1. Who we are
1.2 You have been directed to this Policy because the Company is collecting, using or disclosing your personal data.
1.3 In this Policy, references to “we”, “us” or “our” refer to the Company, which is collecting your personal data and operating the website which you are accessing or using.
1.5 The Company is a limited liability company registered in Singapore (Co. Reg 199102507H) at 23 Woodlands Link Singapore 738730.
2. Purpose of the Policy
2.2 This Private Policy shall apply to all personal data in our possession or under our control.
2.4 The Website is not intended for use by any persons below the age of 18 years. We will neither, nor do we intend to, transact through the Website directly with anyone we know to be under the age of 18 years.
2.6 This Policy applies to all personal data that you may provide to us and the personal data we hold about you. By providing us with your personal data or by accessing, using or viewing the Website or any of its services, functions or contents (including transmitting, caching or storing of any such personal data), you shall be deemed to have agreed to each and all the terms, conditions, and notices in this Policy. If you do not agree, please cease use of the Website and/or its service(s) and DO NOT provide any personal data to us.
3. Personal data that will be collected
3.1 “Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual 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.
3.2 When you use our Website, any service we provide or in your interaction with us, the personal data we may collect include but is not limited to:
3.2.1 Data collected directly from you. This may be done through our Website, over the phone, by email or in person when you meet our employees and/or representatives. The personal data collected may include, but is not limited to:
(a) Your personal particulars, including your first name and last name, date of birth, gender and identification number (such as national ID or passport details);
(b) Your image and/or photograph;
(c) Your signature;
(d) Your personal contact details, such as your personal phone number(s), email address and residential address;
(e) Your professional contact details, such as your company phone number(s) and your company fax number and email address;
(f) Other information required to be able to process your order and provide you with our services, such as information concerning the products that you have ordered or the service that we are providing to you, the billing and/or delivery addresses, banking and/or credit/debit card details;
(g) If you have created an online profile or account, the preferences and/or interests stored in such profile or account; and
(h) If you have contacted customer service, the details of this contact and the contact history.
3.2.2 Data collected by automated means. Our Website adopts various technologies to make them more user-friendly, effective and secure for its users. Such technologies may result in data being collected automatically by us or by third parties on behalf of us. This data does not always, but may, contain a user's personal data or comprise of personal data. Examples of such technologies include:
(a) Click-stream data. A visit to our Website results in data that is transmitted from your browser to our server being automatically collected and stored by us or by third parties on behalf of us. This data can include, in particular, the following:
i. The IP address of the visitor of the Website;
ii. The date and time of the visit to our Website;
iii. The referral URL (the site from which the visitor was directed);
iv. The pages visited on our Website; and
v. Information about the browser used, such as the browser type and version, and operating system.
(c) Web Analytics. Web analytics is the term given to a method for collecting and assessing the behaviour of visitors to websites. This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a website, or to and out which of our information and services our visitors are most interested in. For these purposes, we primarily make use of click-stream data and the other techniques listed above.
4. Purposes for which we collect, use or disclose your personal data
4.1 The company may collect, use, disclosure and/or process your personal data for one or more of the following purposes:
- 4.1.1 Processing and dealing with your interest in our products and/or services;
- 4.1.2. Administering, facilitating, processing, dealing with, administering and/or managing your purchase of our products and services (the “Transaction”). Without limiting the generality of the following, should you make a Transaction that includes third party individual(s) or on behalf of third party individual(s) or for third party individual(s), you consent to us disclosing personal data that identifies you to the said third party individual(s). This includes but is not limited to the following:
- (a) Generating and storing documents concerning the Transaction(s) such as delivery and collection orders, quotations and invoices;
- (b) Dealing with your delivery needs, processing orders and payment transactions, implementing transactions and the supply of products and/or services to you that you have requested;
- (c) Dealing with your ad-hoc queries, requests or bookings; and
- (d) Assessment of your creditworthiness (for which we may use third parties).
- 4.1.3. Administering, facilitating, processing and/or dealing in any Transactions, payments, debt collection or activities carried out by you on the Website;
- 4.1.4 Administering, facilitating, managing, processing and/or dealing in any matters involving your use or access of the Website, including identifying you for login to the Website, our portals and other online services provided by or on behalf of us;
- 4.1.5 Monitoring, processing and/or tracking your use of the Website in order to provide you with a seamless experience, facilitating or administering your use of the Website, and/or to assist us in improving your experience in using the Website;
- 4.1.6 Registering you as a customer of any of our products or services on the Company’s database to contact you or communicate with you via phone/voice call, text message and/or fax message, email and/or postal mail for one or more of the Purposes stated herein. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
- 4.1.7 To process, to facilitate and/or administer the online account that you may open with us, including to facilitate your transactions on the Website or for us;
- 4.1.8 Carrying out due diligence and other activities as may be required by legal and/or regulatory obligations that are applicable to the Company (including but not limited to anti-money laundering checks and Know Your Client checks), the requirements or guidelines of government authorities which the Company determines is applicable to it, and the Company’s risk management procedures that may be required by law.
- 4.1.9 To prevent or investigate any fraud, unlawful activity, omission or misconduct, dealing with conflict of interests, or dealing with investigating complaints;
- 4.1.10 Complying with or as required by any request or direction of any governmental authority (whether Singapore or other countries) which we are expected to comply with, or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities;
- 4.1.11 Conducting research, (including customer research), surveys, market surveys, analysis and development activities (including but not limited to data analytics, and/or profiling), obtaining your feedback to our products and services to improve our products and services and to enhance any continued interaction between yourself and us in relation to your relationship with us, the Website or your Transaction(s);
- 4.1.12 Conducting of training to improve the quality of our products and services and our staff’s service quality;
- 4.1.13 For marketing purposes, including but not limited to, the provision of marketing, advertising and promotional information, materials and documents relating to products, services, contests and events, by postal mail, electronic transmission, fax, voice calls and/or text messaging;
- 4.1.14 Storing, hosting and/or backing up of your personal data, whether within or outside Singapore;
- 4.1.15 Maintaining and/or developing our IT or business systems and infrastructure including testing and upgrading of these systems;
- 4.1.16 Facilitating, dealing with and/or administering external or internal audit(s) of the business of the Company, the Transaction(s) and/or transactions with our customers; and
- 4.1.17 To deal with the or as part of a bankruptcy, winding up, reorganisation, restructuring, insolvency, receivership or an assignment for the benefit of creditors of the Company.
(the purposes set out in this Paragraph 4.1 shall be collectively referred to as the “Purposes”)
4.2 Your consent relating to our processing of your personal data in accordance with the marketing purpose mentioned in Paragraph 4.1.13 may be withdrawn at any time using one of the following methods:
- 4.2.1 Clicking the “Unsubscribe” button located at the bottom of our emailers; or
- 4.2.2 Contacting us through the contact details listed at Paragraph 10.1 below.
4.3. We may need to disclose your personal data to third parties, whether located within or outside Singapore for any of the above Purposes. In this connection, you hereby acknowledge, agree and consent that we are permitted to disclose your personal data to such third parties for one or more of the above Purposes and for the said third parties for their subsequent collection, usage, disclosure and/or processing of your personal data for one or more of the above Purposes. Without limiting the generality of the foregoing or of the above Paragraph 4.1, such third parties include:
- 4.3.1 Our associated or affiliated organizations or related corporations;
- 4.3.2 Any of our agent, contractors or third party service providers that will process your personal data on our behalf, including but limited to those who provide administrative services to us such as mailing houses, telecommunication companies, information technology companies, data centres, hosting and maintenance service providers, email-messaging service providers, handling of payment transactions service providers, marketing service providers, delivery services and debt collectors;
- 4.3.3 Our professional advisers, such as our auditors, lawyers and insurers; and
- 4.3.4 Third parties to whom disclosure by us is for one or more of the Purposes, who will in turn be collecting and processing your personal data for one or more of the above Purposes. Without limiting the generality of this Paragraph 4.3.4, such third parties include debt collectors, finance companies or banks.
4.4 Should you provide us with personal data of your child or children, you confirm, declare and agree that you are the parent or legal guardian of such child or children, and that we may collect, use and/or disclose your child or children’s personal data for the Purposes set out in the above Paragraph 4.1 and in the manner as set out in Paragraphs 4.1 to 4.3 above.
4.5 You may withdraw your consent to the collection, use and/or disclosure of your personal data in our possession or under our control by contacting us at through the contact details listed at Paragraph 10.1 below. We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request, unless an exception under the law or a provision in the law permits us to. However, please take note that your above withdrawal of consent could result in certain legal consequences arising, including us being unable to perform the transactions requested by you or the termination of your relationship with us, as the case may be.
4.6 We may collect, use, disclose or process your personal data for purposes other than the Purposes set out in the above Paragraph 4.1. Prior to the collection, usage, disclosure or processing of your personal data for such other purposes, you will seek your notification unless your consent is not required by the PDPA or by any applicable law.
4.7 Please inform us of any changes to your personal data or if there are any errors in the personal data we hold about you. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you had initially provided us with.
5. Provision by you of third party personal data
5.1 In the event that you provide us with personal data of any individual other than yourself, you represent, undertake and warrant to us the following:
- 5.1.1 For any personal data of third party individuals that you disclose to us, you would have obtained prior consent from such individuals to:
- (a) Permit you to disclose the individuals’ personal data to the Company for the Purposes; and
- (b) Permit the Company to collect, use, disclose and/or process the individuals’ personal data for the Purposes.
- 5.1.2 At the Company’s request, you will use such form(s) and document(s) provided by the Company in obtaining the required consent from the third party individuals in question;
- 5.1.3. Any personal data of third party individuals that you disclose to us are accurate; and
- 5.1.4 For any personal data of third party individuals that you disclose to us, that you are validly acting on behalf of such individuals and that you have the authority of such individuals to provide their personal data to the Company and for the Company to collect, use, disclose and process such personal data for the Purposes.
6. Third Party Websites
6.1 This Policy only applies to our Website and information that we collect from you. Our Website may contain links to other websites which are not owned or maintained by us. When visiting these third party websites or disclosing your personal data to third parties, you should read their privacy policies, or ask relevant questions before you disclose your personal data. We are not responsible for the collection, use or disclosure of your personal data by such third parties.
7. Security and our storage of your personal data
7.1 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, encryption and the use of privacy filters 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.
7.2 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.
8. Retention of Personal Data
8.1 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.
8.2 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, including but not limited to legal purposes and the Purposes set out in the above Paragraph 4.1.
9. Your rights regarding your personal data that is collected and processed by the Company
9.1 If you wish to make an access request for access to a copy of the personal data which we hold about you, information about the ways in which we use or disclose your personal data, a withdrawal of any consent that you have given us at any time, or a correction request to correct or update any of your personal data which we hold about you, you are welcome to contact us through the contact details listed at Paragraph 10.1 below.
9.2 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).
9.3 Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
10. Contact Information of the Company
10.1 You may direct your requests and enquiries to the Company regarding your personal data in the following ways:
- 10.1.1 By Email. Such complaints must be made to the Company’s Person-In-Charge at following address: firstname.lastname@example.org
- 10.1.2 By Telephone. Such complaints must be made to the Company’s Person-In-Charge at the following telephone number: +65 6756 9088
10.2 All requests and enquiries will be evaluated by the Company in a timely manner. After the Company has completed its evaluation, the Company’s Person-In-Charge will respond to the initial contact person with the results of the evaluation.
11. Governing Law
11.1 This Policy is prepared pursuant to the PDPA and governed by the laws of Singapore.
12.1 This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
EFFECTIVE DATE: 1st August 2021, Sunday
LAST UPDATED: 11 September 2020, Friday