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Create an AccountDATA PROTECTION AND PRIVACY POLICY SINGAPORE (MAKE UP FOREVER)
1. Who we are
1.1. This is the Privacy Policy ("Policy" or “Privacy Policy”) of LVMH Fragrances & Cosmetics (Singapore) Pte
Ltd and its subsidiary L Beauty Pte Ltd (collectively, “the Company” and each, a “Company”).
1.2. You have been directed to this Policy because we are collecting, using or disclosing your personal data.
1.3. In this Policy, references to “we”, “us” or “our” refer to the Company, which are, whether individually or collectively, collecting your personal data and operating the Site (defined below) which you are accessing or using.
1.4. We own and operate the website at https://makeupforever.sg (the “Site” or “website”), as well as various boutique stores in Singapore.
1.5. By accessing and using the Site, you are deemed to have read, understood, and gave consent to us for the collection, processing, disclosure and use of your information and personal data as described below. The Privacy Policy may change or be updated at any time without prior notice and/or announcement.
2. Purpose of the Policy
2.1. The purpose of this Privacy Policy is to inform you and provide you with an understanding of how we may handle, collect, use, disclose and deal with personal data about you that you give us, that we receive through third parties or that is in our possession, in accordance with the Personal Data Protection Act (the “PDPA”). Please read this Privacy Policy carefully.
2.2. This Privacy Policy shall apply to all personal data in our possession or under our control.
2.3. The contents of this Privacy Policy may change over time so please check back frequently. Any changes to this Privacy Policy will be posted on and can be viewed at the Site. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
2.4. This Policy applies to all personal data that you may provide to us and the personal data we hold about you. By providing us with your personal data or by accessing, using or viewing the Site or any of its services, functions or contents (including transmitting, caching or storing of any such personal data), you shall be deemed to have agreed to each and all the terms, conditions, and notices in this Policy. If you do not agree, please cease use of the Site and/or its service(s) and DO NOT provide any personal data to us.
2.5. This Policy applies to the products and services related to online channels such as the Site, mini programs, digital applications, and social media platforms provided by us to users, to the extent relevant (“Online Platforms”); products and services provided by offline stores (whether or not in connection with
the Online Platforms); and to all activities related to MUFE products and services (e.g., online membership registration; online purchase and after-sales; participation in online or offline brand events; push product and event information; send invitations to events; customer service centre). At the same time, we will revise and update this Policy from time to time in accordance with the update requirements of applicable laws and regulations or business change needs.
3. Personal data that will be collected
3.1. “Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
3.2. When you use our Site, any service we provide or in your interaction with us, the personal data we may collect include but is not limited to:
3.2.1. Data collected directly from you. This may be done through our Site, over the phone, by email or in person through a variety of activities. These activities include, but are not limited to instances where you:
(a) Enter into a contract with us for the supply of any goods or services;
(b) Participate in our service experience surveys;
(c) Consent to receiving our commercial communications by email;
(d) Interact with our customer services department;
(e) Contact us through any means to find out more about goods or services we provide;
(f) Participate in any events organized by us; and
(g) Collect samples from our stores through our consultants or by notification from our microsites or websites.
The personal data collected may include, but is not limited to:
(a) Your personal particulars, including your first name and last name, date of birth, gender and identification number (such as national ID or passport details);
(b) Your signature;
(c) Your personal contact details, such as your personal phone number(s), email address and residential address;
(d) Other information required to be able to process your order and provide you with our services, such as information concerning the products that you have ordered or the service that we are providing to you, the billing and/or delivery addresses, banking and/or credit/debit card details;
(e) If you have created an online profile or account, the preferences and/or interests stored in such profile or account; and
(f) If you have contacted customer service, the details of this contact and the contact history.
3.2.2. Data collected by automated means. Our Site adopts various technologies to make them more user- friendly, effective and secure for its users. Such technologies may result in data being collected automatically by us or by third parties on behalf of us. This data does not always, but may, contain a user's personal data or comprise of personal data. Examples of such technologies include:
(a) Click-stream data. A visit to our Site results in data that is transmitted from your browser to our server being automatically collected and stored by us or by third parties on behalf of us. This data can include, in particular, the following:
i. The IP address of the visitor of the Site;
ii. The date and time of the visit to our Site;
iii. The referral URL (the site from which the visitor was directed);
iv. The pages visited on our Site; and
v. Information about the browser used, such as the browser type and version, and operating system.
(b) Cookies. The Site adopts the use of cookies. Cookies are small text files which are stored on your computer’s hard drive or user device by your web browser. We can use cookies to identify the owner of a user account and to store articles in a shopping basket during the purchasing process. The cookies usually used by us are so-called "session cookies", which are automatically deleted at the end of the visit to the relevant website. By default, web browsers enable the use of cookies but this function can also be disabled. However, this will result in some services not being available. It is also possible to manually delete cookies after their use via the web browser. More information may be available from your web browser provider.
(c) Web Analytics. Web analytics is the term given to a method for collecting and assessing the behaviour of visitors to websites. This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a website, or to and out which of our information and services our visitors are most interested in. For these purposes, we primarily make use of click-stream data and the other techniques listed above.
4. Purposes for which we collect, use or disclose your personal data
4.1. We may collect, use, disclosure and/or process your personal data for one or more of the following purposes:
4.1.1. Processing and dealing with your interest in our products and/or services;
4.1.2. Administering, facilitating, processing, dealing with, administering and/or managing your purchase of our products and services (the “Transaction”). Without limiting the generality of the following, should you make a Transaction that includes third party individual(s) or on behalf of third party individual(s) or for third party individual(s), you consent to us disclosing personal data that identifies you to the said third party individual(s). This includes but is not limited to the following:
(a) Generating and storing documents concerning the Transaction(s) such as delivery and collection orders, quotations and invoices;
(b) Dealing with your delivery needs, processing orders and payment transactions, implementing transactions and the supply of products and/or services to you that you have requested;
(c) Dealing with your ad-hoc queries, requests or bookings; and
(d) Assessment of your creditworthiness (for which we may use third parties).
4.1.3. Administering, facilitating, processing and/or dealing in any Transactions, payments, debt collection or activities carried out by you on the Site;
4.1.4. Administering, facilitating, managing, processing and/or dealing in any matters involving your use or access of the Site, including identifying you for login to the Site, our portals and other online services provided by or on behalf of us;
4.1.5. Facilitating and managing customer services in terms of responding to, handling and processing
queries, requests, feedback or any complaints that you may send us via our website, our customer services department or on our social media pages;
4.1.6. Monitoring, processing and/or tracking your use of the Site in order to provide you with a seamless experience, facilitating or administering your use of the Site, and/or to assist us in improving your experience in using the Site;
4.1.7. Registering you as a customer of any of our products or services on our database to contact you or communicate with you via phone/voice call, text message (including SMS and other messaging applications such as Whatsapp, WeChat, Viber and Line) and/or fax message, email, postal mail or by other lawful methods consented by you for one or more of the Purposes stated herein. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
4.1.8. To process, to facilitate and/or administer the online account that you may open with us, including to facilitate your transactions on the Site or for us;
4.1.9. Carrying out due diligence and other activities as may be required by legal and/or regulatory obligations that are applicable to us (including but not limited to anti-money laundering checks and Know Your Client checks), the requirements or guidelines of government authorities which we determine is applicable to us, and our risk management procedures that may be required by law.
4.1.10. To prevent or investigate any fraud, unlawful activity, omission or misconduct, dealing with conflict of interests, or dealing with investigating complaints;
4.1.11. Complying with or as required by any request or direction of any governmental authority (whether Singapore or other countries) which we are expected to comply with, or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities;
4.1.12. Conducting research, (including customer research), surveys, market surveys, analysis and development activities (including but not limited to data analytics, and/or profiling), obtaining your feedback to our products and services to improve our products and services and to enhance any continued interaction between yourself and us in relation to your relationship with us, the Site or your Transaction(s);
4.1.13. Facilitating and offering adapted and personalised services particularly for the purposes of developing our products and services and to enhance any continued interaction between yourself and us in relation to your relationship with us, the Site or your Transaction(s);
4.1.14. Conducting of training to improve the quality of our products and services and our staff’s service
quality;
4.1.15. For marketing purposes, including but not limited to, the provision of marketing, advertising and promotional information, materials and documents relating to products, services, contests and events, by phone/voice call, text message (including SMS and other messaging applications such as Whatsapp, Viber and Line), and/or fax message, email, postal mail or by other lawful methods consented by you;
4.1.16. For digital remarketing purposes, including but not limited to using your contact details such as your email or mobile number to retarget you on social media channels such as Facebook and Instagram;
4.1.17. Managing your participation in any of our events and promotions to which you have signed up;
4.1.18. Storing, hosting and/or backing up of your personal data to any third party service providers or agents, whether within or outside Singapore;
4.1.19. Maintaining and/or developing our IT or business systems and infrastructure including testing and upgrading of these systems;
4.1.20. Facilitating, dealing with and/or administering external or internal audit(s) of our business, the Transaction(s) and/or transactions with our customers; and
4.1.21. To deal with the or as part of a bankruptcy, winding up, reorganisation, restructuring, insolvency, receivership or an assignment for the benefit of our creditors; and
4.1.22. any other incidental business purposes related to or in connection with the above. (the purposes set out in this Paragraph 4.1 shall be collectively referred to as the “Purposes”)
4.2. Your consent relating to our processing of your personal data in accordance with the marketing purpose mentioned in Paragraph 4.1.15 may be withdrawn at any time using one of the following methods:
4.2.1. Clicking the “Unsubscribe” button located at the bottom of our emailers; or
4.2.2. Contacting us through the contact details listed at Paragraph 10.1 below.
4.3. We may need to disclose your personal data to third parties, whether located within or outside Singapore for any of the above Purposes. In this connection, you hereby acknowledge, agree and consent that we are permitted to disclose your personal data to such third parties for one or more of the above Purposes and for the said third parties for their subsequent collection, usage, disclosure and/or processing of your personal data for one or more of the above Purposes. Without limiting the generality of the foregoing or of the above Paragraph 4.1, such third parties include:
4.3.1. Our associated or affiliated organizations or related corporations, including but not limited to, our parent company and other entities of the LVMH (LVMH Moët Hennessy – Louis Vuitton SE) group (including LVMH Recherche);
4.3.2. Any of our agent, contractors or third party service providers that will process your personal data on our behalf, including but limited to those who provide administrative services to us such as marketing solutions service providers, marketing and commercial prospection management service providers via social media, event organization service providers, customer service providers, mailing houses, telecommunication companies, information technology companies, data centres, hosting and maintenance service providers, email-messaging service providers, handling of payment transactions service providers, marketing service providers, delivery and logistics services, and anti-fraud and fraud prevention service providers;
4.3.3. Our professional advisers, such as our auditors, lawyers and insurers; and
4.3.4. Third parties to whom disclosure by us is for one or more of the Purposes, who will in turn be collecting and processing your personal data for one or more of the above Purposes. Without limiting the generality of this Paragraph 4.3.4, such third parties include debt collectors, finance companies or banks.
4.4. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw your consent to the collection, use and/or disclosure of your personal data in our possession or under our control by contacting
us at through the contact details listed at Paragraph 10.1 below. We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request, unless an exception under the law or a provision in the law permits us to. However, please take note that your above withdrawal of consent could result in certain legal consequences arising, including us being unable to perform the transactions requested by you or the termination of your relationship with us, as the case may be. Please also note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is required or authorised under applicable laws.
4.5. We may collect, use, disclose or process your personal data for purposes other than the Purposes set out in the above. Prior to the collection, usage, disclosure or processing of your personal data for such other purposes, you will seek your notification unless your consent is not required by the PDPA or by any applicable law.
4.6. Please inform us of any changes to your personal data or if there are any errors in the personal data we hold about you. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you had initially provided us with.
5. Provision by you of third-party personal data
5.1. In the event that you provide us with personal data of any individual other than yourself, you represent, undertake and warrant to us the following:
5.1.1. For any personal data of third party individuals that you disclose to us, you would have obtained prior consent from such individuals to:
(a) Permit you to disclose the individuals’ personal data to us for the Purposes; and
(b) Permit us to collect, use, disclose and/or process the individuals’ personal data for the Purposes.
5.1.2. At our request, you will use such form(s) and document(s) provided by us in obtaining the required consent from the third party individuals in question;
5.1.3. Any personal data of third party individuals that you disclose to us are accurate; and
5.1.4. For any personal data of third party individuals that you disclose to us, that you are validly acting on behalf of such individuals and that you have the authority of such individuals to provide their personal data to us and for us to collect, use, disclose and process such personal data for the Purposes.
6. Third Party Websites
6.1. This Policy only applies to the Site and information that we collect from you. The Site may contain links to other websites which are not owned or maintained by us. When visiting these third party websites or disclosing your personal data to third parties, you should read their privacy policies, or ask relevant questions before you disclose your personal data. We are not responsible for the collection, use or disclosure of your personal data by such third parties.
6.2. To the extent there are advertisements that appear on the Site from us, other brands of the LVMH Group or other third party third parties, these advertisers may use cookies that are hosted by other third- party ad servers to recognize your computer device each time they display an advertisement online. Thus,
these ad servers can collect information. This information allows advertisers to send certain advertisements that they deem of interest to you.
This Policy applies only to cookies placed by us and does not apply to cookies of third party advertises.
7. Security and our storage of your personal data
7.1. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
7.2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
8. Retention of Personal Data
8.1. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
8.2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, including but not limited to legal purposes and the Purposes set out in the above Paragraph 4.1.
8.3. As a general principle and as guiding principles only, your personal data is intended to be retained in our client database:
8.3.1. If you are a “client” (i.e. you have already purchased a MUFE product): for no more than 10 years after your first purchase (but no more than 5 years for marketing development purposes); this period will be renewed each time you interact with MUFE (e.g. when making a purchase).
8.3.2. If you are a “prospect” (i.e. you have never purchased a MUFE product but you are interested in the MUFE brand): we keep your data for 3 years; this period will be renewed each time you interact with MUFE (e.g. when participating in an event).
8.3.3. If you have given consent to the processing of your personal data for market research purposes in the field of cosmetics and statistical analyses, for the purpose of improving the understanding of the skin for the development of MUFE fragrances and cosmetic products: for a duration of 10 years as of the collection date of your data.
9. Your rights regarding your personal data that is collected and processed by us
9.1. If you wish to make an access request for access to a copy of the personal data which we hold about you, information about the ways in which we use or disclose your personal data, a withdrawal of any consent that you have given us at any time, or a correction request to correct or update any of your personal data which we hold about you, you are welcome to contact us through the contact details listed at Paragraph 10.1 below.
9.2. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty
(30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
9.3. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
10. Our Contact Information
10.1. You may direct your requests and enquiries to us regarding your personal data in the following ways to our Data Protection Officer:
10.1.1. By Email. Such complaints must be made to Data Protection Officer of LVMH Fragrances & Cosmetics (Singapore) Pte Ltd and L Beauty Pte Ltd, at following address: Privacy_SG@sg.lvmh-pc.com
10.1.2. By Telephone. Such complaints must be made to our Data Protection Officer at the following telephone number: +65 8428 3714
10.2. All requests and enquiries will be evaluated by our in a timely manner. After we have completed our evaluation, our Customer Service team will respond to the initial contact person with the results of the evaluation.
11. Additional Provisions when this Policy is used in connection with WeChat (and this section is only relevant if there are any mini programs on WeChat by MUFE)
11.1. Without limiting any other provisions of this Policy, when this Policy is applicable to data subjects, MUFE, customers or relating to travel retail, through or in connection with WeChat (including WeChat Pay, WeChat Mini Program and other functions provided via WeChat application on digital devices), the following provisions apply:
A. We may collect additional information about you such as:
a) Your travel destination and preferences
b) Entry permit, visa, passenger and flight details
c) Payment information such as information in relation to your credit card, debit card and/or other payment details (including WeChat Pay)
d) Bio-metric data when you use our online make up ‘try-on’ tools
B. We may collect data about you through the additional touchpoints below:
a) when you are using a MUFE dedicated site through WeChat platform, specifically when you register an account with us, WeChat and/or purchase products through WeChat platform, other Online Platforms, website and/or interact with us through our website. A reference to “our
website” in this Policy shall refer to any of sites or pages dedicated to MUFE products and/ or services on any Online Platforms (for example, a MUFE dedicated page accessible via WeChat app installed on digital devices).
b) when you make payment via WeChat Pay
C. We may use your personal data for the below additional purposes:
a) sending push notifications about special promotions or discounts when customers are close to duty-free shops, or travel hubs;
b) send you MUFE travel retail product offerings, personalised services, channel-exclusive gifts and key opinion leader (KOL) recommendations;
c) allow you to use artificial intelligence-powered function (such as “Mask Finder” tool, to the extent applicable) - This tool allows users to upload or capture a photograph and get their skin analysed for the purposes of generating personalised mask recommendations;
d) to make payment online with WeChat Pay (to the extent applicable);
e) to engage in live chat with a customer service representative (to the extent applicable);
D. In addition, in order to ensure the consistency, immediacy and interoperability of our services, we may synchronize your account information, points records and other personal information between different official websites, mini programs, and official online flagship stores of the brand. Depending on your use of our features, we may also collect additional information:
a) When you choose to fill out a questionnaire, conduct a search, update or add account information, answer a survey, participate in preferential activities, use live streaming services, participate in a group, help/invite others to help, or use other functions of the official channels, we will collect the relevant information you provide to us or generate in the course of use;
b) When you choose to use product reviews, we collect information related to your reviews, and the content of your reviews may be made public;
c) When you choose to use the grass planting feature, we will collect information related to grass planting, and your posts, comments, and replies are publicly posted.
We will only collect the corresponding information when you choose to use the above functions, and we will not collect your corresponding information if you do not use the above functions.
E. When you use any mobile internet application (on our website or on the Online Platforms), you provide the following information:
a) Device information: We will receive and record information about the device you use (device model, operating system version, device settings, unique device identifiers, device environment information) and information about the location of the device (IP address, GPS location and WLAN access point sensor information that can provide relevant information). If you refuse to grant us the corresponding permissions during installation and/or use, we will not record your corresponding information above.
b) Service log information: When you use the products or services provided by our mobile application, we will collect detailed information about your use of our services for the purpose of statistical data, advertising and marketing effect evaluation, including search query content, IP address, browser type, telecommunications operator, language used, date and time of access, and your visit, browsing, stay, A record of the web page where the order was placed.
c) Other system and device permission information: We will apply for the specific device and system permissions granted to you before and/or during your use of the software, and inform you of the corresponding purpose of use, for example, based on the product sharing function, we will apply for the permission of the album to save the pictures or videos of the product and the QR code. If you refuse to grant us the corresponding permissions, we will not record your corresponding information;
F. You agree that in order to provide you with a better service, we may collect and process other data for the purposes set out below:
a) Statistical analysis of e-commerce website data and user characteristics are also provided through services provided by third parties. We will use the relevant personal information within the scope of your authorization, and take necessary security protection measures in accordance with the law. Third-party data processing must comply with the relevant laws and regulations in response to the prior inspection request submitted by "MUFE". If the user does not provide personal data for the purposes set forth in this paragraph, we will not be able to continue to provide the relevant services requested, including notification, reservation, reservation, after-sales, consultation, etc.
b) To provide personalized sales services or to provide automated product recommendations to users, to send information, such as, but not limited to, personal shopping services, online referral services, free assistance services, and concierge services, to send information about the brand's products, exclusive sales and events, by telephone, letter, email, SMS and multimedia messages, social networks, instant messaging, etc" Messages about similar events organized or attended (including potential invitations to participate in such events), and for sending questionnaires to assess the level of satisfaction achieved with the services provided. If you do not wish to receive such messages, you may unsubscribe in the manner provided in the messages you received.
Other data includes:
- Data collected during in-store visits, event attendance, or online purchases, including Wi-Fi system usage, birthdays, age ranges, family days, occupations, hobbies, shopping history, device information, service log information, etc Use of particular social networks or social network IDs, telephone numbers, e-mail addresses, photographs, nationality, gender, method and date of registration in the customer relationship management system managed by us, language, categories of favorite products, details of products purchased, specifications, prices, discounts, statistical spending levels, abandoned shopping carts, usage of services, preferences regarding in- store services, responses to contact activities, activities attended by customers, products purchased but not actually purchased;
- THE INFORMATION COLLECTED WHEN BROWSING OR USING THE APP, WeChat, Online Platforms, INCLUDING BEHAVIOURAL DATA RECORDED WITH COOKIES OR SIMILAR TECHNOLOGIES, IS DESCRIBED IN SECTION 8 OF THE COOKIES POLICY BELOW.
c) Information Collected from Third Parties
We may collect information (including personal information) about you that other parties provide when they use our website, or from other sources, and combine it with information we collect through our website services. We do not control, monitor or respond to how third parties who provide your information process your personal data, and any requests for information sent to us regarding the disclosure of your personal information should be directed to such third parties.
- Third-Party Services. In order to confirm the transaction status and provide you with after-sales and dispute resolution services, we will collect your transaction, payment and logistics information related to the transaction progress through the transaction method, payment institution and logistics company you choose based on the transaction, or share your transaction information with the above-mentioned service providers;
- Other sources. Where permitted by applicable law, we may obtain additional information about you, such as demographic data or fraud detection information, from third-party service providers and/or partners, and combine such information with the information we have about you. For example, we may obtain background check information results (with your consent where necessary) or fraud warnings from service providers (identity verification services) for fraud prevention and risk assessment purposes. We may obtain information about you and your participation in our activities or your experiences and interactions with our partners' advertising
networks through our partners. In the above cases, we will require the third party to provide confirmation of the legitimate source of its personal information and use the relevant information within the scope of your authorization.
For the purposes set out in paragraphs b) and c) above, the user is free to choose whether or not to provide the information free of charge. If we refuse to provide such information, we will not be able to continue to achieve the stated purpose.
In addition, taking into account our ever-changing business scenarios and product functions, in addition to the above description, we may also process your other personal information through online or offline channels, but we will inform you through interactive voice, page copy, notice or authorization letter and obtain your consent.
To the extent that you disclose to us any personal data of another individual, and to the extent permitted by laws, we shall assume, without independent verification, that you have obtained such individual's consent for the disclosure of such personal data as well as the processing of the same in accordance with the terms of this Policy.
G. Your data may be accessed by third parties including operators, owners, processors of the Online Platforms.
H. Your account on our website is secured, please keep your account and password information safe. We will ensure that your information is not lost, misused and altered to the extent possible through security measures such as backing up to other servers and encrypting your password. Notwithstanding the foregoing security measures, please understand that there are no "perfect security measures" on the information network. We cannot guarantee the complete security of your data and information, especially remind you to stay away from telecommunications and network fraud, stay away from online black and grey industries, and properly keep your financial accounts and online account security from illegal acts.
I. In order to respond to personal information security incidents, we will fulfil our reporting and notification obligations in accordance with the requirements of laws and regulations, including: the basic situation and possible impact of the security incident, the measures we have taken or will take to deal with it, suggestions on how you can prevent and reduce risks independently, and remedial measures for you. On the premise of application, we will promptly inform you of the relevant circumstances of the incident by email, letter, telephone, push notification, etc., and if it is not practicable to inform the data subject one by one, we will take reasonable and effective measures to make an announcement. At the same time, we will also take the initiative to report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.
J. Our products or services, as well as the corresponding websites, are not targeted at children. We will not collect any personal information from children without the consent of their guardians. However, due to technical limitations, in some cases, such as when we provide online services, it is not possible to identify the age of users. If you are a child, please do not provide us with any of your personal information. If you are a child but voluntarily and must use our products or services, please be sure to let your guardian read these rules carefully, use our products or services with the consent of your guardian, and provide us with personal information. If we find that we have collected personal information from children without the prior consent of the child's guardian, we will delete the relevant
data in accordance with the law.
K. How you can manage your personal information:
a) Query, copy, change, and delete your personal information. You have the right to inquire, copy, change and delete your personal information, except for exceptions stipulated by laws and regulations. You also have the right to request the transfer of your personal information, subject to the provisions of the law. To exercise the aforesaid rights or request an explanation from us, please contact us through the contact information.
b) Withdrawal of consent and change of the scope of consent - We process your personal information based on consent, and you can withdraw your consent by changing your account settings, sending us an unsubscribe message, or contacting us through the contact information, and indicating which consent you wish to withdraw. Unless otherwise required by law, we will no longer process the corresponding personal information after you withdraw your consent. However, this decision will not affect the processing of personal information previously carried out on the basis of your authorization. You may change the scope of your authorization and consent for the collection and use of the information you choose to submit. You can do this by contacting us and following our guidelines.
c) Cancel your associated account: You can contact us through the contact information and follow our instructions. After the account is cancelled, we will stop providing you with products or services based on the account, and delete or anonymize your personal information according to your requirements, unless otherwise provided by laws and regulations. In order to protect your personal information and account security, we need to verify your identity when you manage your personal information in accordance with this Policy (we may need to obtain additional personal information for identity verification).
12. Specific Provisions on Consent and Exceptions
12.1 We will use our best endeavours to obtain your consent (express or implied) whenever we have to collect, process, use or store your personal data. However, if due to business impracticalities or other practical reasons, we are unable to obtain your consent, we will rely on the below exceptions to the Consent Obligation under the PDPA as the legal basis permitting our collection, use, transfer and/or disclosure of your personal data without consent.
a) Legitimate Interests Exception
We will rely upon this exception for the below purposes (non-exhaustive):
• Security and prevention of misuse of services;
• Detecting or preventing illegal activities (e.g. fraud, money laundering) or threats to physical safety and security, IT and network security;
• Preventing of misuse of services; and/ or
• Carrying out other necessary corporate due diligence
b) Business Improvement Exception
We will rely upon this exception where the use of the personal data falls within the scope of any of the following business improvement purposes:
• Improving, enhancing or developing new goods or services;
• Improving, enhancing or developing new methods or processes for business operations in
relation to the organisations’ goods and services;
• Learning or understanding behaviour and preferences of individuals (including groups of individuals segmented by profile); or
• Identifying goods or services that may be suitable for individuals (including groups of individuals segmented by profile) or personalising or customising any such goods or services for individuals.
Further, the Business Improvement Exception also applies to the sharing of personal data (i.e. collection and disclosure) between us and other entities belonging the LVMH Group, for the following business improvement purposes:
• Improving, enhancing or developing new goods or services;
• Improving, enhancing or developing new methods or processes for business operations in
relation to the organisations’ goods and services;
• Learning or understanding behaviour and preferences of existing or prospective customers (including groups of individuals segmented by profile); or
• Identifying goods or services that may be suitable for existing or prospective customers (including groups of individuals segmented by profile) or personalising or customising any such goods or services for individuals
In relying on the Business Improvement Exception, we will take steps to analyze and satisfy ourselves that a) the business improvement purpose cannot reasonably be achieved without using the personal data in an individually identifiable form; and b) Our use of personal data for the business improvement purpose is one that a reasonable person would consider appropriate in the circumstances.
13. Governing Law
13.1. This Policy is prepared pursuant to the PDPA and governed by the laws of Singapore.
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