PERSONAL DATA PROTECTION POLICY


We are Y-SG Pte. Ltd. (Company Registration No. 200005870E), trading as www.ysg.com.sg ("YSG").

Protection of your Personal Data is important to us. This Personal Data Protection Policy ("Policy") outlines how we manage the Personal Data we hold.

Please read and review this Policy, which will detail you how we collect, use, process and disclose your Personal Data. We may also collect and process your Personal Data under any exceptions to Applicable Laws, which are not set out in this Policy.

Capitalised terms used in this Policy shall have the following meanings:

  • "Applicable Laws" means Singapore’s Personal Data Protection Act 2012 (No. 26 of 2012) and its subsidiary legislations and regulations as enacted and amended from time to time;
  • "Apps" means any app we may own, manage, operate and make available from time to time, including on iOS and Android;
  • "Personal Data" means any data, whether true or not, which is: (a) about an individual who can be identified (i) from that data; or (ii) from that data and other information to which we have or are likely to have access and would include data in our records as may be updated from time to time, or (b) defined as "personal data" or "personal information" under any Applicable Laws.
  • "Platforms"means collectively YSG’s Apps, Social Media and Website, and any other websites or applications which we may own, manage or operate from time to time;
  • "Social Media" means YSG’s pages and accounts on any third party social media platforms such as Instagram, Facebook, Twitter, Pinterest and Google+;
  • "Website" means the web and mobile versions of the YSG website accessed at the following address at www.ysg.com.sg; and
  • "we","us", or "our"  means YSG.


This Policy applies in conjunction with other notices, contractual clauses and consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your Personal Data by us and is not intended to override them unless we state expressly otherwise.

During our relationship with you, we may collect Personal Data from you. Such Personal Data include identity data, such as your name, gender, profile picture and date of birth, contact data, such as mailing, delivery and billing addresses, email address and phone numbers, account data, such as bank accounts and payment details, transaction data, such as details about orders and payments to and from you, and other details of products and services that you have purchased or obtained through our Platform, technical data, such as network and device data (including your internet protocol (IP address and device or advertising identifiers), login data, browser type and version, time zone setting and location, browser plug-in types and versions, device identifier, and other information and technology on the devices you use to access our Platform, profile data, such as your username and password, order history, interests, preferences, feedback and survey responses, usage data, such as information on how you use our Platform, products and services or view any content on our Platform, location data, such as when you capture and share your location with us in the form of photographs or videos and upload such content to our Platform or otherwise link to our Social Media, biometric data, such as your facial image, voice recordings (for customer service calls), marketing and communications data, such as your preferences in receiving marketing from us and our third parties and your communication preferences, and any other personally identifiable information which you have provided us in any forms you may have submitted to us, or in the course of any other forms of interaction between you and us.

If you provide us with Personal Data relating to a third party by submitting such Personal Data to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the relevant purposes.

BY (1) CLICKING "YES" OR CHECKING "SIGN UP" ON OUR POLICY POP-UP OR ANY WEB FORM REFERRING TO THIS POLICY ON ANY OF OUR ONLINE PLATFORMS, (2) SUBMITTING YOUR PERSONAL DATA TO US WHEN SIGNING UP FOR AN ACCOUNT ON THE WEBSITE, (3) BROWSING OUR WEBSITE, OR (4) ORDERING ANY OF OUR PRODUCTS AND SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE BEEN NOTIFIED OF AND UNDERSTAND THE TERMS OF THIS POLICY AND YOU AGREE AND CONSENT TO THE TERMS OF THIS POLICY.

We may update this Policy to ensure that it is consistent with industry trends and/or any changes in relevant legal or regulatory requirements. We reserve the right to amend the terms of this Policy at our absolute discretion. Subject to your rights at law, you agree to be bound by the prevailing terms of this Policy as updated from time to time on our Platform. Any amended Policy will be posted on our Platform and can be viewed at Data Policy. By continuing to use our Platform and/or services after this Policy has been amended, you hereby agree to be bound by the terms of such amended Policy.

You are encouraged to visit the above Website from time to time to ensure that you are well-informed of our latest policies in relation to Personal Data protection.


COLLECTION OF PERSONAL DATA

We collect Personal Data from you when

  1. you register an account on our Platform;
  2. you log in to your account on our Platform or otherwise interact with us via an external service or application (such as Facebook or Google);
  3. you use any of our related services, such as subscribing to our newsletter, marketing collaterals, product or inventory restock notifications;
  4. you browse our products and services or otherwise interact with our Platform;
  5. you use any of the features or functions available on our Platform;
  6. you accept our cookies on your device;
  7. you interact with our customer experience team or other representatives, for example, via our webform or chat function on our Platform, email correspondence, telephone calls, letters, or face-to-face meetings;
  8. you interact with us on our Social Media, such as liking or commenting on our posts, private or direct messaging us on our Social Media;
  9. you record any user-generated content which is uploaded on our Platform;
  10. you participate in our promotions, lucky draws, giveaways, initiatives or any request for additional Personal Data such as customer surveys;
  11. we receive references from business partners and third parties, for example, where they referred you to us to enjoy the benefits of a joint promotion or collaboration or to redeem a voucher you purchased through them;
  12. your authorised representative submits your Personal Data to us for any purpose reasonably authorised by you, for example if such representative is purchasing our product or service to be delivered to you or as a gift;
  13. our third-party analytics and other service providers provide your Personal Data to us, which was collected and processed by them and disclosed to us pursuant to their separate privacy policies; or
  14. when you voluntarily submit your Personal Data to us for any reason

We usually do not collect your credit card details, whether to process your payment or for customer service purposes. Your credit card details are collected, processed and stored directly by our third-party payment processors pursuant to their terms of use and privacy policies. None of your credit card details are stored with us. However, we may collect your bank account details to process refunds.

We may also collect your Personal Data in circumstances where such collection does not require consent under Applicable Laws.

Please ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure to do so may result in our inability to provide or continue providing you with the products and services you have requested.


USE OF PERSONAL DATA

We may use and disclose your Personal Data for purposes necessary to provide you with our products and services, including to:

  1. facilitate your use of and access to our Platform;
  2. register and maintain your user account and to verify your identity or age;
  3. process your order for our products or services, process or collect your payment for the order;
  4. deliver or perform the products or services you purchased, including our couriers (third party or otherwise) calling or messaging you to obtain your delivery instructions;
  5. process your returns or refunds in accordance with our Customer Terms of Service
  6. provide you with supporting services and functions related to your user account, such as saved items in cart, wish list, brand or product notifications;
  7. communicate with you in relation to (a) your queries, requests and feedback, (b) material changes to our Customer Terms of Service or other terms and conditions, and (c) matters relating to the operation of your account;
  8. personalise and improve your customer experience when you visit our Platform, for example by prioritising products and services appearing in your search results or feed;
  9. monitor and enforce compliance with our Customer Terms of Service, including dispute resolution;
  10. comply with (a) internal risk controls, (b) the terms of our access to payment processing, financial or banking services such as credit card disputes, fraud, billing errors, or (c) any applicable law;
  11. ensure our Platform functions properly and to improve its performance, by carrying out activities such as debugging, statistical analyses for optimizing our Platform;
  12. send you marketing communications in relation to our sales, products, services, promotions or our Platform;
  13. send you marketing communications in relation to the sales, products, services or promotions of business partners, including promotional mail together with your order;
  14. deliver ads which are related to our products and services which may be of interest to you on our Platform or other websites, apps or online platforms;
  15. enable businesses to deliver ads which are related to their products and services which may be of interest to you;
  16. provide you with any add-on or premium services we may develop or initiate from time to time;
  17. invite you to our private customer events;
  18. process your participation in and otherwise administer our promotions, contests, lucky draws, initiatives or any request for additional Personal Data such as customer surveys;
  19. process your participation in our business partners’ loyalty or point redemption programs;
  20. promote our products and services on our Platform;
  21. manage the administrative and business operations of YSG and complying with internal policies and procedures;
  22. improve your customer experience across all touchpoints and training our customer experience team, such as by recording and monitoring phone calls; and
  23. any specific purpose in relation to a particular product or service, which we may separately notify you on the product or service page,

(collectively, the "Purposes").

We may also use your Personal Data: (a) for other purposes which are reasonably related to the Purposes; or (b) in circumstances where such use does not require consent under Applicable Laws. The above Purposes are not exhaustive and depending on the nature of your relationship with us, we may collect, use and disclose your Personal Data for additional purposes which you will be notified of, in accordance with applicable terms and conditions.

Please note that if you withdraw your consent for us to use and process your Personal Data the Purposes, we may no longer be able to provide you with the related products, services or benefits associated with such Purposes.


SHARING OF PERSONAL DATA

In relation to our use of your Personal Data for the Purposes, we may disclose your Personal Data to our:

  1. employees, consultants, temporary workers;
  2. sellers on our Platform, who supply and deliver the products or services you ordered through our Platform;
  3. payment processors, who process your payment on our Platform;
  4. logistics providers, such as courier services which will deliver your order to you, third party or otherwise;
  5. business partners who separately maintain an account with you for loyalty or point redemption programs;
  6. business partners or vendors in connection with the processing of any promotion, event or service organised by us;
  7. professional advisers and consultants such as our auditors and lawyers;
  8. banks, credit companies and their respective service providers;
  9. agents, contractors, affiliates or service providers who provide operational services to us, such as online cloud storage and processing, marketing optimisation, information technology, telecommunications, security or other relevant services which requires their collection, use or disclosure of your Personal Data; and
  10. any other party whom you authorise us to disclose your Personal Data to.

We may also disclose your Personal Data: (a) for other purposes which are reasonably related to the Purposes; or (b) in circumstances where such disclosure does not require consent under the Applicable Laws.

We do our best to minimise the disclosure of your Personal Data to the information necessary to perform the related Purpose. We will also require that such organisations or persons to whom such disclosure is made as service providers to us acknowledge the confidentiality of such Personal Data, undertake to respect any individual's right to privacy and comply with Applicable Laws.


ACCESSING OR CORRECTING PERSONAL DATA

You may access or correct your name, birthday, phone numbers, shipping and billing addresses or other Personal Data by logging in to your user account on our Platform.

For Personal Data that cannot be corrected by you by logging in to your user account on our Platform, you may request to access and correct such Personal Data by submitting a written request to us by emailing our Data Protection Officer at [email protected] We may need to request additional information from you to confirm your identity before providing the access or making the correction.

We will do our best to respond to Personal Data access and correction requests within 21 business days. Where we are unable to meet this timeline, we will update you with the soonest possible time within which we can provide the information or make the correction.

We reserve the right to charge a reasonable administrative fee for retrieving your Personal Data records and/or handling and processing your Personal Data access request. If so, we will inform you of the fee before processing your request.

We will take steps to send your corrected Personal Data to every other person or entity to which such Personal Data was disclosed by YSG within the year after the date of the correction, unless such person or entity does not need the corrected Personal Data for any legal or business purpose.


REQUEST TO WITHDRAW CONSENT

If you wish to withdraw your consent for us to send you sales, marketing or promotional information, please inform us as follows:

  1. to withdraw consent from receiving SMS/Whatsapp promotions or promotions via other social media channels: please unsubscribe by following the steps provided in the promotional SMS/Whatsapp or relevant message/post;
  2. to withdraw consent from promotional emails: please click on the Unsubscribe link in the promotional emails;
  3. to withdraw consent from receiving promotional material with your order package: please email our Data Protection Officer at [email protected]

Once we receive notification of your intention to withdraw your consent for receiving sales, marketing or promotional materials or communications, it may take up to 21 business days for your withdrawal to be reflected in our systems. During this interim period, you may still receive marketing or promotional materials or communications.

If you withdraw your consent to receive marketing or promotional materials through a specific communication mode (e.g. SMS), we may still contact you for other purposes in relation to the products and services via other communication modes you have subscribed to (e.g. email).

You may withdraw your consent for the collection, use and/or disclosure of any of your Personal Data in our possession or under our control by submitting a written request via email to our Data Protection Officer at [email protected] Depending on the nature of the consent withdrawal, we may not be able to continue to provide you with some or all of our products or services. We will process such a request within a reasonable time from the date we receive notice from you of your withdrawal of consent. Once processing is complete, we will no longer collect, use and/or disclose your Personal Data, except to the extent we retain your Personal Data for compliance, regulatory or other legal purposes.


ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

We will make reasonable efforts to ensure Personal Data likely to be used by us or disclosed by us to another organization is accurate and complete. However, you should update us of any changes in your Personal Data. We will not be responsible for relying on inaccurate or incomplete Personal Data if you have not updated us of changes.

We will also put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured. This includes putting in place reasonable measures to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage or alteration of your Personal Data, such as restricting access to Personal Data to individuals who require access, maintaining technology products to prevent unauthorised computer access and using 128-bit SSL (secure sockets layer) encryption technology when processing your financial details. However, we will not be responsible for any unauthorized use of Personal Data by third parties which is attributable to factors beyond our control.

When Personal Data in our possession is: (a) no longer required for any reason connected to the purpose it was originally collected; or (b) retention by us is no longer necessary for any other legal or business purposes, we will exercise measures to ensure such Personal Data is either destroyed or anonymised.


TRANSFER OF PERSONAL DATA

Your Personal Data may be stored in external servers located overseas. In addition, in carrying out our business, it may be necessary to share information about you with and between our related corporations and affiliates, and third party service providers, some of which may be located in countries outside your country of residence. Such countries may not afford a standard of protection similar to those in your country of residence. However, we will take reasonable steps to ensure that your Personal Data transmitted outside of your country of residence is adequately protected. In addition, we will ensure that such transfers comply with the requirements of the applicable data protection laws.

 

THIRD PARTY COOKIES

YSG or its authorised service providers may implement cookies, web beacons and other similar technologies for storing data on our Platform. When you visit our Platform through any device with internet connectivity, our computer servers will automatically record data including your IP address, browser type, webpage you were visiting before you came to our Platform, the pages within our Platform which you visit, and the time spent on those pages, items and data searched for on our Platform and other statistics. Advertisements on our Platform may be provided by third party agencies. These advertisements may also generate cookies, for example, to track how many people have viewed the advertisement. The collection, use, and disclosure of information, including Personal Data, collected by such third party cookies are subject to the privacy and data protections policies of the third party vendors and are not under our control.

You may manage and/or reject cookies through the settings on your browser or device. Note that this may result in the loss of Platform functionality, restrict your use of our Platform, or delay or affect the way in which our Platform operates.


RIGHT TO DISCLOSE PERSONAL DATA

YOU ACKNOWLEDGE AND AGREE THAT YSG HAS THE RIGHT TO DISCLOSE YOUR PERSONAL DATA TO ANY LEGAL, REGULATORY, GOVERNMENTAL, TAX, LAW ENFORCEMENT OR OTHER AUTHORITIES OR THE RELEVANT RIGHT OWNERS, IF YSG HAS REASONABLE GROUNDS TO BELIEVE THAT DISCLOSURE OF YOUR PERSONAL DATA IS NECESSARY FOR THE PURPOSE OF MEETING ANY OBLIGATIONS, REQUIREMENTS OR ARRANGEMENTS, WHETHER VOLUNTARY OR MANDATORY, AS A RESULT OF COOPERATING WITH AN ORDER, AN INVESTIGATION AND/OR A REQUEST OF ANY NATURE BY SUCH PARTIES. TO THE EXTENT PERMISSIBLE BY APPLICABLE LAW, YOU AGREE NOT TO TAKE ANY ACTION AND/OR WAIVE YOUR RIGHTS TO TAKE ANY ACTION AGAINST YSG FOR THE DISCLOSURE OF YOUR PERSONAL DATA IN THESE CIRCUMSTANCES.


GOVERNING LAW

This Policy shall be governed and construed in accordance with the laws of the Republic of Singapore.


CONTACT US

For any questions relating to your Personal Data or about this Policy, if you have a complaint regarding the collection, use or handling of your Personal Data by us, or a question about how we are complying with Applicable Laws, you may contact our Data Protection Officer in writing at [email protected]

 

(As at 24 October 2020)  

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