privacy policy

about this policy

This Privacy Policy describes how we manage Personal Data in compliance with the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”). We encourage you to read it so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

We may update this Privacy Policy from time to time. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time. We encourage you to check the latest version regularly.

“Personal Data” refers to data, whether true or not, about an individual who can be identified from that data, or from that data in combination with other information to which the organisation may have access, and includes the meaning otherwise given in the Act as amended from time to time.

By signing up for or using any products or services offered by us, or by submitting information to or otherwise communicating with us, you agree and consent to us and our related entities, affiliates and subsidiaries (individually and collectively, the “Companies”), as well as their respective representatives and/or agents (collectively, the “Company”, “us”, “we” or “our”), collecting, using and disclosing your Personal Data in accordance with this Privacy Policy. “You” or “your” means any individual to whom the Act applies, and includes an actual or prospective individual customer, but excludes any corporate entity (including corporate customers) and any other entity excluded under the Act.

This Privacy Policy does not supersede or replace any other consents you may have previously or separately provided to us in respect of your Personal Data, and your consent to this Privacy Policy is in addition to any other rights which any of the Companies may have at law to collect, use or disclose your Personal Data.

01how we collect personal data

1.1Generally, we collect your Personal Data in the following ways:

1. when you order or purchase services from us;
2. when you post feedback or interact with our customer service officers, e.g. via meetings, emails or telephone calls (which may be recorded for training, quality control, business and/or other lawful purposes);
3. when you use some of our services, including establishing any online accounts with us;
4. when you request that we contact you, or be included in an email or other mailing list;
5. when you respond to our promotions, campaigns or other initiatives, or attend our events;
6. when we receive references from business partners and third parties, for example, where you have been referred by them;
7. when you visit our websites (see section 7);
8. when you take part in any survey or promotion conducted by us and/or our business partners;
9. during CCTV recordings when you visit our premises, or photo taking or video recording at events;
10. when we receive information about you from third-party social networking services when you choose to connect with those services;
11. when you provide, or contemplate providing, security to us for a transaction;
12. when you submit your Personal Data to us for any other reason; and/or
13. by other lawful means.

02purposes and disclosure

2.1Your Personal Data may be collected, used and/or disclosed for the following purposes:

1. to verify and process your personal particulars and payments;
2. to provide goods and services to you;
3. to respond to and deal with enquiries, complaints and other customer-care matters, or otherwise communicate with you;
4. to monitor or record phone calls and customer-facing interactions for quality assurance, employee training, performance evaluation and identity verification purposes;
5. to manage payment, billing, account, credit checks and debt-recovery matters;
6. to send you information, promotions, updates, and marketing and advertising materials in relation to our goods and services and those of our group companies;
7. to manage, develop and improve our business and operations to serve you better;
8. to carry out marketing promotions and campaigns and personalise your experience at our customer touchpoints;
9. to carry out market research and customer surveys;
10. to conduct investigations or audits, or carry out crime and fraud prevention and risk management activities;
11. to comply with legal and regulatory requirements;
12. to enforce our legal rights and obligations;
13. to facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales);
14. for other purposes for which we have obtained your consent; and
15. for any other purposes reasonably necessary, ancillary or related to the above purposes.

2.2Your Personal Data may be used and disclosed for the purposes listed above by our officers and employees, third parties, affiliates, service providers and advisors, which include without limitation the following persons or entities:

1. banks, credit card companies and payment vendors;
2. debt collection agencies;
3. credit information companies;
4. logistics and courier services companies;
5. call centre services providers;
6. relevant government regulators or authorities or law enforcement agencies;
7. our insurers and advisors, including consultants, auditors and lawyers;
8. data intermediaries, such as the website hosting and email providers described in section 7; and
9. any other party to whom you authorise us to disclose your Personal Data.

Save for relevant government regulators and authorities or law enforcement agencies, we will ensure that such parties receiving your Personal Data (i) are under a duty of confidentiality to us with respect to the use, holding, processing, retention and/or transfer of your Personal Data; and (ii) have the need to know or handle such Personal Data.

2.3If you have provided us with your telephone number(s) and have indicated that you consent to receive marketing or promotional information via your telephone number(s), then from time to time we may contact you using such telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services.

2.4Your Personal Data may be transferred, stored and/or processed in a country or territory outside Singapore, and you consent to any such transfer, storage and/or processing of your Personal Data outside Singapore. We will, however, ensure that any party to whom we transfer your Personal Data outside Singapore provides to such Personal Data a standard of protection at least comparable to the protection under the Act. This includes without limitation ensuring that any party coming into contact with the Personal Data outside Singapore:

1. complies with the Act and accompanying guidelines issued by the relevant regulatory authorities, all applicable laws and regulations and this Privacy Policy (“Data Standards”), and shall not do or permit anything to be done which might cause such party or us to breach the Data Standards;
2. takes all appropriate measures to ensure such compliance by implementing such Data Handling Principles as notified by us to them from time to time and appropriate technical and organisational measures, and providing a standard of protection for the Personal Data that is comparable to the protection under the Act; and
3. protects the Personal Data by making reasonable security arrangements to prevent unauthorised access, use, disclosure or modification.

03withdrawal of consent and access

3.1You may withdraw your consent to our continued use and disclosure of your Personal Data, or seek access to your Personal Data (to a reasonable extent and as permitted by the Act), at any time by writing to the Office of our Data Protection Officer (see section 10). You may also withdraw your consent for specific forms of communication, and on specific communications, via the unsubscribe options stated in our emails or other marketing messages.

3.2In withdrawing your consent, you acknowledge that we may not be able to provide or continue providing certain goods and/or services to you, and that we may cease such provision accordingly without any liability. Please note that it may take up to 30 working days for a request to withdraw consent to be reflected in our systems.

3.3We will, at your request, endeavour to provide you with an account of your Personal Data in our possession or control within a reasonable time. Such account shall be in respect of how your Personal Data has been or may have been generally used or disclosed within the year before the date of your request. We reserve the right to charge a reasonable administrative fee for carrying out your request.

04accuracy and correction

4.1We will endeavour to ensure that the Personal Data we use is sufficiently accurate and complete in making any decision that affects you.

4.2To help us maintain the accuracy of your Personal Data, we encourage you to tell us of any changes to the Personal Data you have provided by writing to the Office of our Data Protection Officer. We will correct or complete your Personal Data as soon as reasonably practicable.

05protection, policies and procedures

We will endeavour to protect Personal Data in our possession or control against risks of unauthorised access, collection, use, disclosure, copying, modification, disposal or destruction through reasonable and appropriate security measures. We strive to ensure that our systems are secure and meet industry standards.

To prevent unauthorised access, maintain data accuracy and ensure the correct use of information, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Personal Data we collect. Notwithstanding these measures, you acknowledge that no data transmission over the Internet is completely secure, and that by providing your Personal Data you are transmitting information at your own risk.

06retention of personal data

We will retain your Personal Data for as long as you use our products or services and it is necessarily required or relevant for business or legal purposes.

07this website and cookies

7.1Cookies. This website does not set cookies, and does not use advertising or cross-site tracking technologies.

7.2Visitor statistics. We use Vercel Web Analytics to understand how the website is used, such as the number of visitors, the pages they view, the referring website, and the country, browser and type of device. These statistics are aggregate and anonymous. Visitors are distinguished by a hash of the incoming request that is discarded within 24 hours, and no Personal Data is associated with the statistics.

7.3Contact form. When you use our contact form, we collect your name, email address, company (if given), area of interest and message. We use these details only to reply to your enquiry. The form is delivered to our team by email through our email provider, Resend. To prevent spam, the form briefly counts recent submissions from each IP address; this count is held in memory and is not stored.

7.4Hosting. This website is hosted by Vercel, which keeps standard server logs (such as IP address, browser type and the page requested) for a limited period to operate and secure the service.

7.5Vercel and Resend act as data intermediaries for us and may process data outside Singapore, including in the United States (see section 2.4).

08third-party links and products

Our website and/or services may link to third-party websites and services that are outside our control. We are not responsible for the security or privacy of any information collected by those websites or services. You should exercise caution, and review the privacy statements applicable to the third-party websites and services you use. To the fullest extent permitted by law, we are not responsible for a third party’s acts, omissions, data policies or use of cookies, nor the content or security of any third-party website, even if linked from our website. Any such liability is expressly disclaimed and excluded.

09governing law

This Privacy Policy and your use of this website shall be governed in all respects by the laws of Singapore.

10contact us

To withdraw consent, request access to or correction of your Personal Data, or ask about this policy, write to the Office of our Data Protection Officer: