Personal Data Protection Act
1. Types of Customer Data
The types of Customer Data that HCW collects depend on the circumstances of collection and on the nature of the service requested or transaction undertaken. There are two broad categories of Customer Data that HCW collects:
Personal Data, which includes but is not limited to –
(i) personal information that links back to an individual e.g., name, gender, date of birth;
(ii) contact information e.g., residential addresses, phone numbers, email addresses;
(iii) technical information e.g., IP address; and
Statistical Data e.g., number of visitors, to website. This is stored purely for analytical purposes, and is entirely anonymous. This information will not be stored to your customer record, and will only be aggregated for statistical analysis so that we can better understand customer profile and improve service offering.
For purposes of this policy statement, the phrase Customer Data includes Personal Data and Statistical Data. The provision of Customer Data (save for where the request for data is marked “optional” in the forms used to collect personal data) is obligatory in order for HCW to carry out its services to you. The failure to supply such Customer Data may result in (i) HCW being unable to provide you with the services and/or products requested; (ii) HCW being unable to update you on our latest products and/or launches; and/or (iii) your inability to enter or participate in contests, promotions or redemption activities organised by HCW.
2. Purposes for Collection, Use and Disclosure
Generally, HCW collects Customer Data, either directly from you or from third parties (e.g. our service provider), or from publicly available sources, through our website, mobile services, and other channels including our retail outlets, in order to fulfil the following purposes, which include but are not limited to:
- Providing services to you such as processing a transaction (e.g., making an order online), providing technical or customer service assistance, assisting you in the transaction through HCW’s website;
- Marketing and communicating with you in relation to products and services offered, HCW service partners and appointed agents;
- Contacting you for product or customer satisfaction surveys and market research;
- Safety, security and legal compliance.
In addition, HCW may disclose Customer Data to our legal advisors for establishing, exercising or defending our legal rights, to our other professional advisors, or as otherwise authorised or required by law. HCW also reserves the right to share Customer Data as is necessary to prevent a threat to the life, health or security of an individual or corporate entity. Further, HCW may disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.
3. Transfer of Information Overseas
The HCW Office is based in Singapore. Customer Data may be transmitted to data storage where HCW keeps its central records. Customer Data may be transferred to HCWs offices and appointed agents in Singapore or other countries in connection with HCW’s performance of service to you.
HCW will, upon your written request to our Data Protection Department (see Section 10), allow you to view your stored Personal Data. Where permitted by law, HCW reserves the right to charge a reasonable administrative fee for this service. In exceptional circumstances, HCW reserves the right to deny you access to your Personal Data and may provide an explanation as required by applicable laws. Exceptional circumstances include where:
- An investigating authority or government institution objects to HCW complying with a customer’s request,
- The information may, in the exercise of HCW’s reasonable discretion and/or assessment, affect the life or security of an individual, and
- Data is collected in connection with an investigation of a breach of contract, suspicion of fraudulent activities or contravention of law.
To submit a written request to access your Personal Data, please email us at email@example.com
HCW will retain Customer Data for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes of HCW, or as required by relevant laws. When destroying Customer Data, we will take commercially reasonable and technically possible measures to make the personal information irrecoverable or irreproducible in accordance with the applicable laws.
HCW needs your assistance to ensure that your Personal Data is current, complete and accurate. As such, please inform HCW of changes to your Personal Data by contacting HCW and submitting your updated particulars in writing (see Section 10).
HCW may also request Personal Data updates from you from time to time. As detailed in Section 2 above under the “Purposes for Collection, Use and Disclosure” sub-section, your delivery address may be disclosed to the appropriate delivery fulfilment companies. As such, it is important to ensure that the Personal Data contained in your order confirmation is current, complete and accurate.
8. Security Safeguards
HCW takes the security and protection of your Customer Data very seriously. As such, HCW makes reasonable security arrangements to protect your Customer Data against loss or theft as well as unauthorised access and undue disclosure. Examples of technical safeguards include encryption, Network and Web Application Firewalls ,“firewalls” and Secure Socket Layer (SSL). Further details of these technical safeguards for Customer Data collected through HCW’s websites facility are set out at Part B below. If, however, a customer does not take reasonable care to ensure the continued confidentiality and accuracy of their Customer Data, HCW will not be liable for any consequential misuse and/or fraud. If you have any concerns about security, you should contact HCW (see Section 10).
10. Contact Us
DATA PROTECTION OFFICER
1. Security Safeguards
HCW takes the protection of your Customer Data collected on it’s websites very seriously. All Customer Data collected are protected by a secure server. In addition, SSL (Secure Socket Layer) protects the transmission of data from the internet to our systems. To further strengthen the integrity of your internet transactions on our websites, HCW also employs relevant software programs to monitor network traffic with a view to identifying unauthorised attempts to upload or change Customer Data, perpetuate fraudulent or illegal activities or otherwise cause damage. If such monitoring reveals evidence of possible abuse or criminal activities, such evidence may be provided to appropriate law enforcement authorities or agencies without notice to you. To give you secure access to our online services, arising from your utilisation of HCW’s website, you can register with us. You should not share your User ID or Password and should always ‘log off’ once you have finished your session on the websites as well as take the recommended precautions that ensure the safe and secure provision of HCW’s website.
3. Clickstream Data
In order to improve your online experience, HCW may track online behaviour or clickstream data to advance your use of our web pages and track referrals from other websites. Such data will not be stored to your customer record, and will only be aggregated for statistical analysis.
4. Links to Other Websites
HCW cannot distinguish the age of persons who access and use its websites. If a minor (according to applicable laws) has provided HCW with Customer Data without parental or guardian consent, the parent or guardian should contact HCW (see Section 10 of Part A) to remove the relevant Customer Data and unsubscribe the minor.
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