Personal Data Protection Act (2012)
From 2 July 2014, the Personal Data Protection Act (PDPA) will introduce certain changes to the way in which we may contact you for promotional and marketing messages. These changes will generally not affect informational and service-related messages sent by us (such as quotation updates and confirmation about events).
We aim to conduct our business in compliance with the requirements of the PDPA and respect your choices. Your information is collected for us to understand your needs better so that we can improve our services and also the way we communicate with you.
How is personal data collected?
LAVARA HOLDINGS Pte Ltd may collect your personal information when you:
Sign up for our membership program.
Register your products for warranty service
Subscribe to our e-newsletters
Contact us with a product or service inquiry.
Participate in our contests, surveys, lucky draws and/or other promotional activities
Visit our website
Types of personal data collected
The information LAVARA HOLDINGS Pte Ltd collects depends on the type of products and services you requested and use.
HOW WE SHARE YOUR INFORMATION
From time to time, we may share your information with our affiliates, subsidiaries, business partners, third party service providers and authorities in the following circumstances:
Our Affiliates, Subsidiaries and Business Partners. We may share your information with our affiliates, subsidiaries and business partners for the purposes described above and for other general business administration purposes. By visiting or using our Sites or otherwise providing us with your information, you consent to this transfer of your information throughout our network of entities. To opt-out of such disclosures, please see the “Choice” section below.
Service Providers. We may share your information with third parties who perform functions on our behalf (e.g., hosting or operating our Sites, processing credit card payments, sending email marketing communications, processing job applications, data analysis and other business support services). We do not authorize these third parties to use your information for purposes other than for which it was provided, and do not authorize these third parties to disclose that information to unauthorized parties. We require these third parties to maintain appropriate security to protect your information from unauthorized access or processing.
As Required or Appropriate by Law. We may disclose your information to regulatory authorities, courts, government agencies and other third parties where we believe that doing so would be in accordance with or permitted or required by any applicable law, regulation or legal process, to defend the interests, rights, and/or property of us or others, or to respond to emergencies.
Business Transfers. We may 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, brands, affiliates, subsidiaries or other assets.
In addition to the above circumstances, we may share your information with other parties as directed by you or subject to your consent. We may also share and otherwise process aggregated information or de-identified information that does not identify you individually with other parties. For example, we may share aggregated statistics about pages viewed on our Sites, demographic information and sales, and other shopping information with third parties to enrich your visitor experience.
COOKIES AND SIMILAR TECHNOLOGIES
When you use our Sites, we along with our affiliates, subsidiaries and third-party service providers may use “cookies” and similar technologies (e.g., beacons, log files, pixels and Flash LSOs) (collectively, “technology”). This technology involves placing small files/code on your device or browser that serve a number of purposes, such as remembering your preferences (e.g., language) and generally improving your experience on our Sites. Specifically, we may use such technology for purposes such as to:
Provide us with general analytics about our Sites, including demographic information in a non-identifiable form, in order to improve our Sites’ performance and customize users’ experience;
Support security measures, such as requiring re-login into your account;
Allow you to engage in our social media offerings on our Sites (e.g., Facebook “Like” button); and
More effectively market our Sites and advertise other Sites that may be of interest to you.
Where required by law, we collect your consent for the use of such technologies.
Cookies. A cookie is a small text file saved on your device or browser. Some of these cookies are necessary for the functioning of our Sites (known as “Strictly Necessary” cookies), while others are not (known as “Non-Essential” cookies). Some cookies (known as “persistent cookies”) will remain on your device until you delete them, while others (known as “session cookies”) are automatically erased when you exit your Internet browser.
You can set your device or browser to accept or reject most cookies, or to notify you in most situations that a cookie is offered so that you can decide whether to accept it. However, if you block cookies, certain features on our Sites may not function. Additionally, even if you block or delete Cookies, not all tracking will necessarily stop.
We may place or recognize technology on your browser or device when you visit our Sites for purposes of serving you targeted advertising (also referred to as “online behavioral advertising”). We also work with third party advertising companies who place their own cookies or similar technology on your browser or device when you visit our Sites and other websites to serve customized advertisements to you as you browse the Internet. As noted above, you can set your device or browser to accept or reject most cookies, or at least notify you in most situations that the technology is offered. As an additional step, these advertising companies may participate in one of the following self-regulatory programs for online behavioral advertising, with corresponding user opt-outs:
DAA App Choices Mobile App (Mobile Devices Only) – For mobile devices (e.g., smartphone, tablets), you may consider downloading the DAA AppChoices Mobile App to manage such technology.
Please note that even if you reject such technology, you may continue to receive advertisements, but the advertisements will not be tailored to your browsing activities and interests.
Log Files. We automatically gather log files, such as your IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data when you use our Sites. We may combine information in log files with your information.
Clear Gifs (Web Beacons/Web Bugs/Embedded Pixels). Clear Gifs are embedded on our Sites and are about the size of the period at the end of this sentence. The information collected by these technologies is associated with other technology and information, but only for internal tracking purposes only.
Flash LSOs. Flash Local Storage Objects (“Flash LSOs”/”Flash Cookies”) display content based upon your preferences for how you like to view our Sites. Flash LSOs are different from browser cookies because of the amount of, type of, and how information is stored. Cookie management tools provided by your browser will not remove Flash LSOs. To learn how to manage privacy and storage settings for Flash LSOs, click here.
Third party applications and APIs. We also offer and deliver services, content or interactive features through and/or using third party application programming interfaces, gadgets, and/or extensions that are hosted on our Sites or through other third-party websites or social networking platforms. When you use these services, content, or interactive features, or otherwise connect with, or “accept” or “allow” third party applications, networks, platforms or services through our Sites, you are authorizing those third parties to receive your information and additionally to potentially share any or all of your information with us, based on your privacy or other settings on the particular third-party network or platform. Any information we receive by these means will be treated and/or processed according to this Privacy Policy.
Below are some examples:
Personal Particulars – This may include NRIC, FIN or passport number, address, telephone number, e-mail address and date of birth.
Your account information – For example, the membership program you are enrolled in with us or other details related to your account.
Information on your quotation and use of our services – For example, your quotation history
Use of personal data
LAVARA HOLDINGS Pte Ltd may use your information for the following:
Process your online orders
Respond to inquiries and requests from you or people you have authorized
Inform you about product products and services updates
Conduct market research and customer satisfaction surveys
Membership matters where applicable, such as change in benefits and latest promotions
Provide updates, offers, invitations to events and deliver advertising messages via SMS / MMS, voice, Email or your mailing address with your prior consent or if otherwise permitted under local laws and regulations
Transfer of personal data
LAVARA HOLDINGS Pte Ltd may share your information with:
Business partners and vendors we work with to deliver product and services you purchase and use
Industry regulators and other government organisations, as required by local laws and regulations
Financial institutions for purposes such as facilitating credit card payments
Research institutions for market analysis purposes
Protection of personal data
LAVARA HOLDINGS Pte Ltd has implemented stringent measures to secure and protect your information. These include:
Safeguards to prevent security breaches in our network and database systems
Limits on access to information in our systems and the systems of our business partners and vendors
Strict verification processes to prevent unauthorized access to information
LAVARA HOLDINGS Pte Ltd respects your contact preferences
LAVARA HOLDINGS Pte Ltd is committed to comply with the Do Not Call (DNC) provisions. We have always been mindful of engaging our customers in a more targeted and relevant way.
We may send marketing messages to your Singapore telephone number if:
a. You have given us consent, OR
b. You have not registered with the national DNC Registry, OR
c. The sending of such messages is permissible under applicable laws and regulations.
Our marketing messages aim to update you about our exclusive offers, rewards program and special deals from our preferred partners and advertisers. Kindly note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be able to continue to provide its products and/or services to you.
LINKS TO OTHER WEBSITES
Our Sites may contain links to other websites or services that are not owned or controlled by us, including but not limited to links to websites of our advertisers, sponsors, and partners. This Privacy Policy only applies to information collected by our Sites. We have no control over these third-party websites, and your use of third party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third-party websites linked to our Sites. Your use of third parties’ websites linked to our Sites is at your own risk, so we encourage you to read the privacy policies of any linked third-party websites when you leave one of our Sites.
CHOICE
Email. If you no longer wish to receive email marketing communications from us, you may opt-out of receiving marketing-related emails by using the unsubscribe method provided in our communications (e.g., by clicking on the “unsubscribe” link in the email to unsubscribe). Alternatively, to the extent that applicable law requires your prior opt-in consent to receive marketing and promotional emails, we will ask for your consent and you can choose not to opt-in.
Text Message. If you no longer want to receive text messages from us, reply STOP (or as otherwise instructed) in the text message. Alternatively, to the extent that applicable law requires your prior opt-in consent to receive text messages, we will ask for your consent and you can choose not to opt-in.
CHANGES TO THIS PRIVACY POLICY
Except to the extent limited by applicable law, we reserve the right to update this Privacy Policy to reflect changes to our information practices by prominently posting notice of the update on our Sites. Any updates will become effective immediately after posting the updates to the Privacy Policy and apply to all information collected about you. If we make any changes to this Privacy Policy that materially impact previously collected information about you, we will, to the extent that we have your email address, notify you by email.
NO DATA COLLECTED FROM CHILDREN/MINORS/THOSE UNDER THE LEGAL DRINKING AGE
Our Sites are intended only for those of legal drinking age and we do not knowingly collect information from individuals under the legal drinking age, children or minors.
HAVE A QUESTION?
Should you have any feedback or enquiries relating to your personal data or how LAVARA HOLDINGS Pte Ltd may communicate with you, or if you wish to stop receiving promotional/marketing messages, please contact us at the following email address: [email protected]
For more information about PDPA generally, please visit the Personal Data Protection Commission’s website at www.pdpc.gov.sg