Privacy Statement

                                                                                     Privacy Notice

This privacy notice (“Privacy Notice”) aims to give you information on how Company and its affiliates/group companies as listed in the Appendix (collectively as “we, us, our”) process your personal data through your use, either on behalf of yourself or your company, of our products and/or services and/or website. This includes the information provided by you, as our customer or our customer’s representative/related person, on our website or upon the application or use of our products and/or services. You will be explained on what kind of personal data we collect and why we collect it; this includes what you tell us about yourself and what we learn by having you as a customer, how we process your personal data, who we disclose your personal data to, how long we keep your personal data, and what your privacy rights as a data subject and how the law protects you.

Our website is not intended for children under 20 years old and we do not knowingly collect data relating to children under 20 years old.

What type of information we collect

We currently collect and process the following information:

Identity data: this includes but not limited to your first name, last name, title, date of birth, personal identification number, passport number, tax identification number, nationality, username or similar identifier.

Contact data: this includes but not limited to your billing address, residential address, email address, telephone numbers and social media accounts.

Transaction data: this includes but not limited to details about payments to and from you, your bank accounts and payment card details, your correspondence with us and details of products or services you have purchased from us.

Market research & feedback: any information that you voluntarily share with us about your experience of using the products and/or services offered by us, such as your needs and interests, information and opinions expressed when participating in a market research and/or survey, or contact information that you provide to us in order to receive news and updates from us.

Profile data: this includes your login details, purchases or orders made by you, your interests or preferences, feedback or survey responses.

Our customer support services: any communications with our officers, such as record of contact, complaints and/or disputes, emails or letters you send to us, record of your feedback, and record of advice that we may have given you.

Details of others provided by you: these include any information that you have provided us about other persons with whom we may or may not have direct legal relationship, such as their identity data and contact data

We do not collect, use or store any sensitive personal data about you which includes details about your race or ethnicity, religious or philosophical beliefs, sexual behavior, political opinion, trade union information, health information, disability, genetic and biometric data, criminal records and any data which may affect the data subject in the same manner, as prescribed by law.

Where we collect the information from

We collect your information from various sources as follows:

information that you provide to us: such as the information filled out in the forms on our website, order forms or application forms provided by us.

information that we generate about you: this includes marketing and sales information, such as details of the products and/or services that you receive and your preferences, and audio-visual information, such as recordings from surveillance videos on our premises or recordings of phone or video or chats with our staff.

information we collect from other sources: this includes the information received from our business partners and any information that you share publicly on a third party social network.

If you do not provide the necessary data or consent to the collection, use or disclosure of data, which we indicate to you is mandatory, we may not be able to provide you with the products and/or services you require, or meet all our obligations we have with you, enter into a contract with you, or fulfil legal duties imposed on us by law. In such cases, our service to you may be limited, restricted, suspended, cancelled, prevented or prohibited, as the case may be.

If you give us personal data of other persons, or you request us to share their personal data with third parties, you confirm that such persons understand the information in this Privacy Notice about how we will use their personal data and that you have the rights to share their personal data to us.

What we do with the data we have

We may only collect, use and share (collectively process”) personal data fairly and lawfully and for specified purposes provided by law (“lawful basis”).

The lawful basis for processing available under the applicable data protection law vary depending on the nature and purpose of the processing activities and the types of data being processed.

We will rely on one or more of the following lawful basis when processing personal data:

·       when it is necessary to fulfil a contract or perform obligations we have with you or to act upon your request before entering into any contractual relationship with you;

·       when it is our legal duty;

·       when it is in our legitimate interest; and

·       when you consent to the processing of your personal data.

 

Some processing activities may fall under more than one lawful basis. In such case, we may rely on any of the applicable basis for our processing activities.

The purposes for which we may process personal data, subject to the applicable law, and the legal bases on which we may perform such processing includes:

Purposes of Personal Data Processing

Lawful Basis

Provision of Products and/or Services

·       to verify and authenticate your identity;

·       to deliver our products and/or services to you;

·       to manage our relationship with you or your business;

·       to proceed with your orders or instructions;

·       to collect monies owed to us, if any;

·       to study how you use products and/or services from us and other organizations;

·       to provide service notifications or reminders of your benefits; and

·       to communicate with you about our products and/or services;

·  when it is necessary to fulfil a contractual duty or perform obligations that we have with you or to act upon your request before entering into any contractual relationship with you; or

·  when it is in our legitimate interest

 

Customer Support

·       to respond and manage customer requests; and

·       to manage fees, charges, or interest due on customer accounts, if any.

 

·  when it is necessary to fulfil a contractual duty or perform obligations that we have with you or to act upon your request before entering into any contractual relationship with you; or

·  when it is in our legitimate interest.

Purposes of Personal Data Processing

Lawful Basis

Marketing Activities

·       to conduct targeted advertising;

·       to personalize marketing messages sent to you;

·       to give you information about our and/or our group’s products and/or services that you may be interested in;

·       to let social media platforms send you information about our products and/or services that you may be interested in;

·       to communicate with you via any means (including via email, telephone, text message, social media, post or in person); and

·       to maintain and update your contact information where appropriate.

·  when you consent to the processing of your personal data; or

·  when it is in our legitimate interest.

 

Sharing Your Personal Data to Our Business Partners for Their Marketing

·       to allow our business partners to offer you their products and/or services

·  when you consent to the processing of your personal data

Business Improvement

·       to understand and develop products/services to meet our customers' needs and to improve our business performance;

·       to test, research, analyze and develop new features, products and/or services;

·       to plan improvements to existing products and/or services;

·       to manage your complaints, if any;

·       to do statistical reports or market research;

·       to do internal audits and reports; and

·       to conduct surveys or to hear from you about our products and/or services.

·  when it is necessary to fulfil a contractual duty or perform obligations that we have with you or to act upon your request before entering into any contractual relationship with you; or

·  when it is in our legitimate interest.

 

 

Purposes of Personal Data Processing

Lawful Basis

Fulfilment of Our Legal Obligations

·       to verify and authenticate your identity; and

·       to comply with applicable laws and regulations.

·  when it is our legal duty to process your personal data

Security and Risk Management

·       to prevent crimes and manage the security of our premises (for example, we may use closed circuit television (CCTV) in and around our premises , which may collect photographs, videos or voice recording of you and the individuals connected to you or your business)

·  when it is in our legitimate interest.

 

Other relevant processing activities

·       to conduct any processing activities in relation to the purposes set out in this table.

·  same as the lawful basis applicable to such activities

 

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