1. As used in this Policy:
“Customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
“Personal Data” means data, whether true or not, about a Customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
2. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION OF PERSONAL DATA
3. We generally do not collect your Personal Data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your Personal Data to us (your “Authorised Representative”) after (i) you (or your Authorised Representative) have been notified of the purposes for which the data is collected, and (ii) you (or your Authorised Representative) have provided written consent to the collection and usage of your Personal Data for those purposes, or (b) collection and use of Personal Data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional Personal Data and before using your Personal Data for a purpose which has not been notified to you (except where permitted or authorised by law).
4. Depending on the nature of your interaction with us, some examples of Personal Data which we may collect from you may include but are not limited to:
5. The situations in which we may receive Personal Data from you may include but are not limited to when you:
6. We may combine information we collect about you with information we receive from third party sources.
USE AND DISCLOSURE OF PERSONAL DATA
7. We may use the Personal Data collected for certain purposes, which include but are not limited to the following:
8. In sharing your Personal Data with our affiliates or third parties, we endeavour to ensure that they protect the data and keep it secure from unauthorised access, and only use, disclose, and retain the data for as long as they need your Personal Data to achieve the abovementioned purposes and only in accordance with the PDPA, thereafter securely destroying or disposing of your Personal Data when there is no longer a purpose to retain it.
9. For our online services, information collected through automated technologies are used for purposes such as to (i) help us remember and process items in your shopping cart, (ii) understand and deliver personalized content and advertising according to our users’ interests, and (iii) compile aggregate data about site traffic and site interaction so that we can evaluate and improve on our online services and site experiences in the future.
10. We may also use the information we obtain in other ways for which we will provide specific notice at the time of collection.
11. We may disclose your Personal Data:
12. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
13. Personal Data may be collected from minors (individuals under the age of 21) who access our online services, visit any of our stores or participate in any of our events, workshops, promotions, contests, competitions, prize draws, or surveys.
14. The situations in which we may receive Personal Data from a minor may include but are not limited to when they:
WITHDRAWING YOUR CONSENT
15. The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed above by submitting your request in writing via email to our Data Protection Officer at the contact details provided below.
16. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
17. Depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in Clause 15 above.
18. Please note that if you opt-out of receiving marketing communications from us, we may still send communications to you concerning your transactions, accounts with us and any contests, competitions, prize draws, or surveys in which you have enrolled prior to your withdrawal of consent.
19. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclosure without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
20. If you wish to make (a) an access request for access to a copy of the Personal Data which we hold about you or information about the ways in which we use or disclose your Personal Data, or (b) a correction request to correct or update any of your Personal Data which we hold about you, you may submit your request in writing via email to our Data Protection Officer at the contact details provided below.
21. In order to facilitate processing your request, it may be necessary for us to request further information relating to your request. We may also ask you to verify your identity and/or provide other details to help us respond to your request. If you are below the age of 18, a parent, guardian or ward may request access to, correction or deletion of your Personal Data.
22. We reserve the right to charge a reasonable administrative fee for retrieving your Personal Data records. If so, we will inform you of the fee before processing your request.
23. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA). In certain circumstances, including when required by applicable law, we will comply with your request. Please note that we may be required by law to retain certain information.
PROTECTION OF PERSONAL DATA
24. To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection and SSL encryption services to secure all storage and transmission of Personal Data by us, and disclosing Personal Data both internally and to our authorised third-party service providers and agents only on a need-to-know basis.
25. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
26. If you believe that your privacy has been breached by us, please contact us immediately.
ACCURACY OF PERSONAL DATA
27. We generally rely on Personal Data provided by you (or your Authorised Representative). In order to ensure that your Personal Data is current, complete and accurate, please update us by informing our Data Protection Officer in writing via email at the contact details provided below if (i) there are changes to your Personal Data, or (ii) you believe that the Personal Data we have about you is inaccurate, incomplete, misleading or out of date.
RETENTION OF PERSONAL DATA
28. We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
29. We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
30. We generally do not transfer your Personal Data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
31. If you require us to transmit your Personal data that is in our possession to another Organisation in a commonly used machine-readable format, you can submit your request in writing via email to our Data Protection Officer at the contact details provided below.
32. Upon receipt of your written request for data portability, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed. In general, we shall seek to process your request within ten (10) business days of receiving it.
33. In the event of a data breach, we will take steps to assess if it is notifiable. If the data breach likely results in significant harm to individuals, and/or are of significant scale, we will take steps to notify the PDPC and the affected individuals as soon as practicable.
HOW TO CONTACT US
34. Should you have any enquiries or feedback on our Personal Data protection policies and procedures, or if you wish to make any request, you may contact our Data Protection Officer via email at firstname.lastname@example.org.
EFFECTS OF POLICY AND CHANGES TO POLICY
35. This Policy applies in conjunction with any other Policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us.
Policy Version: 9 May 2023