Privacy Policy
Version 1.0 · Effective October 4, 2026
1. INTRODUCTION
1.1 About this Privacy Policy
This Privacy Policy explains how COMNBUY PTE. LTD. ("Com&Buy", "we", "our", or "us") collects, uses, discloses, stores, transfers, retains, protects, and otherwise processes your Personal Data when you access or use the Platform or any Services provided by Com&Buy.
This Privacy Policy applies to all Personal Data collected through our website, customer portal, mobile applications (where available), customer support channels, warehouses, payment systems, and any other products or Services operated by Com&Buy.
Com&Buy is committed to protecting your Personal Data and handling it responsibly in accordance with applicable data protection laws, including the Personal Data Protection Act 2012 of Singapore ("PDPA") and, where applicable, other relevant privacy and data protection laws.
By accessing or using the Platform or any Services, creating a Customer Account, or otherwise providing your Personal Data to Com&Buy, you acknowledge that you have read and understood this Privacy Policy.
2. APPLICATION OF THIS PRIVACY POLICY
2.1 Application
This Privacy Policy applies to all Personal Data collected, used, disclosed, stored, transferred, retained, or otherwise processed by Com&Buy in connection with the Platform and the Services.
Without limitation, this includes Personal Data collected through:
the Platform;
Customer Accounts;
Buy For Me Services;
Ship For Me Services;
Deliver For Me Services;
Runner For Me Services;
Ask Seller Services;
warehouse operations;
shipment arrangements;
payment processing;
Wallet services;
Customer Support;
email, live chat, WhatsApp, contact forms, and other communication channels;
surveys, promotions, marketing activities; and
any other products or Services provided by Com&Buy from time to time.
This Privacy Policy applies regardless of whether the Personal Data is collected directly from you or through a Third-Party Provider in connection with the Services.
3. DEFINITIONS
Unless the context otherwise requires, the following terms have the meanings set out below.
“Com&Buy” means COMNBUY PTE. LTD.
“Customer” means any individual, business, organisation, or other legal entity that accesses or uses the Platform or any Services provided by Com&Buy.
“Customer Account” means a registered account created by a Customer to access and use the Services.
“Personal Data” means any data, whether true or not, about an individual who can be identified from that data or from that data together with other information to which Com&Buy has or is likely to have access, or any equivalent definition under applicable data protection laws.
“Platform” means the Com&Buy website, mobile applications, customer portal, systems, software, digital interfaces, and any other platform operated by Com&Buy.
“Processing” means any operation performed on Personal Data, whether by automated or non-automated means, including collecting, recording, organising, storing, adapting, retrieving, using, disclosing, transmitting, transferring, analysing, combining, restricting, deleting, destroying, or otherwise handling Personal Data.
“Services” means all services provided by Com&Buy, including Buy For Me Services, Ship For Me Services, Deliver For Me Services, Runner For Me Services, Ask Seller Services, warehouse services, logistics services, payment services, and any other products or services offered by Com&Buy from time to time.
“Third-Party Provider” means any person or entity other than Com&Buy that provides goods, payment services, logistics services, warehousing services, technology services, verification services, insurance services, or any other services in connection with the Platform or the Services.
4. PERSONAL DATA WE COLLECT
Depending on the Platform, Services, and features you use, Com&Buy may collect the following categories of Personal Data.
4.1 Customer Account Information
This may include:
Full name;
Username;
Email address;
Mobile number;
Date of birth (where required);
Password and authentication information;
Preferred language;
Country or region;
Account preferences; and
Other information required to create or manage your Customer Account.
4.2 Identity Verification Information
Where required for legal, regulatory, customs, payment, fraud prevention, insurance, or compliance purposes, we may collect:
Government-issued identification;
Passport;
National identity card;
Driving licence;
Company registration documents;
Tax identification information;
Import or export permits;
Authorisation letters; and
Other supporting verification or compliance documents.
4.3 Order and Shipment Information
Depending on the Services requested, we may collect:
Sender and recipient information;
Billing and delivery addresses;
Contact details;
Warehouse selection;
Shipment preferences;
Customs declarations;
HS Codes (where applicable);
Parcel descriptions;
Declared values;
Parcel dimensions;
Parcel weight;
Tracking numbers;
Shipping methods;
Delivery instructions; and
Other shipment-related information.
4.4 Buy For Me Information
Where you use Buy For Me Services, we may collect:
Product links;
Product descriptions;
Product specifications;
Colours, sizes, and variations;
Seller or marketplace information;
Purchase instructions;
Budget limits;
Reserve amounts;
Preferred alternatives;
Purchase authorisations;
Special handling requests; and
Notes provided by you.
4.5 Payment Information
Depending on your selected payment method, we may collect:
Payment amounts;
Currency;
Payment method;
Payment gateway transaction references;
Wallet transactions;
Refund records;
Withdrawal records;
Payment timestamps; and
Billing records.
Com&Buy does not store complete payment card details. Card payments are processed by authorised third-party payment service providers.
4.6 Warehouse and Operational Information
To provide warehouse and logistics services, we may collect:
Arrival scans;
Barcode scans;
Warehouse locations;
Shelf locations;
Packing records;
Shipment records;
Parcel photographs;
Packaging photographs;
Measurement records;
Weight records;
Dispatch records; and
Delivery records.
4.7 Communications
Where you communicate with Com&Buy, we may collect:
Email correspondence;
Live chat messages;
WhatsApp conversations;
Customer support tickets;
Contact form submissions;
Telephone records (where applicable);
Complaint records;
Dispute communications; and
Internal case notes relating to your enquiries.
4.8 Technical Information
When you access the Platform, we may automatically collect:
IP address;
Browser type;
Operating system;
Device information;
Language settings;
Session identifiers;
Login activity;
Approximate location;
Referral source;
Cookies; and
Analytics information.
4.9 Operational and Evidence Records
To protect Customers and Com&Buy, we may create and retain operational and evidence records, including:
Order history;
Shipment history;
Payment records;
Warehouse records;
Delivery records;
Customer communications;
Checkout confirmations;
Policy acceptance records;
Audit logs;
System activity records;
Device information;
IP addresses;
Session logs; and
Other records reasonably required for fraud prevention, security, dispute resolution, insurance claims, legal proceedings, regulatory compliance, or operational management.
4.10 Information You Choose to Provide
You may voluntarily provide additional Personal Data when submitting feedback, reviews, survey responses, testimonials, special requests, customer support enquiries, or any other information you choose to provide to Com&Buy.
5. HOW WE COLLECT PERSONAL DATA
We may collect Personal Data through various methods depending on how you interact with the Platform or use the Services.
5.1 Information You Provide
We may collect Personal Data directly from you when you:
create, register, maintain, or update a Customer Account;
submit Orders, Service Requests, or other instructions through the Platform;
use Buy For Me Services, Ship For Me Services, Deliver For Me Services, Runner For Me Services, Ask Seller Services, or any other Services;
make payments, Wallet Top-Ups, refund requests, or withdrawal requests;
upload documents, photographs, or other supporting information;
contact Customer Support;
participate in surveys, promotions, competitions, or marketing activities;
subscribe to newsletters or marketing communications; or
communicate with us through email, live chat, WhatsApp, telephone, social media, contact forms, or any other communication channel.
5.2 Information Generated Through Your Use of the Services
When you access the Platform or use the Services, we may automatically generate or collect operational information, including:
Customer Account activity;
Order history;
Shipment history;
Warehouse activities;
payment and Wallet transaction records;
shipment tracking information;
Customer Support interactions;
audit logs;
fraud prevention records;
security monitoring information; and
other operational records generated through your use of the Platform or the Services.
5.3 Information from Third-Party Providers
We may receive Personal Data from Third-Party Providers where reasonably necessary to provide the Services, including:
sellers and marketplaces;
shipping carriers;
logistics providers;
warehouse operators;
customs brokers;
payment service providers;
financial institutions;
identity verification providers;
fraud prevention providers;
insurers;
government authorities;
business partners; and
publicly available sources where permitted by applicable law.
5.4 Information Collected Automatically
When you access or use the Platform, we and our authorised service providers may automatically collect certain technical and usage information through cookies, analytics tools, security technologies, and similar technologies.
Such information may include:
IP address;
browser type;
operating system;
device information;
language settings;
login activity;
session identifiers;
approximate location;
referral source;
cookies;
analytics information; and
other technical information reasonably required to operate, secure, improve, and support the Platform and the Services.
6. HOW WE USE PERSONAL DATA
We use Personal Data only where reasonably necessary to provide the Platform and the Services, comply with applicable laws, protect legitimate business interests, safeguard Customers and the Platform, or where you have provided consent.
6.1 Providing the Services
We may use Personal Data to:
create, manage, and maintain Customer Accounts;
process Orders and Service Requests;
purchase Goods on your behalf;
provide Buy For Me Services, Ship For Me Services, Deliver For Me Services, Runner For Me Services, Ask Seller Services, and other Services;
arrange warehouse operations;
consolidate, pack, repack, store, and dispatch Goods;
arrange shipment and delivery;
process refunds, Wallet transactions, and withdrawals; and
communicate with you regarding the Services.
6.2 Payment Processing
We may use Personal Data to:
process payments;
manage Wallet balances;
process refunds and withdrawals;
verify payment transactions;
detect payment fraud;
manage chargebacks and payment disputes;
maintain accounting and financial records; and
comply with financial, taxation, and regulatory obligations.
6.3 Customer Support
We may use Personal Data to:
respond to enquiries;
provide Customer Support;
investigate complaints;
resolve disputes;
provide technical assistance;
follow up on requests; and
improve customer service.
6.4 Warehouse and Operational Management
We may use Personal Data to:
receive and identify Goods;
manage warehouse operations;
perform Parcel Checks & Photos;
generate packing and shipment records;
coordinate shipment arrangements;
maintain operational records;
improve operational efficiency; and
support quality assurance.
6.5 Fraud Prevention and Security
We may use Personal Data to:
verify identities;
detect and prevent fraud;
investigate suspicious activities;
prevent unauthorised access;
protect Customer Accounts;
detect policy abuse;
investigate chargebacks;
protect the Platform and the Services; and
enforce our Terms and other policies.
6.6 Legal and Regulatory Compliance
We may use Personal Data to:
comply with applicable laws and regulations;
comply with customs, export, import, and sanctions requirements;
verify Restricted Goods where required;
conduct identity verification where reasonably necessary;
cooperate with government authorities, regulators, courts, or law enforcement agencies; and
establish, exercise, or defend legal claims.
6.7 Service Improvement
We may use Personal Data to:
analyse how the Platform and the Services are used;
improve operational efficiency;
enhance customer experience;
improve fraud detection;
develop new features, products, and Services; and
perform internal reporting, research, analytics, and business planning.
Where reasonably practicable, we will use anonymised, aggregated, or de-identified information for analytical and statistical purposes.
7. LEGAL BASIS FOR PROCESSING
Com&Buy processes Personal Data only where permitted by applicable law. Depending on the circumstances, we may process Personal Data on one or more of the following legal grounds.
7.1 Consent
Where required by applicable law, we may process Personal Data with your consent. You may withdraw your consent at any time, subject to any legal, contractual, or operational restrictions and reasonable notice.
7.2 Performance of a Contract
We may process Personal Data where it is necessary to provide the Platform, perform the Services, fulfil our contractual obligations, or take steps requested by you before providing the Services.
7.3 Compliance with Legal Obligations
We may process Personal Data where necessary to comply with applicable laws, regulations, court orders, governmental requests, customs requirements, taxation obligations, or other legal or regulatory requirements.
7.4 Legitimate Business Interests
Where permitted by applicable law, we may process Personal Data where reasonably necessary for our legitimate business interests, provided such interests are not overridden by your legal rights and interests.
These legitimate interests may include:
operating and improving the Platform and the Services;
protecting the security and integrity of the Platform;
preventing fraud, abuse, unauthorised access, and other unlawful activities;
managing operational, financial, and business risks;
conducting internal reporting, analytics, and business planning;
protecting the rights, property, and interests of Com&Buy, our Customers, and Third-Party Providers; and
establishing, exercising, or defending legal claims.
7.5 Other Lawful Bases
Where permitted or required by applicable law, we may also process Personal Data to:
protect the vital interests of any individual;
protect public health or public safety;
establish, exercise, or defend legal rights;
respond to lawful requests from government authorities or regulatory bodies; or
satisfy any other lawful basis recognised under applicable data protection laws.
8. DISCLOSURE OF PERSONAL DATA
We do not sell your Personal Data.
We may disclose Personal Data only where reasonably necessary to provide the Platform and the Services, comply with applicable laws, protect legitimate business interests, or where otherwise permitted or required by law.
8.1 Third-Party Providers
We may disclose Personal Data to Third-Party Providers involved in providing the Platform or the Services, including:
sellers and marketplaces;
shipping carriers;
logistics providers;
warehouse operators;
customs brokers;
payment service providers;
financial institutions;
insurers;
identity verification providers;
fraud prevention providers;
technology providers;
cloud hosting providers;
email and messaging service providers;
customer support service providers; and
other service providers reasonably required to support the Platform or the Services.
8.2 Professional Advisers
Where reasonably necessary, we may disclose Personal Data to our:
legal advisers;
accountants;
auditors;
insurers;
consultants; and
other professional advisers.
8.3 Regulatory and Legal Disclosure
We may disclose Personal Data where reasonably necessary to:
comply with applicable laws or regulations;
comply with court orders or lawful requests;
cooperate with government authorities, regulators, customs authorities, or law enforcement agencies;
establish, exercise, or defend legal claims; or
protect the rights, property, safety, or legitimate interests of Com&Buy, our Customers, Third-Party Providers, or the public.
8.4 Corporate Transactions
Where reasonably necessary in connection with a merger, acquisition, investment, restructuring, business transfer, asset sale, financing transaction, or similar corporate transaction, Personal Data may be disclosed to prospective or actual purchasers, investors, financiers, advisers, or other relevant parties, subject to appropriate confidentiality obligations where reasonably practicable.
8.5 Minimum Necessary Disclosure
Com&Buy will take reasonable steps to disclose only the Personal Data reasonably necessary for the relevant purpose and, where appropriate, require recipients to protect the Personal Data in accordance with applicable legal or contractual requirements.
9. INTERNATIONAL TRANSFERS
As Com&Buy provides international purchasing, warehousing, logistics, and shipment services, your Personal Data may be transferred to, stored in, accessed from, or otherwise processed in countries outside Singapore.
Such transfers may occur where reasonably necessary to:
provide the Platform or the Services;
purchase Goods on your behalf;
arrange domestic or international shipments;
coordinate warehouse operations;
complete customs declarations or regulatory requirements;
process payments, refunds, or withdrawals;
provide Customer Support; or
otherwise perform the Services requested by you.
Where Personal Data is transferred outside Singapore, Com&Buy will take reasonable steps to ensure that the Personal Data continues to receive a standard of protection that is comparable to that required under applicable data protection laws.
10. PAYMENT PROCESSING
Payments made through the Platform are processed by authorised Third-Party Providers.
Depending on your selected payment method, payment information may be processed by payment gateways, banks, financial institutions, digital payment providers, or other authorised payment service providers.
Com&Buy does not store complete payment card details. Payment card information is processed and managed by the relevant authorised payment service provider in accordance with its own privacy policies, security standards, and applicable legal requirements.
Com&Buy may retain payment-related records, including transaction references, payment amounts, currencies, Wallet transactions, refund records, withdrawal records, and other information reasonably necessary for accounting, fraud prevention, dispute resolution, legal compliance, and the provision of the Services.
11. WAREHOUSE AND OPERATIONAL RECORDS
To provide the Platform and the Services, Com&Buy creates and maintains operational records relating to warehouse operations, shipment processing, and related logistics activities.
Depending on the Services used, such records may include:
arrival scans;
barcode scans;
tracking numbers;
warehouse locations;
shelf locations;
parcel photographs;
Parcel Checks & Photos;
packaging photographs;
measurement records;
weight records;
packing records;
dispatch records;
delivery records;
shipment history; and
other operational records reasonably required to provide the Services.
These records may be used for:
providing the Services;
warehouse operations;
shipment processing;
quality assurance;
operational management;
fraud prevention;
dispute resolution;
insurance and Parcel Protection claims;
Customer Support;
legal compliance; and
maintaining the security and integrity of the Platform and the Services.
12. COMMUNICATIONS AND CUSTOMER SUPPORT
Where you communicate with Com&Buy, we may collect, retain, and process records of those communications.
Such communications may include:
email correspondence;
live chat conversations;
WhatsApp messages;
telephone calls (where applicable);
contact form submissions;
Customer Support tickets;
social media communications; and
any other communications between you and Com&Buy.
We may use and retain such communications for purposes including:
providing Customer Support;
responding to enquiries;
processing Orders and Service Requests;
verifying instructions;
resolving complaints and disputes;
improving customer service;
quality assurance;
staff training;
fraud prevention;
legal compliance; and
establishing, exercising, or defending legal claims.
Where permitted by applicable law, communications may be monitored or recorded for the purposes described in this Privacy Policy.
13. MARKETING COMMUNICATIONS
Where permitted by applicable law, Com&Buy may send you marketing communications relating to the Platform, the Services, promotions, campaigns, new features, product updates, special offers, newsletters, surveys, or other marketing activities.
Where required by applicable law, we will obtain your consent before sending marketing communications.
You may withdraw your consent or unsubscribe from marketing communications at any time by following the unsubscribe instructions provided in the communication or by contacting Com&Buy.
Withdrawal of consent or unsubscribing from marketing communications does not affect our ability to send non-marketing communications that are reasonably necessary to provide the Platform or the Services.
Such non-marketing communications may include:
Customer Account notifications;
security alerts;
payment confirmations;
Order confirmations;
shipment updates;
Customer Support responses;
legal notices;
policy updates; and
other operational or administrative communications reasonably required to provide the Platform or the Services.
14. COOKIES AND SIMILAR TECHNOLOGIES
Com&Buy uses cookies and similar technologies to operate the Platform, improve your browsing experience, maintain security, analyse usage, and support the provision of the Services.
Cookies are small data files stored on your device when you access or use the Platform. Similar technologies may include web beacons, pixels, local storage, software development kits (SDKs), and other technologies that perform similar functions.
We may use cookies and similar technologies to:
maintain login sessions;
remember your preferences and settings;
improve the functionality and performance of the Platform;
analyse website traffic and usage patterns;
measure the effectiveness of our Services and marketing activities;
detect and prevent fraud or unauthorised access;
protect Customer Accounts; and
improve the Platform and the Services.
Some cookies may be provided by authorised Third-Party Providers that support the operation of the Platform, including analytics, security, payment, customer support, or other service providers.
Most web browsers allow you to control, block, or delete cookies through your browser settings. Disabling certain cookies may affect the functionality, availability, or performance of parts of the Platform or the Services.
15. DATA RETENTION
Com&Buy retains Personal Data only for as long as reasonably necessary to fulfil the purposes described in this Privacy Policy, provide the Platform and the Services, comply with applicable laws, resolve disputes, enforce our legal rights, or protect the legitimate interests of Com&Buy, our Customers, and Third-Party Providers.
Depending on the nature of the Personal Data and the purpose for which it was collected, we may retain information relating to:
Customer Accounts;
Orders and Service Requests;
shipment and warehouse records;
payment and Wallet transactions;
Customer Support records;
communications;
customs and regulatory documentation;
accounting and taxation records;
fraud prevention and security records;
Parcel Protection and insurance claims;
chargeback investigations;
legal proceedings; and
any other records reasonably required for operational, legal, regulatory, or business purposes.
Where Personal Data is no longer reasonably required, we will take reasonable steps to securely delete, anonymise, or otherwise dispose of the Personal Data in accordance with applicable laws and our internal retention practices.
16. SECURITY
Com&Buy takes reasonable administrative, technical, and physical measures to protect Personal Data against unauthorised access, collection, use, disclosure, copying, modification, disposal, loss, misuse, or other similar risks.
Such measures may include:
access controls;
authentication and authorisation procedures;
encryption of sensitive information where appropriate;
secure communication protocols;
system monitoring and logging;
fraud detection measures;
network and infrastructure security;
backup and recovery procedures;
staff training and confidentiality obligations; and
other security measures reasonably appropriate to the nature of the Personal Data.
While Com&Buy takes reasonable steps to protect Personal Data, no method of electronic transmission, storage, or processing can be guaranteed to be completely secure. Accordingly, Com&Buy cannot guarantee the absolute security of any Personal Data.
Customers are responsible for maintaining the confidentiality of their Customer Account credentials, using strong passwords, protecting access to their devices, and promptly notifying Com&Buy of any suspected unauthorised access or security incident affecting their Customer Account.
17. YOUR RIGHTS
Subject to applicable law, you may have certain rights in relation to your Personal Data.
Depending on the circumstances and the applicable data protection laws, you may have the right to:
request access to your Personal Data;
request correction of inaccurate or incomplete Personal Data;
withdraw consent where processing is based on consent;
request the deletion of Personal Data where permitted by applicable law;
request the restriction of certain processing activities where permitted by applicable law;
object to certain processing activities where permitted by applicable law;
request the transfer or portability of Personal Data where applicable; and
make enquiries or complaints regarding Com&Buy's handling of your Personal Data.
Com&Buy may require reasonable verification of your identity before processing any request relating to your Personal Data.
Certain rights may be limited or unavailable where Com&Buy is required or permitted by applicable law to retain, process, or refuse disclosure of Personal Data, including for legal, regulatory, operational, fraud prevention, dispute resolution, or security purposes.
Where permitted by applicable law, Com&Buy may decline any request that is manifestly unfounded, excessive, repetitive, or otherwise not required to be fulfilled under applicable law.
18. CHILDREN AND MINORS
The Platform and Services are not directed at children. You must meet the minimum age required under applicable law to create a Customer Account or use the Services independently.
Where required by applicable law, a parent, legal guardian, or other authorised person must provide any necessary consent for the collection and processing of a minor's Personal Data.
If we become aware that Personal Data relating to a child has been collected in circumstances where the required consent or other lawful basis has not been obtained, we may take reasonable steps to delete or otherwise appropriately handle such Personal Data in accordance with applicable law.
19. THIRD-PARTY WEBSITES AND SERVICES
The Platform or the Services may contain links to, integrate with, or otherwise interact with websites, applications, marketplaces, payment providers, logistics providers, social media platforms, or other services operated by Third-Party Providers.
Com&Buy does not own, operate, or control such Third-Party Providers and is not responsible for their privacy practices, security measures, content, availability, or the manner in which they collect, use, disclose, or otherwise process Personal Data.
Your use of any Third-Party Provider is subject to that provider's own terms, privacy policy, and applicable practices. We encourage you to review those policies before providing any Personal Data to a Third-Party Provider.
20. CHANGES TO THIS PRIVACY POLICY
Com&Buy may amend this Privacy Policy from time to time to reflect changes to the Platform, the Services, applicable laws, operational requirements, technology, security practices, or our business operations.
The latest version of this Privacy Policy will be published on the Platform together with its effective date.
Where required by applicable law, Com&Buy will provide notice of any material changes through the Platform, email, or any other communication method reasonably considered appropriate.
Your continued access to or use of the Platform or the Services after the effective date of the revised Privacy Policy constitutes your acknowledgement of the updated Privacy Policy, to the extent permitted by applicable law.
21. CONTACT US
If you have any questions, requests, complaints, or concerns regarding this Privacy Policy or Com&Buy's handling of your Personal Data, please contact our Data Protection Officer or designated privacy contact using the contact details published on the Platform.
Com&Buy may require reasonable verification of your identity before responding to any request relating to your Personal Data.
Where required by applicable law, we will respond to your request within a reasonable period or within any timeframe prescribed by applicable law.
22. GOVERNING LAW
This Privacy Policy shall be governed by and construed in accordance with the laws of Singapore.
Nothing in this Privacy Policy limits or excludes any rights or protections that cannot lawfully be excluded under applicable data protection laws.
23. LANGUAGE
This Privacy Policy is provided in English. Any translation, summary, or explanation provided in another language is for convenience only. In the event of any inconsistency, discrepancy, or ambiguity, the English version shall prevail, to the extent permitted by applicable law.