Colour Shop Pte Ltd
1.1 This Policy statement provides information on the obligations and policies of the Company in respect of an individual customer’s Personal Data. The Company undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
1.2 The Company’s officers, management, and members of staff shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, the Company. The Company shall use reasonable endeavours to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data by the Company shall be done in an appropriate manner and in accordance with the Act and this Policy.
1.3 By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to the Company as well as to its respective representatives and/or agents (“Representatives”) (collectively referred to herein as “The Group”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the [Group’s] authorised service providers and relevant third parties in the manner set forth in this Privacy Statement.
1.4 This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.
1.5 For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual customer who can be identified —from that data; or from that data and other information which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of the Company or that which shall be collected by the Company in future.
2. Contacting the Data Protection Officer
2.1 Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data that is in the possession and control of the Company, the Company shall provide and/or correct that data in a reasonable time and manner in accordance with its standard procedures as stated hereinafter.
2.2 In accordance with the Act, the Company has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that the Company receives your complaints and enquiries, please send the same via email to the Data Protection Officer at email@example.com.
2.3 Please note that if your personal data has been provided to us by a third party (e.g. a member via a referral process), you should contact that individual to make such queries, complaints, and access and correction requests to the Company on your behalf.
2.4 Should you not wish the Company to use your Personal Data for any of the purposes listed in Clauses 3.2to 3.4, or not to receive promotional materials from the Company, you may opt out by sending a clearly worded email to the DPO via the email address provided in Clause 2.2. Your request shall be processed within a reasonable time.
3. Statement of Practices
Types of Personal Data Collected:
3.1 As part of its day-to-day activity, the Company may collect from you, through various means, including via our websites, smart phone applications, marketing events such as road shows and any forms used by the Company from time to time, some or all of the following Personal Data:
- Name (first and surname);
- Postal Address;
- Phone number (including mobile);
- Office number;
- Fax number;
- Email address;
- Bank account/credit card details;
- Personal Data of your emergency contacts;
- IP addresses; and
- Photographs and images.
Purpose of Collection of Personal Data
3.2 The above Personal Data mentioned in Clause 3.1 is collected for the purposes of contacting you to inform you about the updates on the progress of your order; for payment and/or credit control purposes; to notify you of any changes to our policies or services which may affect you; to respond to queries and feedback; for identification and verification; for delivery of any deliverables to you; and informing you of new developments, services, promotions of Company and other third parties which we are associated with.
Disclosure of Personal Data
3.3 In order to carry out the functions described above, the Company may, from time to time, disclose your Personal Data to various parties that work with us to provide with the top service we take pride in.
3.4 The Company may disclose your Personal Data to the following third parties:
- Regulators and law enforcement officials;
- Third party service providers and consultants;
- Credit, debit and charge card companies, banks and other entities processing payment;
- Potential buyers or investors of the Company;
- Any agent or subcontractor acting on the Company’s behalf for the provision of the Company’s services; and
- Other client’s of the Company as part of the Company’s portfolio.
3.5 The Company may disclose your Personal Data to the above mentioned parties also in the occurrence of any of the following events:
- To the extent that the Company is required to do so by the law;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise or defend the Company’s legal rights;
- To the purchaser (or prospective purchaser) of any business or asset which the Company is (or is contemplating) selling;
- To any person and/or entity for the purpose of processing such information on the Company’s behalf;
- To third parties who provide services to the Company or on its behalf;
- To any third party that purchases the Company or the Company’s business or any part of the Company or the Company’s business;
- With your consent; and
- For the purposes of disaster recovery.
- Optional Provision of Personal Data
3.6 In some instances, you may also be requested to provide certain Personal Data that may be used to further improve the Company’s products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependent on your providing all requested data, failure to provide the requested data may prevent the Company from providing the service to you. This type of data includes, but is not limited to:
- Your age;
- Salary range and employment details;
- Education and Profession;
- Hobbies and leisure activities;
- Other related products and services subscribed to; and
- Family and household demographics.
3.7 Under certain circumstances, telephone calls made to the Company are recorded for the purposes of quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your clear and unambiguous consent for the collection, use and disclosure of such Personal Data in accordance to this Policy.
4. Transfer of Personal Data Overseas
Your Personal Data may be processed by the Company, its affiliates, agents and third parties providing services to the Company, in jurisdictions outside of Singapore. In this event the Company will comply with the terms of the Act.
5. Accuracy of Personal Data
Where possible, the Company will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, the Company is able to validate the data provided against pre-existing data held by the Company. In some cases, the Company is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of the Company, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2.2.
6. Protection of Personal Data
The Company uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside the Company, other than to you or as described in this Policy. However, the Company cannot ensure or warrant the security of any information you transmit to the Company and you do so entirely at your own risk. In particular, the Company does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of the Company’s physical, technical, or managerial safeguards.
7. Access and Correction of Personal Data
7.1 In accordance with Clause 2.1 of this Policy, you have the right to:
a) Check whether the Company holds any Personal Data relating to you and, if so, obtain copies of such data; and
b) Require the Company to correct any Personal Data relating to you, which is inaccurate for the purpose for which it is being used.
7.2 The Company reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 7.1. Upon payment of the requisite fee, your request shall be processed within a reasonable time.
7.3 If you wish to verify the details you have submitted to the Company or if you wish to check on the manner in which the Company uses and processes your personal data, the Company’s security procedures mean that the Company may request proof of identity before we reveal information. This proof of identity will take the form of full details of name and NRIC or Passport or Fin number. You must therefore keep this information safe, as you will be responsible for any action, which the Company takes in response to a request from someone using your details.
8. Storage and Retention of Personal Data
The Company will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of the Company and where the Personal Data is deleted from the Company, electronic, manual, and other filing systems in accordance with the Company internal procedures and/or other agreements.
9. Contacting you
To the extent that any of the communication means which you have provided the Company with (which may include, your telephone number and fax number) is/will be listed on the Do Not Call Registry (the “DNC”), by agreeing to this Policy through your acceptance of our quotation, or by any other means of indication, you hereby grant the Company your clear and unambiguous consent to contact you using all of your communication means you have provided to the Company including using via voice calls,
SMS, Whatsapp, MMS, fax or other similar communications applications or methods, for the purposes as stated above in Paragraph 3.2. This will ensure your continued enjoyment of the Company’s promotional rates and services
10. Change Policy
The Company reserve the right to alter any of the clauses contained herein in compliance with local legislationand/or to meet its global policy requirements, and for any other purpose deemed reasonably necessary by the Company. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
11. Governing Law
This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.
12.1 This Policy only applies to the collection and use of Personal Data by the Company. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. The Company does not share your Personal Data with third party websites. The Company is not responsible for the privacy and conduct practices of these third party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.
12.2 The Company will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites which you may have linked or been directed to the Company’s website.
12.3 The Company’s website does not target and is not intended to attract children under the age of 18 years old. The Company does not knowingly solicit personal information from children under the age of 18 years old or send them requests for personal data.