BTFL PTE. LTD. (“our Company”) offers via its e-commerce site the sale of curated brands of health, beauty and baby related products.
B. In order for you to fully utilize our Site, purchase the Products, enjoy our loyalty programme, receive our marketing materials, newsletters or updates for information and/or promotion regarding the Products (our newsletters, updates and/or promotions shall be collectively referred to as our “Updates”), your Personal Data (as defined in clause 1.2 below) has to be provided to us, and we will need to keep and use your Personal Data in order to fulfil the purpose for which you have subscribed to our Site, Updates and/or services.
1.1 When you visit our Site, we collect Personal Data and Anonymised Data.
1.2 “Personal Data ” refers to information with personal identifiers that can be used separately or collectively to identify an individual, such as name, address, NRIC number, mobile number, email address, birthdate, credit card details, product preferences, skin type, skin sensitivities, etc.
1.3 "Anonymised Data" refers to information that is not associated with or linked to your Personal Data and cannot be used to identify individual persons.
2.1 We collect Anonymised Data about you when you access or use our Site via the application of generally acceptable web technologies including but not limited to "web beacons", "cookies", "clear GIFs", "widgets", "online evaluations", "surveys", and third-party web analytics such as "Google analytics". This automatic collection of non-personal information includes (without limitation) collection of your IP Address, the web browser software that you used, the specific pages of our Site viewed by you, and third party websites that you may have visited prior to our Site. Our purpose for the aforesaid collection of information is for us to understand the preference of our visitors so as to enhance and facilitate the ease with which you are able to access or use our Site.
2.2 As part of the Anonymised Data that we collect, when you access our Site via your mobile device, we will also collect information regarding the type of mobile device that you are utilising so that our Site can provide you with the version of our Site best suited for access via your mobile device.
2.3 To better assist you in understanding the generally accepted technology used in our collection of Anonymised Data:-
2.3.1 “IP Address” refers to a number that is automatically assigned to your computer when you access the Internet. Under certain circumstances, your IP Address remains the same from browser session to browser session. However, in the event that a consumer Internet access provider is utilized, your IP Address will likely vary from session to session. We track IP Addresses solely in conjunction with session cookies to analyse the flow of webpages on our Site.
2.3.2 “Cookies” refer to small pieces of data that a website sends to your computer’s hard drive while you are viewing the said website. Our Site utilises both session cookies (they expire the moment your Internet browser is closed) and persistent cookies (they will remain on your computer until you actively take steps to delete them) so as to provide you with a more personalised and interactive experience on Our Site. By changing the options on your Internet browser, you can control whether to accept or decline cookies.
2.3.3 “Clear GIFs” refer to clear electronic images that are used to track your opening of webpages on Our Site, for the purpose of allowing us to find out whether the content on Our Site appeals to you. Clear GIFs are also commonly known as "web beacons". Some of our HTML based emails also utilise Clear GIFs in order for us to assess what are the emails we sent that have been opened and acted upon. Clear GIFs collect only limited data, such as a cookie number, the time and date of when a particular webpage on our Site is accessed, and a description of the webpage on Our Site in which the clear GIF resides. Such collected Anonymised Data helps us to determine the effectiveness of the way our webpages are arranged on Our Site, our modes of communications and promotional campaigns.
2.3.4 "Third-party web analytics" refer to services provided by third party service providers for the assessment, analysis, measurement and reporting of the behaviour of visitors to a website in order to assess and improve the effectiveness of the website. One of the most well-known third-party analytics service is "Google Analytics".
3.1 In order for our Company to provide you with our services and products, you agree and consent to our Company collecting your Personal Data as follows:-
(i) When you sign up for our Updates, or you email us with any queries, you will be required to provide us with your Personal Data in order for us to add you to our mailing list, or to revert to your queries.
(ii) When you purchase any of the Products, you will be required to register an account with us, and we will require your Personal Data such as your credit card particulars and contact details in order to transact payment and to deliver your purchased Product. To that end, we will also need to disclose your Personal Data to online payment solutions providers, financial institutions, credit card associations and delivery/logistics service providers.
(iii) When you register an account with us, whether for the purchasing of Products or for our loyalty programme or otherwise, in order for us to provide you with information, Products, and/or Product samples that may be of interest to you, we may request for information on your product preference, skin type, skin sensitivities, any areas of health concern (example, weight loss or dental care), and other information relevant to our provision of Products and services via our Site (“Your Preferences”). You can choose not to disclose Your Preferences to us, however, in the event that you do, such disclosure shall constitute your consent to us to send you information, updates, promotions, Products and/or Product samples in relation to Your Preferences. For the avoidance of doubt, any information or Products that we provide to you pursuant to Your Preferences shall not be construed as the provision of medical advice or the dispensation of medicines.
(iv) When you enroll for our loyalty programme, we will require your Personal Data in order to keep a record of and provide you with the benefits that accompany our loyalty programme.
(iv) When you click on any of our Company’s Google ads or other internet based advertisements for more information regarding the Products or our Site, we collect the Personal Data that you provide in order to follow up with you pertaining your interest in the Products and/or our Site.
4.1 We will retain and use your Personal Data:-
(i)in order to send you Updates, and to provide you with information pertaining to our loyalty programme which you may have been rolled in. Unless you withdraw from our loyalty programme, we will keep your Personal Data for as long as you are still part of our loyalty programme so that we can provide you with the benefits as and whenever you purchase the Products;
(ii)to fulfil your purchase orders, transact your purchases, deliver the Products, and provide after-sales services;
(iii)where necessary and for such duration as may be required in order for our Company to comply with applicable laws and regulations, assist in any legal investigations, meet the demands from any regulatory or law enforcement bodies, for utilization in legal proceedings, minimizing fraud, collection of debts, resolving disputes, identifying issues, enforcing contractual breaches and/or claiming for damages.
5.1 We may need to disclose your Personal Data to:-
(i)third party service providers in order for us to facilitate your access to and use of our Site, for us to contact you as you may have requested via our Site, and for us to maintain your records to ensure that you receive the benefits accompanying your participation in our loyalty programme. The aforesaid third party service providers have a contract with us to perform the services necessary for you to use our Site and receive Updates, and such third party service providers therefore include but is not limited to webhost companies, website maintenance companies, database storage companies, loyalty programme service providers, companies that assist to perform mass mailing on our behalf, etc.;
(ii)our book-keepers, accounting firms, audit firms, law firms and/or other professional advisory firms who are maintaining our records in accordance with legal requirements;
(iii)governmental, regulatory or law enforcement bodies who have a legal right to demand for your Personal Data;
(iv)financial institutions, online payment service providers, credit card associations, and other third parties whose services are required in order for us to accept payment online from you when you purchase a Product;
(v)credit bureaus, credit rating agencies and fraud preventing companies for the purpose of minimizing fraudulent activities via your payment details;
(vi)courier, delivery and logistics service providers in order for them to deliver your purchased Products to you;
(vii)third party manufacturers in the event that your purchased Product is to be delivered directly from the manufacturer to you; and
(viii)our affiliated or related companies and/or third parties to whom we may sell, divest, transfer, assign, share or otherwise engage in a transaction that involves, some or all of our Company’s assets (which may include your Personal Data), in the course of a corporate divestiture, corporate restructuring, merger, acquisition, joint venture, bankruptcy, dissolution, reorganisation, or any other similar transaction or proceeding.
6.1 Pursuant to the purposes and activities as set out in sections 3, 3 and 4 above, it may be necessary for us to transfer your Personal Data out of Singapore. You hereby agree and consent to the aforesaid transfer, on the understanding that the recipients of such Personal Data are also subject to applicable laws or contractual obligations similar to the obligations as set out in the Personal Data Protection Act 2012.
7.1 In order for us to provide you with our services and to perform the activities as set out in sections 2, 3 and 4 above, the Personal Data that you provide to us must be accurate and relevant for that particular purpose/circumstance for which your Personal Data was provided (for example, when registering an account with us, and purchasing a Product, you must provide the correct credit card particulars and delivery address).
8.1 We respect your selections in relation to the channels via which you wish to receive our Updates. Therefore, if you have registered your telephone and/or fax number with the Do-Not-Call Registries in relation to telephone calls, text or fax messages, we will not send you any Updates via the channels that you have opted out of by registering with the Do-Not-Call Registries. However, if you have previously consented to our sending you Updates via your telephone number (text messages) and/or facsimile number, we will continue doing so until you withdraw your consent by contacting our Data Protection Officer at email@example.com
9.2 Should you wish to unsubscribe to our Updates, please click the "unsubscribe" option made available in our emails to you. Please note however that this may result in our being unable to make available to you updates on your benefits under our loyalty programme and any ongoing promotions (which may also relate to our loyalty programme, or otherwise).
10.1 Should you wish to access, update or make corrections to your Personal Data held with us, please email our Data Protection Officer at firstname.lastname@example.org
10.2 There will be no administrative fees or other charges levied for any request to correct or update your Personal Data. However, for all other requests such as accessing your Personal Data held with us, obtaining a record of when you accessed our Site etc., a reasonable administrative fee may be levied depending on your request as time and resources will be spent in accommodating your requests.
12.1 Our Site, the Products and its associated products and services are not meant for persons who may be defined as minors under applicable law. We do not knowingly collect Personal Data from minors, however, through the internet, we are not able to ascertain on our end whether such individuals are minors. It is thus the responsibility of parents or guardians to ensure that their minors do not provide us with Personal Data without their parental/guardian's consent. If a parent or guardian becomes aware that his or her minor has provided us with Personal Data without his/her consent, he or she should contact our Data Protection Officer at email@example.com promptly. If we become aware that a minor under 18 has provided us with Personal Data without their parent or guardian's consent, we will delete such information from our records.
13.1 We ensure that our Site is protected by reasonable security measures afforded by current technology, and that all our data hosts and servers are similarly protected by such security measures, including but not limited to firewalls.
13.2 Your Personal Data is kept securely and protected against unauthorized access and disclosure. We utilize security means such as (without limitation) password protection, encryption, locked and restricted access. We have strict policies in place restricting access to Personal Data to only our authorized personnel on a need-to-know basis.
14.3 The association of our Site with the Social Media Sites makes available certain features which when used by you, may result in information being made available from your accounts with the Social Media Sites to our Company. Such information which we collect about you shall constitute public information that is available in the general domain because such information was made publicly available by the Social Media Sites. Should you prefer that we do not collect your information from the Social Media Sites, please (i) do not use the features or links that associates our Site with the Social Media Sites; and (ii) adjust the settings in your accounts with the Social Media Sites to prevent the sharing of your information with our Site. Please note that our Company cannot control nor is our Company howsoever responsible for the sharing of your information by the Social Media Sites with third parties.
14.4 One of the features which you may see available on our Site in association with the Social Media Sites, is the “like” feature by Facebook, and other similar functions provided by other Social Media Sites. When you “like” our Products, information about our Products will be made known to your network within your Social Media Sites’ accounts via a variety of methods employed by the relevant Social Media Site. Your information may also be made known alongside with the Products that you have liked pursuant to the methods/channels made available by Social Media Sites in relation to such features. If you are not agreeable to the aforegoing, please instruct the relevant Social Media Site or adjust your account settings with the Social Media Site. Please note however that we are not obliged to display on our Site or any related webpages (whether on Social Media Sites or otherwise) any of your information, including but not limited to your photo or name, even if you “like” our Products. In the event that any of your information, product or service endorsements (including your liking of the Products or any of our Company’s services or third party products or services) appear on our Site or any related webpages (whether on Social Media Sites or otherwise), we shall have the right in our sole discretion to remove such information or product/service endorsements from our Site or any related webpages.