Data Protection Officer of HauteRobe Pte. Ltd.
For Matters Relating to Personal Data Protection
HauteRobe Pte Ltd, a company incorporated in Singapore with registration number 201420857K ("HauteRobe") designates
the following person as its data protection officer pursuant to the Personal Data Protection Act, Singapore.
If you wish to contact HauteRobe on any matters relating to personal data protection, please address
your communications to the following person whose contact particulars are as stated:
1. Terms and Expressions
“HauteRobe Services” services made available by HauteRobe as described and within the scope stated in HauteRobe Terms;
“HauteRobe Terms” the terms and conditions applicable to the use of HauteRobe Services as referred to and to which a link is provided in the opening paragraph above (including all updates and amendments thereto);
“HauteRobe Website” HauteRobe’s website located at www.hauterobe.com;
“Other Purpose” the meaning given to it in paragraph 2.3 below;
“person” any natural person or legal entity, as the case may be;
“Personal Data” any data about an individual who can be identified either
(i) from that data alone; or
(ii) from that data together with other information to which HauteRobe has or is likely to have access;
and may include, inter alia, such individual’s name, date of birth, gender, email address, delivery address, billing address, contact number and payment details;
“Specified Purposes” the meaning given to it in paragraph 2.1 below;
“Third Party Website” any website operated by a third party other than HauteRobe;
“User” a person who is effectively registered with HauteRobe in accordance with HauteRobe’s prescribed requirements, for the use of HauteRobe Services;
“User Account” the unique account assigned to User by HauteRobe for the use of HauteRobe Website and HauteRobe Services.
1.2.1 importing a gender shall be construed in any other gender as the context requires;
1.2.2 denoting the plural shall be construed accordingly based on the definition herein of such word in the singular; or
1.2.3 denoting the singular shall be construed as denoting the plural or vice versa as the context requires.
2. Purposes for Collection, Use and/or Disclosure of Personal Data
2.1 Specified Purposes
Generally, HauteRobe may collect, use and/or disclose User’s Personal Data for the following purposes (“Specified Purposes”):
2.1.1 administering and providing User with various HauteRobe Services;
2.1.2 generating invoices and/or processing payments from User;
2.1.3 handling and responding to User’s requests and/or complaints;
2.1.4 assisting User in evaluating and finding suitable products and services on HauteRobe Website;
2.1.5 managing, developing, personalising and/or enhancing operations, content and features in relation to HauteRobe Services and/or HauteRobe Website;
2.1.7 profiling User and performing market research and analytics;
2.1.8 maintaining and archiving electronic records and correspondence relating to User;
2.1.9 verifying User’s identity and other particulars;
2.1.10 preventing, detecting and/or investigating fraud, other criminal offences or violations of HauteRobe Terms;
2.1.11 obtaining legal advice or carrying out any legal processes or purposes, including dispute resolution;
2.1.12 complying with any local or foreign law, regulation, guideline, administrative direction, court order or request from any government authority (whether for investigative or law enforcement purposes or otherwise);
2.1.13 any purpose set out in HauteRobe Terms; and
2.1.14 any other purpose reasonably related or ancillary to those stated above.
2.2 Consent to Specified Purposes
By assessing or using any part of HauteRobe Website or HauteRobe Services, User consents to the collection, use and/or disclosure of her Personal Data for the Specified Purposes.
2.3 Consent to Other Purpose
In the event that HauteRobe proposes to collect, use and/or disclose User’s Personal Data for any purpose other than any of the Specified Purposes (“Other Purpose”):
2.3.1 HauteRobe will notify User of such Other Purpose prior to such collection, use and/or disclosure of Personal Data; and
2.3.2 User shall have 7 days to object to such Other Purpose, failing which, User shall be deemed to have consented to the collection, use and/or disclosure of her Personal Data for such Other Purpose.
2.4 Third Party Consent
Where User provides to HauteRobe any Personal Data relating to a third party, User represents and warrants that she has obtained all necessary consents relating to the collection, use and disclosure of Personal Data from such third party for the Specified Purposes or any Other Purpose as may be applicable.
2.5 Withdrawal of Consent
2.5.1 User may withdraw her consent in relation to any of the Specified Purposes or any Other Purpose by:
(i) changing her preferences in relation to such Specified Purpose or Other Purpose manually using her User Account where such editing facility is made available; or
(ii) giving not less than 10 days’ notice of such withdrawal of consent to HauteRobe Data Protection Officer.
2.5.2 Upon and depending on the extent of such withdrawal of consent, HauteRobe may not be in a position to continue providing User with some or all of HauteRobe Services and/or access to some or all parts of HauteRobe Website.
3. Collection of Personal Data
3.1 HauteRobe may collect User’s Personal Data when:
3.1.1 Personal Data is submitted (whether directly by User or otherwise) to HauteRobe in connection with the registration of User Account;
3.1.2 User performs transactions using HauteRobe Services, whether on HauteRobe Website or otherwise;
3.1.3 User consents or subscribes to HauteRobe’s marketing or promotional activities or materials;
3.1.4 User communicates with HauteRobe’s customer service officers or operations personnel, whether via HauteRobe Website, email, mobile devices or other electronic means, and whether for purposes of obtaining technical support or otherwise; or
3.1.5 User submits Personal Data to HauteRobe in any other manner or for any other reason.
3.2 In addition, upon User’s access to HauteRobe Website, whether or not for the purpose of using HauteRobe Services, the following information, including any embedded Personal Data, may be automatically collected:
3.2.1 information on User’s browser type and internet protocol (IP) address;
3.2.2 the website that User was browsing prior to visiting HauteRobe Website; and
3.2.3 the dates and times of User’s access to HauteRobe Website.
4. Disclosure of Personal Data
HauteRobe shall keep confidential any Personal Data of User within its possession or control, but may disclose such Personal Data to the following parties for or in connection with the Specified Purposes or any Other Purpose:
4.1 persons affiliated with HauteRobe, such as HauteRobe’s related companies;
4.2 third party service providers who provide various services to HauteRobe, including but not limited to data processing, information storage, telecommunications, payment, marketing and collection/delivery services; or
4.3 HauteRobe’s professional advisors, such as lawyers and auditors;
4.4 banks and other financial institutions;
4.5 liquidators, receivers, judicial managers or other persons appointed pursuant to any bankruptcy, winding-up, judicial management or other similar proceedings;
4.6 any court, competent tribunal or other judicial body;
4.7 any government agency or regulatory or administrative body; and/or
4.8 any other party to whom the disclosure of User’s Personal Data by HauteRobe has been authorised by User.
5. Retention of Personal Data
HauteRobe shall retain User’s Personal Data until the retention of such Personal Data:
5.1 no longer serves the purpose for which the Personal Data was collected; and
5.2 is no longer necessary for legal or business purposes.
6. Accuracy of Personal Data
User shall ensure that all Personal Data that she provides to HauteRobe is accurate, complete and not misleading in any way.
7. Access to and Correction of Personal Data
User may request access to her Personal Data within the possession or control of HauteRobe by submitting such request to HauteRobe Data Protection Officer.
User may correct her Personal Data within the possession or control of HauteRobe by:
7.2.1 making such corrections manually using her User Account where such editing facility is made available; or
7.2.2 submitting a request for such correction of Personal Data to HauteRobe Data Protection Officer.
7.3 Response and Fees
Upon receiving any request from User regarding access to or correction of Personal Data, HauteRobe shall:
7.3.1 endeavor to respond to such request within 30 days of receiving the same; and
7.3.2 be entitled to charge a reasonable fee for processing such request.
8. Security Measures
8.1 HauteRobe shall take all reasonable security arrangements to protect Personal Data within its possession or control from unauthorised access, collection, use, disclosure, modification or other similar risks.
8.2. However, as the electronic storage and/or transmission of information is subject to inherent risks and cannot be completely secure from unauthorised access, HauteRobe does not guarantee absolute security of such Personal Data and shall not be liable for events arising from any security breach including on account of any third party mischief or technical failure.
9.1 A “cookie” is a small text file placed by a web server on the web browser of a computer, and which can thereafter be retrieved by or through such web server.
9.2 HauteRobe uses “cookies” on HauteRobe Website in order to:
9.2.1 enable HauteRobe Website to function correctly; and/or
9.2.2 record information for administrative, statistical and maintenance purposes, such as the:
(i) date, time or duration of visits to HauteRobe Website, including in relation to specific pages on HauteRobe Website; and
(ii) information searched for by Users on HauteRobe Website.
9.3 Although User may choose if and how “cookies” used by HauteRobe will be accepted or permitted to operate, such as by configuring her preferences and options in the web browser of her computer, HauteRobe cautions that disabling such “cookies” may affect the functionality or cause delays in the operation of HauteRobe Website.
10. Third Party Websites
10.1 HauteRobe Website may contain links to Third Party Websites, which:
10.1.1 automatically receive User’s IP address when User clicks on such links; and/or
10.2 User acknowledges and accepts that HauteRobe does not have access to or control of and shall not be responsible for the “cookies” or other tracking technologies that may be placed or deployed through Third Party Websites, the practices and policies in relation to which may differ from HauteRobe’s.
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