Privacy policy
Your privacy is important to us. This Privacy Policy lists out how Luxury Personified LLP will use all commercially reasonable efforts to manage your personal data in accordance with the Personal Data Protection Act ("the Act"). By interacting with us, submitting information to us or signing up for any promotions or services offered by us, you agree and consent to Luxury Personified LLP, it's related organizations, corporations and affiliates, (collectively referred to herein as "Luxury Personified LLP", "us", "we" or "our"), as well as our respective representatives collecting, using, disclosing and sharing amongst ourselves your Personal Data, which includes disclosing such Personal Data to Luxury Personified LLP's authorized service providers and relevant third parties in the manner set forth in this Privacy Policy.
This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to Luxury Personified LLP nor does it affect any rights which Luxury Personified LLP may have at law in connection with the collection, use or disclosure of your Personal Data. Luxury Personified LLP may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on our websites.
This Privacy Policy also forms a part of the Website Terms and Conditions ('Website Conditions'). In the event of any conflict, inconsistency or conflict between this Privacy Policy and the Website Conditions, this Privacy Policy shall prevail. All defined terms contained in the Website Conditions shall apply to this Privacy Policy unless otherwise specifically stated.
1.Your Personal Data
1.1 In this Privacy Policy, "Personal Data" refers to any data or information about you from which you can be identified either
(a) from that data; or
(b) from that data and other information to which we have or are likely to have access.
Examples of such Personal Data which you may provide to us include (depending on the nature of your interaction with us):
(a) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;
(b) information about your use of Luxury Personified LLP website and services, including cookies, IP address, subscription account details and membership details, but only to the extent that Luxury Personified LLP may identify you from such information;
(c) your employment history, education background, and income levels;
(d) your payment related information, such as your bank account or credit card information, and your credit history; and
(e) information about your usage of and interaction with our website and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our website.
2. Collection of Personal Data
2.1 Generally, Luxury Personified LLP collects your Personal Data in the following ways:
(a) when you submit forms relating to any of our products or services;
(b) when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us, or use services on such websites;
(c) when you interact with our customer service officers;
(d) when you use some of our services, e.g. our subscription service;
(e) when you establish any online accounts with us;
(f) when you request that we contact you;
(g) when you are contacted by, and respond to, our marketing representatives and agents;
(h) when you respond to our request for additional Personal Data;
(i) when you ask to be included in an email or other mailing list;
(j) when you respond to our promotions and other initiatives;
(k) when you submit a job application or a scholarship application;
(l) when you enter into tenancy agreements with us;
(m) when we receive references from business partners and third parties, for example, where you have been referred by them;
(n) when you submit your Personal Data to us for any other reason.
2.2 When you browse our website, you generally do so anonymously but please see the section below on cookies.
2.3 If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorised representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.
2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested.
3. Purposes for the Collection, Use and Disclosure of Your Personal Data
3.1 Luxury Personified LLP generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
3.2 Generally, Luxury Personified LLP collects, uses and discloses your Personal Data for the following purposes:
(a) responding to your queries and requests and responding to complaints;
(b) managing the infrastructure and business operations of Luxury Personified LLP and complying with internal policies and procedures;
(c) facilitating business asset transactions (which may extend to any merger, acquisition or asset sale;
(d) matching any Personal Data held which relates to you for any of the purposes listed herein;
(e) verifying your identity;
(f) preventing, detecting and investigating crime, including fraud and money-laundering, and analysing and managing other commercial risks;
(g) protecting and enforcing our contractual and legal rights and obligations;
(h) conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;
(i) preventing, detecting and investigating crime and managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances;
(j) compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or
(k) any other purpose relating to any of the above.
3.3 In addition, Luxury Personified LLPmay collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
(a) If you have a membership account with us:
(i) to process your application for any online and offline Services;
(ii) to maintain your account with us;
(iii) to verify and process your personal particulars and payments in relation to provision of online and offline Services to you;
(iv) to provide you with the goods and services which you have signed up for, including the provision and delivery of merchandise ordered;
(v) communicating with you to inform you of changes and development to Luxury Personified LLPpolicies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
(vi) resolving complaints and handling requests and enquiries;
(vii) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
(viii) processing of your Personal Data in relation to any of the purposes stated above.
(b) If you use download or use any of our Apps:
(i) where the App includes any web applications and/or native applications offered by us, to process your registration for these applications;
(ii) to maintain your account with us and to ensure your access of the App is within the scope of your registration;
(iii) to verify and process your personal particulars and payments in relation to provision of products and services connected to the App;
(iv) to provide you with the products and services which you have signed up for and to push articles to you which may be relevant to you;
(v) communicating with you to inform you of changes and development to Luxury Personified LLP policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
(vi) resolving complaints and handling requests and enquiries;
(vii) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
(viii) processing of your Personal Data in relation to any of the purposes stated above.
(c) If you submit an application to us as a candidate for employment or an internship:
(i) processing your application including pre-recruitment checks;
(ii) providing or obtaining employee references or other references where relevant for background screening/vetting;
(iii) collecting information about your suitability for the position applied for;
(iv) organising training and staff development programs;
(v) assessing your performance;
(vi) administrating benefits and payroll processing;
(vii) providing you with tools to facilitate or as required for you to do your job;
(viii) communicating with you as required by Luxury Personified LLPto comply with its policies and processes, including for business continuity purposes; and
(ix) for any other purposes relating to the purposes stated above.
3.4 In addition, where permitted under the Act, Luxury Personified LLP may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as "Additional Purposes" for the handling of Personal Data):
(a) providing services, products and benefits to you, including promotions, loyalty and reward programmes;
(b) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by Luxury Personified LLP or other third parties;
(c) administering contests, competitions and conducting lucky draws, including, where necessary, in order to announce the results of these contests, competitions and lucky draws and identify and contact the winners, and in order to publicise and conduct marketing strictly related to these contests, competitions and lucky draws;
(d) sending you details of products, services, special offers and rewards, either to our customers generally, or of particular products and services which may be of interest to you; and
(e) conducting market research, understanding and determining customer location, preferences and demographics for us to review, develop and improve our products, services and also develop special offers and marketing programmes.
3.5 If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then Luxury Personified LLP may contact you from time to time using such Singapore telephone number(s) (including via voice calls, SMS, fax or other means) with information about our products and services (including discounts and special offers).
3.6 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have notified you otherwise in writing or in email.
3.7 Luxury Personified LLP will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in Singapore:
(a) Luxury Personified LLP affiliates;
(b) agents, contractors or third party service providers who provide operational services to Luxury Personified LLP, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival or other services to Luxury Personified LLP;
(c) vendors or any third party business partners who offer goods and services or sponsor contests or other promotional programs on Luxury Personified LLP`s sites, whether in conjunction with us or not;
(d) external business and charity partners in relation to corporate promotional events;
(e) the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
(f) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale;
(g) anyone to whom we transfer or may transfer our rights and duties;
(h) banks, credit card companies and their respective service providers;
(i) our professional advisors such as our auditors and lawyers;
(j) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and
(k) any other party to whom you authorise us to disclose your personal data.
4. Consent Withdrawal
4.1 The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request via email to our Data Protection Officer at the contact details provided below.
4.2 Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within twenty-one (21) business days of receiving it.
4.3 Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, Luxury Personified LLP may not be in a position to continue to provide its products or services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with Luxury Personified LLPand your being in breach of your contractual obligations or undertakings, and Luxury Personified LLP's legal rights and remedies in such event are expressly reserved. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 4.1 above.
4.4 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
5. Access and Correction of your Personal Data
5.1 If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which Luxury Personified LLP use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
5.2 Please note that a reasonable fee may be charged for an access request. If so, Luxury Personified LLP will inform you of the fee before processing your request.
5.3 Luxury Personified LLP will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within twenty-one (21) days after receiving your request, we will inform you in writing within twenty-one (21) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the country’s regulation).
5.4 Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and requests for access and correction to Luxury Personified LLP on your behalf
6. Protection of Personal Data
6.1 To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, Luxury Personified LLPhave introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
6.2 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, Luxury Personified LLP strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
7. Accuracy of Personal Data
7.1 Luxury Personified LLP generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
8. Retention of Personal Data
8.1 We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
8.2 We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
9. Transfer of Personal Data Outside of Singapore
9.1 We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
10. Data Protection Officer
10.1 You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:Data Protection OfficerDPO@luxurypersonified.in
11. Use of cookies
11.1 When you interact with us on our websites, we may collect or analyse anonymised information from which individuals cannot be identified ("Aggregate Information"), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on the website and common entry and exit points into website.
11.2 Luxury Personified LLP may use "cookies", where a small data file is sent to your browser to store and track Aggregate Information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites.
11.3 Luxury Personified LLPmay use an independent company (the "Third Party Market Research Company") to measure and analyse the Internet usage across Luxury Personified LLP web sites. Luxury Personified LLP uses the Third Party Market Research Company's services to collect the following core information on the usage of our web sites, including:
(a) The number of page views (or page impressions) that occur on Luxury Personified LLP web sites;
(b) The number of unique visitors to Luxury Personified LLP web sites;
(c) How long these unique visitors (on average) spend on Luxury Personified LLPweb sites when they do visit; and
(d) Common entry and exit points into Luxury Personified LLP web sites.
11.4 This information is aggregated by the Third Party Market Research Company and provided to Luxury Personified LLP to assist in analysing the usage of Luxury Personified LLP web sites. Such data may also accessible by media organizations and research companies, for the purpose of conducting industry comparisons with other Internet portals.
11.5 Pages on Luxury Personified LLP web sites may be coded with software which enables the Third Party Market Research Company to track visitors to our web sites.
11.6 Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enjoy the full experience that was designed for our web sites.
12. Third-Party Sites
12.1 Our website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website and you are encouraged to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.
13. Governing Law
13.1 This Privacy Policy shall be governed in all respects by the laws of Singapore.
14. Effect of Privacy Policy and Changes to Privacy Policy
14.1 This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
14.2 Luxury Personified LLP may revise this Privacy Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
