CARRAGHEEN BOUTIQUE COMPLIANCE ON PDPA

General

The Personal Data Protection Act 2012 (“PDPA”), which applies to all private organisations that ollect or process personal data in Singapore, will be implemented in two phases. The first phase, which was implemented on 2 January 2014, established a Do-Not-Call (“DNC”) registry, allowing persons to opt out of telemarketing activities by registering their Singapore telephone numbers with the DNC Registry. The second phase, governing the collection use and disclosure of personal data, is scheduled to come into effect on 2 July 2014.

Personal data is any data which can be used by an organisation to identify an individual, either on its own or together with other information to which that organisation has access. It expressly excludes business contact information, e.g. as contained in a business card, unless the card is given by an individual for a personal purpose (except where business contact information is specifically referred to in the PDPA).

The PDPA comprises rules governing the collection, use, disclosure and care of personal data and requires organisations to have a legitimate and reasonable purpose for their collection, use or disclosure of personal data and to obtain the informed consent of an individual prior to the collection, use or disclosure of his personal data.

Organisations must also take steps to duly verify and protect personal data collected and to remove such data when it is no longer required. Individuals must further be allowed to access and correct their personal data and to withdraw any previously provided consent.

Fundamentally, organisations must adopt and implement appropriate internal policies and practices relating to their collection, use or disclosure of personal data which are reasonable and relevant to their business needs and compliant with the provisions of the PDPA, by 2 July 2014. Organisations may continue to use personal data which has been collected before 2 July 2014 for the purposes it was collected, unless the individual has withdrawn consent. However if the purpose has changed, new consent will need to be obtained. Organisations must also appoint a Data Protection Officer (“DPO”) to be overall responsible for their compliance with the provisions of the PDPA.

Actions Required

a. Appoint Personal Data Officer

b. Briefing to staff on how to use data especially on contacting customers.

c. Privacy statement to be put on website

d. Consent form for customers to sign to allow their data to be used by CARRAGHEEN

e. Notice at front of shop ( Our premises are monitored by CCTV for security purposes)

CARRAGHEEN BOUTIQUE PTE LTD PRIVACY POLICY

CARRAGHEEN BOUTIQUE PTE LTD take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We also 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

1. INTRODUCTION

1.1 This is the privacy policy (“Privacy Policy”) of CARRAGHEEN BOUTIQUE PTE LTD and its affiliates (including but not limited to its subsidiaries, related, associated and affiliated companies, whether such companies are residing, situated, carrying on business, incorporated or constituted within or outside SINGAPORE).

1.2 This Privacy Policy applies to personal information about individuals held by the CARRAGHEEN BOUTIQUE PTE LTD. CARRAGHEEN BOUTIQUE PTE LTD will only process your Personal Data in accordance with the Personal Data Protection Act 2012, the applicable regulations, guidelines, orders made under the PDPA and any statutory amendments or re-enactments made of the PDPA from time to time (collectively referred to as the “PDPA”) as well as this Privacy Policy.

1.3 CARRAGHEEN BOUTIQUE PTE LTD reserves the right, at its sole discretion, to modify, update and/or amend this Privacy Policy from time to time with reasonable prior notice to you. CARRAGHEEN BOUTIQUE PTE LTD will notify you of any amendments via announcements on the CARRAGHEEN BOUTIQUE PTE LTD website (“Site”) or other appropriate means as determined by the CARRAGHEEN BOUTIQUE PTE LTD. Please therefore remember to check this Site from time to time to see if there are amendments to this Privacy Policy.  Any amendments to this Privacy Policy will be effective upon notice to you. By continuing to use the services and/or access to the Site after being notified of any amendments to this Privacy Policy, you will be treated as having agreed to and accepted those amendments.

1.4      You may obtain a copy of this Privacy Policy on http://www.carragheen.com/ or by contacting the CARRAGHEEN BOUTIQUE PTE LTD at the contact details below.

1.5      If you do not agree to this Privacy Policy or any amendments to this Privacy Policy, CARRAGHEEN BOUTIQUE PTE LTD may not be able to render all services to you and you may be required to terminate your relevant agreement with CARRAGHEEN BOUTIQUE PTE LTD and/or stop accessing or using the website.

2. COLLECTION OF PERSONAL DATA

2.1      The term “Personal Data” means any information in the possession of CARRAGHEEN BOUTIQUE PTE LTD or control of CARRAGHEEN BOUTIQUE PTE LTD that relates directly or indirectly to an individual to the extent that the individual can be identified or are identifiable from that and other information in the possession of CARRAGHEEN BOUTIQUE PTE LTD such as name, address, telephone number, NRIC, email address, etc. CARRAGHEEN BOUTIQUE PTE LTD may “process” your Personal Data by way of collecting, recording, holding, storing, using or disclosing it.

2.2      Your Personal Data may be collected from you during your course of dealings CARRAGHEEN BOUTIQUE PTE LTD in any way or manner including pursuant to any transactions and/or communications made from/with the CARRAGHEEN BOUTIQUE PTE LTD. CARRAGHEEN BOUTIQUE PTE LTD may also collect your Personal Data from a variety of sources, including without limitation, at any events, seminars, road shows, customer satisfaction surveys organised or sponsored by the CARRAGHEEN BOUTIQUE PTE LTD and/or from the cookies used on the Site.

2.3      In addition, the CARRAGHEEN BOUTIQUE PTE LTD may also receive, store and process your Personal Data which are provided or made available by any third parties, credit reference bodies, regulatory and law enforcement authorities, for reasons including delivery of CARRAGHEEN BOUTIQUE PTE LTD products and/or services, performance of conditions of agreements and/or to comply with the CARRAGHEEN BOUTIQUE PTE LTD legal and regulatory obligations.

3.PURPOSE OF ACQUIRING AND PROCESSING YOUR PERSONAL DATA

Your Personal Data may be processed for the following purposes:

(a)            to communicate with you;

(b)            to provide products and/or services to you;

(c)            to respond to your enquiries or complaints;

(d)            to process your purchase and/or contest entry;

(e)            to provide you with information and/or updates on the present and future appointments, other products, services and/or promotions offered by the CARRAGHEEN BOUTIQUE PTE LTD and selected third parties which may be of interest to you from time to time by SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels;

(f)            to send you seasonal greetings messages from time to time;

(g)            to send you invitation to join CARRAGHEEN BOUTIQUE PTE LTD membership, events and promotions and other events;

(h)           to monitor, review and improve the, treatments, products and/or services that you currently have with CARRAGHEEN BOUTIQUE PTE LTD;

(i)             to process and analyse your Personal Data either individually or collectively with other individuals;

(j)            to conduct market research or surveys, client profiling activities, planning and statistical analysis within CARRAGHEEN BOUTIQUE PTE LTD.

(k)           to share any of your Personal Data with the auditor for CARRAGHEEN BOUTIQUE PTE LTD internal audit purposes;

(l)           to share any of your Personal Data with a third party necessary for the preparation of legal documents or contract to be entered by you with CARRAGHEEN BOUTIQUE PTE LTD.

(m)           to share any of your Personal Data with a third party necessary for the purpose of applying and obtaining insurance policy(ies), where necessary;

(n)          to maintain and improve customer relationship;

(o)          to maintain and update internal record keeping;

(p)          for registration for a user account with CARRAGHEEN BOUTIQUE PTE LTD

(q)          for internal administrative purposes;

(r)           for audit and risk management purposes;

(s)           for detecting, investigating and preventing fraudulent, prohibited or illegal activities;

(t)           for direct marketing purposes via SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels;

(u)           for meeting any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to the CARRAGHEEN BOUTIQUE PTE LTD;

(v)            to enforce or defend CARRAGHEEN BOUTIQUE PTE LTD rights and your rights under, and to comply with, CARRAGHEEN BOUTIQUE PTE LTD obligations under the applicable laws, legislation and regulations; and/or

(w)         for other purposes required to operate and maintain CARRAGHEEN BOUTIQUE PTE LTD business, (collectively referred to as the “Purposes”), and you agree and consent to CARRAGHEEN BOUTIQUE PTE LTD using and processing your Personal Data for the Purposes in the manner as identified in this Privacy Policy. If you do not consent to CARRAGHEEN BOUTIQUE PTE LTD processing your Personal Data for one or more of the Purposes, please notify CARRAGHEEN BOUTIQUE PTE LTD at the contact details below.

4. CONSEQUENCES OF NOT CONSENTING TO THIS PRIVACY POLICY

It is obligatory for CARRAGHEEN BOUTIQUE PTE LTD to collect and to retain your Personal Data unless stated otherwise. If you do not supply CARRAGHEEN BOUTIQUE PTE LTD with your Personal Data, or do not consent to the above or this Privacy Policy, CARRAGHEEN BOUTIQUE PTE LTD may not be able to:

(a)            to process your purchase of any of the CARRAGHEEN BOUTIQUE PTE LTD products and/or services;

(b)            communicate with you;

(c)            provide you with CARRAGHEEN BOUTIQUE PTE LTD products and/or services requested;

(d)            accept and process your entry to any contest;

(e)            update you on CARRAGHEEN BOUTIQUE PTE LTD latest products, services and/or promotions; and/or

(f)            allow you to access certain sections of the Site where log in is required,

and you may be required to terminate your agreement or discontinue your business relationship with CARRAGHEEN BOUTIQUE PTE LTD.

5. DISCLOSURE OF YOUR PERSONAL DATA

CARRAGHEEN BOUTIQUE PTE LTD will not disclose any of your Personal Data to any third party without your consent except to the following third parties, for one or more of the above Purposes:

(a)            companies within CARRAGHEEN BOUTIQUE PTE LTD and their respective employees;

(b)            your immediate family members and/or emergency contact person as may be notified to CARRAGHEEN BOUTIQUE PTE LTD from time to time;

(c)             CARRAGHEEN BOUTIQUE PTE LTD business partners and affiliates that provide related products and/or services in connection with CARRAGHEEN BOUTIQUE PTE LTD s business for joint promotions and/or contests;

(d)            any person under a duty of confidentiality to which has undertaken to keep your Personal Data confidential which CARRAGHEEN BOUTIQUE PTE LTD has engaged to discharge our obligations to you;

(e)            any party in relation to legal proceedings or prospective legal proceedings;

(f)              CARRAGHEEN BOUTIQUE PTE LTD auditors, consultants, lawyers or other financial or professional advisers on a need to know basis for the purpose of those advisers providing advice to CARRAGHEEN BOUTIQUE PTE LTD;

(g)             any party nominated or appointed by CARRAGHEEN BOUTIQUE PTE LTD either solely or jointly with other service providers, for purpose of establishing and maintaining a common database where CARRAGHEEN BOUTIQUE PTE LTD has a legitimate common interest;

(h)            data centres and/or servers located within or outside Singapore for data storage purposes;

(i)              payment channels including but not limited to financial institutions for purpose of assessing, verifying, effectuating and facilitating payment of any amount due to the CARRAGHEEN BOUTIQUE PTE LTD in connection with your purchase of the CARRAGHEEN BOUTIQUE PTE LTD products and/or services;

(j)              government agencies, law enforcement agencies, courts, tribunals, regulatory bodies, ministries, and/or statutory agencies or bodies, offices or municipality in any jurisdiction, if required or authorised to do so, to satisfy any applicable law, regulation, order or judgment of a court or tribunal or queries from the relevant authorities;

(k)          any provider of public utility or related services, whether or not governmental owned and/or any corporations approved and established for the provision of utility services and facilities,

(l)           CARRAGHEEN BOUTIQUE PTE LTD appointed product and/or service providers, suppliers or agents, to discharge or perform one or more of the above Purposes;

(m)           any persons, authorities or regulators to whom the CARRAGHEEN BOUTIQUE PTE LTD is permitted or required to disclose to under the applicable laws; and/or

(n)            the general public when you become a winner in a contest by publishing your name, photographs and other Personal Data without compensation for advertising and publicity purposes.

6. ACCURACY OF YOUR PERSONAL DATA

CARRAGHEEN BOUTIQUE PTE LTD aims to keep all Personal Data as accurate, complete, not misleading, up-to-date and reliable as possible. Therefore, the accuracy of your Personal Data depends to a large extent on the information you provide. As such, it is a condition CARRAGHEEN BOUTIQUE PTE LTD providing the products and/or services to you that you:

(a)            warrant and declare that all your Personal Data submitted or to be submitted to CARRAGHEEN BOUTIQUE PTE LTD are accurate, not misleading, updated and complete in all respects for purposes of acquiring or using the relevant products and/or services and you have not withheld any Personal Data which may be material in any respect and that CARRAGHEEN BOUTIQUE PTE LTD is authorized to assume the authenticity and up datedness of the Personal Data given by you when processing the Personal Data submitted by you to CARRAGHEEN BOUTIQUE PTE LTD (and CARRAGHEEN BOUTIQUE PTE LTD not obliged to independently verify any of such Personal Data); and

(b)            you understand and agree to, the importance of the need to, update CARRAGHEEN BOUTIQUE PTE LTD as and when such Personal Data provided earlier to CARRAGHEEN BOUTIQUE PTE LTD becomes inaccurate, incomplete, misleading, outdated or changes in any way whatsoever by contacting CARRAGHEEN BOUTIQUE PTE LTD at the contact details below.

7.YOUR RIGHTS

7.1      Subject to the exceptions provided under the PDPA, you have the right to request for access to, request for a copy of, request to update or correct, your Personal Data held by CARRAGHEEN BOUTIQUE PTE LTD. CARRAGHEEN BOUTIQUE PTE LTD may charge a small fee (such amount as permitted by the PDPA) to cover the administration costs involved in processing your request to access your Personal Data.

7.2      In respect of your right to access and/or correct your Personal Data, CARRAGHEEN BOUTIQUE PTE LTD has the right to refuse your request to access and/or correct your Personal Data for the reasons permitted under the law, such as where the expense of providing access to you is proportionate to the risks to your privacy, or where the rights of others may also be violated, amongst other reasons.

7.3      You have the right at any time to request CARRAGHEEN BOUTIQUE PTE LTD to limit the processing and use of your Personal Data (for example, requesting CARRAGHEEN BOUTIQUE PTE LTD to stop sending you any marketing and promotional materials or contacting you for marketing purposes).

7.4      In addition, you also have the right to inform CARRAGHEEN BOUTIQUE PTE LTD on your withdrawal (in full or in part) of your consent given previously to CARRAGHEEN BOUTIQUE PTE LTD subject to any applicable legal restrictions, contractual conditions and a reasonable duration of time for the withdrawal of consent to be effected.

8. RETENTION OF YOUR PERSONAL DATA

Any of your Personal Data provided to CARRAGHEEN BOUTIQUE PTE LTD is retained for as long as the purposes for which the Personal Data was collected continues; your Personal Data is then destroyed unless its further retention is required to satisfy a longer retention period to meet the operational, legal, regulatory, tax or accounting requirements of CARRAGHEEN BOUTIQUE PTE LTD.

9. SECURITY OF YOUR PERSONAL DATA

9.1      CARRAGHEEN BOUTIQUE PTE LTD is committed to ensuring that your Personal Data is stored securely. In order to prevent unauthorised access, disclosure or other similar risks, CARRAGHEEN BOUTIQUE PTE LTD endeavours, where practicable, to implement appropriate technical and organisational measures in accordance with the applicable laws and regulations to safeguard against and prevent the unauthorised or unlawful processing of your Personal Data, and the destruction of, or accidental loss, damage to, alteration of, unauthorised disclosure of or access to your Personal Data.

9.2      CARRAGHEEN BOUTIQUE PTE LTD will make reasonable updates to its security measures from time to time and ensure the authorised third parties only use your Personal Data for the Purposes set out in this Privacy Policy, and to adequately safeguard your Personal Data.

9.3      The Internet is not a secure medium. However, CARRAGHEEN BOUTIQUE PTE LTD will put in place various security procedures with regard to the Site and your electronic communications with CARRAGHEEN BOUTIQUE PTE LTD.

9.4      Please be aware that communications over the Internet, such as emails/webmails are not secure unless they have been encrypted. Your communications may be routed through a number of countries before being delivered – this is the nature of the World Wide Web/Internet.

9.5      CARRAGHEEN BOUTIQUE PTE LTD cannot and does not accept responsibility for any unauthorised access or interception or loss of Personal Data that is beyond CARRAGHEEN BOUTIQUE PTE LTD reasonable control.

10. PERSONAL DATA FROM MINORS AND OTHER INDIVIDUALS

To the extent that you have provided (or will provide) Personal Data about your family, spouse and/or other dependents, you represent and warrant that you have obtained their consent to provide their Personal Data to CARRAGHEEN BOUTIQUE PTE LTD and they consent to their Personal Data being processed in accordance with this Privacy Policy and, with respect to minors (i.e. individuals under 18 years of age) or any individuals not legally competent to give consent, you consent on their behalf (and you confirm that you have the authority to do so).

11. WEBSITE

11.1   External links

(a)            If any part of the Site links you to other websites, those websites do not operate under this Privacy Policy and CARRAGHEEN BOUTIQUE PTE LTD does not accept any responsibility or liability arising from those websites.

(b)            Likewise, if you subscribe to an application, content or a product from a strategic partner of CARRAGHEEN BOUTIQUE PTE LTD and you subsequently provide your Personal Data directly to that third party, that Personal Data will be subject to that third party’s privacy policy (if they have such a policy) and not to this Privacy Policy.

(c)            CARRAGHEEN BOUTIQUE PTE LTD recommends you to read and understand the privacy statement/policy posted on those other websites in order to understand their procedures for collecting, processing, using and disclosing personal data and before submitting your Personal Data to those websites.

12. CONTACT DETAILS

For any questions about this Privacy Policy or would like to make a complaint or data access or correction request, please email to customercare@carragheen.com