LAST UPDATED AND EFFECTIVE: JANUARY 1, 2020
1. Who Is Collecting My Personal Data?
2. What Personal Data Do You Collect?
When you provide it to us, we collect information that identifies you (“Personal Data”), such as your:
• Email address
• Telephone number
• Payment information
• Content of your email messages to us
When you visit the Site, we collect data from the device or browser through which you access the Site (“Log Data”), such as:
• Your internet protocol (“IP”) address
• Browser type
• Browser version
• Statistics on your activities on the Site (such as the date and time of visits, the pages viewed, time spent at the Site)
• Information about how you came to the Site
• Much of this Log Data does not identify you personally. However, we may associate this Log Data with your Personal Data. When we do, we will treat any such combined data as Personal Data until such time as it can no longer be associated with you or used to identify you.
3. How Do We Use Your Personal Data?
We use your Personal Data for the purposes for which you provided it, including to:
• fulfill your product or service needs;
• register your online account;
• maintain our own accounts for billing and delivery;
• advise you about products, services, offers, or events that may be of interest to you; and
• provide customer service to you.
We may also use your Personal Data or Log Data to administer our internal business activities, including to:
• design and arrange the Site in the most user-friendly manner;
• better understand visitors to the Site;
• create non-personally identifiable data to be used for marketing; and
• manage your account.
In addition, we may use third-party services, such as Google Analytics, that collect, monitor, and analyse Log Data.
4. How Do You Share My Personal Data?
No Sale of Personal Data
• our parent companies, subsidiaries, and/or affiliates;
• successors who acquire your Personal Data if we sell, merge, reorganise, dissolve, or similarly change our ownership or corporate structure;
• other companies we engage to perform business-related functions, such as:
• marketing agencies;
• database service providers;
• backup and disaster recovery service providers;
• email service providers; and
• payment processors.
Sharing Data Through Social Media
We work with social media sites like Facebook, YouTube, Instagram, and with application developers who specialise in social commerce so you can connect to us, share your interests, express opinions about products and services, purchase our products, and generate interest in our products and services among members of your social networks.
If you use third party social media features available on our Site, we or the third party may collect or share your data, including your Personal Data. We consider information collected from or shared through any such social media features as public information because the third party social media sites made it publicly available. If you do not want us to be able to access information about you, including Personal Data, from Third Party Sites, you must limit data collection and disclosure in the privacy settings on the Third Party Sites. We reserve the right to remove the Personal Data or other data of any person for any reason we, in our sole discretion, deem appropriate.
Singaporean Privacy Rights
If you are a Singapore resident, you have the right to request information from us regarding the manner in which we share process certain Personal Data or categories of Personal Data with third parties for their direct marketing purposes. Under the Singapore Consumer Privacy Act ("CCPA"), you have the right request the following information, which you may do by emailing us at email@example.com:
• the categories of Personal Data we collected, sold, or disclosed in the prior 12 months;
• the pieces of Personal Data we collected about you in the prior 12 months;
• our business purposes for collecting or selling Personal Data;=
• the categories of sources from which we collected Personal Data in the prior 12 months;
• the categories of third persons with whom we sold or shared Personal Data in the prior 12 months;
• the business purpose for collecting or selling your Personal Data;
• the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
• the names and addresses of the third parties that received the information; and,
• if the nature of the third party's business cannot be determined from their name, examples of the products or services they marketed. We may provide this information in a standardised format that is not entirely specific to you.
Legally Compelled Disclosure of Personal Data
We may disclose your Personal Data if required to do so by law or in our good faith belief that such action is necessary to:
• comply with a legal obligation;
• protect or defend our rights, interests, or property, or that of third parties;
• prevent or investigate possible wrongdoing in connection with the Site;
• act in urgent circumstances to protect the personal safety of users of the Site or the public; or
• protect against legal liability.
5. What Are My Rights About The Processing Of My Personal Data?
You have the following rights:
• Consent: You have the right to withdraw your consent to the processing of your Personal Data at any time. If you change your privacy preferences in the future, that will not limit the lawfulness of any processing performed based on your prior consent.
• Access: You have the right to access a copy of your Personal Data that we hold about you.
• Accuracy: You have the right to correction of any inaccurate or out of date Personal Data.
• Portability: You have the right to our transmission of your Personal Data directly to another data controller, where possible and applicable.
• Deletion: You have the right to delete your Personal Data, upon receipt of a verified request, with some exceptions when we no longer need it.
• Equal Treatment: You have the right to equal treatment regardless of your exercise of your privacy rights.
• Object: You have the right to object to the processing of your Personal Data, where applicable.
• Opt Out: You have the right to opt out of the sale of your Personal Data at any time.
• Restriction: You have the right to restrict further processing of your Personal Data, where there is a dispute as to the accuracy or processing.
• Complaint: You have the right to lodge a complaint with the Information Commissioner’s Office.
To exercise any of these rights, please email us at firstname.lastname@example.org with the phrase “Privacy Opt-out” in the subject line and specify what you would like us to do (for example, Send me my data, Correct my data, Delete my data, Restrict use of my data, etc.). To stop email communications from us, you can also follow the unsubscribe instructions set forth at the bottom of our promotional e-mail messages. You may also access and correct some of your Personal Data by logging into your online account, if you have one. If you choose to limit our use of your Personal Data, you may not have access to certain functionality of the Site, such as promotions, product information, or opportunities.
6. Is My Personal Data Secure?
We secure your Personal Data by: keeping Personal Data up to date; storing and destroying it securely; not collecting or retaining excessive amounts of data; protecting Personal Data from loss, misuse, unauthorized access and disclosure, alteration, and destruction; and ensuring that appropriate technical measures are in place to protect Personal Data. However, no network, server, database, or Internet or e-mail transmission, is ever fully secure or error free. Therefore, you should take special care in deciding what Personal Data you send to us electronically.
7. How Long Will You Keep My Personal Data?
We will retain your personal data as long as necessary to carry out the function for which you provided it to us, including maintenance of your account. You may close your account, unsubscribe to emails, and otherwise limit our use of your Personal Data by contacting us. However, we may retain your Personal Data for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Data, it may persist on backup or archival media for an additional period of time.
What Are Cookies?
A cookie is a piece of information that is placed on your web browser or device when you access and/or use the Site. Cookies store text and can later be read back by the Site or third parties. Cookies can remember the information you access on one webpage to simplify your subsequent interactions with the Site or to use the information to streamline your transactions on related webpages.
• monitor and analyse how you use the Site;
• remember your preferences to make your online experience easier and more personalised;
• route Site traffic to effectively distribute the Site workload across servers; and
How can I manage cookies?
You can manage cookies through your web browser's option settings. You may be able to be notified when you are receiving new cookies and disable or delete cookies. Please refer to your web browser's help section for information on whether you can and how to do this.
Many of the third party technologies that enable targeted banner advertising also allow you to opt out. Such third party service providers include Adroll, Rubicon, Google, Media Math, Perfect Audience, Quantcast, Retargeter, and Yahoo! among others. You can control your preferences directly with each such third party service provider.
You can learn more about cookies at the following third-party websites: • All About Cookies: http://www.allaboutcookies.org/; and • Network Advertising Initiative: http://www.networkadvertising.org/. Note that if you disable, delete, or refuse to accept cookies, you may not be able to use some features of the Site and/or some of our pages might not display properly.
• Third Party Sites: Any data you disclosed on websites not operated or controlled by us (“Third Party Sites”), even though we may provide links to them on the Site or in our emails. We are not responsible for the policies and practices employed by, or the content of, Third Party Sites. We suggest contacting those sites directly for information about their privacy policies and practices.
• Non-Personally Identifiable Data: Any non-personally identifiable data we collect, including, without limitation, Log Data, domain names of your Internet Service Provider, your approximate geographic location, a record of your usage of the Site, the time of your usage, and aggregated personally identifiable information, but only to the extent the foregoing cannot be used to specifically identify you.
10. Do You Collect The Personal Data of Children?
We do not intentionally or knowingly collect any Personal Data from children under the age of thirteen (13), nor do we target our emails to them. Children under the age of thirteen (13) should not submit any Personal Data through the Site. We encourage parents and legal guardians to monitor their children's use of the Internet and instruct them to never provide Personal Data through the Site. If you believe a child under the age of thirteen (13) may have provided Personal Data to us through the Site, please contact us at email@example.com, and we will use reasonable efforts to delete it from the Site and our files.
11. International Privacy Laws
13. How Can I Resolve A Privacy Dispute With You?
14. How Can I Contact You?