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Value-Top Bangladesh (hereafter referred as “Value-Top ”) is committed to respecting the privacy of the personal information of the individuals that visit this website or that we otherwise interact with. We have developed this privacy statement to describe the privacy policies and practices that will govern the processing of personal information that you provide to Value-Top  (whether through this website or through other means) and to obtain your consent to Value-Top ’s collection, use, disclosure, and processing of that personal information in accordance with this privacy statement.

In addition, with respect to certain of our current or future product offerings Value-Top  may implement a supplemental privacy statement, notice, or policy that that will be in addition to, and should be read in conjunction with, this privacy statement.

NOTE: If this privacy statement is not acceptable to you, please do not submit any personal information (whether yours or that of other persons) to Value-Top , whether through this website or through other means.


For the purposes of this privacy statement, “personal information” (also referred to as “personal data”) is any information relating to an identified or identifiable natural person (being a natural person who can be identified, directly or indirectly, in particular by reference to one or more identifiers such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person). For the purposes of this privacy statement, “personal information” or “personal data” may include, without limitation, your name, title, mailing address, e-mail address, phone number, identification number (such as a passport number), date of birth, or image.

For the avoidance of doubt, “personal information” does not include anonymous or non-personal information, including information that cannot be associated with or tracked back to a specific individual.


By using this website or otherwise providing Value-Top  with your personal information, you consent to our collection, use, disclosure, and processing of such personal information in accordance with this privacy statement.

To the extent you provide Value-Top  with the personal information of any other natural person, you represent and confirm to Value-Top  that you have such person’s permission and consent to do so, and their consent to our collection, use, disclosure, and processing of such personal information in accordance with this privacy statement.

Value-Top ’s legal basis for collecting and using personal information will depend on the personal information concerned and the specific context in which we collect it. However, Value-Top  will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, Value-Top  may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If Value-Top  asks you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if Value-Top  collects and uses your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

Notwithstanding the forgoing, please note that Value-Top  may also collect, use, disclose, or process your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.


In connection with your use of the website or you otherwise interacting with Value-Top , you may provide and Value-Top  may collect your personal information. If you choose to provide such information to Value-Top , whether through this website or by other means, Value-Top  may collect, use, disclose, and process such personal information in accordance with this privacy statement. For the purposes of the EU’s General Data Protection Regulation (GDPR), Value-Top  may be considered a “controller” of the personal information or personal data that you (the data subject) provide to Value-Top .

Instances where we may collect your personal information include, without limitation, the following:

Interacting with our Channel Partners

If you represent a Value-Top  channel partner (i.e. an authorized reseller of Value-Top ’s products), you may visit Value-Top ’s websites intended specifically for our channel partners and you may otherwise interact with Value-Top  with respect to purchasing or servicing our products. We may use information provided in these interactions to administer and develop our business relationship with you, the channel partner you represent, and channel partners generally. For instance, this may involve using your information to send you details of channel partner programs, including product offerings or special opportunities. It may also include sharing certain information with other channel partners (subject to any confidentiality obligations that may exist), or prospects. In connection with a particular transaction or program, we may also contact you as part of customer satisfaction surveys or for market research purposes. We will process your data on the basis of performance of a contract to which you (as a representative of a Value-Top  channel partner) are party or in order to take steps at your request prior to entering into a contract.

Interacting with our Suppliers

If you represent a Value-Top  supplier (of products or services), you may visit Value-Top ’s websites intended specifically for use by our suppliers and you may otherwise interact with Value-Top  with respect to the provision of your products and services to Value-Top . We may use the information provided in these interactions in connection with entering into or performing purchases, contracts, or other transactions with you or related business partners. Where necessary in order to administer our business relationship with you or otherwise carry-out our business operations, this may include sharing your information with Value-Top ’s channel partners, shipping companies, financial institutions, and postal or government authorities involved in fulfillment. Your information may also be used to administer and develop our relationship with you, the supplier you represent, and other Value-Top  suppliers generally.

Marketing, Promotional, and Product Development Activities

We may interact with you in connection with our marketing, promotional, and product development activities. In this regard, we may ask you for and collect personal information when you participate in a promotion or marketing campaign sponsored by Value-Top  or one of our business partners; when you want to find out about a product or service offered in your area; when you complete surveys or other questionnaires for Value-Top ; when you participate in a user forum or blog hosted by Value-Top  or one of our business partners; or when you send an email to Value-Top .

Value-Top  (and our service providers) may also collect information made publicly available through third- party platforms such as social media websites, online databases, or directories or other legitimately obtained information. This information may be governed by the privacy notice(s) provided by the third party at the time of collection.

In carrying-out our marketing and promotional activities, we employ either an opt-in or opt-out mechanism (as applicable under relevant laws) to ensure we have your consent to receive any relevant communications through electronic means. If, as applicable, you either choose not to opt-in or choose to opt-out, we will not send you any further marketing or promotional communications through electronic means, but we may continue to contact you to the extent necessary to administer any other ongoing business relationship we may have with you.


We will collect personal information when you express interest in employment with Value-Top , whether directly or via an agent or recruiter (speculatively or in response to any ad on the basis of our legitimate interest to recruit new employees or contractors). Personal information that may be collected by Value-Top  in connection with these activities may include, without limitation, your name, contact information, CV or resume, date of birth, performance management information, compensation information, race and ethnic origin.

Non-Personal Information

In addition, our web server may also collect non-personal information related to your visit to our website, which may include the IP address (to the extent it cannot be used as an identifier in relation to a natural person) and domain used to access our website, the type and version of your browser, the date and time you accessed our website, the website that you came from to access our website, the page of our website that you entered and exited at, any of our website pages that are viewed by that IP address, and what country our website was accessed from. Such non-personal information may be collected and used by Value-Top  without reference to this privacy statement.


The personal information collected by Value-Top  may be used for certain business purposes including, without limitation:

to manage, develop and improve our business and operations;

to assist in the development and marketing of our products and services;

to respond to specific requests from you;

to provide localized content based on your location;

for recruitment purposes, when you express interest in employment with Value-Top ;

to engage in a business transaction, including a purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization of financing involving Value-Top , our products or services, or a part of our business; or

to establish and maintain an effective relationship with those with whom Value-Top  interacts, including, without limitation, customers, channel partners, end-users of our products or services, suppliers, and contractors with whom we do business.

In connection with these purposes, Value-Top  may disclose your personal information to Value-Top ’s employees, contractors, consultants, affiliates, suppliers, service providers, and other parties. When Value-Top  shares personal information with such parties, we require that they only use or disclose such personal information in a manner consistent with the use and disclosure provisions of this privacy statement and applicable legislation.

Except as outlined in this privacy statement or any other Value-Top  publication addressing our collection, use, disclosure, and processing of personal information, Value-Top  does not provide your personal information to third parties without your consent. Please note that, in special cases, we may need to share personal information without acquiring consent, such as when we believe in good faith that the law requires it, or to identify, contact or bring legal action against someone who may be violating Value-Top ’s or other's rights or causing injury to or interference with Value-Top ’s or others' property.

Value-Top  may share your personal information if required to do so by law, court order, subpoena or other legal process; as requested by a governmental or law enforcement authority; or to enforce applicable contractual rights we may have with you. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or advisable.

Non-personal information collected by our web server may be used to monitor our website's performance (such as number of visits, average time spent, page views) and for business purposes such as working to continually upgrade our website. Such non-personal information may be disclosed to other third parties or permanently retained for future use without restriction.



Value-Top  endeavors to maintain physical, technical, and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification, or disclosure.

Unfortunately, no data transmission or data storage medium, whether electronic or physical, can be guaranteed to be entirely secure. As a result, we endeavor to protect your personal information, but we cannot warrant the security of any information you transmit or otherwise provide to us, and such provision of personal information is at your own risk. Once we receive your personal information, we make commercially reasonable efforts to maintain its security on our systems.

As stated above, personal information collected by Value-Top  from you may be transmitted, used, disclosed, stored, and otherwise processed outside of the country where you submitted that personal information and may be subject to disclosure in accordance with the laws of such jurisdictions.



We apply a general rule of keeping personal information only for as long as required to fulfil the purposes for which it was collected. However, in some circumstances we may retain personal information for longer periods of time, for instance where we are required to do so in accordance with applicable legal, tax, or accounting requirements.

In specific circumstances we may also retain your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

When we have no ongoing legitimate business need to retain your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will endeavor to securely store your personal information and isolate it from any further processing until deletion is possible.


Some pages on Value-Top ’s website use a technology called “cookies”. Cookies are placed on your computer’s hard drive and are capable of storing data to help provide additional functionality. They also help to identify you when you visit a particular website. Cookies are generally limited to collecting statistical data about website visitor usage. With most Internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. Please refer to your browser instructions or help screen to learn more about these functions.

Many of our websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). For more information on the use of Google Analytics, please visit Google’s privacy policy here. You can also view Google’s currently available opt-out options here.


If you connect social media to the Value-Top  website, interactions will exist and posts to your profile at such third party websites may occur. Social media websites or services may have different privacy practices and policies than Value-Top  and we recommend that you review their privacy policies to determine if they are acceptable to you.


Under the laws of Bangladesh, you may have the right, by contacting Value-Top , to access, review, correct, amend, delete, or receive a copy of any of your personal information that has been collected by Value-Top . You may also have the right to withdraw your consent to our collection, use, disclosure, and processing of your personal information.

To the extent you are providing personal information to Value-Top , you are responsible for the accuracy and completeness of such information, and for contacting Value-Top  if correction of such information is required. Should you believe that any of your personal information we hold is incorrect or incomplete, you have the ability to request to see this information, rectify it, or have it deleted.


If you have other questions, comments or concerns about this privacy statement or our privacy practices, please contact our Privacy Office at info@comcitybd.com or at the address below. If you wish to issue a request to exercise your rights where applicable by law please complete the form found here.

Value-Top Bangladesh
3rd Floor, BS Bhaban
 75-76, Laboratory Road, Dhaka 1205, Bangladesh

If you still feel that your personal data has not been handled appropriately according to the law, you can contact the applicable data protection authority and file a complaint with them.

This privacy statement is subject to change at Value-Top ’s discretion. The last content update was made on May 29, 2022.