- “Personal Data” is defined under the Singapore Personal Data Protection Act 2012 (“PDPA”) to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access.
2. Policy Application
- We (“TRESSE”) are committed to safeguarding your Personal Data in compliance with PDPA and all the associated regulations and guidelines as may from time to time be issued under it.
3. Collection of Personal Data
- We will collect your Personal Data in accordance with the PDPA from information which you provide to us: (a) through your use of our Website; (b) in your interaction with us; (c) via application or other forms; (d) via cookies or through any other voluntary submission of any information by you.
- Personal Data that may be collected includes, among other things, your name; address; telephone number(s); email addresses; date of birth; gender; nationality; purchases of products; payment information; credit card numbers; marketing preferences; answers you provide to security questions; information used to provide products or services; information needed to administer rewards or loyalty programs and any other types of information that you choose to provide to us or that we may collect about you through your transactions with us.
- If you are only browsing our Website, we do not capture data that allows us to identify you individually.
4. Purposes for Collection, Use, Disclosure and Processing of your Personal Data
- By submitting your Personal Data to us, you acknowledge and consent to our use and disclosure of your Personal Data for the purposes for which it was collected and for any related or ancillary purpose, including but not limited to the following:-
- To respond to your requests;
- To process any orders or purchases which you make at our store;
- To manage and/or process your registration as a Member, or your sign-ups for mailing lists or promotional activities, etc.
- To communicate with you on your enquiries;
- To obtain your feedback on our services to you;
- To improve the quality of service provided to you on the Website;
- To our related companies and/or our agents for internal auditing and administration;
- For the marketing of promotions, products and services which we think may be of interest to you; and
- For conducting market research and customer satisfaction surveys on our products.
- As the Purposes for which we may collect, use, disclose or process your Personal Data depend on the circumstances at hand, such purpose may not appear above. We shall notify you of such other purpose at the time of obtaining your consent, unless processing of your Personal Data without your consent is permitted by the PDPA or by law.
5. Disclosure to third parties
- We may provide information to third parties who assist us in operating our Website, conducting our business, or servicing you, as long as these parties agree to keep the information confidential. If you can be identified from the information that is disclosed, then we will not disclose such information without prior notification to you and we will obtain your approval and opt-in in relation to such disclosure.
- Information which does not constitute Personal Data may be provided to third parties for marketing, advertising, or other uses.
- We may disclose your Personal Data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
- cases in which the disclosure is required or authorised based on the applicable laws and/or regulations;
- cases in which the purpose of such disclosure is dearly in your interests, and if consent cannot be obtained in a timely manner;
- cases in which the disclosure is necessary to respond to an emergency that threatens the health or safety of yourself or another individual;
- cases in which disclosure is necessary for any investigation or proceedings;
- cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
- cases where disclosure without your consent is permitted by the PDPA or by law.
6. Accuracy of Personal Data
- We take all reasonable measures to ensure that the Personal Data collected from you is accurate, comprehensive and up-to-date. However, if there are any errors or changes in relation to your Personal Data, you may contact us to correct such errors or to update your personal information by emailing us at TRESSE.
- Once we receive sufficient information from you to deal with your request to correct your Personal Data, we will correct your Personal Data within 30 days. Please note that the PDPA exempts certain types of Personal Data from being subject to a request for correction and also provides for situations when corrections need not be made by us despite your request.
7. Access to Personal Data
- We recognise that every individual has a right of access to his or her Personal Data. Should you wish to request for access to your Personal Data in our possession or control, you may make a written request(hereafter “Access Request”) to TRESSE and we shall endeavour to respond to your access request within 30 days, failing which at the reasonably soonest time. We reserve the right to charge a fee to recover the costs and time spent in acceding to the Access Request. Please note that the PDPA exempts certain types of Personal Data from being subject to your Access Request.
8. Withdrawal of consent
- You may withdraw your consent for the collection, use and/or disclosure of your Personal Data in our possession by submitting your request to TRESSE. If you do not want your Personal Data to be shared among our Affiliates, please inform us by sending us an email at TRESSE. If you do not wish to receive any further emails from us regarding launches, offers, promotions, special events or other information, you may unsubscribe by clicking the unsubscribe link in our mailers.
- Please note that if you withdraw your consent for a limited purpose, such as for marketing, we may still contact you or use your information for other purposes for which you have not withdrawn your consent and such Personal Data may still be used or shared, as permitted under the PDPA and other applicable law.
- We shall process your request within a reasonable time from such 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. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. Depending on the extent of your withdrawal of consent, it may mean that we will not be able to continue with your existing relationship with us.
9. Security of Personal Data
- We have a variety of security measures to ensure that your Personal Data is adequately and securely protected and stored. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your Personal Data.
- In addition, the Website has security measures in place to protect against the accidental loss, misuse, and unauthorized access to your Personal Data while under our control. Such security measures include, but are not limited to, password controls, firewalls, and other industry standard security measures.
- We have a business continuity plan which identifies business functions and assets (including Personal Data) which would need to be maintained in the event of disaster and which set out the procedures for protecting and restoring the Personal Data if necessary.
- You should be aware that no method of transmission over the Internet or method of electronic storage has 100% security. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
- We cannot assume responsibility for any unauthorised use of your Personal Data by third parties which are wholly attributable to factors beyond our control.
- We shall ensure that your Personal Data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data; and retention is no longer necessary for any other legal or business purposes.
- Where your Personal Data is to be transferred out of Singapore, we shall comply with the PDPA in doing so. This includes obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the recipient of the Personal Data is bound by legally enforceable obligations to provide a standard of protection for the Personal Data that is at least comparable to the protection under the PDPA.
10. Usage of Cookies and re-targeting technologies
- Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies. Generally, you can remove these cookies by following directions provided in your Internet browser’s “help” file. If you choose not to allow us to place a cookie on your computer, you may be restricted from some services and some of the interactive features offered on our Website may be similarly restricted or rendered inoperable.
- In addition to cookies, we may also use other Internet technologies, such as web beacons or pixeltags, and other similar technologies, to deliver or communicate with cookies and track your use of our Website. The information we obtain in this manner is primarily for statistical analysis purposes and enables us measure the overall effectiveness of our Content, advertising campaigns, and the products we offer through our Website. By accessing our Website and agreeing to receive our e-mail messages or newsletters, you agree that we can use technologies such as those mentioned above on your device(s).
- Our Website may contain web analytic services provided by third parties such as Google Analytics. This means that when you visit our Website, a cookie will be stored on your computer, except when your browser settings do not allow for such cookies. This is used to collect data about your online activities while you are on our Website for the purposes of analysis on our behalf and this information may be used to measure usage of our Website and personalize advertising content on our Website. Google Analytics acts as our agent, which means that we solely determine the purposes for which the data is being used. If you do not wish information about your behaviour at our Website to be collected and assessed by Google Analytics, you can install the Google Analytics opt-out browser add-on to opt-out of this data collection process.
- Our Website may use retargeting technologies which enables us to show our visitors advertisements from us on partner websites. We also work with other companies who use tracking technologies to serve advertisements on our behalf across the Internet. These companies may collect non-personally identifiable information about your visits to our Website. Retargeting technologies analyse your cookies and display advertisement based on your past surfing behaviour.
12. Complaint process
- Should you have any complaint regarding the way we handle your Personal Data or relating to our compliance with the PDPA, please contact us with details of your complaint via:
- Email: firstname.lastname@example.org
- All complaints will be evaluated by us in a timely manner. After we have completed the evaluation, we shall respond to the person who submitted the complaint with the results of our evaluation.