PRIVACY POLICY

mark8place.com

Effective Date: December 12, 2025 | Last Updated: December 12, 2025

1. INTRODUCTION

Lions Agentix Pte. Ltd. ("Company," "we," "us," or "our"), operating the mark8place.com platform (the "Platform"), is committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Platform.

We are incorporated in Singapore and maintain our principal place of business at 10 Marina Boulevard, Singapore 018983. As a global marketplace, we comply with applicable data protection laws including:

This Privacy Policy explains the legal bases for our data processing activities in Section 4. We process your personal data based on different legal grounds depending on the purpose, including contract performance, legal obligations, legitimate interests, and where applicable, your consent for specific activities. Throughout this Privacy Policy, we use the term "personal data" (as used in GDPR and UK GDPR), which also encompasses "personal information" as defined under the California Consumer Privacy Act (CCPA/CPRA) and similar terms used in other jurisdictions.

1A. DEFINITIONS

The following terms have the meanings set forth below. Capitalized terms not defined here have the meanings given in our Terms of Service (available at mark8place.com/terms).

2. DATA CONTROLLER INFORMATION

For the purposes of applicable data protection laws, Lions Agentix Pte. Ltd. is the data controller responsible for your personal data. Our Data Protection Officer can be contacted at:

Data Protection Officer

Lions Agentix Pte. Ltd.

10 Marina Boulevard, Singapore 018983

Email: privacy@mark8place.com

2.1 EU Representative (GDPR Article 27)

We are established in Singapore and are currently focused on serving users in the Asia-Pacific region. As of the effective date of this Privacy Policy, we have not yet appointed an EU Representative under Article 27 of the General Data Protection Regulation.

Commitment to Comply: Within 30 days of our first user (whether Buyer or Vendor) from the European Union registering on the Platform, we will appoint an EU Representative and update this section with their name, address, and contact details. The representative will be established in an EU Member State and authorised to act on our behalf regarding GDPR compliance matters, including receiving communications from EU supervisory authorities and data subjects exercising their rights.

In the interim, EU residents with data protection inquiries may contact our Data Protection Officer at privacy@mark8place.com.

2.2 UK Representative (UK GDPR Article 27)

We are established in Singapore and are currently focused on serving users in the Asia-Pacific region. As of the effective date of this Privacy Policy, we have not yet appointed a UK Representative under Article 27 of the UK GDPR.

Commitment to Comply: Within 30 days of our first user (whether Buyer or Vendor) from the United Kingdom registering on the Platform, we will appoint a UK Representative and update this section with their name, address, and contact details. The representative will be established in the United Kingdom and authorised to act on our behalf regarding UK GDPR compliance matters, including receiving communications from the Information Commissioner's Office (ICO) and UK data subjects exercising their rights.

In the interim, UK residents with data protection inquiries may contact our Data Protection Officer at privacy@mark8place.com.

3. INFORMATION WE COLLECT

3.1 Information You Provide Directly

Account Registration Information:

Vendor/Seller Verification Information (for KYC/KYBC compliance):

Transaction Information:

User-Generated Content:

3.2 Information Collected Automatically

Device and Technical Information:

Usage Information:

3.3 Information from Third Parties

3.4 Social Login Data

If you register or sign in using a social login provider, we receive the following data:

To disconnect a social login:

We do not receive your social media password or post to your social accounts without explicit permission.

3.5 Biometric Data (Identity Verification)

For Vendor identity verification (KYC) and certain high-value Buyer transactions, our identity verification partners may process biometric data:

Important disclosures:

Illinois Residents (BIPA Notice): Under the Illinois Biometric Information Privacy Act, you have specific rights regarding biometric data. We will not sell, lease, trade, or profit from your biometric data. Contact privacy@mark8place.com for a written copy of our biometric data retention and destruction policy.

3.6 Affiliate Program Data

If you participate in the Mark8place Affiliate Program, we collect and process the following additional information:

Affiliate Account Information:

Referral Tracking and Performance Data:

Data Shared with Affiliates: To protect user privacy, affiliates receive only limited information about their referrals: (a) whether a referral resulted in a successful registration or purchase (conversion status); (b) the commission amount earned; and (c) aggregated performance statistics. Affiliates do not receive personal details of referred users such as names, email addresses, or specific purchase information.

Retention: Affiliate performance data and commission records are retained for 7 years after the affiliate relationship ends for tax and audit purposes. Referral tracking cookies expire according to their specified duration (displayed in Section 9).

4. HOW WE USE YOUR INFORMATION

4.1 Legal Bases for Processing

Purpose

Legal Basis (GDPR/PDPA)

Account creation and management

Contract performance; Consent

Processing transactions

Contract performance

Identity verification (KYC/KYBC)

Legal obligation; Contract performance

DSA/INFORM Act compliance

Legal obligation

Product safety (GPSR compliance)

Legal obligation; Legitimate interest

Customer support

Contract performance; Legitimate interest

Fraud prevention and security

Legitimate interest; Legal obligation

Marketing communications

Consent; Legitimate interest

Platform improvement and analytics

Legitimate interest

Transparency reporting (DSA)

Legal obligation

4.2 Specific Uses

5. HOW WE SHARE YOUR INFORMATION

5.1 With Other Platform Users

To facilitate Transactions, we share certain information between Buyers and Vendors, including name, contact details (as necessary for delivery), and relevant Transaction details.

5.1a Vendors as Independent Data Controllers

When you purchase from a Vendor on our Platform, that Vendor receives your personal data (name, delivery address, contact information, order details) and becomes an independent data controller for that data. This means:

We require Vendors to agree to data protection obligations in our Terms of Service, but we cannot guarantee Vendor compliance. If you have concerns about a Vendor's data practices, contact the Vendor directly or report the issue to support@mark8place.com.

5.1b Joint Controller Arrangements

For certain processing activities, we and Vendors act as joint controllers under GDPR Article 26. These include:

For joint controller activities, we serve as the primary contact point for data subject requests. Contact privacy@mark8place.com to exercise your rights regarding jointly controlled data.

5.2 Public Disclosure of Seller Information

In compliance with regulatory requirements (EU DSA and US INFORM Consumers Act), we publicly display certain Vendor information:

5.3 With Service Providers (Subprocessors)

We share information with trusted third-party service providers who process data on our behalf under Data Processing Agreements:

All subprocessors are bound by Data Processing Agreements that require them to process data only as instructed, implement appropriate security measures, and comply with applicable data protection laws. A complete list of current subprocessors is available upon request at privacy@mark8place.com.

5.4 With Regulatory Authorities

We may share information with regulatory authorities as required by law, including:

5.5 DSA Transparency Database

Under the EU Digital Services Act, we submit statements of reasons for content moderation decisions to the DSA Transparency Database. These statements do not include personal data that would directly identify individual users but may include information about the type of content removed or actions taken.

5.6 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will provide notice of any such transfer.

5.7 What We Do Not Share

We do not sell your personal data to third parties. We do not share your information with third parties for their direct marketing purposes without your explicit consent.

6. INTERNATIONAL DATA TRANSFERS

As a global marketplace headquartered in Singapore, your personal data may be transferred to, stored, and processed in countries other than your country of residence, including Singapore, the United States, the European Union, and other countries where our service providers operate.

6.1 Transfer Mechanisms by Jurisdiction

EU/EEA Transfers:

UK Transfers:

Singapore Transfers:

6.2 Supplementary Measures (Post-Schrems II)

Following the CJEU Schrems II decision, we implement supplementary technical and organizational measures for transfers to countries without adequacy decisions:

You may request a copy of the transfer mechanisms used for your data by contacting privacy@mark8place.com.

7. DATA RETENTION

We retain your personal data only as long as necessary for the purposes described in this Privacy Policy:

Data Type

Retention Period

Account information

Duration of account + 5 years

Transaction records

7 years from transaction date

KYC/KYBC verification documents

5 years after relationship ends

DSA/INFORM Act seller verification

6 months after account termination

Product safety records (GPSR)

10 years from product supply

Communication records

3 years from communication

Content moderation decisions

3 years from decision

Usage analytics

26 months (anonymized after)

Marketing preferences

Until consent withdrawn

7.1 Retention Period Legal Justifications

Our retention periods are based on the longest applicable legal requirement across jurisdictions where we operate:

Upon account deletion request, we will delete or anonymize your personal data within 30 days, except where retention is required for legal compliance, dispute resolution, or fraud prevention.

8. YOUR PRIVACY RIGHTS

8.1 Rights Under GDPR (EU/EEA Residents)

8.2 Rights Under UK GDPR (United Kingdom Residents)

UK residents have the same rights as EU residents listed above under the UK GDPR and Data Protection Act 2018. The Information Commissioner's Office (ICO) is the supervisory authority for data protection in the UK.

8.3 Rights Under CCPA/CPRA (California Residents)

8.4 Rights Under PDPA (Singapore)

Under the Singapore Personal Data Protection Act 2012, you have the following rights:

To exercise these rights, contact our Data Protection Officer at privacy@mark8place.com. We will respond within 30 days of receiving your request with sufficient information to verify your identity. You may lodge a complaint with the Personal Data Protection Commission (PDPC) if you believe we have not complied with the PDPA.

8.5 Rights Under Australian Privacy Act

8.6 Rights Under LGPD (Brazilian Residents)

8.7 Exercising Your Rights

To exercise any of these rights, please contact us at privacy@mark8place.com. Response timelines:

We may need to verify your identity before processing your request. For transaction disputes or refund requests, please refer to the dispute resolution process in our Terms of Service.

9. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to operate our Platform, analyze usage, and provide personalized experiences. This section explains what cookies we use and how you can control them.

9.1 Cookie Categories

Category

Cookie Name

Duration

Purpose

Essential

sb-*-auth-token

Session

Supabase authentication - maintains your login session

__stripe_mid

1 year

Stripe fraud prevention and payment security

__stripe_sid

30 min

Stripe session identifier for checkout process

cookie_consent

1 year

Stores your cookie preferences

Analytics

_ga

2 years

Google Analytics - distinguishes unique users

_ga_*

2 years

Google Analytics 4 - maintains session state

_gid

24 hours

Google Analytics - distinguishes users for daily analysis

Functionality

locale

1 year

Remembers your language preference

currency_pref

1 year

Remembers your currency preference

Marketing*

intercom-*

9 months

Intercom - customer messaging and support widget

_fbp

3 months

Meta Pixel - advertising attribution (if enabled)

* Marketing cookies are only set with your explicit consent.

9.2 Third-Party Cookie Providers

9.3 Managing Your Cookie Preferences

You can manage cookies through:

Note: Disabling essential cookies may prevent you from using core Platform features like checkout and account access. Analytics and marketing cookies can be disabled without affecting functionality.

10. DATA SECURITY

We implement comprehensive security measures to protect your personal data:

10.1 Data Breach Notification

In the event of a data breach affecting your personal data, we will notify you and relevant supervisory authorities according to applicable law:

Breach notifications will include:

We maintain a breach response team and incident management procedures to ensure rapid detection, containment, and notification.

11. AUTOMATED DECISION MAKING, PROFILING, AND AI

We may use automated decision-making and profiling in the following contexts:

11.1 AI Foundry and Machine Learning Features

Our Platform includes AI-powered features ("AI Foundry") that process personal data:

AI Processing Principles:

11.2 Your Rights Regarding Automated Decisions

You have the right not to be subject to decisions based solely on automated processing that significantly affect you. Where such decisions are made, you have the right to: obtain human intervention; express your point of view; receive an explanation of the decision; and contest the decision. Contact privacy@mark8place.com to exercise these rights.

12. CHILDREN'S PRIVACY

Our Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without parental consent, we will take steps to delete that information. We do not present targeted advertising to users we know to be minors.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our Platform and, where required, by email at least 30 days before changes take effect. The "Last Updated" date at the top of this policy indicates when it was last revised.

14. COMPLAINTS AND SUPERVISORY AUTHORITIES

If you have concerns about our processing of your personal data, please contact us first at privacy@mark8place.com. If you are not satisfied with our response, you have the right to lodge a complaint with a supervisory authority:

15. CONTACT US

For privacy-related inquiries or to exercise your rights, please contact us:

Lions Agentix Pte. Ltd.

Data Protection Officer

10 Marina Boulevard, Singapore 018983

Republic of Singapore

Privacy Inquiries: privacy@mark8place.com

General Support: support@mark8place.com

Product Safety (GPSR): productsafety@mark8place.com

DSA Contact (EU): dsa@mark8place.com

Website: https://mark8place.com

— End of Privacy Policy —