers | ERP systems (e.g., SAP, Oracle), e-signature platforms (e.g., DocuSign), cloud hosting (e.g., AWS), logistics partners |
| Credit & Compliance Agencies | proform provision of services by external auditing firms, legal advisors, or other professional consultants |
| Legal Authorities | If required by law (e.g., subpoena, export control investigation) |
We ensure all third parties are bound by data processing agreements (DPAs) that meet GDPR/CCPA standards.
4. International Data Transfers
Your data may be transferred to and processed in countries outside your jurisdiction (e.g., from EU to U.S.). Where required by law, we rely on:
-
Standard Contractual Clauses (SCCs) approved by the European Commission;
-
Adequacy decisions (e.g., for transfers to UK, Switzerland);
-
Other lawful transfer mechanisms under applicable privacy laws.
5. Data Retention
We retain your personal data only as long as necessary for the purposes outlined above, typically:
You may request earlier deletion, subject to legal or contractual obligations.
6. Your Rights (Under Applicable Law)
Depending on your location (e.g., EU, California), you may have the right to:
-
Access, correct, or update your personal data;
-
Request restriction of processing (e.g., during a dispute);
-
Object to processing based on legitimate interests;
-
Receive your data in a structured, machine-readable format (data portability);
-
Lodge a complaint with a supervisory authority (e.g., ICO in UK, CNIL in France).
Note: These rights apply to you as an individual, even when acting on behalf of your company.
To exercise your rights, contact our Data Protection Officer at: DPO@yarbo.com.
7. Security Measures
We implement technical and organizational measures to protect your data.
8. Changes to This Policy
We may update this Policy periodically. The revised version will be posted on the Partner Portal with an updated “Effective Date.” Continued use of the Portal constitutes acceptance.
9. Contact Us
For questions about this Policy or to submit a data subject request, please contact:
Data Protection Officer (DPO) Email:DPO@yarbo.com
By clicking “I Agree” 、accessing the Portal or engaging to register, Distributor acknowledges that it has read, understood, and accepted this policy.