PERSONAL DATA PROTECTION POLICY

A) PERSONAL DATA PROTECTION POLICY (IN GENERAL)

We at A DrBrand Pte Ltd (“ADB”) including our subsidiaries, partners, associates, affiliates, brand advocates, brand ambassadors, third party providers, agents, resellers and distributors (collectively “Affiliates”) take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We recognise the importance of safeguarding the personal data you have provided us and it is our responsibility to properly manage, protect and process your personal data.

This Personal Data Protection Policy describes how we collect, use, disclose and/or process the personal data you have provided to us (both online and offline) through the websites, membership and other programmes, social media platforms, blogs, forums, promotions, campaigns as well as physical stores of ADB and its Affiliates (collectively “Channels”). By accessing our Channels and providing your personal data and information, you hereby consent to the use of your information, including your personal data, in the manner described in this Policy and represent and warrant that you understand the contents of this Policy. ADB may revise and/or amend and/or supplement this Policy at its discretion from time to time. Such changes will be published on our Channels.

1   INTRODUCTION TO THE PDPA

1.1 “Personal Data” is defined under 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.

1.2 We will collect your personal data in accordance with the PDPA directly from you. Our Channels will publish the purposes (refer to Paragraph [4] below) for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.

2   DATA PROTECTION OFFICER

2.1 ADB has appointed a Data Protection Officer (“DPO”) as required by the Act. The DPO has been appointed to oversee ADB’s compliance with the Act. Other employees within ADB may be delegated to act on behalf of the DPO or to take responsibility for the day-to-day collection, processing and use of personal data.

2.2 If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please contact our Data Protection Officer at

Data Protection Officer

A DrBrand Pte. Ltd.

#06-01 OC @ Pasir Panjang

100H Pasir Panjang Road

Singapore 118524

Email: dpo@a-drbrand.com

3   COLLECTION OF PERSONAL DATA

3.1 Ways in which personal data can be collected include but are not limited to:

(a) you providing it to us upon completing an application form, when you make a purchase or participate in any of our promotions or campaigns, or when you make an enquiry with us, or which is otherwise volunteered to us in any way;

(b) automatically, when you visit our online Channels using technologies such as cookies;

(c) we obtain it from other Affiliates of ADB and/or;

(d) we collect it by other lawful means

3.2 Subject to Clause 3.1, unless permitted by relevant laws, ADB shall not collect personal data without your consent.

3.3 You warrant and represent to ADB that personal data which you disclose, provide or volunteer to ADB, or to any entity that subsequently provides it to ADB, is accurate and complete.

3.4 If you disclose, provide or volunteer the personal data of another person to ADB, you warrant and represent to ADB that you have been authorised by such other person to disclose such personal data to us, and that such personal data is accurate and complete.

4   PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA

4.1 The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, which include but are not limited to:

(a) Communicating with you on your enquiries, and/or sending you marketing, advertising and promotional information and materials relating to events; productions; shows; concerts; products and/or services that we, our partners and/or third party organisations with whom we are collaborating, may be selling or marketing.

(b) Administrative matters on your sign-ups/registrations for accounts, payments or refunds.

(c) Creating, providing, maintaining and operating your membership and/or other programme accounts with us

(d) Conducting investigations or take actions in relation to bad debts, crime and fraud prevention, detection or prosecution, risk management, or to prevent you or ADB from harm, illegal or unlawful activities.

(e) Any other purposes that we notify you of at the time of obtaining your consent

(collectively, the “Purposes”)

As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will 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   SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

5.1 We respect the confidentiality of the personal data you have provided to us.

5.2 In that regard, we will not disclose your personal data to other persons or third parties for other purposes other than the ones stated under Paragraph [4] without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:

(a) cases in which external service providers, contractors and third parties provide the products and/or services (or any part of the services) on ADB’s behalf;

(b) for processing of payment to banks, credit card companies and payment vendors;

(c) for delivery of goods to courier service companies;

(d) cases in which the disclosure is required or authorised based on the applicable laws and/or regulations;

(e) cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;

(f) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;

(g) cases in which the disclosure is necessary for any investigation or proceedings;

(h) cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;

(i) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or

(j) where such disclosure without your consent is permitted by the PDPA or by law.

5.3 The instances listed above at Paragraph [5.2] are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at statutes.agc.gov.sg.

5.4 Where we disclose your personal data to third parties, we will employ our best efforts to require such third parties to protect your personal data.

5.5 To the extent that any of the communication means which you have provided to ADB (which may include your contact numbers) is/will be listed on the Do Not Call Registry, by agreeing to this Policy through the signing of our forms (either physical copies or online), or by any other means of indication, you hereby grant ADB your clear and unambiguous consent to contact you using any of the communication means you have provided to ADB for the above-mentioned purposes. If you wish to opt-out of being contacted for marketing purposes, please write in to our Data Protection Officer at: dpo@a-drbrand.com.

6   REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA

6.1 To the extent required by the Act, you may request to access and/or correct the personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. Please submit your written request to: dpo@a-drbrand.com. Pursuant to the Act, ADB is entitled to charge you a reasonable fee for this service and we will process your request upon receipt of such payment.

6.2 For a request to access personal data we will seek to provide you with the relevant personal data within 30 days of your request. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that the PDPA exempts certain types of personal data from being subject to your access request.

6.3 For a request to correct personal data, once we have sufficient information from you to deal with the request, we will:

(a) correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request; and

(b) subject to Paragraph [6.4], we will send the corrected personal data to every other organisation to which the personal data was disclosed by ADB within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.

6.4 Notwithstanding Paragraph [6.3(b)], we may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.

7   REQUEST TO WITHDRAW CONSENT

7.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request to the Data Protection Officer at: dpo@a-drbrand.com.

7.2 We will process your request within a reasonable time from such a 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.

7.3 However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us. Notwithstanding any withdrawal of consent, (a) unless otherwise agreed by ADB, you will still be bound by any contract(s) with ADB, and should you choose to terminate the relevant contract(s), early termination charges and other charges, penalties or contractual consequences may apply in accordance with the contract(s) or under relevant laws, and ADB reserves all rights thereof, and (b) ADB has the right to terminate the contract(s) in its discretion, without liability to you.

7.4 You may write in to our Customer Service at: cs@a-drbrand.com or ask@a-drbrand.com to indicate the withdrawal of your consent to receiving marketing communications from ADB. You may separately withdraw such consent via the unsubscribe options as stated on the SMS or email marketing message.

8   ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

8.1 We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by ADB to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.

8.2 We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. 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. However, we cannot assume responsibility for any unauthorised use of your personal data by third parties which are wholly attributable to factors beyond our control.

8.3 We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.

8.4 Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Act. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.

9   COMPLAINT PROCESS

9.1 If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, please contact us with your complaint or grievance.

9.2 Please contact us through one of the following methods with your complaint or grievance:

(a) E-mail Data Protection Officer at: dpo@a-drbrand.com

(b) Office address: 100H Pasir Panjang Road, #06-01 OC @ Pasir Panjang, Singapore, 118524 (Attention: “Data Protection Officer”)

9.3 We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.

10 UPDATES ON PERSONAL DATA PROTECTION POLICY

10.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.

10.2 We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our Channels.

10.3 You are encouraged to visit the Channels from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.

B) COOKIE POLICY (FOR ONLINE CHANNELS)

1   Please note that we use cookies on our online Channels. Cookies are text files that we put on your computer and they store/record information about your visit to and use of the online Channels. Cookies can compile information about your browsing habits and can also enhance your browsing experience.

2   We use cookies for the following purposes:

(a) to improve your user experience on our online Channels;

(b) to remember your preferences;

(c) to help us understand how these online Channels are performing;

(d) to monitor traffic to the online Channels;

(e) to enable these online Channels to function properly;

(collectively the “ Online Purposes”)

You can control cookies through your web browser settings. This allows you to determine which cookies to allow and which to refuse. If you disallow the use of cookies on our online Channels, please note that you may not be able to access the full range of functions that our online Channels offer. Personal data (if any) that we collect from you through cookies may be passed to our third-party service providers, whether located in Singapore or elsewhere, for one or more of the Online Purposes, for managing and/or administering our online Channels, or for the purpose of data hosting/storage/backup. Your use of our online Channels constitutes consent by you to our use of cookies and to the matters set out herein.

C) TERMS AND CONDITIONS OF USE

Your use or access or visit of our Channels including our DrGL® website, DrSpa® website and DrHair® website is expressly conditioned on your acceptance of ADB and its Affiliates’ Terms and Conditions of Use. (“Terms and Conditions”).

The Terms and Conditions apply to the use or access to the information, products and/or services available through our Channels. By using or accessing or visiting our Channels, you unconditionally agree and accept to be legally bound by the Terms and Conditions. If you do not agree with any part of the Terms and Conditions, you must not, or must cease to, use or access or visit our Channels.

Certain products and/or services have their own specific governing terms and conditions which shall apply in addition to the Terms and Conditions. These specific terms and conditions shall include any terms and conditions found on your screens and when using any part of our Channels. In the event of any inconsistency between the specific terms and conditions and the Terms and Conditions, the specific terms and conditions shall prevail in relation to the product or service in question.

1    Ownership

Our Channels and each of its respective modules, together with the arrangement and compilation of the content found on our Channels, are the copyrighted property of ADB and/or its Affiliates.

Nothing contained on our Channels should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any of the content on our Channels or Trademarks without the prior written permission of ADB, or such other party that may own the content on the site or the ADB Trademarks.

ADB and/or its Affiliates grant you a limited, non-exclusive, non-transferable right to use or access or visit our Channels in accordance with the Terms and Conditions. You agree that you:

a) shall not employ misleading email addresses and other contact details or falsify information in the header, footer, return path, or any part of any communication, including emails, transmitted through our Channels.

b) shall not copy, reproduce, republish, upload, post, transmit distribute or otherwise communicate to the public any of the content provided in our Channels, including the text, graphics, button icons, audio and video clips, digital downloads, data compilations and software, without the prior written permission of ADB and/or its Affiliates, except that you may download, display and print the materials presented on our Channels solely for your personal, non-commercial use only.

c) shall not alter, modify, translate, decompile, adapt, disassemble, reverse engineer or create derivative works from any content or component from our Channels without the prior written permission of ADB and/or its Affiliates.

d) shall not use any “robot,” “spider”, “crawler” or other automated device, or a program, algorithm or methodology having similar processes or functionality, or any manual process, to monitor or copy any of the web pages, data or content found on our Channels, in any case without the prior written permission of ADB and/or its Affiliates.

e) shall not transmit or otherwise transfer any web pages, data or content found on our Channels to any other computer, server, web site, or other medium for mass distribution or for use in any commercial enterprise. The use of such materials on any other web site or in any environment of networked computers is prohibited.

f) shall not post or transmit any information which (i) infringes the rights of others or violates their privacy or publicity rights, (ii) is protected by copyright, trademark or other proprietary right, unless with the express written permission of the owner of such right, (iii) contains a virus, bug, worm, time bomb, trojan horse, trap door or other harmful item, (iv) is used to unlawfully collude against another person in restraint of trade or competition, or (v) creates any liability on ADB and/or its Affiliates or causes ADB and/or its Affiliates to lose (in whole or in part) the services of our internet service providers or other suppliers.

You agree that you shall be solely liable for any damages resulting from any infringement of copyright, trademark, or other proprietary right, or any other loss or harm resulting from your use, access or visit of our Channels.

Registration use of our Channels may require you to register and provide certain personal information to access and/or download certain information and materials, and/or to sign-up for ADB and/or its Affiliates’ mailing lists. You may choose not to provide any personal information, but if you decline to provide any mandatory information required, you may not be able to complete the registration process.

In consideration of ADB and/or its Affiliates permitting you to use the site, in registering and providing such personal information, you represent and warrant that: (a) the information about yourself is true, accurate, current, and complete (apart from optional items) as required by various registration forms on the site (the “Registration Data”) and (b) you will maintain and promptly update the Registration Data to keep it true, accurate, current and complete. If you provide any information that is untrue, inaccurate, not current or incomplete, or if ADB and/or its Affiliates have reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, ADB and/or its Affiliates have the right to suspend or terminate your account and refuse any and all current or future access to and use of our Channels.

2    Privacy

You have read ADB’s Data Protection Policy, the terms of which are incorporated herein and which are an integral part of the Terms and Conditions, and you agree that the terms of such policy are reasonable.

You consent to the use and processing of your Registration Data and other personally identifiable user information by ADB and/or its Affiliates in accordance with the terms of and for the purposes set forth in ADB’s Data Protection Policy. You acknowledge and agree that the technical processing of our Channels and the transmission of transaction messages relating to the products and services on our Channels may involve (a) transmissions of your Registration Data and other data collected and maintained by ADB and/or its Affiliates with regard to you, over various networks and to various countries; and (b) changes to conform and adapt your Registration Data and other data collected and maintained by ADB and/or its Affiliates with regard to you to technical requirements of connecting networks or devices. 

3    Disclaimer

The information and materials contained in our Channels, including text, graphics, links or other items are provided “As is”, “As available”. No warranty of any kind (implied, express or statutory) is given in conjunction with the information and materials contained herein including but not limited to accuracy, adequacy or completeness; non-infringement of third party rights; title; satisfactory quality, merchantability; fitness for a particular purpose and freedom from computer virus. ADB expressly disclaims liability for any loss or damage arising out of or in connection with the reliance on, use of or inability to access such information and materials.

Links to third party websites contained in our Channels are provided for your convenience only, and not for the purposes of making any endorsement or recommendation thereof. ADB and/or its Affiliates do not warrant and are not responsible for the content, privacy policy or practices of websites that you access through links which are contained in our Channels.

Updated as at 21 August 2017

 

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