This Privacy Notice is provided by Sequebb Pte Ltd (a company limited by shares which is incorporated in Singapore and registered with company number 201017758H, whose registered office is at 5 Shenton Way, #10-01 UIC Building, Singapore, 068808 and which trades as ‘SEQUEBB’ and ‘www.sequebb.com’ (plus such other potential trading names as may be used from time to time, referred to in this Privacy Notice as we, us or our).
We respect your privacy and are committed to protecting your personal data.
This Privacy Notice is intended to inform you as to how we look after your personal data – however you interact with us (including via use of our website(s) and regardless of where you visit any of them from) and to tell you about your privacy rights and how the law protects you.
This Privacy Notice has sought to have been prepared in plain English (and is provided with ‘Headings’ with the aim that you can easily review the specific areas set out below).
2. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this Privacy Notice
This Privacy Notice aims to give you information on how we collect and process your personal data, including any data you may provide through the use of our website(s) (e.g. when you might purchase a product or service, or sign up to any of our newsletter(s), or take part in a competition etc.).
Our website(s) are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Notice (together with any other Privacy Notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you) so that you are fully aware of how and why we are using your data.
This Privacy Notice supplements the other notices and is not intended to override them.
We are the controller and responsible for your personal data.
We have appointed a data protection officer (‘DPO’). Our DPO is based in Singapore and may be contacted via email. When contacting, please provide as much information as possible that is specific to your enquiry (including geographical or location information where relevant).
You have the right to make a complaint at any time to the PDPC in Singapore. We would, however, appreciate the chance to deal with your concerns before you approach the PDPC, so please contact us in the first instance.
So that we’re clear and there’s no misunderstanding about how we handle your personal data, we will:
- Always keep your data safe and private
- Never sell your data
- Allow you to manage and review your marketing choices at any time
- Only collect, manage, transfer and use your data for the purposes set out in this policy
Our website(s) may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
We do not control these third-party websites and are not responsible for their privacy statements. When you leave any of our website(s), we encourage you to read the Privacy Notice of every website that you visit.
3. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you – which we have grouped together as follows:
- Identity Data including first name, last name, marital status, title, date of birth and gender
- Contact Data including billing address, delivery address, email address and telephone number
- Transaction Data including details about payments to and from you (or a linked business) and other details of products and services that you (or a linked business) have purchased from us
- Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website(s)
- Profile Data including your username and password, your interests, preferences, feedback and survey responses
- Usage Data including information about how you use our website(s), products and services
- Marketing and Communications Data including your preferences in receiving marketing from us and third parties and your communication preferences
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you – or a linked business – with goods or services).
In such circumstances, we may have to cancel a product or service you – or a linked business – has with us, but we will notify you if this is the case at the time.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email, via our website(s) or otherwise.
This includes personal data you provide when you:
- apply for our products or services;
- create an account on any of our website(s);
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback
Automated technologies or interactions
Third parties or publicly available sources
We may receive personal data about you from various third parties (and public sources) – such as those as are set out below:
- Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers or aggregators; and from publicly available sources.
5. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to.
Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
- Where we need to comply with a legal or regulatory obligation
Generally, we do not rely on consent as a legal basis for processing your personal data (other than in relation to sending third party direct marketing communications to you via email or electronic text message – where your consent – in appropriate circumstances – may be treated as implicit).
You have the right to withdraw consent to marketing at any time by methods that will be provided in the relevant communication and/or by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so.
We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may establish a privacy centre where you can view and make certain decisions about your personal data use or the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you – or a linked business. This is how we decide which products, services and offers may be relevant for you – or a linked business (we call this marketing).
You may receive marketing communications from us if you – or a linked business – have requested information from us or purchased goods or services from us (or if you provided us with your details when you entered a competition or registered for a promotion) and, in each case, you have not opted out of receiving that marketing.
We will obtain your express opt-in consent before we share your personal data with any other company (outside of our group of companies) for marketing purposes.
You can ask us (or third parties) to stop sending you marketing messages at any time:
- by accessing any privacy centre accessible from our website(s) and checking or unchecking relevant boxes to adjust your marketing preferences; or
- by following the opt-out links on any marketing message sent to you; or
- by contacting us (at any time).
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
You can set your browser to refuse all (or some) browser cookies, or to alert you when websites set or access cookies.
Some cookies are needed to run the website. For example, when you log in, cookies help to recognise you and keep you logged in as you browse the website. We call these strictly necessary cookies.
We also use the following types of cookies:
- Necessary cookies – We need to use these cookies to make our website work, for example, so you can get promotions awarded to your account.
- Analytics and advertising cookies – These allow us to recognise and count the number of visitors to our website, and see how visitors browse our website, so we can improve it where necessary. These also allow us to see what pages and links you have visited so we can provide more relevant content. We may share this information with other organisations, such as Google, Facebook and LinkedIn, for the same purpose.
These cookies are all session cookies, which means that they will stop tracking your activity on the website when you close your website browser.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.
- Internal Third Parties
- External Third Parties
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets
- Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. STORAGE SECURITY & INTERNATIONAL TRANSFERS
The data that we collect from you may be transferred to, processed, and stored at, a destination outside Singapore. Your data also may be processed outside Singapore in order for us to fulfil our contract with you to provide the Sequebb Services.
We will need to process your personal data in order for us to action a request made by you. We will take all steps to ensure that your data is treated securely and in accordance with the PDPA.
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology or a secure virtual private network.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of our app and/or our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our app or our website; any transmission is at your own risk.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
8. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach (where we are legally required to do so).
9. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for at least six (6) years after they cease being customers (for tax purposes).
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes – in which case we may use this information indefinitely without further notice to you.
10. YOUR LEGAL RIGHTS
You have rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a 'data subject access request').
This enables you to receive a copy of the personal data we hold about you. If you require this, then please contact us.
Please note that Singapore law allows us to refuse your request for access for various reasons, including where the burden or expense of providing such access would be unreasonable to us or disproportionate to your interests.
Request correction of the personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please contact us.
Please note that Singapore law allows us to refuse your request for correction for various reasons, including where your personal data is contained in a document that is related to a prosecution if all proceedings related to the prosecution have not been completed.
Request erasure of your personal data.
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data.
You have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling grounds to process your information which override your rights.
Request restriction of processing of your personal data.
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it; or
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you (including Sequebb Services). In this case, we may have to cancel your use of Sequebb Services but we will notify you if this is the case at the time.
Request the transfer of your personal data to you or to a third party.
We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party.
Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you require this then please contact us.
Withdraw consent at any time where we are relying on consent to process your personal data.
However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide the Sequebb Services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than one month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you fail to provide personal data.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (including the Sequebb Services). In this case, we may have to cancel your use of the Sequebb Services but we will notify you if this is the case at the time.