We ask that you read this Privacy and Cookies Notice carefully as it contains important information on who we are and how we look after personal information that you share with us. Looking after the information you share is important to us and we want you to be confident that your personal information is safe and secure and want you to understand how and why we collect, use and protect your personal information. The below notice explains what information we collect and why we collect it, what circumstances we share your information and the rights and choices you have in relation to your personal information.
We are Simple Wellness Pte Ltd (‘Simple Wellness’ ‘we’ ‘us’ or ‘our’), a company registered in Singapore under company registration number 201409793N.
CHANGES TO THIS PRIVACY AND COOKIES NOTICE
This Privacy and Cookies Notice was last updated on 12 April 2020. We may change this Privacy and Cookies Notice from time to time.
1.Collection of Personal Data
1.1 We may collect Personal Data from you through various means, including but not limited to instances when you:
- provide your Personal Data through our Site for the purpose of registering for and creating an account;
- apply for a membership or account with our Loyalty Program (“Loyalty Program”)
- participate in a promotion or other website features;
- request for a product information or to receive any marketing, promotional or other types of communications;
- provide your ratings and review of products as a customer;
- make purchases through our retail store or Site;
- make enquiries or comments through our Customer Department through email@example.com; and/or
- interact with our sales staff or with us, including in store via sign-up devices.
1.2 In addition to the above, we may use the following technologies (elaborated below) to automatically collect information about your activities on the Site, as the case may be (each a “Mobile Technology”):
- Cookies • Flash Cookies • Web beacons, clear pixels, or pixel tags • Analytical tags • Web server logs • Geo-location technologies
1.3 You have no obligation to provide any of the Personal Data requested by us. However, depending on circumstances, it may be the case that if you do not provide the requested Personal Data, we may not be able to provide you with certain products and services, or transact with you, that depend on the collection, use or disclosure of your Personal Data.
2. Children’s Privacy
2.1 We do not and do not intend to, transact through the Site directly with anyone we know to be under the age of 18. If you are under the age of 18, you should use the Site only with the involvement of a parent or guardian and should not submit any Personal Data to us. By providing any Personal Data to us, you declare that you are over the age of 18.
3.Purposes For Collection, Use, Disclosure And Processing Of Personal Data
3.1 Simple Wellness will/may collect, use, disclose and/or process your Personal Data for one or more of the following purposes:
(a) administering, facilitating, processing and/or dealing in any matters relating to your use or access of the Site. Without limiting the generality of the foregoing, if you:
(i) gain access to or sign in to the Site, using your login credentials of a Social Networking Site, or (ii) use any features of a Social Networking Site such as its widgets, plug-ins and browser push notifications, made available to you on our Site, it may result in information or your Personal Data being collected or shared between us and the third party. For example, if you use Facebook’s “Like” feature, Facebook may register the fact that you “liked” a product and may post that information on Facebook. (“Social Networking Site” refers to an online or digital platform owned or operated by a third party, that is used by people to build social networks or social relations, or to interact, with other people, such as but not limited to Facebook, Instagram, Twitter). By your proceeding pursuant to (i) or (ii) above, you consent to such collection, use or disclosure of your Personal Data;
(b) monitoring, processing and/or tracking your use of the Site in order to provide you with a seamless experience, facilitating or administering your use of the Site, and/or to assist us in improving your experience in using the Site;
(c) assessing and processing your request for the purchase of and/or subscription to our products and/or services;
(d) registering you as a customer of Simple Wellness and/or to deal with, process and/or administer the account that you may open with us, including to facilitate your transactions or activities on the Site, or your transactions or activities with us;
(e) administering, facilitating, processing and/or dealing with your relationship with us, any transactions or activities carried out by you on the Site or at our retail stores. This includes processing your application, orders and payment transactions; implementing transactions and the supply of products and/or services to you that you have requested. Without limiting the generality of the foregoing, should you make a purchase to be delivered to a third party recipient, you consent to us disclosing Personal Data that identifies you, to the said third party recipient (such as but not limited to your name). Further, you acknowledge and agree that delivery of your purchase could involve disclosure of certain Personal Data about you to bring about delivery of the same such as your name and contact details, which may be disclosed on the cover of the parcel, on an envelope or a delivery related document, as the case may be, which could be seen by third parties who view such parcel, envelope or said document;
(f) carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf including responding to your customer service enquiries and complaints; or responding to or dealing with your interactions with us;
(g) contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for the purposes of administering and/or managing your use of the Site, your loyalty program membership and/or account with us, your relationship with us or any transactions made by you with us. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain Personal Data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
(h) providing services to you as our account holder, as our customer, as a member of our loyalty program(s) or when requested by you; dealing with or administering your participation in contests, gamification, social events organized by us;
(i) sharing or disclosing (at our discretion) your suggestions, comments, feedback or content (including audio, video etc.) (collectively “Feedback” ) that you provide through Social Networking Sites, to the Site or to us (including at the retail stores), with other users of the Site or with the public, for publicity and/or promotion purposes with a view to marketing or showcasing the business of Simple Wellness, and/or to acquiring customers, and/or for the purpose of providing the public with your Feedback which may be useful for the public’s purchasing decision or for the public’s information or otherwise. This includes us disclosing your name together with your Feedback. Without limiting the generality of the foregoing, in the above regard, your Feedback and name may/will be published or shared by us on public media platforms such as the newspaper, the Internet, in our (including our affiliates’) annual reports (if any) etc., and/or incorporated as part of Simple Wellness’ marketing collaterals/materials or corporate video to be disclosed to the public, and you hereby consent to the same. Do not provide us with Feedback if you do not wish for such Feedback to be disclosed to the public. If you wish to give us your Feedback without it being disclosed to the public, please separately email our Customer Department at firstname.lastname@example.org and head the subject of your email with the word “Confidential”;
(j) carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations (whether Singapore or foreign Country/Region) applicable to us or our affiliates/associated companies, the requirements or guidelines of governmental authorities (whether Singapore or foreign Country/Region) which we determine are applicable to us or our affiliates/associated companies, and/or our risk management procedures that may be required by law (whether Singapore or foreign Country/Region) or that may have been put in place by us or our affiliates/associated companies;
(k) to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with and/or investigating complaints;
(l) complying with or as required by any applicable law, court order, order of a regulatory body, governmental or regulatory requirements of any jurisdiction applicable to us or our affiliates/associated companies, including meeting the requirements to make disclosure under the requirements of any law binding on us or our affiliates/associated companies, and/or for the purposes of any guidelines issued by regulatory or other authorities (whether of Singapore or elsewhere), with which we or our affiliates/associated companies are expected to comply;
(m) complying with or as required by any request or direction of any governmental authority (whether Singapore or foreign Country/Region) which we are expected to comply with; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities (including but not limited to Singapore Customs and Ministry of Health) (whether Singapore or foreign Country/Region). For the avoidance of doubt, this means that we may/will disclose your Personal Data to such parties upon their request or direction;
(n) conducting research (including customer research), surveys, market surveys, analysis and/or development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services and facilities, or to improve our understanding of your interests, concerns and preferences, in order to enhance any continued interaction between yourself and us connected or in relation to the Site, or improve any of our products or services. Without limiting the generality of the foregoing, we may/will in this regard send you surveys or request a face to face interview survey, by way of email or postal mail;
(o) storing, hosting, backing up (whether for disaster recovery or otherwise) of your Personal Data, whether within or outside Singapore;
(p) facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of Simple Wellness or that of its affiliates/related corporations;
(q) for marketing purpose and in this regard, we would be providing you with marketing, advertising and promotional information, materials and/or documents relating to products, contests, services and/or events (including those of third party organisations whom Simple Wellness may collaborate with) that Simple Wellness (including its affiliates/related corporations) or such third party organisations may be selling, marketing, offering, organizing, involved in or promoting, whether such products, services and/or events exist now or are created in the future:
(ii) if you have separately expressly consented to one or more of the following 3 DNC Modes, by way of the 3 modes of communications of voice calls, text messages or faxes (the “3 DNC Modes” ) to your Singapore telephone number, in compliance with the requirements of the PDPA.
For the avoidance of doubt, this subparagraph is without prejudice to subparagraph (o) above for which you have hereby consented to us contacting you for a survey, which you may subsequently opt out of by sending our Data Protection Officer notice;
(r) dealing with and/or facilitating a business asset transaction or a potential business assert transaction, where such transaction involves Simple Wellness as a participant or involves only a related corporation or affiliated company of Simple Wellness as a participant or involves Simple Wellness and/or any one or more of Simple Wellness’ related corporations or affiliated companies as participant(s), and there may be other third party organisations who are participants in such transaction. “business asset transaction” means the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation;
(s) to implement and maintain our information technology systems, including to store and process Personal Data in computer databases and servers located within and outside Singapore;
(t) anonymization of your Personal Data. In this regard, you acknowledge that Personal Data that has been anonymized is no longer Personal Data and the requirements of the PDPA would no longer apply to such anonymized data;
(u) record-keeping purposes and producing statistics and research for internal and/or statutory reporting and/or record-keeping requirements, of Simple Wellness or of its affiliates/related corporations; and
(v) Simple Wellness’ reporting purposes including but not limited to reporting on Simple Wellness’ business performance;
(the purposes set out in this paragraph 3.1 above shall be collectively referred to as the “Purposes”).
3.2 For the avoidance of doubt, you acknowledge and consent to Simple Wellness sharing anonymised information such as but not limited to in the following circumstances. For the further avoidance of doubt, the PDPA does not apply to anonymised data that does not identify an individual and the PDPA does not provide you with a right to object to an organisation handling or processing anonymised data:
(a) Aggregate information. We may share anonymised aggregate information about our customers with advertisers and marketing partners;
(b) Behavioural-based advertising. A third party may use technology to collect anonymised information about your use of Site so that they can provide advertising about products and services tailored to your interest. That advertising may appear either when you are using the Site, or using the Internet or your mobile device to visit other websites.
4. Sharing and Disclosure of Personal Information
4.1 Simple Wellness may/will need to disclose your Personal Data to third parties, whether located within or outside Singapore, for one or more of the above Purposes, as such third parties, would be processing your Personal Data for one or more of the above Purposes. In this regard, you hereby acknowledge, agree and consent that we are permitted to disclose your Personal Data to such third parties (whether located within or outside Singapore) for one or more of the above Purposes and for the said third parties to subsequently collect, use, disclose and/or process your Personal Data for one or more of the above Purposes. Without limiting the generality of the foregoing or of paragraph 3, such third parties include:
(a) any of our agents, contractors or third party service providers that process or will be processing your Personal Data on our behalf or otherwise, including but not limited to those which provide administrative or other services to us such as mailing houses, call centres, telecommunication companies, logistics companies, information technology companies and data centres;
(b) our business partners;
(c) any actual or proposed assignee or transferee of the business of Simple Wellness, or a merged entity in the event Simple Wellness is merged to create the said merged entity;
(d) any other person to whom such disclosure is required by law or regulatory requirement or pursuant to a court order;
(e) third parties to whom disclosure by Simple Wellness is for one or more of the Purposes and such third parties would in turn be collecting and processing your Personal Data for one or more of the Purposes.
4.2 We will provide our preferred service providers with the information they need to perform their services and work with them to respect and protect your Personal Data. We require our service providers to adhere to strict privacy guidelines and not to use your Personal Data for unauthorised purposes.
4.3 Where your Personal Data is to be transferred out of Singapore, we will comply with the PDPA in doing so. This includes taking appropriate steps to ascertain that the overseas 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 PDPA.
5. Provision Of Third Party Personal Data By You
5.1 Should you provide Simple Wellness with Personal Data of individual(s) other than yourself, you represent and warrant to Simple Wellness and you hereby confirm that:
(a) prior to disclosing such Personal Data to us, you would have and had obtained consent from the individuals whose Personal Data are being disclosed to us, to:
(i) permit you to disclose the individuals’ Personal Data to Simple Wellness for the Purposes; and
(ii) permit Simple Wellness to collect, use, disclose and/or process the individuals’ Personal Data for the Purposes, as set out in paragraph 3 above;
(b) any Personal Data of individuals that you disclose to us is accurate; and
(c) you are validly acting on behalf of such individuals and that you have the authority of such individuals to provide their Personal Data to Simple Wellness and for Simple Wellness to collect, use, disclose and process such Personal Data for the Purposes.
6. Request For Access And/ Or Correction Of Personal Data
6.1 You may request to access and/or correct your 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, to deal with your request. Please submit your written request to email@example.com.
6.2 For a request to access Personal Data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant Personal Data within 30 days. 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. 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 deal with your request in compliance with the PDPA, including 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.
6.4 We may also charge you a reasonable fee for the handling and processing of your requests to access your Personal Data. If so, we will provide you with a written estimate of the fee. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
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 firstname.lastname@example.org.
7.2 We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will subsequently not collect, use and/or disclose your Personal Data in the manner stated in your request, unless the law or the PDPA allows us to.
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 may not be able to fulfill the transaction you have entered into with us or continue with your relationship with us, or send you information that you have requested, as examples depending on the circumstances.
8. Protecting and Managing Your Personal Data
8.1 We will endeavour to take all reasonable steps to ensure your Personal Data is kept confidential and secure, and to take appropriate technical and organizational measures to prevent unlawful or accidental destruction, accidental loss, unauthorized disclosure or access or other unlawful forms of processing. We will not rent, trade, distribute or sell any Personal Data that you give us to any third party unless we receive your prior consent or applicable law permits the same.
8.2 We will 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 unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your Personal Data. However, we cannot assume responsibility for any unauthorized use of your Personal Data by third parties which are wholly attributable to factors beyond our control.
8.3 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 us 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 you not updating us of any changes in your Personal Data that you had initially provided us with.
8.4 We will also put in place measures such that your Personal Data in our possession or under our control is destroyed and/or anonymized 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.
9. Cookies and Mobile Technology
9.2 Flash Cookies. "Flash Cookies" (also called Local Shared Objects or "LSOs") are data files similar to cookies, except that they can store more complex data. Flash Cookies are used to remember settings, preferences, and usage, particularly for video, interactive gaming, and other similar services.
9.3 Web Beacons. Web beacons are small graphic images on a web page or in an e-mail that can be used for such things as recording the pages and advertisements clicked on by users, or tracking the performance of e-mail marketing campaigns.
9.4 Analytics Tags. We use analytical tags to analyse what our clients like to do and the effectiveness of our features and advertising. They can also help us customize your browsing and shopping experience. We may use information collected through analytical tags or tracked links in combination with your Personal Data. We may also combine Personal Data you provide to us with other Personal Data (such as purchase history and demographic information).
9.5 Web Server Logs. Web server logs are records of activity created by the mobile device or computer that delivers the webpages you request to your browser. For example, a web server log may record the search term you entered or the link you clicked to bring you the webpage. The Web server log also may record information about your browser, such as your IP address and the cookies set on your browser by the server.
9.6 Geo-Location Technologies. Geo-location technology refers to technologies that permit us to determine your Country/Region. We may ask you to manually provide Country/Region information (like your postal code), or to enable your mobile device to send us precise Country/Region information.
10. Placing an order
10.1 We keep details of the transactions you make through our Site and the fulfilment of orders. This includes payment details, your name, billing and postal addresses, the items you ordered and your email and telephone number.
(a) If you checkout as a guest we will store your order details; name, email address, billing and shipping address, order details and payment method.
(b) We collect details of your visits to our Site including, but not limited to, if applicable which URL you used to get to our Site, searches you make, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access. We collect these details to better understand how our customers arrive on and use our Site and enable us to improve them.
(c) If you purchase a Gift Card the details of both the sender (you) and the recipient (if applicable) are stored in your order history.
10.2 Payment. We use a third-party ecommerce provider, Shopify, to provide our payment gateway and to record our order fulfilment. This includes name, billing and shipping address and order amount which will check if your payment passes fraud security.
(a) If PayPal is chosen as the payment method, you will be taken to the PayPal Site to complete payment by logging into your PayPal account and confirming payment is to be made.
(b) All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology.
10.3 Delivery. We use various third-party logistics partners including Qxpress Delivery and Ninja Van to fulfil our order delivery. We pass your name, telephone and postal address plus order value (for insurance purposes) to these contractors so that they can track and deliver your parcel and communicate with you via telephone to provide the delivery time details.
(b) Instagram: We use Instagram to post marketing activity, we occasionally use the paid advertising service to target users based on demographics. We promote products, offers, news and brand messages – this is all run through the Facebook Advertising platform.
12. Prize Draws, Promotions and Surveys
12.1 When entering our prize draws or promotions, you may be required to provide us with your name, email address and mailing address. We use a third party provider, PromoVeritas, to choose a winner at random. Name and email address data is passed to PromoVeritas to carry this service out and deleted once the winner has received their prize. If you win, we will notify you as described in the prize draw/promotion terms and will send the prize to the address you provide to us. When you enter a prize draw or promotion, you are also able to opt-in to hear from us by email or post and be the first to know about our prize draws, offers and news. You may unsubscribe from this by following the unsubscribe instructions in any email received.
12.2 We will only contact you following a prize draw / promotion if you opted-in to do so. Unless you have opted-in to receiving marketing communications, your data will be deleted after 3 months.
12.3 Occasionally, we run joint prize draws / promotions with other likeminded companies where data will be collected on entry, we collect this data but do not distribute it. It’s used for our own marketing purposes and will only be shared with the partner company with your express permission.
12.4 We use third party providers such as SurveyMonkey, Google Forms and Mention Me to carry out surveys and promotions on our behalf. If you agree to take part, your data will be processed in accordance with their privacy notices as appropriate for the purposes of carrying out and administering the services which they offer. The responses and data you provide will be used by us for research and marketing purposes which will enable us to improve and enhance the services and experiences we offer to you. For example, we may publish a quote/review on our Site or a catalogue, that you have provided about a product.
12.5 We use internal analytics software to run business analysis on customer transactional data, this imports from our Site, instore POS system, payment gateways and databases. The data includes name, addresses and email of those who have placed an order including the related transactional data. This is so we can ensure we offer the best promotions, offers and discounts.
13. Site Development and Maintenance
We use a third-party ecommerce provider Shopify to support the maintenance and development of the Site. This means that they can see and access live customer data if required. This only happens if we are making improvements to areas such as your account functionality, improvements in ordering or other areas that interact with customers and their data. They cannot export this data without our approval or use it for anything other than providing us support to improve our service to you.
14. Registration Information
Our Site contains areas where you can submit information to us (such as our registration service), and we also have features (such as cookies and performance tracking technology) that automatically collect information from the visitors to our Site. During the registration process, you must provide us with a password, your name, address and a valid email address, etc. It is your responsibility to keep your password strictly confidential.
16. Problems, queries or complaints
16.2 You may also contact us at the details above if you have a complaint about how we have handled your Personal Data. We will investigate your complaint and will use reasonable endeavours to respond to you in writing as soon as possible.
17.2 For the avoidance of doubt, in the event that Singapore Personal Data protection law permits an organisation such as us to collect, use or disclose your Personal Data without your consent, such permission granted by the law shall continue to apply.