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PRIVACY POLICY
This Privacy Policy outlines how The Hunstreet SG Pte. Ltd. and its related entities (“HS”) deal with and manage Personal Data (as defined below) and other personal information, in compliance with the requirements of the Personal Data Protection Act 2012 (“PDPA”) and other applicable laws.
HS may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with its business needs and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as may be updated by HS from time to time.
PERSONAL DATA
1. In this Privacy Policy, “Personal Data” means any data about an individual who can be identified:
1. from that data; or
2. from that data and other information to which HS has or is likely to have access to, including data in HS’s records as may be updated from time to time.2. Types of Personal Data that may be provided to or collected by HS include but are not limited to:
1. name;
2. NRIC, passport or other personal identification number;
3. telephone or mobile number;
4. fax number;
5. mailing address;
6. e-mail address;
7. for the purpose of transacting with HS, such as entering into the Buying Services (as defined below) or Consignment (as defined below), your financial information (including but not limited to your credit card number and expiration date) and personal characteristics (including but not limited to your height, weight, body measurements and clothing size); and
8. any other personal information relating to you or other individuals that you have provided to HS.3. By providing your Personal Data to HS or using any products or services offered by HS, you agree and consent to HS collecting, retaining, processing, using, disclosing and transferring your Personal Data to HS’s related entities, authorised service providers and relevant third parties in the manner set out in this Privacy Policy.
4. This Privacy Policy supplements and does not supersede nor replace any other consents you may have previously provided to HS in relation to your Personal Data. Your consents shall be valid and effective notwithstanding any current or future registration made by you on the Do-Not-Call-Registry and are additional to any rights that HS may have at law to collect, retain, process, use, disclose or transfer your Personal Data.
COLLECTION OF PERSONAL DATA
1. HS may collect your Personal Data in the following ways:
1. when you register, create and sign up for a personal account with HS on its website , mobile applications, online services or online platforms (collectively referred to as the “Websites”) with a username and password (the “Account”);
2. when you enter into a rental services arrangement with HS to buy clothes, accessories and related items in accordance with the pricing and other related terms and conditions as determined by HS (the “Buying Services”);
3. when you enter into a consignment arrangement with HS to list your clothes, accessories and related items on the Websites, for the purpose of selling your clothes, accessories and related items to users of HS’s services (the “Consignment”);
4. when you submit any form relating to HS’s products and/or services, including but not limited to order forms and customer enquiry forms;
5. when you transact with HS or use any of HS’s services;
6. when you interact with HS’s officers, employees, representatives and agents via telephone calls, letters, fax, face-to-face meetings, events, social media platforms and e-mails;
7. when you request for HS to contact you or include you in its e-mail mailing lists, newsletters or other subscription-based distribution materials in connection with HS’s products and services;
8. when you respond to HS’s marketing promotions, surveys, contests or other initiatives or when you are contacted by and respond to HS’s officers, employees, representatives and agents;
9. when you enter into any agreement or provide other documentation or information in relation to your interactions with HS;
10. when you respond to HS’s request for additional information to supplement your Personal Data;
11. when HS requests for and receives your Personal Data in connection with your relationship with HS, for example, from your business partners, public agencies and relevant authorities;
12. when your photographs or videos are taken by HS when you attend its events;
13. when you provide HS with your third party account credentials to services provided by third party websites and mobile applications such as Facebook, Instagram, Google or Twitter, whereby your Personal Data contained in these third party websites and mobile applications may be transmitted to HS; and/or
14. when you provide, submit or disclose your Personal Data to HS for any other reasons.2. If you provide HS with any Personal Data relating to a third party, you represent to HS that you have obtained the consent of that third party to provide HS with such Personal Data.
3. You shall make reasonable efforts to ensure that all Personal Data provided to HS is complete, accurate, true and correct. Further, you shall give HS notice in writing as soon as reasonably practicable should your Personal Data be updated or changed after such disclosure, in accordance with Clause 7 below. Failure to do so may result in HS’s inability to provide to you the services under the Buying Services or Consignment or any products and services as requested.
PURPOSES FOR THE COLLECTION, RETENTION, PROCESS, USE, DISCLOSURE AND TRANSFER OF PERSONAL DATA
1. HS collects, retains, processes, uses, discloses and transfers your Personal Data for and in connection with the following purposes:
1. verifying your identity;
2. registering, creating and maintaining the Account;
3. providing HS’s products and/or services to you, including but not limited to fulfilling your orders under the Buying Services or Consignment;
4. billing you for HS’s products and/or services;
5. providing any of HS’s products and/or services to you;
6. providing information relating to HS’s products and/or services to you, which you may have indicated your interest in;
7. providing marketing materials and relevant information to you, including but not limited to promotions, special deals, information and any updates on HS’s products and services, newsletters and any upcoming events organised by HS;
8. sending notifications and alerts to you via HS’s mobile application, if you have enabled push notifications on your mobile device;
9. requesting feedback, conducting market research, surveys and/or analysis for statistical, profiling or other purposes in connection with HS’s business and/or to review, develop and improve HS’s product and service offerings;
10. providing information in relation to lucky draws, surveys or contests to participants, and to notify winners and award prizes;
11. providing customer service and support (including but not limited to customer relationship management, providing follow-up calls, providing you with administrative support and service-related announcements);
12. responding to, processing and handling your queries, feedback, complaints and requests;
13. if you use HS’s Websites, mobile applications, online services or online registration and payment systems, displaying your Personal Data on such websites, mobile applications or online registration and payment systems to facilitate the provision of HS’s services to you;
14. registering and tracking the mobile device that you use to download HS’s mobile applications;
15. administering and processing your requests, including creating and maintaining profiles of HS’s customers in HS’s system database for administrative purposes;
16. conducting research on HS’s customers’ behavioural patterns, preferences, interests and demographics, to provide better services to HS’s customers;
17. managing and planning the administrative and business operations of HS and complying with its internal policies and procedures;
18. monitoring or recording telephone calls and customer interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
19. in connection with any claims, actions or proceedings (including but not limited to obtaining legal advice and facilitating dispute resolution), and/or protecting and enforcing HS’s contractual and legal rights and obligations;
20. complying with any applicable laws, regulations, rules, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on HS (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations);
21. administering debt recovery and debt management;
22. taking or filming photographs and videos for corporate publicity or marketing purposes, and featuring your photographs and/or testimonials in our articles and publicity materials;
23. organising campaigns and promotional events; and/or
24. any other purposes which are reasonably related to the business relationship between HS and you.2. If you have provided HS with your telephone number, fax number, mailing address and/or e-mail address and indicated that you consent to receiving information from HS via telephone calls, SMS messages, data messages, WhatsApp messages, fax, post or e-mails, HS may contact you from time to time using the foregoing methods for the purposes listed in this Clause 3.
3. In relation to the provision of HS’s products or services to you or in your interactions with HS, HS may have notified you of other purposes for which it collects, retains, processes, uses, discloses or transfers your Personal Data, in addition to those listed in Clause 3.1 above. HS may collect, retain, process, use, disclose or transfer your Personal Data for such additional purposes, unless specifically excluded.
DISCLOSURE OF PERSONAL DATA
1. HS may disclose or transfer your Personal Data to the following entities or parties for the purposes listed above in Clause 3 where necessary:
1. HS’s affiliates;
2. HS’s professional advisers such as consultants, auditors and lawyers;
3. companies providing insurance-related services to HS;
4. agents, contractors, sub-contractors or third party service providers who provide operational and logistics services to HS, such as courier services, telecommunications, information technology, payment, printing, billing, debt recovery, processing, technical services, transportation, training, market research, call centre, security or other services;
5. HS’s vendors, sponsors, third party service providers or marketing and business partners, in connection with HS’s marketing events, promotions, surveys, contests or the provision of HS’s products and services;
6. HS’s successors, assigns or any third party to whom HS sells all or a part of its assets, or which acquires or merges with HS;
7. any party to whom HS determines in its sole discretion that such disclosure is appropriate or necessary to prevent the violation of HS’s terms of use or other agreements, prevent liability that may potentially be incurred by HS, protect the rights and property of HS, maintain and protect the security and integrity of HS’s products and/or services or investigate and defend HS from any third party allegations or claims;
8. external banks, credit card companies, other financial institutions and their respective service providers;
9. relevant government ministries, regulatory bodies, courts of law, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or directives imposed by any governmental authority; and/or
10. any other party to whom you authorise HS to disclose your Personal Data to.RETENTION OF PERSONAL DATA
1. HS shall retain your Personal Data as may be required for its legal or business purposes until such time that HS reasonably determines that such Personal Data is no longer necessary for its legal or business purposes.
2. HS protects and keeps your Personal Data safe by:
1. only disclosing your Personal Data to such entities or parties listed in Clause 4 above; and
2. taking reasonable measures to protect your Personal Data from unauthorised access, use or disclosure.3. HS is committed to maintaining the confidentiality of your Personal Data, and under no circumstances shall HS sell, rent or share your Personal Data with any unrelated third parties.
USE OF HS’S WEBSITES
1. When you visit and use the Websites, the following information may be automatically tracked and collected by HS:
1. IP address;
2. domain server;
3. type of computer used to access the Websites;
4. type of web browser used to access the Websites;
5. the previous website which directed you to the Websites; and
6. other information based on your online behavioural patterns, preferences and interests in the course of using and accessing the Websites.2. When you visit or interact with HS or its authorised service providers’ websites, HS or its authorised service providers may use cookies, web beacons and other similar technologies for collecting and storing information to provide you with a better, faster, and safer web experience. The terms “cookies” or “similar technologies” may be used interchangeably to refer to all technologies that HS may use to collect or store information in your browser or device or that collect information or assist in identifying you as a unique user in the manner described above.
3. The information collected by HS or its authorised service providers may recognise a visitor as a unique user and may collect information including but not limited to how a visitor arrives at its websites, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address and a visitor’s click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page). By visiting or interacting with HS or its authorised service providers’ websites, you are deemed to have consented to the collection of the aforesaid information.
4. HS offers certain site features and services that are available only through the use of these technologies. You may block, delete, or disable these technologies if your browser permits. However, if you decline cookies or other similar technologies, you may not be able to use certain site features or services tools on the Websites.
5. The Websites may contain links to other websites operated by third parties, including but not limited to HS’s service providers or business partners. HS shall not be responsible for the data protection practices of such third party websites that are linked to the Websites. You are encouraged to read the data protection policies of such third party websites.
WITHDRAWAL OF CONSENT, ACCESS AND CORRECTION OF PERSONAL DATA
1. You may withdraw your consent for HS to use your Personal Data for the purposes listed in Clause 3 above, in accordance with this Clause 7. Upon receiving such notice from you, HS may require up to thirty (30) days to process the withdrawal of your consent and securely dispose your Personal Data. During this period, HS shall be entitled to continue using your Personal Data for the purposes listed in Clause 3 above. Notwithstanding any withdrawal of consent by you, HS may contact you for other purposes in relation to the existing products and/or services that you have requested or purchased from HS.
2. If you:
1. have any questions or feedback relating to your Personal Data or this Privacy Policy;
2. would like to withdraw your consent to use of your Personal Data as set out in this Privacy Policy; or
3. would like to obtain access and/or make corrections to your Personal Data records,3. Please contact our Data Protection Officer as follows:
1. Telephone No.: +65 9299 8806
2. E-mail: sg@huntstreet.com
3. Address: 201 Henderson Road, #04-09/10, Singapore 1595454. If your Personal Data has been provided to HS by a third party on your behalf, you should contact that organisation or individual to make any such queries, complaints, and access and correction requests.
5. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, HS may not be in a position to continue providing its products and services to you, which in turn may result in the termination of any agreements or transactions between HS and you, and your being in breach of your contractual obligations or undertakings. HS’s legal rights and remedies in such event are expressly reserved.
SECURITY
1. The security of your Personal Data is important to HS. As such, HS uses reasonable security measures to protect against the loss, misuse, unauthorised access or disclosure, alteration and deletion of your Personal Data under HS’s control. This includes the use of firewalls and encryption on the Websites.
2. Notwithstanding our attempts to protect your Personal Data in good faith and through reasonable efforts, HS does not guarantee that:
1. all methods of transmission over the Internet or methods of electronic storage are secure and that your Personal Data under HS’s control will remain free from loss, misuse, unauthorised access or disclosure, alteration or deletion; and
2. the security measures that HS has put in place will prevent “hackers” or other unauthorised third parties from illegally accessing and obtaining your Personal Data under HS’s control.
GOVERNING LAW
1. This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of Singapore.