DATA PROTECTION POLICY
OVERVIEW
This Privacy and Data Protection Policy (“Policy”) sets out the basis which OWELL Bodycare Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”) 2012.
This Policy applies to personal data in our possession or under our control, including personal data in the possession of organizations that we have engaged to collect, use, disclose or process personal data for our purposes. This policy also applies to information we receive from you through our website and social media platforms (“Site”) that we control.
OWELL strongly believes in protecting the privacy and security of our customers and Site visitors. Through the access and use of the Site, you have represented and warranted that you are 18 years of age or over. If you are under 18, please do not submit any personal information to us.
PERSONAL DATA
1. As used in this Policy:
“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
“personal data” means data, whether true or not, about a customer 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.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you includes:
(a) Your contact information such as name, residential address, email address, telephone numbers;
(b) Your billing and payment information;
(c) Unique information such as identification numbers, contact preferences, date of birth;
(d) Your membership details such as nationality, gender, transaction history;
(e) Services used during your visit to our physical stores such as 3-step health check records, photographs and video images.
HOW WE COLLECT OF YOUR PERSONAL DATA
3. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us (your “authorized representative”) after (i) you (or your authorized representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorized representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose that has not been notified to you (except where permitted or authorized by law).
4. We may collect your Personal Data in the following ways:
(a) When you submit an application form registering as our customer or other forms relating to any of our Products and Services;
(b) When you use our Products and Services at our physical stores.
(c) When you interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings, fax, email or social media;
(d) When you subscribe to our membership programs or sign up for our newsletters or marketing content.
(e) When you visit our site, using technologies such as cookies;
(f) When you place an order using our site;
(g) When you take part in our promotions, surveys, enter into any competitions, lucky draws, giveaways;
(h) Closed-circuit television (CCTV) recordings when you visit our physical stores or premises;
(i) From our partners or third parties via our site, or uses any of our application programs/ software;
(j) When you submit your Personal Data to us for any other reasons, including when you express your interest in any of our Products and Services;
(k) When you apply for employment with us.
5. Providing your personal information to us is voluntary. However, if you choose not to share your information with us, we may not be able to provide some or all of the products and services that you may require; and you are unlikely to receive optimal customer service experience.
6. If you are a candidate for employment, we will collect your personal data that you provide to us during the recruitment process. Such personal data may include your employment history, working eligibility rights and information contained in your resume and in any application form that we require you to fill up.
PURPOSE FOR COLLECTION, USE, AND DISCLOSURE OF PERSONAL DATA
7. We may collect, use, disclosed, and/or process your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) communicating and managing your relationship with us via SMS, WhatsApp, phone call, email, fax, mail, social media and/or any other communication channels;
(e) processing payment or credit transactions;
(f) providing personalized marketing promotions and services to you, such as analyzing and predicting your interest so as to improve your shopping experience.
(g) sending you marketing messages about our brand, products, events, offers, campaigns, programs and your entitlements under the loyalty and rewards program;
(h) facilitating your participation in, and our administration of, any events including contests, promotions or campaigns;
(i) managing and conducting internal operations including troubleshooting, market research, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, planning and statistical and trend analysis in relation to improving our products and/or services offered to you;
(j) for security and safety purpose such as detecting, investigating and preventing fraudulent, prohibited or illegal activities;
(k) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(l) transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, that we have engaged to perform any of the functions with reference to the above-mentioned purposes;
(m) carrying out verification and background checks as part of any recruitment and selection process in connection with your application for employment with us;
(n) any other incidental business purposes related to or in connection with the above;
(o) any other purposes for which you have provided the information at the time of obtaining your consent.
8. Unless permitted by the law, OWELL will not publish, share or sell your personal data to any third-party. However, in some cases, we may provide third parties such as professional consultants or external auditors with aggregated but anonymized (does not identify you) information and analytics about our customers.
9. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to your employment contract should you be hired) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
WITHDRAWING YOUR CONSENT
10. The consent that you provide for the collection, use, and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using, and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at [email protected].
11. Upon receipt of your written request to withdraw your consent, we may require a reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within fourteen (14) business days of receiving it.
12. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing.
13. Please note that withdrawing consent does not affect our right to continue to collect, use, and disclose personal data where such collection, use, and disclosure without consent is permitted or required under applicable laws.
MARKETING COMMUNICATIONS
14. If you give us your consent, you will receive marketing and promotional information about the brand, products, events, offers, campaigns, and programs through marketing communication channels like SMS, WhatsApp, phone call, email, and mail.
15. OWELL is committed to complying with the DO Not Call (DNC) provisions. We may send marketing messages to your Singapore telephone numbers if:
(a) You have given us consent, OR
(b) You have not registered with the DNC registry, OR
(c) The sending of such a message is permissible under applicable laws and regulations.
16. Should you wish to withdraw your consent for us to send you marketing or promotional information via a specific mode, please inform us in the following manner:
(a) to withdraw consent from receiving SMS promotions: please unsubscribe by following the steps provided in the promotional SMS;
(b) to withdraw consent from promotional emails: please click on the “Unsubscribe” link in the promotional emails; and
(c) to withdraw consent from receiving promotional material by mail, WhatsApp, or phone call: please email us, with the words “PERSONAL DATA” in the subject line, to our email address – [email protected].
17. Please note that once we receive your wish to withdraw, it will take us about fourteen (14) business days to update our system. Please be aware that even if you withdraw your consent for marketing communications, we will still contact you for purposes related to Products and Services, such as repair and order updates.
ACCESS TO AND CORRECTION OF PERSONAL DATA
18. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at [email protected].
19. For a request to access personal data, we shall reasonably provide you with the relevant personal data within fourteen (14) business days after receiving your request. Should we not be able to respond to your request within fourteen (14) days after receiving your request, we will inform you in writing within fourteen (14) 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).
20. Depending on the scope and nature of the work required to process your access request, we may be required to impose a fee to recover our administrative costs. This will be assessed on a case-by-case basis by our Data Protection Officer. Where such a fee is to be imposed, we will provide you with a written estimate of the fee for your consideration. Please note that we will only process your request once you have agreed to the payment of the fee.
21. For a request to correct personal data, we will correct your personal data as soon as reasonably possible. In general, our response will be within seven (7) business days, unless we have reasonable grounds not to do so.
ACCURACY OF PERSONAL DATA
22. We generally rely on personal data provided by you (or your authorized representative). In order to ensure that your personal data is current, complete, and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email [email protected].
PROTECTION OF PERSONAL DATA
23. To safeguard your personal data from unauthorized 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, use of privacy filters, and disclosing personal data both internally and to our authorized third-party service providers and agents only on a need-to-know basis.
24. 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.
RETENTION OF PERSONAL DATA
25. We may retain your personal data for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws.
26. 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, and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE SINGAPORE
27. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
THIRD-PARTY SITES
28. Our Site may include links to third-party websites. The terms of this Privacy and Data Protection Policy shall not be applicable to such websites, and OWELL is not responsible for the privacy practices of these third parties. You are advised to read the privacy policy on these websites before disclosing your Personal Data.
CONTACT OUR DATA PROTECTION OFFICER
29. If you have any inquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, please contact our Data Protection Officer either by post or by email at the following address:
Data Protection Officer
OWELL Bodycare Pte Ltd
629 Aljunied Road, Cititech Industrial Building, #07-06
Singapore 389838
Email Address: [email protected]
EFFECT OF POLICY AND CHANGES TO POLICY
30. 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.
31. We may revise this Policy from time to time without any prior notice. Any amended Personal Data Protection Policy will be posted on http://www.owellbodycare.com/privacy-policy. As such, you are encouraged to visit the above-mentioned website from time to time to ensure that you are well informed of our latest policies in relation to personal data policies. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgment and acceptance of such changes.
Last updated: 24 August 2020