PRIVACY POLICY STATEMENT

This Platform is operated and managed by City Chain Stores (S) Pte. Ltd. We are committed to respect and protect your privacy. This Privacy Policy Statement is made in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”) and related guidelines issued by the Singapore Personal Data Protection Commission and sets out our policies and practices with regard to the collection and disclosure of your Personal Data when you use the Platform and our Services. Please read this Privacy Policy Statement carefully. Upon receipt of your consent to our Privacy Policy Statement, your Personal Data will be collected, processed and stored in the manner set out below.

1. Collection of Personal Data

When you use the Platform and our Services, you may be requested to provide your Personal Data under various circumstances such as when you apply to our membership programme, when you purchase a Product, when you submit any comments or feedback to us or when we ask you to verify your identity when collecting Products or redemption of gifts. Please note that this Website is hosted on a cloud platform based in Taiwan, Republic of China. As such, our Website collects, stores and uses your Personal Data including but not limited to processing your Order in a jurisdiction outside of Singapore.

We collect Personal Data on a lawful, open and fair basis. Whilst we collect most of the Personal Data directly from you, we may also verify and/or obtain Personal Data about you from third party sources such as the National Registration Department, Insolvency and Public Trustee’s Office and/or your social media accounts which are made available to us or the public.

2. What Personal Data do we collect and when?

We collect your Personal Data:
a. when you use or access our Platform or Services (please see Item 7 of Section I “Cookies”);
b. when you register as a user or subscribe to any membership programme on the Platform;
c. when you respond to surveys or questionnaires we may conduct; and/or
d. when you use the services of our Business Partners.

3. For what purposes do we use your Personal Data?

We collect, process and store your Personal Data that is necessary for the following purposes:
a. provision of our Services to you;
b. carrying out your instructions or responding to your enquiries, requests and complaints;
c. to perform administrative and operational tasks such as maintaining our customers database, identification purposes and process payment;
d. to communicate with you by e-mail, telephone call, text message, letter or social media;
e. to conduct and compile statistics data, research analysis and for marketing and promotional purposes;
f. transferring or sharing your Personal Data to/with our Business Partners for the purposes of carrying out (a) to (f) above in this section;
g. to allow our Business Partners or person or body corporate with whom our Business Partners enter into arrangements with to carry out the purposes set out in (a) to (f) above in this section;
h. for security purposes;
i. any purposes related to and/or for the furtherance of (a) to (i) above; and/or
j. other purposes that are authorised by applicable law.

Without your consent, we shall not use your Personal Data for purposes other than those specified above.
The failure to furnish us with any Personal Data which is necessary for the purposes set out above will result in us not being able to fulfill the purpose effectively or completely.

4. Data Integrity

We will take all practicable steps to ensure that Personal Data collected is accurate. For this purpose, it is important for you to provide us with Personal Data which is accurate, complete and not misleading when subscribing to any of our Services. Where there are any changes to your Personal Data, please inform us as soon as possible by sending an e-mail to our Personal Data Officer at cs@solvil-et-titus.sg (Attention: Personal Data Officer).

5. Personal Data Sharing, Transfer and Disclosure

All Personal Data collected by us will be kept confidential.

In order to satisfy the purposes set out in Section 3 above or a directly related purpose, we may share, transfer or disclose your Personal Data to the following parties and those allowed under the PDPA:
a. any person, within and outside Singapore, who is acting on behalf of us as agent in respect of the purpose or a directly related purpose for which the Personal Data was provided such as our cloud hosting service provider, data processors, media agencies or service providers for marketing services, mailing services, storage services, data processing services or to carry out certain functions and activities for or with us;
b. our Affiliates;
c. any person to whom we are compelled or required to do so pursuant to any statute or law, provided that such person is able to provide valid authorisation to access or request such Personal Data;
d. our Business Partners within and outside Singapore; and
e. such other person, within and outside Singapore, to whom we are legally required to disclose.

As we are part of Stelux Holdings International Limited a company listed on the Stock Exchange of Hong Kong with its headquarters in Hong Kong, we report to our headquarters frequently and our headquarters has access to various aspects of our operations. As far as it is permitted under the PDPA, your Personal Data may also be transferred, shared and disclosed to our headquarters via the reports and it may be accessible by our headquarters through the shared system or database.

6. Access and Correction

Subject to the provisions of the PDPA, you may (i) check whether we hold any of your Personal Data/access to the Personal Data held by us (subject to payment of a prescribed fee); (ii) request to correct or update the Personal Data collected by us; and/or (iii) direct any inquiries, complaints or limit the processing of your Personal Data by sending an e-mail to our Personal Data Officer at cs@solvil-et-titus.sg (Attention: Personal Data Officer).

We will take reasonable steps to verify your identity before granting access or permitting corrections to your Personal Data or attend to your enquiries, complaints or request to limit the processing of your personal data. We will endeavour to respond to any request for access or correction, if not refused by us, as soon as practicable upon our receipt of your written request.
In the event we are not able to comply with your request to access the Personal Data, we will notify you in writing the reasons for such refusal as soon as practicable upon our receipt of your written request.

7. Withdrawal of Consent

The Personal Data collected by us is to enable us to carry out the functions and activities in relation to the purposes for which such personal data is collected. Failure to provide us with such Personal Data or by providing us limited Personal Data may prevent us from performing such functions or activities. However, you may, at any time, send an e-mail to our Personal Data Officer at cs@solvil-et-titus.sg (Attention: Personal Data Officer) to withdraw your consent for us to process either:
a. all or selected Personal Data of yours which has been collected by us;
b. marketing activities relating to watches, eyewear and other lifestyle accessories sold at our stores or by our Affiliates; or
c. unsubscribe from any of our newsletters or mailing lists.

8. Direct Marketing

We intend to use your name, contact number, e-mail address, physical address and gender for direct marketing purposes as described below:

a. Promotions relating to the Services, Products and other lifestyle accessories sold:
i. at our Stores,
ii. at the Platform; and/or
iii. other online or social media platforms,
that are managed by us or our Affiliates.
b. Marketing activities relating to the Services, Products and other lifestyle accessories sold:
i. at our Stores,
ii. at this Platform; and/or
iii. other online or social media platforms,
that are managed by us or our Affiliates.

If you do not wish to receive or continue receiving our direct marketing materials, notify us by writing to our email set out in Section 6 above. Notwithstanding your registration of your telephone number with the Do Not Call Registry under the Do Not Call Provisions of the PDPA, if you have provided your Singapore telephone number(s) and have consented to receiving our direct marketing materials through your telephone number, we will continue to do so until you withdraw your consent.
Please note that whether or not you consent or withhold your consent for receiving direct marketing materials from us, unless you expressly indicate otherwise, we will still process your Personal Data for the purposes set out in Section 3 above.

9. Security

We strive to ensure that your Personal Data will be protected, stored and processed in a secure manner against unauthorised or accidental access, processing, erasure or other use but at the same time we cannot guarantee a 100% security, for example from hacking or cybertheft as your Personal Data is transmitted over the internet or stored electronically. We maintain this commitment to data security by implementing appropriate administrative security safeguard and procedures in accordance with the applicable laws and regulations.

10. Retention of Personal Data

Your Personal Data will only be retained for as long as is necessary to fulfill the original or directly related purpose for which it was collected as set out in Item 3 of this Section XI, unless it is contrary to any applicable laws. All Personal Data which is no longer required shall be destroyed or permanently deleted.

11. Amendment to this Statement

We may amend this Privacy Policy Statement from time to time as we deem fit. Please check back frequently for any updates or changes to this Privacy Policy Statement. Your continuing use of the Platform and/or the Services will be deemed as your acceptance of the revised Privacy Policy Statement.