LHWY International Pte. Ltd. (“we”, “our”, “us”) value the information you have provided us or permitted us to collect. We strive to protect your privacy while providing you with the best service and experience we can provide. All such personal information in our possession is valued and is collected, used, disclosed and protected in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”). This Privacy Policy applies to all websites on which this Privacy Policy or a link to this Privacy Policy appears, as well as all our services and activities to the extent that you have been notified that such services and activities are subject to this Privacy Policy. By visiting or using any of the websites on which this Privacy Policy or a link to this Privacy Policy appears, you are deemed to agree to the terms of this Privacy Policy. Please review this Privacy Policy carefully prior to visiting or using any such websites or otherwise providing any personal data.
1. PERSONAL INFORMATION AND OTHER DATA WE COLLECT
1.1 “Personal data” as defined in the PDPA refers to data about an individual who can be identified from either that particular data, or from that data and other information which we have or are likely have access to. Personal data is collected where reasonably necessary for our functions and activities.
1.2 Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification number such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, year of birth, employment and income range, photographs and other audio-visual information, employment information and financial information such as credit card numbers or bank account information, your image in our CCTV recording when you visit our premises, etc.
1.3 Collection of Personal Data
1.3.1 Wherever possible, we will collect personal data directly from you. We will only collect, use and disclose personal data with your consent, your deemed consent or as may be otherwise permitted under the PDPA or other applicable laws.
1.3.2 If you are submitting personal data on behalf of another individual or concerns another individual other than yourself, you represent and warrant to us that all the necessary consents (procured in accordance with all applicable data protection legislation, including without limitation the PDPA, for such purposes stated in clause 2 of this Privacy Policy, have been obtained from the relevant individuals and that you have proof of these consents.
1.3.3 For the avoidance of doubt, personal data with respect to the making of payment for our services (e.g., credit card number) are collected by us solely for the purposes of processing payment. We do not store such personal data.
1.3.4 In addition to the personal data you provide to us, certain information related to you that is not considered personal data under the PDPA may also be collected. We collect this information to improve our website. Such non-personal data may include information such as your IP address, the internet browser you use, details of your interaction with our website and other types of non-personal data.
1.4 Use of Cookies
1.4.1 Cookies are small files which require user permission in order to be installed on a computer’s hard drive. Cookies will only start to perform their functions after such permission is granted. By collecting and analysing data on the user’s browsing patterns, cookies allow web applications to respond to the user as an individual by tailoring a web application’s operations to the user’s specific needs and preferences.
1.4.2 Permission for cookies is granted by default in most web browsers. You can however choose to disable this function in your browser’s settings. This may prevent you from taking full advantage of our website.
1.4.3 We may use traffic log cookies to identify which pages are being used. This use is designed to assist us in gathering data on web page traffic. The gathered data is used only for statistical purposes and is removed from our database shortly after.
1.4.4 Overall, the data collected by the cookies is used for the purpose of improving your browsing experience on our website. Cookies do not grant us access to your computer or any information about you outside of your browsing activity on our website.
2. USE AND DISCLOSURE OF YOUR PERSONAL DATA
2.1 We may collect and use personal data from our existing and prospective customers, business associates and employees for various reasons. Without limitation, these purposes include: – a) administering your accounts with us; b) responding to, handling, and processing queries, orders, requests, applications, complaints, and feedback from you; c) processing payment transactions; d) providing customer support; e) supplying you with information that is relevant to your existing relationship with us; f) sending you information about our products and services; g) sending your marketing information about our goods and services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions relating to LHWY International’s products, services and activities, and/or products, services and activities of third parties (including Millionaireasia Pte Ltd) that LHWY may collaborate with; h) obtaining your views or comments on the products and services that we provide; i) carrying out business improvements including making general improvements to our website, enhancing or developing new products and services, methods or processes for our operations, and understanding individuals’ behaviour in relation to our products and services; j) processing your employment applications; k) verifying your identity; l) for fraud prevention and detection; m) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; or n) any other purposes for which you have provided the information; o) transmitting to our authorised agents, related and/or associated companies (including Millionaireasia Pte Ltd), distributors, affiliates and partners; p) transmitting to any unaffiliated third parties including our third-party service providers and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and q) any other incidental business purpose related to or in connection with the above.
2.2 We may, for the above purposes, contact you via mail, electronic mail, telephone, SMS, facsimile or other forms of communication through mobile applications. Should you wish to opt-out of our contact list for any reason, please refer to the below clause 3 for the relevant procedure.
2.3 In the course of providing our services and products to you, we may need to disclose your personal data with external organisations. The reasons for which we may disclose your personal data are set out under clause 2.1 above. The possible parties we may share your personal data with include our related and/or associated companies (including Millionaireasia Pte Ltd), distributors and authorised agents, our affiliates, partners, third party service providers (for the purpose of providing us operational and/or marketing support), and governmental or regulatory authorities. If any of our businesses are sold or transferred to another entity, your personal data may be transferred along with the business.
2.4 We may transfer your Personal Data to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected.
2.5 The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce its rights under any contract with you).
2.6 There are exceptions under the PDPA whereby consent from you is not required for us to collect, use or disclose your personal data. You may write in to the Data Protection Officer at the contact details provided in clause 9 for more information regarding our reliance on such exceptions.
3. WITHDRAWING YOUR CONSENT
3.1 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 consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided in clause 9.
3.2 Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
3.4 Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our products or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 3.1.
3.5 Please 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 permitted or required under applicable laws.
4. ACCESS TO AND CORRECTION OF PERSONAL DATA
4.1 If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided in clause 9.
4.2 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.
4.3 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).
5. PROTECTION OF PERSONAL DATA
We will take all reasonable security measures to protect your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. While the transference of electronic data over the internet has inherent risks, we use reasonable precautions to ensure your personal data is not subject to unnecessary risks.
6. ACCURACY OF PERSONAL DATA
We generally rely on personal data provided by you. In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided in clause 9.
7. RETENTION
We will retain your Personal Data for as long as necessary in order to fulfil the business or legal purposes for which it was collected, or as required by the relevant laws.
8. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
In the event that any of the above parties mentioned in clause 2 receiving your personal data are located or are operating outside of Singapore, we will take reasonable steps to ensure that the overseas recipient provides a standard of protection to your personal data so transferred that is comparable to the protection under the PDPA.
9. DATA PROTECTION OFFICER
You may contact our Data Protection Officer at admin@youtlocked.com or write in to us if you have any enquiries or feedback on our personal data protection policies and practices, or if you wish to make any request or complaint relating to the use or disclosure of your personal data.
10. RIGHTS TO AMEND THIS PRIVACY POLICY
10.1 We reserve the right to amend this Privacy Policy at any time. If material changes are made to this Privacy Policy, they will be posted on this page and date stamped. We encourage you to review this page periodically in order for you to stay notified of any changes.
10.2 Your continued use of this website and acceptance of our services after any changes to this Privacy Policy constitutes your consent to any such changes, to the extent such consent is not otherwise provided.I