Privacy Policy

1. INTRODUCTION

1.1 We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data. Please read this Privacy Policy carefully. We understand that you are very concerned about the usage and sharing of your personal information. And we are very appreciated your belief on our prudence and sensitivity handling this issue. This declaration will specify our policy regarding the protection of your privacy. If you have visited our website, that will be considered to be your acceptance to this privacy policy. Data protection is a matter of trust and your privacy is important to us. We shall therefore only process your name and other information which relates to you in the manner set out in this Privacy Policy. We will only collect information where it is necessary for us to do so and we will only collect information if it is relevant to our dealings with you. We will only keep your information for as long as we are either required to by law or as is relevant for the purposes for which it was collected. If you have any comments or suggestions, we would be pleased to receive them at our address or by contacting our Customer Service.
1.2 “Personal Data” means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include name, identification number and contact information.
1.3 By using the Services, registering for an account with us, visiting our website, or accessing the Services, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR WEBSITE. If we change our Privacy Policy, we will post those changes or the amended Privacy Policy on our website. We reserve the right to amend this Privacy Policy at any time.

2. WHEN WILL SINGGAHBELI COLLECT PERSONAL DATA?

2.1 We will/may collect personal data about you:
(a) when you register and/or use our Services or Site, or open an account with us;
(b) when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;

(c) when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
(d) when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails;
(e) when you use our electronic services, or interact with us via our application or use services on our website. This includes, without limitation, through cookies which we may deploy when you interact with our application or website;
(f) when you carry out transactions through our Services;
(g) when you provide us with feedback or complaints;
(h) when you register for a contest; or
(i) when you submit your personal data to us for any reason.
The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.
2.2 When you visit, use or interact with our mobile application or the Site, we may collect certain information by automated or passive means using a variety of technologies, which technologies may be downloaded to your device and may set or modify settings on your device. The information we collect may include, without limitation, your Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web site (if any), and the pages you visit on our website and mobile applications and the times of visit. We may collect, use disclose and/or process this information only for the Purposes (defined below).
2.3 Our mobile applications may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, etc.. We collect, use, disclose and/or process this information for one or more Purposes including, without limitation, location-based services that you request or to deliver relevant content to you based on your location or to allow you to share your location to other Users as part of the services under our mobile applications. For most mobile devices, you are able to withdraw your permission for us to acquire this information on your location through your device settings. If you have questions about how to disable your mobile device’s location services, please contact your mobile device service provider or the device manufacturer.

3. WHAT PERSONAL DATA WILL SINGGAHBELI COLLECT?

3.1 When you register a SinggahBeli account, the personal data or information we collect may include but is not limited to:
• Name
• Delivery Address
• Billing Address
• Email Address
• Date of Birth (Optional)
• Gender (Optional)
When you make a purchase on the SinggahBeli website, the additional personal information we collect may include:
• Telephone Number
• Mobile Number
• Delivery Address
• Bank Account information
• Credit card details (optional) and payment methodology
• any other information about the User when the User signs up to use our Services or website, and when the User uses the Services or website, as well as information related to how the User uses our Services or website; and
• aggregate data on content the User engages with.
3.2 The mandatory personal information we collect from you will be used and/or disclosed within our corporate group and to third parties for one or more of the following purposes:
• To deliver products that you purchase from our website. For example, we may pass your name and address on to a third party such as our courier service company or supplier of choice in order to make delivery of the product to you;
• To inform and update you on the delivery of the product and for customer support purposes;
• To provide you with relevant product information;
• To process your orders and to provide you with the services and information offered through our website and which you may request;
• To allow us to administer your registered account with us;
• To verify and carry out financial transactions in relation to payments you may make online. For example, payments that you make through our website will be processed by our appointed agent. Disclosure to these data processing agents such as that of our appointed agent in this context is necessary for the purpose of conducting the sales transaction that you have opted for.
• The non-mandatory personal information such as date of birth and gender are used to carry out research/es on our users’ demographics and for us to send you suggestion or information in the form of promotional emails which we think you may find useful, thereby, enhancing your experience when you visit our website. By providing us these non- mandatory personal information, you are deemed to have consented to be part of our research/es and to receiving suggestions or information as outlined above.
• any other purposes which we notify you of at the time of obtaining your consent. (collectively, the “Purposes”).

Subscription to our marketing and promotional materials
In addition to the personal information outlined above, when you register a SinggahBeli account with us, you shall be asked if you would like to subscribe to our marketing and or promotional materials from time to time. These marketing and or promotional materials may come from within our corporate group wholly or through affiliation with third parties. If you choose to so subscribe, you are deemed to have consented to us

processing within our corporate group and or third parties your personal information for this purpose. You can always choose to unsubscribe from marketing information at any time by opting for the unsubscribe function within the electronic marketing material.

Accessing Actual Orders
Your actual order details may be stored with us but for security reasons, cannot be retrieved directly by us. However, you may access this information by logging into your account on the website. Here, you can view the details of your orders that have been completed, those which are open and those which are to be dispatched as well as administer your address details, bank details and any newsletter to which you may have subscribed. You undertake to treat the personal access data confidentially and not make it available to unauthorised third parties. We cannot assume any liability for any misuse of passwords unless this misuse is through our own fault.

3.3 As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.

4. SECURITY OF YOUR PERSONAL INFORMATION

4.1 SinggahBeli ensures that all information collected will be safely and securely stored.
We protect your personal information by:
• Allowing access to personal information only via passwords;
• Maintaining technology products to prevent unauthorised computer access; and
• Securely destroying your personal information when it is no longer needed for our record retention purposes.

5. COOKIES

5.1 We may from time to time implement “cookies” or other features to allow us or third parties to collect or share information that will help us improve our Site and the Services we offer, or help us offer new services and features. “Cookies” are identifiers we transfer to your computer or mobile device that allow us to recognize your computer or device and tell us how and when the Services or website are used or visited, by how many people and to track movements within our website. We may link cookie information to personal data. Cookies also link to information regarding what items you have selected for purchase and pages you have viewed. This information is used to keep track of your shopping cart, for example. Cookies are also used to deliver content specific to your interest and to monitor website usage.

5.2 You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of our Site or the Services.

6. SHARING OF INFORMATION FROM THE SERVICES

Our Services enable Users to share personal information with each other, in almost all occasions without SinggahBeli’s involvement, to complete transactions. In a typical transaction, Users may have access to each other’s name, user ID, email address and other contact and postage information. Our Terms of Service require that Users in possession of another User’s personal data (the “Receiving Party”) must (i) comply with all applicable Privacy Laws; (ii) allow the other User (the “Disclosing Party”) to remove him/herself from the Receiving Party’s database; and (iii) allow the Disclosing Party to review what information have been collected about them by the Receiving Party.

7. HOW DOES SINGGAHBELI PROTECT CUSTOMER INFORMATION?

We implement a variety of security measures to ensure the security of your personal data on our systems. User personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. We will retain personal data in accordance with the Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any legal or business purposes. If you cease using the Site, or your permission to use the Site and/or the Services is terminated, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.

8. DISCLOSURE OF THE PERSONAL INFORMATION

8.1 In conducting our business, we will/may need to disclose your personal data to our third party service providers, agents and/or our affiliates or related corporations. Such third parties include, without limitation:
(a) our subsidiaries, affiliates, our corporate group and related corporations;
(b) contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies and data centres;
(c) a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of SinggahBeli’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by SinggahBeli about our Service Users is among the assets transferred; or to a counterparty in a business asset transaction that SinggahBeli or any of its affiliates or related corporations is involved in; and

(d) those third parties directly related to and necessary for the purchase of products, delivery of the same and purpose for which you have authorised. In exceptional circumstances, SinggahBeli may be required to disclose personal information, such as when there are grounds to believe that the disclosure is necessary to prevent a threat to life or health, or required by the law. SinggahBeli is committed to complying with the Personal Data Protection Act 2010, in particular, its policies as well as corresponding guidelines and orders.
8.2 This may require, among other things, share statistical and demographic information about our Users and their use of the Services with suppliers of advertisements and programming. This would not include anything that could be used to identify you specifically or to discover individual information about you.
8.3 For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the laws shall continue to apply.
8.4 Third parties may unlawfully intercept or access personal data transmitted to or contained on the site, technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of ours. We will nevertheless deploy reasonable security arrangements to protect your personal data as required by the Privacy Laws; however there can inevitably be no guarantee of absolute security such as but not limited to when unauthorised disclosure arises from malicious and sophisticated hacking by malcontents through no fault of ours. If you believe that your privacy has been breached by SinggahBeli please contact Customer Service and we will resolve the issue.

9. COLLECTION OF COMPUTER DATA NOT NECESSARILY PERSONAL INFORMATION

9.1 When you visit SinggahBeli, our company servers will automatically record information that your browser sends whenever you visit a website. This data may include:
• Your computer’s IP address
• Browser type
• Webpage you were visiting before you came to our website
• The pages within SinggahBeli that you visit
• The time spent on those pages, items and information searched for on our site, access times and dates, and other statistics
9.2 This information is collected for analysis and evaluation in order to help us improve our website and the services and products we provide. This data will not be used in association with any other personal information.

10. INFORMATION COLLECTED BY THIRD PARTIES

10.1 Our Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your computer, to help the website analyse how Users use

the Site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.
10.2 SinggahBeli and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone’s past visits to your website and across the Internet. These applications may separately access, and allow a third party to view, your identifiable information, such as your name, your user ID, your computer’s IP Address or other information such as any cookies that you may previously have installed or that were installed for you by a third party software application or website. Additionally, these applications may ask you to provide additional information directly to third parties. Third party products or services provided through these applications are not owned or controlled by SinggahBeli. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise.

11. DISCLAIMER REGARDING SECURITY AND THIRD PARTY SITES

11.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We do implement a variety of security measures to maintain the safety of your personal data that is in our possession or under our control. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the personal data confidential. When you place orders or access your personal data, we offer the use of a secure server. All personal data or sensitive information you supply is encrypted into our databases to be only accessed as stated above.
11.2 In an attempt to provide you with increased value, we may choose various third party websites to link to, and frame within, the Site. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our visitors. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third party web sites (even if offered on or through our Site) may not be received by us.
11.3 We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for your convenience and you therefore access them at your own risk. Nonetheless, we seek to protect the integrity of our Site and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).

12. TERMS AND CONDITIONS

Please also read the Terms of Service establishing the use, disclaimers, and limitations of liability governing the use of the Site and the Services and other related policies.

13. CHANGES TO THE PRIVACY POLICY

SinggahBeli reserves the right to modify and change the Privacy Policy at any time. Any changes to this policy will be published on our website. You should check this Policy each time you access our website so as to be aware of the most recent applicable version of the Policy.

14. COMPLAINTS ABOUT BREACHES OF PRIVACY

If you are not satisfied with the way in which we handle your enquiry or complaint, please don’t hesitate to contact Customer Service.