Privacy Policy

Release Date of this Privacy Policy: June 25th, 2025

Effective Date of this Privacy Policy: June 25th, 2025

Welcome to Openow! Openow provides an online marketplace that connects users for the purchase and sale of physical products and other permitted items (“Item”). If you purchase Items or make offers through the platform, you are a “Buyer.” If you wish to list or sell Items through the platform, you must apply to become a“Seller.”

As the operator of Openow (“we” or “us”), we respect your right to privacy and highly value the protection of your Personal Data. This Privacy Policy (“Privacy Policy”) explains how we collect, process and protect your Personal Data when you use Openow and how you can exercise your rights to Personal Data protection. For information that demands your particular notice and that may have a significant impact on your rights and interests, we have highlighted it in bold font to draw your attention. If you do not agree with this policy, you should not access or use Openow

Personal Data” in this Privacy Policy refers any information relating to an identified or identifiable natural person (data subject), including name, date of birth, email address, phone number, order history,billing and shipping addresses, etc..

Openow is not intended for use by individuals under the age of 18, except that users between the ages of 13 and 17 may use the platform only through an account set up by their parent or legal guardian and with that adults consent and supervision. We do not knowingly collect Personal Data from minors under the age of 13. If we become aware that Personal Data has been collected from a user under the age of 13, we will delete such data and terminate the account. If you believe that we may have collected Personal Data from a minor under the age of 13 in violation of this Privacy Policy, please contact us using the contact details provided in the How to contact us section below.

If you are a parent or legal guardian of a minor under the age of 18, please ensure that you have read this Privacy Policy and are responsible for your child's activities before allowing your child to use Openow. You are suggested to pay close attention to your child’s use of Openow and to ensure that your child only uses the age-appropriate functions.

If you have any questions about this Privacy Policy, please contact us using the contact details provided at the end of this Privacy Policy.

1. What types of Personal Data do we collect and our purposes

The scope of Personal Data we collect depends on the functions of Openow you use and how you use these functions. The purposes and types of Personal Data we collect are summarized in the below.

A. The Personal Data you directly provide to us

Account Information. New users of Openow may log in through a third-party platform account (please refer to Section 1.C below for more information). You may be required to provide the following information: username, name, profile photo, age, email address, mobile phone number, mailing address, billing address. If you refuse to provide such Personal Data, you will not be able to complete the registration process and can only use very limited functions of Openow as a visitor.

Seller Verification. If you choose to become a Seller on our platform, we may need to collect additional information including: government-issued identification documents, business registration information, bank account details, tax identification numbers, proof of address, and product authenticity certifications. This information is necessary to verify your identity, comply with tax regulations, prevent fraud, and maintain platform integrity.

Contact and Marketing. We may use the contact information provided by you (e.g., email address) to conduct user survey or to send you information about products and services that may be of interest to you. Where required by applicable laws and regulations, we will obtain your consent before sending you marketing messages. If you are not interested in such information, you may refuse at any time during the communication, for example, by clicking on the unsubscribe/refuse option or sending us a reply to opt-out.

B. The Personal Data we collect and process during your use of Openow

Product Listings and Store Management. When you create product listings, we collect product information including descriptions, images, videos, pricing, inventory levels, shipping information, product categories, and condition reports. We also collect data about your store management activities such as listing updates, inventory adjustments, and promotional activities. We collect this information to display your products to potential buyers, enable search functions, and facilitate transactions.

Chat and Message. When you use our messaging features to communicate with Sellers, or other users, we collect message content, conversation history, and communication metadata generated through platform interactions. We collect this information to facilitate communications between users, provide customer support, resolve disputes, detect and prevent fraud or abuse, ensure compliance with our policies, and maintain transaction records.

Payment and Transaction. When you use our payment functions, and initiate a payment request, we collect certain information necessary to complete the transaction via third-party payment service providers (e.g., Paypal, Airwallex) through an Application Programming Interface (API). This includes your user ID, country/region, payment currency, payment amount, payment time, payment method, order number, and other related information. If such payment information is not provided or invalid, we may not be able to process your payment or complete the transaction.

Feedback and Report. When you use the feedback feature within Openow, we need to collect the feedback description and screenshot. If you do not provide such information, we may not be able to help you resolve the issue or respond to your feedback. In addition, if you wish to make a report (for example, when you discover any illegal content, illegal user activity, or your rights have been violated), we need to collect a description of your report, the type of report, and relevant chat logs (if any) in order to understand the facts and help you resolve the issue.

Browsing and Shopping Behavior. We collect information about your browsing patterns, search queries, product views, purchase history, cart abandonment data, wishlist items, and interaction with product recommendations. We collect this data to personalize your shopping experience, improve our recommendation systems, optimize platform functionality, analyze user preferences, conduct market research, and enhance our services.

Maintaining Stability and Security. In order to maintain the stability and security of Openow and your account, we will automatically collect data related to the operation of the mobile application and your online operations, such as data related to your login status, clicks and actions, user device data (e.g., IMEI and other device identifiers), operating system data, network information (e.g., IP address), etc. when you are using Openow.

Reviews and Ratings. We collect reviews, ratings, and feedback you provide about Items, Sellers, or your overall experience on our platform. This includes written reviews, star ratings, photos, and responses to Seller feedback. We collect this information to display public feedback on our platform and enhance overall platform experience.

Customer Support and Communication. When you contact our customer support or use communication features, we collect your inquiries, support tickets, chat messages, email correspondence, and any documentation you provide to help resolve issues. We collect this information to provide customer service, resolve technical issues, address complaints, improve our services, and maintain records.

Notifications and Alerts. To keep you informed of important activities on your account, such as order status updates, shipping notifications, security alerts, or policy changes, we may send push notifications or in-app messages. We automatically collect device-related data (e.g., device model, operating system version) to enable these alerts. These notifications are essential to platform functionality and cannot be disabled unless you stop using the service.

C. The Personal Data provided by third parties

Third-Party Login. To make it easier to use Openow, you may choose to register and login within Openow through your account on a third-party platform (e.g., Facebook, Google, Apple ID). In such cases, we may collect your nickname, profile photo, third-party account email and Open ID, age, location, and by logging in through these third-party accounts, you are consenting to the third-party providing us with the Personal Data concerned. We may also use the contact information (e.g., email address) provided by the third-party platforms to conduct user survey or to send marketing communications to you. Where required by applicable laws and regulations, we will obtain your consent before sending you marketing messages. If you are not interested in such information, you may refuse or opt out at any time.

Shipping and Logistics Partners. Our shipping partners provide us with delivery status updates, tracking information, address validation data, and delivery confirmation details to ensure successful order fulfillment.

If you provide us with any Personal Data of any data subjects other than yourself, please bring this Privacy Policy to their attention. You hereby acknowledge that you have obtained their consent or completed other formality as required by other lawful bases for the Personal Data processing in lieu of consent before providing such Personal Data to us. By submitting such information to us, you represent to us that you are entitled to provide and we are entitled to process the relevant Personal Data for the purposes as stated in the Privacy Policy.

In general, we will use your Personal Data only for the purposes described in this Privacy Policy or for purposes that we explain to you at the time we collect the relevant Personal Data. However, we may also process Personal Data for other purposes that are not incompatible with the purposes that we have disclosed to you if and where it is permitted by applicable laws and regulations. If we do so, we will inform you separately by other means to ensure transparency.

2. How do we use cookies and similar technologies

Like many online services, we use cookies and similar technologies to operate and provide our services and to improve user experience. Cookies are small text files that are stored on your device’s browser directory or program data subfolders when you use Openow. Cookies allow Openow to access or store information from your application about you, your settings or your device. They are mainly used to ensure Openow’s expected functionality.

As a rule, cookies do not contain any information that could identify you directly. They do, however, make it possible to offer you a more personalized user experience. If you do not accept these cookies, you may not be able to use all functions of Openow. For example, we use first-party cookies to save your login information for future logins to our service. Such cookies are strictly necessary for the normal operation of Openow. You can find out more about cookies on www.allaboutcookies.org.

3. How do we process minors’ Personal Data

Openow is not intended for use by individuals under the age of 18, except that users between the ages of 13 and 17 may use the platform only through an account set up by their parent or legal guardian and with that adults consent and supervision. We do not knowingly collect Personal Data from minors under the age of 13. If we become aware that Personal Data has been collected from a user under the age of 13, we will delete such data and terminate the account. If you believe that we may have collected Personal Data from a minor under the age of 13 in violation of this Privacy Policy, please contact us using the contact details provided in the How to contact us section below.

If you are a parent or legal guardian of a minor under the age of 18, please ensure that you have read this Privacy Policy and are responsible for your child's activities before allowing your child to use Openow. You are suggested to pay close attention to your child’s use of Openow and to ensure that your child only uses the age-appropriate functions.

We recognize that we have a special obligation to protect minors with respect to the collection and processing of Personal Data. We also strongly recommend that parents and guardians educate their children to never disclose or provide any Personal Data about them without your prior permission when using our services. If you have questions on how we process minors’ Personal Data, please contact us using the contact details provided in “How to contact us”.

4. How do we share and entrust the processing of your Personal Data

In order to provide you with better services, we may engage third parties (such as those who assist us in providing services related to Openow, e.g., cloud service providers) to process your Personal Data on our behalf. We will enter into strict confidentiality contractual terms with such third parties and require them to process Personal Data in accordance with our requirements, this Privacy Policy, and the confidentiality and security measures required by applicable laws and regulations.

We may share your Personal Data with third parties in the following circumstances:

  1. To provide you with a better user experience, we may share your Personal Data with our cooperation partners, such as sharing your behavioral data and profiling data with online advertising service providers. We may also use third-party SDKs such as Google Analytics, Firebase Analytics, Facebook Login SDK, AppsFlyer, and others to collect information about how users interact with our services. These SDKs may collect information including device identifiers, user account identifiers, app usage data, crash reports, push notification tokens, network information, and location data. We collect and share aggregated information with these partners for purposes including marketing, analytics, fraud prevention, and personalized service delivery tailored to specific regions or user groups. For more information about our use of SDKs, please contact us as set forth in “How to contact us.”
  2. In the event we use information such as user-generated content or transaction data on our platform as part of our advertising and marketing campaigns to promote our services, your Personal Data contained in such information may be disclosed to the recipients of such advertising or marketing content.
  3. In the event of any change, merger, acquisition, reorganization, or liquidation involving the transfer of Personal Data, we will ask the new company or organization handling your Personal Data to continue to process your Personal Data in accordance with this Privacy Policy. If the new company or organization handling your Personal Data needs to use your Personal Data for purposes not stated in this Privacy Policy, the new company or organization will obtain your consent, unless otherwise provided by the applicable laws and regulations.
  4. To relevant competent law enforcement body, regulatory, government agency, court or other third parties where we believe that such disclosure is to (i) comply with an applicable law or regulation; (ii) exercise, establish or defend our legal rights; or (iii) protect your vital interests or those of any other persons.

When third parties that act as data controllers are involved in processing your Personal Data, please refer directly to their privacy policies on their official websites or other platforms and learn more about their data processing practices.

5. How do we protect your Personal Data

We use appropriate technical and organizational measures to protect your Personal Data that we collect and process. The measures that we use are designed to provide a level of security appropriate to the risk of processing your Personal Data. In particular, access to Personal Data is strictly controlled and limited to authorized personnel on a need-to-know basis. Our data systems are configured to only allow access from whitelisted servers, reducing the risk of unauthorized intrusion.

Please be aware and understand that we cannot ensure an absolutely secure Internet. If you find that your Personal Data is breached, please contact us using the contact details provided in “How to contact us” immediately so that we can take the corresponding measures.

In the event of any accident, force majeure event or other circumstances leading to the breach of your Personal Data, we will make every effort to control the situation and promptly inform you of the cause, the security measures we have taken and you can take and other relevant information. In the event of a security incident related to Personal Data, we will report such incident to the competent authorities in accordance with the requirements of applicable laws and regulations, promptly investigate the problem, and take the emergency measures.

6. How do we store your Personal Data

  1. Cross-border Transfer
  2. We deploy local servers in the United States. For the need of our global operation and security management, your Personal Data may be transferred to and processed in several jurisdictions where our affiliated entities are based in, which may be different from the jurisdiction you locate. We will take necessary and appropriate safeguards to ensure the security of your Personal Data in transit and require that the recipient of your Personal Data offers an adequate level of protection and security in accordance with this Privacy Policy and applicable laws and regulations.

  3. Retention Period
  4. We will store your Personal Data to the extent as necessary for the proper business needs of our company (e.g., for the purposes of providing service to you and complying with the requirements of laws, tax and finance), except as provided otherwise by applicable laws or regulations. When there is no such need to use your Personal Data or the retention period expires according to applicable laws or regulations, we will delete or anonymize your Personal Data.

7. Your rights

We value the protection of your Personal Data. If you want to access, correct, or delete your Personal Data, or if you want to refuse marketing messages, file a complaint, withdraw consent, or exercise other rights under applicable laws and regulations, please do so as described below or contact us using the contact details provided in “How to contact us”.

  1. Access your Personal Data
  2. You can access some of your Personal Data through your account, order history, communication records, and Seller dashboard (if applicable).

  3. Correct your Personal Data
  4. In some cases, we may provide self-service tools that enable you to update your personal information. For example, you can change some of your Personal Data through in-app controls and settings (such as your account information you directly provide to us). For data that cannot be self-corrected, contact us for assistance.

  5. Delete your Personal Data
  6. You have the right to request us to delete your Personal Data, including your Openow account and related Personal Data. You can do this by deleting your account via “Profile-Setting-Delete Account”. Please note that after you submit a request to delete your account, you will no longer be able to use Openow, so please decide carefully. In addition, we will also voluntarily delete your Personal Data after the expiration of the retention period of the Personal Data when the purposes of processing in the first part of this Privacy Policy no longer exist.

    If we terminate our services or operations, we will notify you at least thirty (30) days in advance and will delete or anonymize your Personal Data after termination of services or operations.

  7. Right to opt-out marketing
  8. You can exercise this right by clicking on the “unsubscribe” or “opt-out” option (or other similar option or link) in the marketing messages we send you.

  9. Right to file a complaint
  10. You have the right to file a complaint with the data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority. Before you file a complaint, we also sincerely hope that you will first provide us with your comments and we will endeavor to answer your questions and protect your rights.

  11. Right to withdraw consent
  12. If we process your Personal Data based on your consent, you may withdraw your consent at any time. Please note that withdrawal of your consent will not affect the lawfulness of any processing we have carried out prior to your withdrawal of consent, nor will it affect the lawfulness of our processing of your Personal Data based on a lawful basis other than your consent.

  13. Other rights under applicable laws and regulations
  14. If you want to exercise your other statutory data subject rights under applicable laws and regulations, you may contact us using the contact details provided in the “How to contact us” section below.

  15. Identity verification and responding to your requests
  16. In order to protect the security of your information, we may need to verify your identity before responding to your requests to exercise your rights, for example, by requiring you to provide the account, screenshot of your profile and other identity-related supporting information. We will respond to your request to exercise your data subject rights in accordance with the requirements under applicable laws and regulations and in a timely manner.

8. Special notice to California residents

If you are a California resident, this section provides a special notice and applies to you. For California residents, Personal Data in this section is equivalent to “Personal Information” that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

California Shine the Light Law: California residents may request a list of all third parties to which we have disclosed certain Personal Data about you for marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information by contacting us using the contact details provided in the “How to contact us” section below. Please allow up to thirty (30) days for a response.

California Minors: If you are a California resident under the age of 18 and you are unable to remove publicly-available information that you have submitted to Openow, you may request removal by contacting Openow using the contact details provided in the “How to contact us” section below. When requesting removal, you must be specific about the information you want to be removed and provide Openow with specific information, such as the URL for each page where the information is located, so that we can find it. Openow is not required to remove any information where: (i) federal or state law requires us or a third party to maintain the information; (ii) the information was not posted by you; (iii) the information has been anonymized by Openow so that you cannot be identified from such information; (iv) you don't follow our instructions for removing or requesting removal; or (v) you received compensation or other consideration for providing the information. Removal of your information from the services does not ensure complete or comprehensive removal of that information from our systems or the systems of our service providers. In addition, materials that you have posted may be republished or reposted by another user or third party. Please note, Openow is not required to destroy the information; Openow’s obligations under California law are satisfied so long as we anonymize the information or render it invisible to other users and the public.

Do Not Sell My Personal Data: Where applicable, the California Consumer Privacy Act and its amendments (“CCPA”) provides you with the right to opt out of the “sale” of your Personal Data. We generally do not directly sell your Personal Data in the conventional sense (i.e., for monetary or other valuable consideration). Like many online marketplace mobile applications, however, we use services that help deliver interest-based ads to you and may transfer Personal Data to business partners for their use. Making Personal Data (such as online identifiers or browsing activity) available to these companies may be considered a “sale” under the CCPA. To request that Openow may not “sell” your Personal Data, please contact us using the contact details provided in the “How to contact us” section below. Please note, some transfers of your Personal Data may not be considered “sales” and certain exemptions may apply under the CCPA, such as sharing aggregated demographic and interest data of users. Your selection does not affect other sharing of your data, as outlined in this Privacy Policy. You may still see some advertising, regardless of your selection.

Do Not Track: At this time, we are not aware of worldwide uniform or consistent industry standard or definition for responding to, processing, or communicating Do Not Track signals. Accordingly, our services may be unable to respond to “Do Not Track” requests from browsers. In addition, when you use our services, we and third parties may use tracking technologies to collect your Personal Data about your online activities for a variety of purposes, including serving you advertising and personalized content. If you want to opt out of having your online activity and device data collected by third parties, there are a number of tools and methods that any user may use. For example, your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes. Please note that using these tools to opt out of tracking and targeting does not mean that you will not receive advertising while using Openow, nor will it prevent the receipt of interest-based advertising from third parties. It will exclude you, however, from interest-based advertising conducted through relevant networks and platforms, as provided by their policies and choice mechanisms.

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable laws and regulations, we may charge a reasonable fee to comply with your request.

9. How do we update this Privacy Policy

We may update this Privacy Policy from time to time in response to the changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, depending on the significance of the changes we make. You can see when this Privacy Policy came into effect by checking the “Effective Date” or Last updated date displayed at the top of this Privacy Policy. If you continue to use any functions of Openow, you are deemed to have read and understood the updated version of the Privacy Policy.

10. Governing law and dispute solution

This Privacy Policy is governed by the internal substantive laws of Singapore, without respect to its conflict of law provisions. Any dispute arising out of or in connection with the Agreement, including any question regarding existence, validity or termination of the Agreement, shall be referred to and finally resolved by arbitration administered by Singapore International Arbitration Centre (“SIAC”) in accordance with the Arbitration Rules of SIAC (“SIAC Rules”) for the time being in force, which rules are deemed to be incorporated by reference in this clause. The seat of the arbitration shall be Singapore. The Tribunal shall consist of three (3) arbitrators. The language of the arbitration shall be English.

11. How to contact us

If you have any questions or concerns about this Privacy Policy or our processing of your Personal Data, especially if you consider that our processing your Personal Data impairs your legitimate interests, please contact us using the contact details below. We will review your question without delay and make a timely reply according to the applicable laws and regulations. Our contact details are as follows:

Company Name: Skywork AI Pte. Ltd.
Address: 2 Science Park Drive, #01-08, Ascent, Singapore 118222
Email: contact@openow.com