- “Applicable Laws” refers to Singapore’s Personal Data Protection Act 2012 (PDPA) and its associated regulations and subsidiary legislation, and guidelines issued by the Singapore Personal Data Protection Commission (“PDPC”) as amended from time to time;
- “Apps” refers to our HOMLÈDJ mobile app on iOS and Android and any other app we may own or operate from time to time;
- “Personal Data” refers to any data, whether true or not, which is (1) about an individual who can be identified (1.1) from that data; or (1.2) from that data and other information to which we have or are likely to have access and would include data in our records as may be updated from time to time, or (2) defined as “personal data” or “personal information” under any applicable Data Protection Laws.
- “Platforms” refers to all HOMLÈDJ’s Apps, Social Media and Website, and any other websites or applications which we may own or operate from time to time;
- “Social Media” refers to HOMLÈDJ’s pages and accounts on third party social media platforms including LinkedIn, Pinterest, Facebook, Instagram, Twitter, and Google+’
- “Website” refers to the HOMLÈDJ website accessed at the following address www.homledj.com; and
- “HOMLÈDJ, we, us, or our” refers to HOMLÈDJ Pte. Ltd.
We may collect Personal Data from you during our relationship with you. The types of Personal Data we may collect encompasses your name, contact details, mailing and delivery addresses, email address(es), date of birth, network and device data (including your IP address and device or advertising identifiers), nationality, marketing preferences, answers you provide to security questions (e.g. first school’s name, grandmother’s name), aggregated site statistics data, your shopping or browsing behaviours and any other personally identifiable information which you have provided us in any forms you may have submitted to us, or in the course of any other forms of interaction through our Website.
When submitting any Personal Data relating to a third party to us, you agree that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
WHEN IS MY PERSONAL DATA COLLECTED?
We collect Personal Data from you when:
- You visit our Website with a cookies-enabled browser and/or accept our cookies on your device;
- You register an account on the Website or the Apps;
- You utilise any of our related services, including subscribing to our mailing list, newsletter or product notifications;
- You browse our products and services or in any way interact with our Website and Apps;
- You make purchases of our products or services through our Website and Apps
- You reach out to our customer relations team or other sales representatives, including but not limited to, letters, emails, online forms, telephone calls, or face-to-face meetings;
- You communicate with us on our Social Media, including but not limited to, liking of our posts, commenting on our posts, private messaging us on our Social Media;
- You fill in any forms on our website;
- You participate in our campaigns, promotions, lucky draws, lucky wheel spins equivalence or any request for additional Personal Data such as customer reviews;
- Your authorised representative submits your Personal Data to us for any purpose rationally authorised by you, such as the purchase of our product or service on your behalf to be delivered to you or as a gift;
- We are presented with your Personal Data by our third-party analytics and other service providers where the collection and processing by them and disclosure to us are pursuant to their independent privacy policies; or
- When you, at your discretion, submit your Personal Data to us for any reason.
We may also collect your Personal Data in situations where such collection does not require consent under Applicable Laws.
Please establish that all Personal Data submitted to us is correct, complete, accurate, and true. Incorrect, incomplete, inaccurate or untrue Personal Data may result in our inability to provide you with the products and services you have requested.
HOW IS MY DATA USED?
In order to provide you with our products as services, we may use and disclose your Personal Data for crucial purposes, including to:
- register and maintain your access to your user account and to verify your identity;
- process your order for our products or services,
- process or collect your payment for the order;
- evaluate website preferences to personalise and improve your customer experience when you visit the Website and the Apps
- deliver or perform the products or services you purchased, including our couriers calling or messaging you to obtain your delivery instructions;
- process your returns or refunds by means of our Terms and Conditions;
- provide you with support and services pertinent to your user account, such as saved items in cart, or product notifications;
- correspond with you in relation to (i) your enquiry, requests and feedback, and (ii) matters relating to the operation of your account;
- observe and carry out conformity to our Terms and Conditions, including dispute resolution;
- adhere to (1) internal risk controls, (2) the terms of our access to payment processing, financial or banking services, including but not limited to, credit card fraud, disputes, billing glitch, or (3) any applicable law;
- facilitate online purchases of goods and services, and our related entities including subsidiaries, third-party service providers (such as subcontractors, couriers, agents or network operators) who are employed to perform business and administrative functions, third party businesses with whom we collaborate, Government bodies where applicable, such as Overseas Purchase that requires shipping of products out of Singapore to recipient’s place of residence or delivery address, your personal data may be transferred out of Singapore from time to time and such transfers will be carried out in accordance with the PDPA. Third parties, with the exception of Government bodies and other public agencies, are subject to data protection obligations and may only use your personal data to perform the vital operations; and
(collectively, the “Purposes“)
Furthermore, we may use and disclose your Personal Data for the following purposes, to:
- send you marketing information and transmissions in relation to our sales, products, services, campaigns, promotions or the Platforms;
- send you marketing information and transmissions in relation to the sales, products, services, campaigns or promotions of business partners, including promotional mail together with your order;
- deliver advertisements which are related to our products and services which may be of interest to you on the Platforms or other websites, apps or online platforms;
- invite you to our private customer events;
- process your joining of our campaigns, promotions, lucky draws, lucky wheel spins equivalence or any request for additional Personal Data such as customer reviews;
- assist market and customer research, analysis or tracking;
- advertise our products and services on our Platforms;
- maintain the business administration and operations of HOMLÈDJ and adhering to internal policies and procedures;
- enhance your customer experience across all correspondences and training our customer relations team; and
- any specific purpose pertinent to a particular product or service, which we may separately inform you on the product or service page;
(collectively, the “Additional Purposes”)
We may also use your Personal Data (1) for other purposes which are rationally related to the Purposes and where we have obtained and maintained related consent, the Additional Purposes; or (2) in circumstances where such use does not require consent under Applicable Laws.
Note: We may no longer be able to support or provide you with the related products, services or benefits associated with our campaigns, promotion, lucky draws and lucky wheel spins equivalence, in the event you withdraw your consent for us to use and process your Personal Data for the Purposes or the Additional Purposes.
WHO WILL MY PERSONAL DATA BE SHARED WITH?
Pertinent to our use of your Personal Data for the Purposes or Additional Purposes, we may disclose your Personal Data to our:
- employees, professional advisers, consultants, temporary workers;
- payment processors, including Stripe and ATOME, who process your payment on the Website and the Apps;
- logistics providers, including but not limited to, courier services which will deliver your order to you;
- business partners or vendors concerning the processing of any campaigns, promotions, events or services coordinated by us;
- agents, contractors or service providers who provide operational services to us, such as marketing optimisation, telecommunications, online cloud storage and processing, information technology, security or other relevant services which requires their collection, use or disclosure of your Personal Data; and
- any other party whom you authorise us to disclose your Personal Data to.
We may also disclose your Personal Data (1) for other purposes which are rationally related to the Purposes and where we have obtained and maintain related consent, the Additional Purposes; or (2) in circumstances where such disclosure does not require consent under the Applicable Laws.
We do our best to minimise the disclosure of your Personal Data that is vital to execute the related Purpose or Additional Purpose.
HOW CAN I ACCESS OR UPDATE MY PERSONAL DATA?
You may access or update your name, payment methods, shipping and billing addresses by logging in to your user account on the Website or Apps under “My Account”.
If you encounter a Personal Data that cannot be updated by you by logging in to your user account on the Website or Apps, you may request for us to access and update such Personal Data by submitting a written request to our Data Protection Officer via email to [email protected]. We may need to request additional information from you to confirm your identity before updating on your behalf.
We will do our best to respond to Personal Data access and update requests within 30 days. In the case that we are unable to meet this timeline, we will update you with the soonest possible time within we can provide the information or update the Personal Data. Please note that various types of Personal Data access and update requests may be exempt under Applicable Laws.
Also note that we may charge you a reasonable fee for the administration and processing of your Personal Data access request.
We will share your updated Personal Data to every other person or entity to which such Personal Data was disclosed by HOMLÈDJ within the year before the date of the correction, unless such person or entity does not need the corrected Personal Data for any legal or business purpose.
Subject to acquiring your consent, we may share the corrected Personal Data only to specific organisations to which the Personal Data was disclosed by us within a year before the date the update was made.
HOW CAN I REQUEST TO WITHDRAW CONSENT?
In the event you wish to withdraw your consent for us to send you sales, marketing or promotional information, from:
- SMS- please unsubscribe by following the steps provided in the promotional SMS;
- emails- please click on the Unsubscribe link in the promotional emails;
- materials within your order package- please email our Data Protection Officer at [email protected]
Once we are notified of your request to withdraw your consent for receiving marketing or promotional materials or communications, it may take up to thirty (30) days for your withdrawal to be reflected in our systems during which, you may still receive marketing or promotional materials or communications.
Supposing you withdraw your consent to receive marketing or promotional materials through a specific communication mode (e.g. email), we may still contact you for other purposes with regards to the products and services via other communication modes you have subscribed to (e.g. SMS).
You may withdraw your consent for the collection, use and/or disclosure of any of your Personal Data in our system or under our control through a written request vey way of email to our Data Protection Officer at [email protected]. Contingent upon the nature of the consent withdrawal, we may no longer be able to support or provide you with some or all of our products or services. We will process your request in a reasonable timeframe from receiving notice from you of your withdrawal of consent. Once the processing of the request is complete, we will no longer collect, use and/or disclose your Personal Data, except to the extent we retain your Personal Data for compliance, regulatory or other legal purposes.
ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
Reasonable efforts will be made to ensure Personal Data plausibly to be used by us or disclosed by us to another organisation is accurate and complete. However, you should update us of any revision to your Personal Data. We will not be responsible for relying on incorrect, inaccurate, untrue or incomplete Personal Data if you have not updated us of changes.
We will also safeguard your Personal Data with reasonable security precautions and process it securely. However, no method of transmission over the internet, or electronic storage, is absolutely and comprehensively secure and, we cannot be held liable for any loss you may suffer for unauthorised access or loss of any Personal Data provided to our website. Furthermore, we will not be responsible for any unauthorised use of Personal Data by third parties which is due to factors beyond our control. Nonetheless, we endeavour to protect the security of your information, and are constantly evaluating and enhancing our information security measures. We may, but are not obliged to, post a notice on our website if a security breach occurs, or send an email to you at the email address you have provided to us in these situations.
Your personal data will be retained for as long as it is necessary to effectuate the purpose for which it is collected or for business or legal purposes, or in accordance with applicable laws. Your personal data may also continue to be retained on our databases to the extent permitted by law. However, when Personal Data in our possession is (i) no longer required for any reason connected to the purpose it was originally collected or (ii) withholding by us is no longer vital for any other legal or business purposes, we will exercise measures to establish that such Personal Data is either destroyed or anonymised.
We do not sell or trade your personal data to external parties. If Personal Data is transferred out of Singapore, in situations such as Overseas Purchase that requires shipping of products out of Singapore to recipient’s place of residence or delivery address, we will comply with Applicable Laws in doing so. In the event of Overseas Purchase, we may share your Personal Data with our related entities including subsidiaries, third-party service providers (such as subcontractors, agents or network operators, courier services) who are employed to perform business and administrative functions, third party businesses with whom we collaborate and Government bodies where applicable. Third parties, with the exception of Government bodies and other public agencies, are subject to data protection obligations and may only use your personal data to perform the vital operations. In addition, we may also disclose or transfer personal data as otherwise permitted or required by law, including for compliance with regulations on anti-money laundering and countering the financing of terrorism.
THIRD PARTY COOKIES AND LINKS TO THIRD PARTY WEBSITES
The collection, use, and disclosure of information, including Personal Data, collected by such third party cookies and/or websites and micro-sites are subject to the privacy and data protections policies of the third party vendors and are not under our control.
You may reject third party cookies through the settings on your browser. Note that this may result in the loss of Website functionality, restrict your use of the Website, or delay or affect the way in which the Website operates.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
All other questions on our use of your personal data should be addressed to our Data Protection Officer, whom you may contact at:
- Email address: [email protected]
Emails should clearly express that you are making a data protection enquiry, request or complaint in the subject line to ensure the matter is dealt with as soon as possible. We endeavour to deal with any enquiry, request or complaint expeditiously and reasonably.
Effective Date: 21 February 2020