HUBERROSS Private Policy

We HUBERROSS.com  (“Company”, “us”, “we”, “our” or “ours”), understand the importance of personal data (“Personal Data” refers to any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual) and sensitive personal data which includes but is not limited to, information pertaining to the physical or mental health or condition of an individual and religious beliefs, or any other sensitive personal data (“Sensitive Personal Data”) as defined under the applicable regulations, guidelines, orders made under the Personal Data Protection Act 2012 and any statutory amendments or re-enactments made of the Personal Data Protection Act 2012 from time to time (collectively referred to as the “PDPA”). We endeavor to protect Personal Data through our compliance with the PDPA, and this privacy policy for processing of personal data (“Privacy Policy”), and by appropriately processing the Personal Data of our customers, applicants for potential employment or recruitment activities by the Company, vendors and suppliers, and users of our website or application software.

• We will collect Personal Data and Sensitive Personal Data during your course of dealings with us in any way or manner including pursuant to any transactions, any event and/or communications made from/with us in an appropriate manner not limiting to using for performance of contract, entering into contract, legal obligation, vital interests, and administration of justice;
• We will inform you regarding the purpose of use for your Personal Data and Sensitive Personal Data, and use such information within the scope of such lawful, direct purpose and/or for secondary purposes;
• We will take necessary and appropriate measures to safely manage Personal Data and Sensitive Personal Data;
• We will collect/use/disclose personal data without the consent of individual in case of: necessary for purpose, life threatening situation, publicly available data, national interest, investigations, evaluation purpose, artistic purpose, news activity, provision of legal services, collected by credit bureau, employment purpose, disclosed by public agency, etc;
• Except where otherwise specified, we will not share, disclose or sell Personal Data or Sensitive Personal Data to any third parties without the consent of the individual;
• We will respond appropriately in the event that an individual contact the appropriate point of contact regarding display, correction, deletion, withdrawal (in full or in part) and/or termination of use of their respective Personal Data or Sensitive Personal Data;
• We will maintain records of application, notice, requests, etc. related to Personal Data being processed by the Company;
• The collection of your Personal Data by us may be mandatory or voluntary in nature depending on the Purposes for which your Personal Data is collected. Where it is obligatory for you to provide us with your Personal Data and you fail or choose not to provide us with such data, or do not consent to the purposes of collection or this Privacy Policy, we will not be able to provide products and/or services or otherwise deal with you.

Purpose of use for Personal Data and Sensitive Personal Data
We use Personal Data provided to us by individuals for only the following purposes (“Purposes”):

(1) Personal Data and Sensitive Personal Data of our customers (including users of our application software)

• to communicate with you;
• to maintain and improve customer relationship;
• to assess, process and provide products, services and/or facilities to you;
• to administer and process any payments related to products, services and/or facilities requested by you;
• to provide you with information and/or updates on our products, services, upcoming promotions offered by us and/or events organized by us and selected third parties which may be of interest to you from time to time;
• for direct marketing purposes via SMS, phone call, email, mail, social media and/or any other appropriate communication channels to members of our loyalty program in accordance with their consent;
• to facilitate your participation in, and our administration of, any events including contests, promotions or campaigns;
• to award points in a loyalty or rewards program;
• to maintain and update internal record keeping;
• for internal administrative purposes;
• to send you seasonal greetings messages from time to time;
• to send you invitation to join our events and promotions and product launch events;
• to monitor, review and improve our events and promotions, products and/or services;
• to process and analyse your Personal Data either individually or collectively with other individuals;
• to conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, planning and statistical and trend analysis in relation to our products and/or services;
• to share any of your Personal Data with our business partners to jointly develop products and/or services or launch marketing campaigns;
• to share any of your Personal Data with insurance companies necessary for the purposes of insurance claims;
• for audit, risk management and security purposes;
• for detecting, investigating and preventing fraudulent, prohibited or illegal activities;
• for enabling us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;
• to transfer or assign our rights, interests and obligations under any agreements entered with us;
• to respond to your enquiries or complaints and resolve any issues and disputes which may arise in connection with any dealings with us;
• 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 us;
• to enforce or defend our rights and your rights under, and comply with, our obligations under the applicable laws, legislation and regulations; other purposes required to operate, maintain and better manage our business and your relationship with us, which we notify you of at the time of obtaining your consent.

(2) We will not provide Personal Data to any third parties within or outside Singapore, except in the following cases:

• If you have agreed to the provision of your Personal Data;
• If it is necessary for the preservation of life, body or property, and the relevant consent(s) cannot be easily obtained;
• If the handling of Personal Data has been entrusted in whole or in part to a third party within the scope necessary to fulfill the purposes of use (we take measures to prevent leakage, loss, or falsification of Personal Data, such as by carefully selecting our contractors, entering into agreements with contractors regarding the handling of Personal Data, and directing and supervising our contractors as necessary);
• If your Personal Data is processed on the behalf of the Company by third party intermediaries providing adequate level of data protection;
• If Personal Data is provided in connection with the succession of business due to merger or other reason; and
• Where required by applicable laws or regulations.

In these situations, we will bear responsibility for the processing of any shared use of Personal Data by way of our Data Protection Officer.

Your rights under the Personal Data Protection Act:

As an individual, you have the following rights under the PDPA:

1. You have the right to be informed whether Personal Data pertaining to you shall be, are being or have been processed.

2. You have the right to be furnished the following information before the entry of your Personal Data into our processing system, or at the next practical opportunity:

(1)           Description of the Personal Data to be entered into the system or our work processes;
(2)           Purposes for which they are being or are to be processed;
(3)           Scope and method of the Personal Data processing;
(4)           The recipients or classes of recipients to whom they are or may be disclosed;
(5)           Methods utilized for automated access, if the same is allowed by you, and the extent to which such access is authorized;
(6)           The period for which the Personal Data will be stored; and
(7)           The existence of your rights, i.e., to access, to correct, to request for a copy of, to request to update, and to withdraw (in full or in part) consent to process your Personal Data held by us, as well as the right to lodge a complaint before the Personal Data Protection Commission.

Any Personal Data supplied or declaration made to you on these matters shall not be amended without prior notification to you.