DATA PROTECTION
 
This Data Protection Policy “Policy” describes how the CHARLES & KEITH (“C&K”) collects, uses and discloses personal information of customers through our websites and online services, through our membership and other programs and in our physical stores (collectively, the “Services”). By accessing our websites or utilising the Services, you hereby consent to the use of your information, including your personal data, in the manner described in this Policy and represent and warrant that you understand the contents of this Policy.
 
C&K may revise and/or amend and/or supplement this Policy at its discretion from time to time. Such changes will be published on our website. You are advised to check periodically to ensure that you are aware of any changes. To the fullest extent permissible under relevant laws, you agree to be bound by the prevailing terms of this Policy.
 
This Policy is to be read in conjunction with our Privacy Policy.
 
 
1.
GENERAL
 
 
1.1.
This Policy provides information on the obligations and policies of C&K in respect of an individual customer’s information and personal data in compliance with the Personal Data Protection Act 2012 of Singapore (the “Act”).
 
1.2.
For the purposes of this Policy, “personal data” shall have the same meaning as set out in the Act, being data, whether true or not, about an individual customer who can be identified from that data; or from that data and other information to which an organisation has or is likely to have access. Such personal data includes those which are already in possession by C&K or that which shall be collected by C&K in the future.
 
 
2.
DATA PROTECTION OFFICER
 
 
2.1.
C&K has appointed a data protection officer (“DPO”) as required by the Act. The DPO has been appointed to oversee C&K’s compliance with the Act. Other employees within C&K may be delegated to act on behalf of the DPO or to take responsibility for the day-to-day collection, processing and use of personal data.
 
2.2.
The DPO may be contacted at:
 
Data Protection Officer
CHARLES & KEITH
6 Tai Seng Link, Charles & Keith Group Headquarters, Level 8
Singapore 534101
 
Email: dataprotection@charleskeith.com
 
 
3.
COLLECTION OF PERSONAL DATA
 
 
3.1.
a.
you providing it to us upon completing a service application form, when you make a purchase or apply for our Services, or when you enquire with us about our Services, or which is otherwise volunteered to us in any way;
 
 
b.
automatically, when you visit our website, using technologies such as cookies;
 
 
c.
during recording of calls made when you contact our customer service hotline, which may be recorded for training, quality control, business and/or other lawful purposes;
 
 
d.
through close circuit television recordings when you visit our physical stores or premises;
 
 
e.
we obtain it from other entities within C&K and/or;
 
 
f.
we collect it by other lawful means.
 
 
3.2.
Subject to Clause 3.1, unless permitted by relevant laws, C&K shall not collect personal data without your consent.
 
3.3.
You warrant and represent to C&K that personal data which you disclose, provide or volunteer to C&K, or to any entity that subsequently provides it to C&K, is accurate and complete.
 
3.4.
If you disclose, provide or volunteer the personal data of another person to C&K, you warrant and represent to C&K that you have been authorised by such other person to disclose such personal data to us, and that such personal data is accurate and complete.
 
 
4.
PURPOSES FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
 
 
4.1.
a.
to verify your identity and to process orders and applications for the Services;
 
 
b.
to provide the Services to you;
 
 
c.
to create, provide, maintain and operate your membership account with us;
 
 
d.
to respond and deal with enquires or complaints and for other after-sales activities;
 
 
e.
to generate bills, facilitate the payment of bills, manage accounts and debt-recovery functions;
 
 
f.
to carry out credit checks and for evaluation of creditworthiness;
 
 
g.
to manage, develop and improve our business and operations to serve you better;
 
 
h.
to carry out contests and lucky draws;
 
 
i.
to carry out market research and customer surveys and performing of analytics;
 
 
j.
to inform you of our latest marketing updates and promotions;
 
 
k.
to conduct investigations or take actions in relation to bad debts, crime and fraud prevention, detection or prosecution, risk management, or to prevent you or C&K from harm, illegal or unlawful activities;
 
 
l.
to conduct investigations or take action in relation to any violation of our terms and conditions for Services;
 
 
m.
to establish, exercise or defend C&K’s legal rights;
 
 
n.
in connection with any legal proceedings or prospective legal proceedings;
 
 
o.
in applications for employment with us;
 
 
p.
to third parties who perform Services on our behalf, but only to the extent necessary for the Services to be performed;
 
 
q.
to protect and maintain the personal data, and to have access to it including for the updating of personal data;
 
 
r.
to comply with legal and regulatory requirements and all relevant laws; and
 
 
s.
any other purpose reasonably related to the above specified purposes.
 
 
4.2.
Your personal data will be disclosed for the purposes indicated above to our officers and employees, third parties, service providers, advisors, at all times in compliance with the Act. Such parties which your personal data may be disclosed may include but are not limited to:
 
 
a.
external service providers, contractors and third parties providing the Services or performing any of the Services (or any part of the Services) on C&K’s behalf;
 
 
b.
banks, credit card companies and payment vendors for the processing of payment;
 
 
c.
courier service companies;
 
 
d.
public agencies, including without limitation government and law enforcement agencies;
 
 
e.
professional advisors such as auditors and lawyers; and
 
 
f.
any data intermediaries.
 
 
4.3.
To the extent that any of the communication means which you have provided to C&K (which may include your contact numbers) is/will be listed on the Do Not Call Registry, by agreeing to this Policy through the signing of our membership forms (either physical copies or online), or by any other means of indication, you hereby grant C&K your clear and unambiguous consent to contact you using any of the communication means you have provided to C&K for the above-mentioned purposes. If you wish to opt-out of being contact for marketing purposes, please take the steps set out in Clause 8.4.
 
 
5.
DEEMED CONSENT
 
 
5.1.
You are deemed to have given your consent for the collection, use and disclosure of your personal data in the following circumstances:
 
 
a.
when the personal data is voluntarily provided by you to C&K;
 
 
b.
when you are aware or should reasonably be aware of the purposes for which you have provided your personal data to us;
 
 
c.
it is reasonable for you to have provided the personal data to C&K in the circumstances; and
 
 
d.
in any other circumstances where consent is deemed under the Act.
 
 
6.
LIMITING COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
 
 
6.1.
C&K collects personal data primarily from persons who are our customers (including prospective customers). The collection of personal data is limited to that which is necessary for the identified purposes above.
 
6.2.
Unless permitted by relevant laws, C&K will not disclose personal data to other persons or entities for the advertising, promotion or marketing of any third party’s products and services, and C&K will not sell for payment your personal data to anyone for any marketing purpose, unless your consent has first been given.
 
6.3.
If your personal data is provided to our third party service providers or data intermediaries, they are only to use your personal data for the purpose(s) for which we have supplied the personal data to them. We will also take reasonable steps to ensure that such organisations to whom we have disclosed your personal data are legally bound to comply with the provisions of the Act.
 
 
7.
RETENTION OF PERSONAL DATA
 
 
7.1.
C&K will collect and retain personal data at our discretion, for as long as you remain our customer or access our Services and for as long as it is necessarily required or relevant for business or legal purposes.
 
 
8.
WITHDRAWAL OF CONSENT
 
 
8.1.
You are able to withdraw your consent to our continued use and disclosure of your personal data at any time. Such withdrawal must be made formally in writing to the DPO.
 
8.2.
If such consent is withdrawn, you acknowledge that C&K may no longer be able to provide the Services to you. Accordingly, C&K may, insofar as such consent is integral to the provision of the Services, cease to provide the Services to you. Notwithstanding any withdrawal of consent, (a) unless otherwise agreed by C&K, you will still be bound by any contract(s) for Services with C&K, and should you choose to terminate the relevant contract(s), early termination charges and other charges, penalties or contractual consequences may apply in accordance with the contract(s) or under relevant laws and C&K reserves all rights thereof, and (b) C&K has the right to terminate the contract(s) in its discretion, without liability to you.
 
8.3.
For further clarification on the implications of withdrawing consent, you may write in to the DPO.
 
8.4.
You may write in to our Customer Service at customers@charleskeith.com to indicate the withdrawal of your consent to receiving marketing communications from C&K. You may separately withdraw such consent via the unsubscribe options as stated on the SMS or email marketing message.
 
8.5.
You may also set your browser to warn you when a cookie is being sent or to remove or reject cookies. If you choose to remove or reject cookies, it will affect some features of our Services on our website.
 
 
9.
PROTECTION OF PERSONAL DATA
 
9.1.
To the extent required by the Act, C&K shall protect personal data in its possession or under its control against risks of unauthorised access, collection, use, disclosure, copying, modification, disposal or destruction, through reasonable and appropriate security measures. However, C&K cannot ensure or warrant the security of any information you transmit to C&K and you do so entirely at your own risk.
 
 
10.
ACCURACY AND CORRECTION OF PERSONAL DATA
 
 
10.1.
To the extent required by the Act, C&K will use reasonable efforts to ensure that the personal data is sufficiently accurate and complete to minimise the possibility that incorrect personal data may be used to make a decision that impacts you, or if such personal data is likely to be disclosed to a third party. However, you acknowledge that there may be circumstances where C&K is entitled to assume such accuracy and completeness.
 
10.2.
It is your sole responsibility to inform us when there are any changes to your personal data which has been provided to us, so as to ensure that we have the most current, accurate and complete information.
 
10.3.
If you would like to update us with your updated personal data, please write in to the DPO. Please provide your full name, NRIC number, contact details and any other details required by the DPO. We may take up to thirty (30) working days to process your request.
 
 
11.
ACCESS TO PERSONAL DATA
 
 
11.1.
To the extent required by the Act, upon request, if you would like a copy of your personal data held by C&K or how it has been used, please write in to the DPO. Please provide your full name, NRIC number, contact details and any other details required by the DPO. Pursuant to the Act, C&K is entitled to charge you a reasonable fee for this service and we will process your request upon receipt of such payment. We will need up to thirty (30) working days to process your request.
 
11.2.
We may provide a standard list of possible purposes, third parties or data intermediaries who may have accessed or used your personal data as part of its response to you, and the same shall suffice as performance of C&K’s obligations in respect thereof.
 
11.3.
Subject to the Act, C&K may not be able to provide access to all of your personal data that we hold. For example, C&K may not provide access to your personal data if such provision would reveal the personal data of another person, if such information is subject to legal privilege or if such provision will be contrary to national interest. If access to personal data cannot be provided, where possible, the reasons for denying access will be provided upon your request.
 
 
12.
MISCELLANEOUS
 
 
12.1.
Your personal data may be processed by C&K or its data intermediaries or third parties, providing services to C&K in jurisdictions outside of Singapore. In such an event, C&K will take reasonable steps to ensure that such organisations will be legally bound to comply with the terms of the Act.
 
12.2.
This Policy only applies to the collection, disclosure and use of personal data by C&K. It does not cover third party sites not operated by us, even if such sites are co-branded or licensed to use our logo. C&K does not share your personal data with such third party sites. C&K is not responsible for the privacy and conduct practices of these third party sites and shall not be held responsible or liable in anyway way for the actions of these third party sites.
 
12.3.
For more information on the Act, or to contact the Personal Data Protection Commission, please visit www.pdpc.gov.sg.
 
 
 
DATA PROTECTION
 
This Data Protection Policy “Policy” describes how the CHARLES & KEITH (“C&K”) collects, uses and discloses personal information of customers through our websites and online services, through our membership and other programs and in our physical stores (collectively, the “Services”). By accessing our websites or utilising the Services, you hereby consent to the use of your information, including your personal data, in the manner described in this Policy and represent and warrant that you understand the contents of this Policy.
 
C&K may revise and/or amend and/or supplement this Policy at its discretion from time to time. Such changes will be published on our website. You are advised to check periodically to ensure that you are aware of any changes. To the fullest extent permissible under relevant laws, you agree to be bound by the prevailing terms of this Policy.
 
This Policy is to be read in conjunction with our Privacy Policy.
 
 
1.
GENERAL
 
 
1.1.
This Policy provides information on the obligations and policies of C&K in respect of an individual customer’s information and personal data in compliance with the Personal Data Protection Act 2012 of Singapore (the “Act”).
 
1.2.
For the purposes of this Policy, “personal data” shall have the same meaning as set out in the Act, being data, whether true or not, about an individual customer who can be identified from that data; or from that data and other information to which an organisation has or is likely to have access. Such personal data includes those which are already in possession by C&K or that which shall be collected by C&K in the future.
 
 
2.
DATA PROTECTION OFFICER
 
 
2.1.
C&K has appointed a data protection officer (“DPO”) as required by the Act. The DPO has been appointed to oversee C&K’s compliance with the Act. Other employees within C&K may be delegated to act on behalf of the DPO or to take responsibility for the day-to-day collection, processing and use of personal data.
 
2.2.
The DPO may be contacted at:
 
Data Protection Officer
CHARLES & KEITH
6 Tai Seng Link, Charles & Keith Group Headquarters, Level 8
Singapore 534101
 
Email: dataprotection@charleskeith.com
 
 
3.
COLLECTION OF PERSONAL DATA
 
 
3.1.
a.
you providing it to us upon completing a service application form, when you make a purchase or apply for our Services, or when you enquire with us about our Services, or which is otherwise volunteered to us in any way;
 
 
b.
automatically, when you visit our website, using technologies such as cookies;
 
 
c.
during recording of calls made when you contact our customer service hotline, which may be recorded for training, quality control, business and/or other lawful purposes;
 
 
d.
through close circuit television recordings when you visit our physical stores or premises;
 
 
e.
we obtain it from other entities within C&K and/or;
 
 
f.
we collect it by other lawful means.
 
 
3.2.
Subject to Clause 3.1, unless permitted by relevant laws, C&K shall not collect personal data without your consent.
 
3.3.
You warrant and represent to C&K that personal data which you disclose, provide or volunteer to C&K, or to any entity that subsequently provides it to C&K, is accurate and complete.
 
3.4.
If you disclose, provide or volunteer the personal data of another person to C&K, you warrant and represent to C&K that you have been authorised by such other person to disclose such personal data to us, and that such personal data is accurate and complete.
 
 
4.
PURPOSES FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
 
 
4.1.
a.
to verify your identity and to process orders and applications for the Services;
 
 
b.
to provide the Services to you;
 
 
c.
to create, provide, maintain and operate your membership account with us;
 
 
d.
to respond and deal with enquires or complaints and for other after-sales activities;
 
 
e.
to generate bills, facilitate the payment of bills, manage accounts and debt-recovery functions;
 
 
f.
to carry out credit checks and for evaluation of creditworthiness;
 
 
g.
to manage, develop and improve our business and operations to serve you better;
 
 
h.
to carry out contests and lucky draws;
 
 
i.
to carry out market research and customer surveys and performing of analytics;
 
 
j.
to inform you of our latest marketing updates and promotions;
 
 
k.
to conduct investigations or take actions in relation to bad debts, crime and fraud prevention, detection or prosecution, risk management, or to prevent you or C&K from harm, illegal or unlawful activities;
 
 
l.
to conduct investigations or take action in relation to any violation of our terms and conditions for Services;
 
 
m.
to establish, exercise or defend C&K’s legal rights;
 
 
n.
in connection with any legal proceedings or prospective legal proceedings;
 
 
o.
in applications for employment with us;
 
 
p.
to third parties who perform Services on our behalf, but only to the extent necessary for the Services to be performed;
 
 
q.
to protect and maintain the personal data, and to have access to it including for the updating of personal data;
 
 
r.
to comply with legal and regulatory requirements and all relevant laws; and
 
 
s.
any other purpose reasonably related to the above specified purposes.
 
 
4.2.
Your personal data will be disclosed for the purposes indicated above to our officers and employees, third parties, service providers, advisors, at all times in compliance with the Act. Such parties which your personal data may be disclosed may include but are not limited to:
 
 
a.
external service providers, contractors and third parties providing the Services or performing any of the Services (or any part of the Services) on C&K’s behalf;
 
 
b.
banks, credit card companies and payment vendors for the processing of payment;
 
 
c.
courier service companies;
 
 
d.
public agencies, including without limitation government and law enforcement agencies;
 
 
e.
professional advisors such as auditors and lawyers; and
 
 
f.
any data intermediaries.
 
 
4.3.
To the extent that any of the communication means which you have provided to C&K (which may include your contact numbers) is/will be listed on the Do Not Call Registry, by agreeing to this Policy through the signing of our membership forms (either physical copies or online), or by any other means of indication, you hereby grant C&K your clear and unambiguous consent to contact you using any of the communication means you have provided to C&K for the above-mentioned purposes. If you wish to opt-out of being contact for marketing purposes, please take the steps set out in Clause 8.4.
 
 
5.
DEEMED CONSENT
 
 
5.1.
You are deemed to have given your consent for the collection, use and disclosure of your personal data in the following circumstances:
 
 
a.
when the personal data is voluntarily provided by you to C&K;
 
 
b.
when you are aware or should reasonably be aware of the purposes for which you have provided your personal data to us;
 
 
c.
it is reasonable for you to have provided the personal data to C&K in the circumstances; and
 
 
d.
in any other circumstances where consent is deemed under the Act.
 
 
6.
LIMITING COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
 
 
6.1.
C&K collects personal data primarily from persons who are our customers (including prospective customers). The collection of personal data is limited to that which is necessary for the identified purposes above.
 
6.2.
Unless permitted by relevant laws, C&K will not disclose personal data to other persons or entities for the advertising, promotion or marketing of any third party’s products and services, and C&K will not sell for payment your personal data to anyone for any marketing purpose, unless your consent has first been given.
 
6.3.
If your personal data is provided to our third party service providers or data intermediaries, they are only to use your personal data for the purpose(s) for which we have supplied the personal data to them. We will also take reasonable steps to ensure that such organisations to whom we have disclosed your personal data are legally bound to comply with the provisions of the Act.
 
 
7.
RETENTION OF PERSONAL DATA
 
 
7.1.
C&K will collect and retain personal data at our discretion, for as long as you remain our customer or access our Services and for as long as it is necessarily required or relevant for business or legal purposes.
 
 
8.
WITHDRAWAL OF CONSENT
 
 
8.1.
You are able to withdraw your consent to our continued use and disclosure of your personal data at any time. Such withdrawal must be made formally in writing to the DPO.
 
8.2.
If such consent is withdrawn, you acknowledge that C&K may no longer be able to provide the Services to you. Accordingly, C&K may, insofar as such consent is integral to the provision of the Services, cease to provide the Services to you. Notwithstanding any withdrawal of consent, (a) unless otherwise agreed by C&K, you will still be bound by any contract(s) for Services with C&K, and should you choose to terminate the relevant contract(s), early termination charges and other charges, penalties or contractual consequences may apply in accordance with the contract(s) or under relevant laws and C&K reserves all rights thereof, and (b) C&K has the right to terminate the contract(s) in its discretion, without liability to you.
 
8.3.
For further clarification on the implications of withdrawing consent, you may write in to the DPO.
 
8.4.
You may write in to our Customer Service at customers@charleskeith.com to indicate the withdrawal of your consent to receiving marketing communications from C&K. You may separately withdraw such consent via the unsubscribe options as stated on the SMS or email marketing message.
 
8.5.
You may also set your browser to warn you when a cookie is being sent or to remove or reject cookies. If you choose to remove or reject cookies, it will affect some features of our Services on our website.
 
 
9.
PROTECTION OF PERSONAL DATA
 
 
9.1.
To the extent required by the Act, C&K shall protect personal data in its possession or under its control against risks of unauthorised access, collection, use, disclosure, copying, modification, disposal or destruction, through reasonable and appropriate security measures. However, C&K cannot ensure or warrant the security of any information you transmit to C&K and you do so entirely at your own risk.
 
 
10.
ACCURACY AND CORRECTION OF PERSONAL DATA
 
 
10.1.
To the extent required by the Act, C&K will use reasonable efforts to ensure that the personal data is sufficiently accurate and complete to minimise the possibility that incorrect personal data may be used to make a decision that impacts you, or if such personal data is likely to be disclosed to a third party. However, you acknowledge that there may be circumstances where C&K is entitled to assume such accuracy and completeness.
 
10.2.
It is your sole responsibility to inform us when there are any changes to your personal data which has been provided to us, so as to ensure that we have the most current, accurate and complete information.
 
10.3.
If you would like to update us with your updated personal data, please write in to the DPO. Please provide your full name, NRIC number, contact details and any other details required by the DPO. We may take up to thirty (30) working days to process your request.
 
 
11.
ACCESS TO PERSONAL DATA
 
 
11.1.
To the extent required by the Act, upon request, if you would like a copy of your personal data held by C&K or how it has been used, please write in to the DPO. Please provide your full name, NRIC number, contact details and any other details required by the DPO. Pursuant to the Act, C&K is entitled to charge you a reasonable fee for this service and we will process your request upon receipt of such payment. We will need up to thirty (30) working days to process your request.
 
11.2.
We may provide a standard list of possible purposes, third parties or data intermediaries who may have accessed or used your personal data as part of its response to you, and the same shall suffice as performance of C&K’s obligations in respect thereof.
 
11.3.
Subject to the Act, C&K may not be able to provide access to all of your personal data that we hold. For example, C&K may not provide access to your personal data if such provision would reveal the personal data of another person, if such information is subject to legal privilege or if such provision will be contrary to national interest. If access to personal data cannot be provided, where possible, the reasons for denying access will be provided upon your request.
 
 
12.
MISCELLANEOUS
 
 
12.1.
Your personal data may be processed by C&K or its data intermediaries or third parties, providing services to C&K in jurisdictions outside of Singapore. In such an event, C&K will take reasonable steps to ensure that such organisations will be legally bound to comply with the terms of the Act.
 
12.2.
This Policy only applies to the collection, disclosure and use of personal data by C&K. It does not cover third party sites not operated by us, even if such sites are co-branded or licensed to use our logo. C&K does not share your personal data with such third party sites. C&K is not responsible for the privacy and conduct practices of these third party sites and shall not be held responsible or liable in anyway way for the actions of these third party sites.
 
12.3.
For more information on the Act, or to contact the Personal Data Protection Commission, please visit www.pdpc.gov.sg.