Last updated: 1 February 2024
INTRODUCTION
We value your personal data privacy, and we are committed to protecting your personal data. This Privacy Notice explains how members of the LUXASIA group collect, process, and manage your personal data.
The LUXASIA group issues this Privacy Notice, and it applies to the handling of personal data by LUXASIA Group Pte. Ltd. and its subsidiaries and affiliates (collectively “LUXASIA”, “we”, “us”, or “our”).
Your use of our websites, microsites, mobile applications, web-based applications, web-based programs, or non-digital platforms (collectively “Platforms”) in any jurisdiction, as well as your transaction at any point of sale, are subject to this Privacy Notice and the terms and conditions issued by the relevant LUXASIA group member identified as transacting with you.
YOUR CONSENT
We will obtain your consent to collect and process your personal data for the purposes set out in this Privacy Notice at the time of collection, subject to certain legally prescribed circumstances where your consent is not required.
Where applicable, we obtain your express consent to collect your personal data when you perform any of the activities as set out in the section titled “How We Collect Your Data”. For instance, you may be asked to fill in a form, tick a box, and click a button to indicate your consent to be bound by the terms and conditions of this Privacy Notice.
In addition, when you use our Platforms, you consent to us collecting and processing your personal data in accordance with this Privacy Notice.
You must ensure all personal data submitted to us is complete, accurate, true, and up to date at the time of submission. We will not be liable for any damage, claim, and/or harm suffered by you due to your failure to provide or update us with your complete, accurate, true, and up-to-date Personal Data.
If you do not consent to this Privacy Notice, we may not be able to fulfil certain contractual obligations with you, provide certain products to you, or render certain services to you.
HOW WE COLLECT YOUR DATA
We collect personal data that you knowingly and voluntarily provide to us when you:
- sign up for an account on our Platforms.
- sign up to receive marketing and promotional materials about our Brand Partner(s) via our Platforms.
- execute any contract with us or purchase any products or services from us.
- visit our retail outlets, counters, stores, events, or pop-up stores.
- fill in forms at our retail outlets, counters, stores, events, or pop-up stores.
- receive product samples, beauty treatment, or advisory services at our retail outlets, counters, stores, events, or pop-up stores.
- participate in any event organised by our affiliated service provider or us.
- take part in our surveys, focus groups, or market research activities.
- contact us via communication channels (e.g. email, phone, SMS, social media platforms, or otherwise) for any query or to provide feedback.
- use services delivered via new technologies, such as virtual and augmented reality.
PERSONAL DATA WE COLLECT FROM YOU
Your data is any information about you that may be used to identify you. It includes the information that you provide to us, that we collect, or that we are provided with by third parties who act for you, whether directly or indirectly. It does not include anonymous data whereby the identity has been removed so that it can no longer be associated with you.
We may collect, process, use, store, and transfer different types of personal data about you to the extent permissible under the applicable laws and regulations:
Basic Personal Data
- Identity Data includes first name, last name, national identification documentation, audio, photographs, CCTV, and video recordings of you.
- Contact Data includes email address, phone number, billing address, delivery address, and social network details.
- Demographic Data includes age, gender, race, ethnicity, marital status, estimated income, and household information.
- Psychographic Data includes your interests, preferences, values, hobbies, and lifestyles.
- Profile Data includes username and password, purchase or order history, feedback, and survey responses.
- Financial Data includes banking information, payment card or digital wallet details.
- Usage Data includes information about your browser type, IP addresses, and how you use our Platforms, products, and services.
- Geolocation Data includes information that permits us to determine your location, such as if you enable your browser or mobile device to send us precise location information.
Sensitive Personal Data:
We may sometimes need to collect sensitive personal data from you. We only do so if it is necessary and with your consent, to the extent permissible under the applicable laws and regulations:
- Health and Medical Data includes information about any medical history, allergies, or skin conditions.
HOW WE USE YOUR PERSONAL DATA
We process your data based on your consent, our legitimate interests, and the necessity to fulfil our contractual obligations to you.
We may use your data together with other information we collect for one or more of the following purposes:
- perform or carry out contractual obligations arising from any contracts between you and us (i.e. purchase and delivery of products and services from us).
- enable our subcontractors, third-party agents, and service providers, to fulfil obligations as stipulated in your contract with us.
- process billing, payment, and other credit-related activities arising from your transaction with us.
- administer and update your records in our databases; monitor and maintain a copy of your record of previous transactions.
- facilitate the delivery, maintenance, and enhancement of our products, services, programmes, activities, and events.
- plan, monitor, and enhance the provision of new products, services, projects, programmes, activities, and events.
- provide a personalised recommendation of relevant products and services to you via various communication channels, including email, SMS, voice call, social messaging applications, post, and in-person communication through our beauty advisors.
- conduct direct or indirect marketing activities (including promotions and offers) on our Platforms or through other communication channels.
- perform cross-marketing activities (e.g. you may receive recommendations of products and services from our other brand partners in addition to the brand partner(s) that you signed up for).
- conduct research and data analytics for business and administrative processes.
- improve our customer service through your feedback and recommendations.
- process your inquiries and any other ancillary administrative purposes.
- assist in legal investigation and enforcement purposes.
- comply with or fulfil regulatory requirements.
- conduct security, surveillance, and monitoring activities.
- protect or defend our property, services, and legal rights.
- prevent fraud against the LUXASIA group and others.
- take emergency measures to secure the safety of our customers, our personnel, or the public.
- purposes incidental to each or all of the above.
WHO HAS ACCESS TO YOUR DATA
We may share or disclose some or all of your personal data to the following parties in connection with the purposes described in this Privacy Notice:
- any member within the LUXASIA group, including our subsidiaries, affiliates, and ultimate holding company.
- Facebook, Google, or any social media platforms that we may use from time to time (if you use your account with them to sign up/in with us), if applicable.
- brand partners or strategic partners that we cooperate with based on contractual arrangements or joint ventures.
- service providers, suppliers, subcontractors, or agents.
- professional advisers including consultants, lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
- government or other supervisory authorities.
- any person or entity to whom we are required or requested to make such disclosure by any court of competent jurisdiction or by any governmental, taxation, or other regulatory authority, law enforcement agency, or similar body.
- analytics and search engine providers that assist us in the improvement and optimization of our Platforms.
- any party who acquires us or substantially all our assets.
MINOR’S PRIVACY
If you are under 16 years of age, you may browse our Platforms. However, you may not provide personal information to us. Our Platforms are not designed for persons under the age of 16 and we do not knowingly collect personal information from anyone under the age of 16.
As a parent or legal guardian, please do not allow minors under your care to submit personal data to us. If such personal data of a minor is disclosed to us, you hereby consent to the processing of the minor’s personal data and accept and agree to be bound by this Privacy Notice and take responsibility for his or her actions.
We will not be responsible for any unauthorised use of our Platforms by you, users who act on your behalf, or any unauthorised users. It is your responsibility to make your own informed decisions about the use of our Platforms and take necessary steps to prevent any misuse of our Platforms.
LOCATION AND TRANSFER OF PERSONAL DATA
We may collect and process your personal data in countries other than your country of residence or the country from which you provided us with your personal data. These other countries may not have the same data protection laws as the country in which you reside or provide personal data. Where there is a need to transfer your personal data to other countries for the purposes described in this Privacy Notice, we will ensure the transfer is accorded with similar levels of data protection as those in your country.
RETENTION OF YOUR PERSONAL DATA
We retain your personal data for as long as it is necessary to fulfil the purposes for which it was collected as outlined in this Privacy Notice, to satisfy our business or legal requirements, to properly resolve disputes, or to troubleshoot problems. In determining the retention period, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process your personal data, whether we can achieve those purposes through other means, and the applicable legal requirements. In addition, certain information may be stored indefinitely due to technical constraints and will be blocked from further processing for purposes that are not mandatory by law.
If you choose to unsubscribe from our mailing list or should your membership to any of LUXASIA group’s membership programmes expire, we may still retain your personal data in our database to the extent permitted by law and LUXASIA group’s Data Retention Policy.
SECURITY OF YOUR PERSONAL DATA
All electronic storage and transmission of your personal data is secured and stored on managed servers with controlled access and appropriate security technologies.
We implement a variety of organisational, information security, and technical measures to protect your personal data against loss, misuse, destruction, unauthorised access, unauthorised modification, or similar risks. To maintain the confidentiality and integrity of your personal data, we will only share your data with authorised persons within the LUXASIA group on a need-to-know basis.
When we engage third parties to process personal data on our behalf, we will ensure they provide sufficient guarantees to us to have implemented the necessary organisational, information security, and technical measures and have taken reasonable steps to comply with these measures.
USE OF COOKIES
We use cookies to collect information about your online activity on our Platforms. A cookie is a small text file created by the website that is stored in your computer to provide a way for the website to recognise you and keep track of your preferences. The cookie makes it convenient for you such that you do not have to retype the same information again when you revisit the website or fill out electronic forms.
You may choose not to accept cookies by turning off this feature in your web browser. Note that by doing so, you may not be able to use some of the features and functions on our Platforms.
LINKS TO THIRD-PARTY WEBSITES FROM OUR PLATFORMS
Our Platforms may contain links to other external websites, such as our business partners, that we do not control or operate (collectively, “Third-Party Sites”). While some of the Third-Party Sites may display our logo or trademark, we are not responsible for the privacy notices and the data collection practices of all Third Party Sites. We strongly encourage you to check the privacy notice of each website that you visit. Please contact the owner of the respective websites should you have any questions about their privacy notices. Your use of these Third-Party Sites is at your own risk, and we do not accept any responsibility or liability for the data collection practices of these Third Party Sites.
YOUR RIGHTS
You have the right to obtain access, rectification, erasure, restriction, and portability of your personal data. You can also object to the processing of your personal data or withdraw your consent at any time. Please contact us via [email protected] should you wish to exercise your rights. Before we accede to your request, we may need to verify your identity by sighting your national personal identification document.
CONTACT US:
If you have queries, concerns, or complaints, or would like to exercise your rights, please contact our Data Protection Officer at [email protected]. Any query or complaint should include, at least, the following details:
- Your full name and contact details.
- Brief description of your query or complaint.
CHANGES TO THIS PRIVACY NOTICE:
We recognise that data privacy is an ongoing responsibility. We may update this Privacy Notice from time to time. If we make any material changes to our Privacy Notice, we will notify you by posting the latest notice on our websites. Please visit our websites periodically to note any changes.
