PRIVACY POLICY

 

Effective Date: September 1, 2021

Last updated: September 1, 2021

 

This Privacy Policy sets out the basis which Abcomo Ecommerce Pte Ltd] (“we”, “us”, or “our”) may collect, use, disclose or otherwise process Personal Data of you (“you”, “your” or “user”) in accordance with the Personal Data Protection Act (“PDPA”). This Privacy Policy applies to Personal Data in our possession or under our control, including Personal Data in the possession of organizations which we have engaged to collect, use, disclose or process Personal Data for our purposes.

In this Privacy Policy, if we refer to:

 

Platform,” we are referring to any website, media form, media channel, mobile website or mobile application of ours that references or links to this Privacy Policy;

Services,” we are referring to our Platform, and other related services, including sales, marketing, or events;

 

The purpose of this Privacy Policy is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Platform and/or Services immediately.

 

Please read this Privacy Policy carefully, as it will help you understand what we do with the information that we collect.

 

  1. COLLECTION OF PERSONAL DATA

 

1.1 As used in this Privacy Policy, “Personal Data” means data about a user 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.

 

1.2 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 authorised by you to disclose your Personal Data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised 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 which has not been notified to you (except where permitted or authorised by law).

 

1.3 Depending on the nature of your interaction with us, you acknowledge and agree that the Personal Data which we may collect from you include:

 

(a)    Your name and identification information;

(b)    Contact information such as your address, email address or phone number;

(c)    Nationality;

(d)    Gender;

(e)    Date of birth;

(f)     Photographs and other audio-visual information;

(g)    IP address;

(h)    Cookies and/or statistical/analytical data such as your browsing behaviour;

(i)     Documentation that may help us to verify the accuracy of the information you have provided, such as proof of identity;

(j)     Your social media links or public profiles, and any personal information that may be visible thereon, which you may provide to us in the course of using our Services or customer support dealings;

(k)    Payment data such as bank account information that may be necessary to process your payment if you make purchases on our Platform, all of which is stored by the third-party payment institutions and you may find their privacy policy on your payment page;

(l)     Transaction information such as purchase amount, date of purchase, information about the digital content, goods and/or services that you are purchasing, in order to pursue our legitimate interests and to abide by our contractual obligation to provide you access to our Platform and/or the Services;

(m) Any other personal information that you may provide to us in the course of using our Platform and/or Services.

 

1.4 All Personal Data that you provide to us must be true, complete and accurate, and you must notify us of any changes to such Personal Data.

 

  1. USE AND DISCLOSURE OF PERSONAL DATA

 

2.1 We use Personal Data collected via our Platform for the business purposes described below. We process your Personal Data for these purpose in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. 

 

2.2 We use the information we collect or receive for the following purpose:

 

(a)    performing obligations in the course of or in connection with our provision of the Services and/or goods requested by you;

(b)    verifying your identity;

(c)    responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

(d)    managing your relationship with us;

(e)    processing payment or credit transactions;

(f)     sending your marketing information about our Services or goods including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;

(g)    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;

(h)    any other purposes for which you have provided the information;

(i)     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, for the aforementioned purposes; and

(j)     any other incidental business purposes related to or in connection with the above.

 

2.3 You understand and accept that we may disclose your Personal Data:

 

(a)    where such disclosure is required for performing obligations in the course of or in connection with our provision of the Services or goods requested by you; or

(b)    to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 2.2 above for us.

 

2.4 The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) 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 any contract with you).

 

  1. WITHDRAWING YOUR CONSENT

 

3.1 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 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 us at the contact details provided below.

 

3.2 Upon receipt of your written request to withdraw your consent, we may require 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 ten (10) business days of receiving it.

 

3.3 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 Services or goods 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 at the contact details provided below.

 

3.4 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclose without consent is permitted or required under applicable laws.

 

  1. ACCESS TO AND CORRECTION OF PERSONAL DATA

 

4.1 You have the right to access, update, or request correction of the Personal Data that you have provided to us at any time. 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 us at the contact details provided below.

 

4.2 Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

 

4.3 We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) 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).

 

  1. PROTECTION OF PERSONAL DATA

 

5.1 To safeguard your Personal Data from unauthorised 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 and the use of privacy filters to secure all storage and transmission of Personal Data by us, and disclosing Personal Data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

 

5.2 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.

 

  1. RETENTION OF PERSONAL DATA

 

6.1 We will only keep your Personal Data for as long as it is necessary to fulfil or complete the purpose for which it was collected, or as required or permitted by applicable laws.

 

6.2 When we have no ongoing legitimate business need to retain or process your Personal Data, we will either delete or anonymize such Personal Data, or if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it form any further processing until deletion is possible.

 

  1. TRANSFERS OF PERSONAL DATA INTERNATIONALLY

 

7.1 7.1 The Personal Data that we collect from you may be transferred to, and stored at, a destination outside Singapore. It may also be processed by staff operating outside Singapore who work for us.

 

7.2 By submitting your Personal Data, you accept and agree to this transfer, storing and processing depending on applicable data localization regulations. We will take appropriate steps to ensure that your data is treated securely and in accordance with this Privacy Policy and continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

 

7.2 If you are accessing our Platform from outside Singapore, please be aware that your Personal Data may be transferred to, stored, and processed by us in our facilities in Singapore.

 

7.3 If you are a resident in the European Economic Area or United Kingdom, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your Personal Data in accordance with this Privacy Policy and applicable law.

 

  1. COOKIES AND DO-NOT-TRACK FEATURES

 

8.1 “Cookies” are a feature on your web browser which store small amounts of data on your computer when you visit a website. They allow us to recognise a particular device or browser so that we can personalise and curate content to your preferences and make our Services and Platform more useful to you. Cookies do not tell us who you are unless you specifically give us personally identifiable information. You may be able to manage and delete “cookies” by selecting certain options on your browser. 

 

8.2 Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can active to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

 

  1. LINKS TO OTHER WEBSITES

 

Our Platform may contain links to other websites which are not maintained by us. Therefore, when visiting these third-party websites, you should read their respective privacy policies, which will apply to your use of their websites. We are not responsible for the content, use, or privacy practices of these websites. 

 

  1. EFFECT OF PRIVACY POLICY AND CHANGES TO THIS PRIVACY POLICY

 

10.1 This Privacy 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.

 

10.2 We may update this Privacy Policy from time to time. You may determine if any such updated revision has taken place by referring to the date on which this Privacy Policy was last updated. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. Your continued use of our Platform and/or Services constitutes your acknowledgement and acceptance of such changes.

 

  1. GOVERNING LAW AND DISPUTE RESOLUTION

 

This Privacy Policy shall be governed by and construed in accordance with the laws of Singapore without regard to its conflicts-of-law provisions. We shall endeavour to amicably resolve any disputes that arise out of or in connection with this Privacy Policy (including any question regarding its existence, validity or termination), but in the event that such efforts shall fail, such disputes shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (“SIAC”) in accordance with the Arbitration Rules of the SIAC for the time being in force. The seat of arbitration shall be Singapore, and the Tribunal shall consist of one (1) arbitrator. All arbitration proceedings shall be in the English language. The decision of the arbitrator shall be final and binding.

 

  1. CONTACT INFORMATION

 

If you have any comments or questions about this Privacy Policy, please contact our Data Protection Officer at yoshi@abcomo.com.

 

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