For more information about the PDPA, please visit the Personal Data Protection Commission’s website at http://www.pdpc.gov.sg.
- INFORMATION COLLECTION
This Site collects information about you to provide and improve our services, communicate offers that we believe will interest you, and to administer our business.
INFORMATION YOU PROVIDE TO US
We collect personal information from you when you submit that information to us voluntarily. For example, we collect information from you when you create an account on the Site, sign up for our newsletter or marketing text, place an order on the Site, participate in our rewards program; communicate with our customer service team online; participate in a promotion, such as a contest; post a tagged photo or other content on a third party social network in response to our requests; or post a product review, question, answer, or other information on the Site. Additionally, if you make a purchase, we work with a third-party payment processor to collect and process your payment information.
The personal information we collect may include the following: name, email address, shipping/billing address, phone number, payment information such as credit card information. Collecting this information allows us to complete your order efficiently, to notify you of your order status, and provide personalized interactions. We may also ask you to provide other information, such as demographic information (gender, age) or about your product preferences and interests. If you register at this Site, enter a promotion, opt-in to receive emails, marketing texts, newsletters or other offers or communications, we collect and store the information provided. You can choose not to provide certain information, but you might not be able to take advantage of some of our features including customization and communication.
When you purchase something from our store, as part of the buying and selling process, we collect the personal information you give us such as your name, address, contact number and email address.
When you browse our store, we also automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system.
Email marketing: With your permission, we may send you emails about our store, new products, and other updates.
Text marketing: With your permission, we may send you text messages about our store, new products, and other updates.
INFORMATION ON THIRD PARTY SOURCES
We may collect information about you from third parties. Such information may include demographic data (such as age and gender) and purchase preference information. We may use this information to supplement or update our records, improve the quality or personalization of our communications to you, and help prevent or detect fraud.
We obtain information from other sources. For example, we may collect information about you from the Shopify platform. We may also collect information about you from third-party services and organizations such as: identity verification services, financial services providers, data brokers, advertising networks, data analytics providers, or mailing list providers. This information may include identifiers such as real name, alias, postal address, or other similar identifiers, and inferences reflecting your consumer preferences, characteristics, and predispositions. Additionally, if applicable, if you create or log into your account with us through a third-party application, such as an app store, a third-party login service, or a social networking site, we will have access to certain information from that application, such as your name, birthday, and profile picture, in accordance with the authorization procedures determined by such application.
AUTOMATED INFORMATION COLLECTION
We automatically receive and store certain types of information when you interact with our Site, our emails, and/or our online advertisements. This information helps us to make our Site work more efficiently, evaluate use of our Site, and support our website analytics and marketing campaigns. Here are some of the types of information we may automatically receive:
Technical information like your internet protocol (IP) address, your device operating system and browser type, your referring website's address, and your clickstream through our Site.
The cookies used on this website are as follows:
- Strictly Required Cookies - These cookies are required for the website to run and cannot be switched off. Such cookies are only set in response to actions made by you such as language, currency, login session, privacy preferences. You can set your browser to block these cookies but this might affect the way our site is working.
- Analytics and Statistics - These cookies allow us to measure visitors traffic and see traffic sources by collecting information in data sets. They also help us understand which products and actions are more popular than others.
- Marketing and Retargeting - These cookies are usually set by our marketing and advertising partners. They may be used by them to build a profile of your interest and later show you relevant ads. If you do not allow these cookies you will not experience targeted ads for your interests.
- Functionality Cookies - These cookies enable our website to offer additional functions and personal settings. They can be set by us or by third-party service providers that we have placed on our pages. If you do not allow these cookies, these or some of these services may not work properly.
MOBILE APPLICATIONS AND WEBSITE
When you use our mobile website, we may receive information about your location and your mobile device. This information may include the type of mobile device you use, the temporary or persistent unique device identifier (UDID) placed by us or our service providers, the unique identifier assigned by us to your device, the IP address of your device, your mobile operating system, the type of mobile web browser you use, and data from the way you use our mobile website.
Our mobile website may also collect information about the location of your device. Your device should require you to provide permission before our mobile website obtains location information from technologies like GPS, Wi-Fi, and/or cell towers. We and our service providers may use this information, along with other information submitted by you, to provide you with location-based services like local store information, search results, special offers, and other personalized content.
Most mobile devices allow users to disable location services by using controls located in the device's settings menu. If you have questions about how to disable your device's location services, please contact your mobile service carrier or your device manufacturer.
SOCIAL MEDIA WIDGETS AND SINGLE SIGN-ON SERVICES
This Site may use third party social media widgets such as buttons or similar mechanisms from Facebook, Twitter, Instagram, Pinterest, and Google. Such third party features may collect information about you, like your IP address and the page(s) you visit on the Site. They may also place cookies on your device. These social media widgets are either hosted by a third party or by our Site. Your interactions with those features are governed by the privacy policies of the third party social media networks that provide them.
CHILDREN UNDER 13 YEARS OF AGE
This Site is directed to adults, and does not knowingly collect personal information online from children under the age of 13 without prior parental consent and if we become aware that we have inadvertently received personal information from a visitor under the age of 13 on the Site, we will delete the information from our records. If you are the parent or guardian of a child under the age of 13, and you believe your child has provided personal information to our Site that you would like us to delete, please contact us. Also, if you are under the age of 13, you must not submit personal information to us.
- INFORMATION USE, DISCLOSURE, AND SHARING
The information we collect on this Site may be used to fulfil your requests (such as responses to email questions and product orders), to support our core business functions (such as order fulfilment, internal business process management, authentication, loss and fraud prevention), and when in line with the preferences you have shared with us, provide you with information or advertising relating to our product offers and promotions. You can sign up for our electronic mailing list by providing your email address through our Site services. When you provide your e-mail address to us, you agree to receive product offers, promotions, and newsletter emails of the Company.
We may make third party services, including third party applications, available to you on this Site. We use third party payment service providers to process your purchases. We do not store or have access to your full credit card information or bank account information. We use third party fulfilment service providers to process and deliver your orders. All such information is stored by such third party service providers.
We may disclose your personal information to identify you to anyone to whom you send messages via the Site. You may also disclose your own personal information on interactive services such as message boards, product reviews, question-and-answer pages, profile pages, and social network features offered by us or by third parties. Information you post or disclose through such interactive services may be available to the general public. Please exercise caution when deciding whether to disclose your personal information, location, or similar information via this Site.
We may combine information about you that we collect online, via mobile applications, and from third party sources. We may also transfer or disclose your information we collect about you (including personally identifiable information) to the Company’s group of companies including the Company’s parent/holding company, subsidiaries, related and/or associated companies that are located in different countries, including, but not limited to, the Republic of Singapore, third parties to comply with applicable laws, regulations, and/or governmental requests. By using the Site, you consent to us transferring your data to these countries. Please note that laws vary from jurisdiction to jurisdiction, and so laws and regulations relating to privacy and data disclosure, applicable to the places where your information is transferred to or stored, used or processed in, may be different from the laws and regulations applicable to the place where you are a resident.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
- PUBLIC FORUMS
Please remember that any information you may disclose in public areas of our Site or the Internet becomes public information. You should exercise caution when deciding to disclose personal information in these public areas.
Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Company and/or the Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
- TEXT MARKETING NOTIFICATIONS
By subscribing to our text marketing, you agree to receive automated text messages from us about our products and services at the phone number you provided when you subscribed, and that the messages may be sent via an automatic telephone dialling system or other technology (“Service”). Your consent to receive autodialled marketing text messages is not required as a condition of purchasing any goods or services. If you have opted in, the Service provides updates, alerts, information, promotions, specials, and other marketing offers (e.g., cart reminders) from the Company via text messages through your wireless provider to the mobile number you provided. Message frequency varies. Text the single keyword command STOP, STOPALL, UNSCUBSCRIBE, CANCEL, END or QUIT to cancel at any time. You will receive a one-time opt-out confirmation text message. If you have subscribed to other Company’s mobile message programs and wish to cancel, you may need to opt out separately from those programs by following the instructions provided in their respective mobile terms. For Service support or assistance, reply text with keyword HELP or INFO or email firstname.lastname@example.org. We may change any short code or telephone number we use to operate the Service at any time and will notify you of these changes. You acknowledge that any messages, including any keyword requests, you send to a short code or telephone number we have changed may not be received and we will not be responsible for honouring requests made in such messages.
- OPTING OUT
If you wish to withdraw your consent for our use of your personal data, you may do so in the following ways:
- To unsubscribe from our electronic mailing list, follow the unsubscribe instructions in our emails or other electronic marketing materials;
- To unsubscribe from our text marketing notification list, follow the opt-out instructions provided in paragraph 4 (Text Marketing Notifications) above; or
- If you have an online subscription or membership account with us, you may access your account(s) with us to change your settings; or
If you would like to stop receiving promotions, updates and/or special offers, or any form of targeted advertising, at any time, you may contact our Data Protection Officer in the manner set out below with a statement requesting that you wish to opt out of our email promotions, updates and special offers. Please allow sufficient time for your request to be processed. It may take up to 10 days to process an email opt-out request, and 4-6 weeks for other requests. Please be aware that, even if you opt out of receiving marketing communications from us, we may still contact you for transactional purposes. For example, we may contact you for order fulfilment purposes, customer service purposes, or product recalls.
- DATA TRANSFERS AND INTERNATIONAL DATA TRANSFERS
Whenever we transfer personal data, we take legally required steps to make sure that appropriate safeguards are in place to protect your personal data.
- DATA RETENTION
- GENERAL DATA PROTECTION REGULATION (GDPR)
We maintain our commitment to protect the privacy of our users and abide by the legislation of all regions we operate. We are willing to deliver the best experience to our end-users. Considering the above, personal data (if any) of our users is processed under the “purposes of legitimate interests” as outlined in Article 6(1)(f) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). GDPR applicable to all residents of the European Economic Area (“EEA”).
If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you. We might engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.
Our processor - Shopify uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you. Services that include elements of automated decision-making include:
- Temporary blacklist of IP addresses associated with repeated failed transactions. This blacklist persists for a small number of hours.
- Temporary blacklist of credit cards associated with blacklisted IP addresses. This blacklist persists for a small number of days.
If you are a resident of the EEA, you have the right to understand the processing of your personal data, right to access the personal information we hold about you, to port it to a new service, and to ask that your personal information be corrected, updated, or erased or to stop or restrict the processing of your personal data under certain grounds. If you would like to exercise these rights, please contact our Data Protection Officer in the manner set out below – paragraph 12.
The provisions of GDPR can be also applied to how data is processed and verified outside the European Union. Such an approach also helps us to fight against fraud and reimburse our contractors and agents. In accordance with the applicable laws, users are authorized to access and modify their own data held by the companies, which includes data collection, ad tracking, surveys, cookies, location data, and every other bit of a user’s “digital footprint”. Users are also entitled to transmit their personal details to other organizations. The GDPR also enforces companies to determine their in-house data security policies. Users are to note that your information will be transferred outside of Europe, including to Canada and the United States.
- FOR CALIFORNIA RESIDENTS
The California Code of Regulations defines a “resident” as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.
All other individuals are defined as “non-residents”.
If you are a resident of California, you are granted specific rights, such as the right to understand the processing of your personal data, right to access, correct, delete, the right to obtain a copy of your personal data and the right to limit use and disclosure of personal information which may be sensitive. If you would like to exercise these rights, please contact our Data Protection Officer in the manner set out below – paragraph 12. We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data. Notwithstanding we do not sell any of your information that, on its own, identifies you, like your name or email address, we might share other identifies with partners and/or service providers for product, service and advertising reasons. Sharing this information allows us to provide the content and services you enjoy, helps our partners and/or service providers deliver better content and advertising, and keeps out services supported by our advertisers. Under the California Consumer Privacy Act some of this sharing may be considered a “sale” that you have a right to opt out of.
If you are a California resident and would like to make an opt-out request, please contact our Data Protection Officer in the manner set out below – paragraph 12. If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
- FOR COLORADO CONSUMERS
The Colorado Privacy Act (“CPA”) defines a “consumer” as:
(a) means an individual who is a Colorado resident acting only in an individual or household context; and
(b) does not include an individual acting in a commercial or employment context, as a job applicant, or as a beneficiary of someone acting in an employment context.
If you are a consumer in Colorado, you are granted specific rights, such as the right to understand the processing of your personal data, right to access, correct, delete, and the right to obtain a copy of your personal data. If you would like to exercise these rights, please contact our Data Protection Officer in the manner set out below – paragraph 12. We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data. Notwithstanding we do not sell any of your information that, on its own, identifies you, like your name or email address, we might share other identifies with partners and/or service providers for product, service and advertising reasons. Sharing this information allows us to provide the content and services you enjoy, helps our partners and/or service providers deliver better content and advertising, and keeps out services supported by our advertisers. Under the CPA some of this sharing may be considered a “sale” that you have a right to opt out of.
If you are a Colorado consumer and would like to make an opt-out request, please contact our Data Protection Officer in the manner set out below – paragraph 12. If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
- FOR VIRGINIA CONSUMERS
The Virginia Consumer Data Protection Act (“VCDPA”) defines a “consumer” as:
“a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.”
If you are a consumer in Virginia, you are granted specific rights, such as the right to understand the processing of your personal data, right to access, correct, delete, and the right to obtain a copy of your personal data. If you would like to exercise these rights, please contact our Data Protection Officer in the manner set out below – paragraph 12. We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data. Notwithstanding we do not sell any of your information that, on its own, identifies you, like your name or email address, we might share other identifies with partners and/or service providers for product, service and advertising reasons. Sharing this information allows us to provide the content and services you enjoy, helps our partners and/or service providers deliver better content and advertising, and keeps out services supported by our advertisers. Under the VCDPA some of this sharing may be considered a “sale” that you have a right to opt out of.
If you are a Virginia consumer and would like to make an opt-out request, please contact our Data Protection Officer in the manner set out below – paragraph 12. If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
- CONTACTING US
You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Data Protection Officer
Ara Brands Pte. Ltd.
7 Temasek Boulevard
Suntec Tower One
Do note that the withdrawal of consent is subject to all applicable laws and applicable terms and conditions. To protect your privacy and security, we will require you to verify your identity before we can respond substantially to your request.
We make reasonable efforts to update the information on our Site. However, we make no representations, warranties or guarantees, whether express or implied, that the content on our Site is accurate, complete or up-to-date.
- GOVERNING LAW