SPECTACLE HUT SEA PTE LTD SINGAPORE PERSONAL DATA PROTECTION POLICY
Spectacle Hut SEA Pte. Ltd. (“Company”, “we”, “us” or “our”) is committed to the protection of the personal data which you have entrusted to us.
We have prepared this policy (“Policy”) on how the Company collects, uses, discloses and protects your personal data. We encourage you to take the time to read it.
Please note that this Policy may be amended or updated from time to time without notice to reflect the change/s in the applicable personal data protection laws.
By interacting with us, visiting our physical stores or website, submitting information to us, purchasing any products offered by us, you agree and consent to the Company, including its related companies, as well as their respective representatives and/or agents to collect, use, disclose to our authorised service providers and relevant third parties for the purposes and in the manner set forth herein.
You are also deemed to have given your consent for the collection, use, and disclosure of your personal data when it is reasonable for you to have provided the personal data to us in the circumstances allowed under the law.
PERSONAL DATA DEFINED
In this Policy, “personal data” means data, whether true or not, about an individual who can be identified —
- from that data; or
- from that data and other information to which the organisation has or is likely to have access to and includes but is not limited to:
- Identity data such as your name, gender, and date of birth;
- Contact information such as a delivery address, telephone numbers, and email address;
- Account data such as bank account and payment information (e.g. name of cardholder, card number, billing address, expiry date) and the like;
- Network data such as your internet protocol address, cookies, web browser type, and version, operating system, the domain name of your internet provider, location and device identifier and/or any information generated from any computer system/s;
- Health-related and biometric data, and all personal information necessary for the provision of our services to you and necessary for your experience in our stores; and/or
- Any other information relating to any individual/s which you have provided to us in any form/s which you may have submitted to us, or obtained through any form of interaction with you whether through any electronic system or with you in person.
COLLECTION OF YOUR PERSONAL DATA
Generally, the Company collects your personal data when:
- You visit our website or participate in our promotions, contests, campaigns, customer surveys or any other marketing initiatives;
- You accept our cookies on your device/s;
- You place an order with us in our physical stores or through our website/s.
- You visit our physical stores and your image is captured by our closedcircuit television system;
- You interact with us on our social media platform/s and other facial recognitions tool which may be implemented by Luxottica from time to time;
- You interact with our retail staff or other representatives, through face-toface meetings, telephone calls, letters, emails or fill in our webforms;
- You subscribe to our publication/s or marketing collaterals;
- You enquire about our products or services in any form;
- Your authorised representative submits your personal data to us for any purpose authorised by you; and/or
- You voluntarily submit your personal data to us for any other reason.
USE AND DISCLOSURE OF YOUR PERSONAL DATA
The personal data which we have collected from you may be used by us and/or shared with or transferred to a third party such as our related companies and our authorised service providers for which purpose may include but is not limited to the following:
- To facilitate your use of our website including the identification of visitors;
- To process your orders which you have placed with us in our physical stores or through our website;
- To respond to your queries, complaint/s, feedback, claim/s or any update/s;
- To deliver the product/s you have purchased through our website;
- To administer our promotion/s, contest/s, campaign/s, customer survey/s events or any other initiative/s. Communications may be sent in various forms, including mail, SMS/MMS, e-mail, phone, social network, instant messaging, application/s and newsletter
- To facilitate your use of facial recognition tools, experience and to register, upon users’ request, his/her image in our servers
- To ascertain or to investigate any fraud, carry out an audit or any other investigation/s as required under the law;
- To comply with the legal requirements under any relevant law; and/or
- To fulfil any other business requirement/s.
To the fullest extent permitted under the law, the Company cannot be responsible for any consequence/s arising from your use of any third-party's link on our website, and any such liability is expressly disclaimed and excluded.
If you provide us with any personal data relating to a third-party including but not limited to information of your spouse, children, parents, employees, you represent to us that you have obtained the consent of the third-party in the provision of that personal data.
You may unsubscribe from receiving any marketing information from us at any time by using the unsubscribed method/s as described in any marketing material/s provided.
TRANSFER OF YOUR PERSONAL DATA
If you are in Singapore, we may transfer your personal data outside of Singapore for any of the purposes set out as in the above. The Company will not transfer any of your personal data outside of Singapore unless the transfer conforms with the requirements under the law.
SECURITY OF YOUR PERSONAL DATA
We will protect your personal data by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risk/s. Despite such reasonable efforts, please note that it is the nature of the Internet, that any transmission and any method of electronic storage is inherently insecure, and the Company cannot warrant the security of the information which you have provided to us. We assume no liability for disclosure of your personal data due to errors in transmission, unauthorised third-party access, or other cause/s beyond our control.
ACCESSING & CORRECTING YOUR PERSONAL DATA
You should ensure that all personal data submitted to us is true, accurate and complete. Failure on your part to do so may result in our inability to provide you with the goods and services you have requested. You may request information about how your personal data is managed and may correct and/or update any personal data submitted to us you deem as erroneous. We reserve the right to charge a reasonable administrative fee for retrieving your record/s and we will inform you of the fee before processing your request. We will respond to your request within 30 days from the date of your request.
WITHDRAWAL OF YOUR CONSENT
You may communicate the withdrawal of your consent to the collection, use or disclosure of your personal data by submitting your request in writing to email@example.com
RETENTION OF YOUR PERSONAL DATA
We will only retain your personal data for as long it is necessary for any legal or business purpose.
This Policy and your use of the Company's services and website shall be governed in all respects by the laws of Singapore and you agree to submit to the exclusive jurisdiction of the courts of Singapore in the event of any dispute.
DATA PROTECTION OFFICER
Please contact or write to our Data Protection Officer if you have any request or question at: Email: firstname.lastname@example.org We will acknowledge receipt of your query or request within 3 working days and we endeavor to respond to your query or request within 30 days from the date of submission. As a matter of policy, we do not attend or respond to an anonymous query or request.