Last Updated: JULY 2019
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual, including
- Postal address (including billing and shipping addresses)
- Telephone number
- Email address
- Credit and debit card number
- Profile picture
- Social media account ID
- Travel information, including trip flight information
- Date of birth
COLLECTION OF PERSONAL INFORMATION
We and our service providers may collect Personal Information in a variety of ways, including:
- Through the Services: We may collect Personal Information through the Services, e.g., when you sign up for a newsletter or make a purchase.
- Offline: We may collect Personal Information from you offline, such as when you visit our stores, attend one of our trade shows, place an order over the phone or contact customer service.
- From Other Sources: We may receive your Personal Information from other sources, such as our affiliates, public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties. In addition, if you elect to connect your social media account to your Website account, certain Personal Information from your social media account will be shared with us, which may include Personal Information that is part of your profile or your friends' profiles.
HOW WE MAY USE PERSONAL INFORMATION
We and our service providers may use Personal Information:
- To respond to your inquiries and fulfill your requests, such as to complete your transactions and provide you with related customer service.
- To send administrative information to you, such as changes to our terms, conditions and policies, as well as marketing communications that we believe may be of interest.
- To personalize your experience on the Services by presenting products and offers tailored to you and to facilitate social sharing functionality.
- To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules containing additional information about how we use and disclose your Personal Information.
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
DISCLOSURE OF PERSONAL INFORMATION
Your Personal Information may be disclosed:
- To our third-party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
- To third-party sponsors of sweepstakes, contests and similar promotions.
- By you, on message boards, chat, profile pages and blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
OTHER USES AND DISCLOSURES
We also may use and disclose your Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include such authorities outside your country of residence, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others. We may furthermore use, disclose or transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). We may also use and disclose Personal Information collected through the Services in other ways, with your consent.
“OTHER INFORMATION” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:
- Browser and device information
- App usage data
- Information collected through cookies, pixel tags and other technologies
- Demographic information and other information provided by you that does not reveal your specific identify.
- Information that has been aggregated in a manner that it no longer reveals your specific identity.
If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information, as detailed in this Policy.
COLLECTION OF OTHER INFORMATION
We and our service providers may collect Other Information in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
- If applicable, through your use of the App: When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
- Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.
, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. We also use the services of Emarsys to track and gather certain information on this website that helps us to better understand our visitors’ needs related to our website, our services and/or our products. You can learn about Emarsys’s practices by going to https://www.emarsys.com/ privacy-policy/, and opt out of them by using the “unsubscribe” link at the bottom of any email that may send you, or by emailing email@example.com.
- IP Address: Your IP address is a number that is automatically assigned to your computer by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
- Physical/Site Location: We may collect the physical location of your device by, for example, using the Internet, satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
USES AND DISCLOSURES OF OTHER INFORMATION
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
THIRD PARTY SERVICES
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
YOUR CHOICES REGARDING OUR USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from receiving electronic communications from us by (1) FOLLOWING THE UNSUBSCRIBE LINK IN ANY MARKETING COMMUNICATION, (2) LOGGING IN ON OUR WEBSITE AND CHANGING THE SETTINGS IN THE “MY PROFILE” SECTION, OR (3) BY CONTACTING US ATsam.firstname.lastname@example.org Similarly, to stop receiving SMS text messages, you will have to send an email to email@example.com to unsubscribe the SMS contact.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
HOW YOU CAN ACCESS, CHANGE OR SUPPRESS YOUR PERSONAL INFORMATION
If you would like to review, correct, update, suppress/restrict or delete Personal Information that you have previously provided to us, or if you would like to transfer your Personal Information to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us by writing to firstname.lastname@example.org or 6 Temasek Boulevard, #12-01 Suntec Tower 4, Singapore 038986 .
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). There may also be residual information that will remain within our databases and other records, which will not be removed.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.
JURISDICTION AND CROSS-BORDER TRANSFER
The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.
If you are located in the EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of protection according to EEA standards (the full list of these countries is available here a hyperlink to EU Commission’s adequacy list online: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.With regard to transfers to other countries, we have put in place measures, such as [standard contractual clauses adopted by the European Commission and binding corporate rules to protect your Personal Information. You may obtain a copy of these measures by contacting European Commission https://ec.europa.eu/info/about-european-commission/contact_en or by following this link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.