In conducting our business, we, Sophie’s Bionutrients Pte. Ltd., may collect, use, disclose or otherwise process Personal Data relating to you.

This Privacy Policy sets out how we comply with our obligations under the Personal Data Protection Act 2012 of Singapore (“PDPA”).

Please read the following carefully to understand our views and practices regarding your Personal Data, and how we will treat such Personal Data.

In this Data Privacy Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

By visiting our website or using our products and services, you are accepting and agreeing to our practices described in this Privacy Policy.

Collection And Processing Of Personal Data

We may collect Personal Data (which may include sensitive Personal Data) when you provide it to us. Generally, we collect Personal Data in the following ways:

• when you submit any form, including but not limited to consent and order forms, as well as customer inquiry forms or other forms relating to any of our products and services;
• when you enter into any agreement or provide documentation or information in respect of your interactions with us, or when you use our products and services;
• when you interact with our staff, either directly or indirectly through referral intermediaries or our business partners via telephone calls (which may be recorded), letters, fax, face-to-face meetings and emails;
• when you request that we contact you or request that you be included in an email or other mailing list;
• when we seek information about you and receive your Personal Data in connection with us, including our products and services, for example, from business partners, public agencies, referral intermediaries and the relevant authorities; and/or
• when you have chosen to provide or submit your Personal Data to us.

Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, identification document, nationality, address, telephone number, race, gender, date of birth, email address and any other information about yourself and your use of our Products and Services, as well as data relating to your health and diet history, religious or other similar beliefs, and any other information which you have provided us, in any forms you may have submitted to us, or via other forms of interaction with you.

If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children and/or parents), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

We may also use various technologies on our website which may lead to information being automatically collected and stored by us, including device-specific and other technical information about your mobile or computer device such as the hardware model, operating system version, browser type and version, Internet Protocol (IP) address, advertising identifier, unique application identifiers, unique device identifiers, browser type, language, wireless network, and mobile network information. This information does not generally, but may, contain your Personal Data, and we, and our data intermediaries, do not use such information to identify you unless permitted by law.

We use cookies on our website, which are small text files that a website stores on your PC, telephone or any other device with information on your navigation on our website, whose principal objective is to improve your experience on our website, track use of the website and to provide us subsequently with aggregated information that are either necessary for the functioning of our services, help us improve our performance or serve to provide you with extra functionalities. By default, cookies are enabled on web browsers but if you prefer, you may disable the use of cookies in your browser and delete the cookies saved in your browser associated with our website.

Purposes of Use

All Personal Data and other information collected may be used by us for any of the following purposes:

• responding to, handling, and processing your enquiries or requests pursuant to your emails, telephone calls, faxes and/or submission of form(s) in relation to the provision of our products and services;
• responding to and taking follow-up action on feedback or complaints;
• troubleshooting crashes associated with specific hardware and software used to access our website;
• monitoring and tracking your usage of our website, in order to assist us in understanding user behaviour, trends and preferences;
• managing our administrative and business operations and complying with internal policies and procedures;
• to notify you about any changes to our products and services or this policy;
• complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; and/or
• any other purpose(s) that do not appear above where permissible under any written law, as may be notified by us to you from time to time.

The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

Disclosure Of Personal Data

It may be necessary for us to disclose your personal data to third parties in a manner compliant with the PDPA in the course of our business, such as for processing activities like verification, due diligence, website hosting, data analytics and payment processing.

We will not disclose or sell your personal data to unrelated third parties under any circumstances unless we employ other companies to perform tasks on our behalf and we need to share your information with them to provide services to you and we have obtained your consent to do so. Please be rest assured that our third party service providers are carefully selected and are bound (whether at law or in contract) by obligations of confidentiality and data protection similar to the requirements of the PDPA.

There are some circumstances in which we may disclose your personal data:

• third party service providers in order for us to facilitate your access to and use of our services and for us to contact you as you may have requested. The aforesaid third party service providers have a contract with us to perform the services necessary for you to use the Services and receive updates thereto, and such third party service providers therefore include but is not limited to webhost companies, website maintenance companies, database storage companies, telecommunications companies, etc.
• third party advertisers and advertising networks to collect information about your activities and geographic location to enable them to display targeted ads to you however to the extent that we display advertising of our products and services only;
• our related entities in order for them to offer their products and services to you;
• our book-keepers, accounting firms, audit firms, law firms and/or other professional advisory firms who are maintaining our records in accordance with legal requirements;
• governmental, regulatory or law enforcement bodies who have a legal right to demand for your personal data, in response to a legal request such as a Court order, to investigate or report illegal activity, or to enforce our rights or defend claims;
• credit bureaus, credit rating agencies and fraud preventing companies for the purpose of minimizing fraudulent activities via your personal data; or
• our affiliated or related companies and/or third parties to whom we may sell, divest, transfer, assign, share or otherwise engage in a transaction that involves, some or all of the Company’s assets (which may include your personal data), in the course of a corporate divestiture, corporate restructuring, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding.

Except as provided above, we do not sell, rent, licence or otherwise disclose your personal ata to third parties or our affiliated companies. We are careful in our selection of third party service providers, and all such third party service providers as well as our above mentioned affiliated companies are bound by obligations of data protection (pursuant to contracts and/or applicable laws) similar to the obligations herein this Privacy Policy. You hereby authorize us to transfer your Personal Data to such third parties, who will process your Personal Data in accordance with this Privacy Policy.

Storage And Transfer Of Personal Data

Pursuant to the purposes and activities as set out herein, it may be necessary for the Personal Data that we collect from you to be transferred to, and stored at, a destination outside Singapore. It may also be processed by staff operating outside Singapore who work for us or for one of our service providers.

By providing your Personal Data, you agree and consent to the aforesaid transfer, storing and processing, on the understanding that the recipients of such Personal Data will take appropriate steps to ensure that your data is treated securely and continues to receive a standard of protection that is at least comparable to that provided under the PDPA, applicable laws and in accordance with this Privacy Policy.

Withdraw Consent, Request Access To And Correction Of Personal Data

You have the right to withdraw consent, request access to or make corrections to the Personal Data that we hold about you in accordance with applicable laws.

All requests for withdrawal of consent, access to, or correction of Personal Data held by us shall be made in writing or via email addressed to our Data Protection Officer at:

Address	:	Sophie’s Bionutrients Pte. Ltd. 52 International Road, #02-02, Singapore 619626
Email	:	info@sophiesbionutrients.com

We may charge a reasonable fee for processing your request for access. If so, we will inform you of the fee before processing your request.

Please note that if your Personal Data has been provided to us by a third party (for example, a business partner) you should contact that organization or individual to make such queries, complaints, and access any correction request to us on your behalf.

We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under applicable laws).

If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our products and services to you, or administer any contractual relationship in place, which in turn may result in the termination of any agreements with us.

Protection Of Personal Data

To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of Personal Data by us, and disclosing Personal Data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures However, we cannot accept responsibility for misuse or loss of, or unauthorised access to your Personal Data.

Disclaimer

To the fullest extent permitted by law, we shall not be liable in any event for any special, exemplary, punitive, indirect, incidental or consequential damages of any kind or for any loss of reputation or goodwill, whether based in contract, tort (including negligence), equity, strict liability, statute or otherwise, suffered as a result of unauthorized or unintended use, access or disclosure of your Personal Data.

Retention Of Personal Data

We retain the Personal Data we receive as described in this Privacy Policy for as long as necessary to fulfill the purpose(s) for which it was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Whilst we will securely dispose of or anonymise Personal Data which we can reasonably determine is no longer needed and we do not generally hold on to Personal Data “just in case”.

We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes.

Third Party Websites

Our website may, from time to time, contain links to and from third party websites who are not related to us. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. These links are provided for your information and convenience only and are not an endorsement by us of the content of such websites or third parties.

Data Protection Officer

 Any complaints, enquiries or feedback regarding your Personal Data or this Privacy Policy should be addressed to our Data Protection Officer at info@sophiesbionutrients.com.

 All complaints will be evaluated by us in a timely manner. After we have completed our evaluation, our Data Protection Officer (or duly appointed representative) will respond to the person who submitted the complaint or feedback, with the results of the evaluation.

We may be prevented by law from complying with any request that you make. We may also decline any request that you may make if the law permits us to do so.

Effect Of Privacy Policy And Changes To Privacy Policy

This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us.

We may revise this Privacy Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. Your continued use of our products and services constitutes your acknowledgement and acceptance of such changes.

Governing Law

All matters related to or arising from this Privacy Policy will be interpreted and governed by the laws of Singapore.

In the event of any disputes arising from this Privacy Policy, you must first contact our Data Protection Officer regarding your concern and use your best endeavors to amicably settle any dispute in good faith. If no mutually satisfactory resolution can be reached within reasonable time, we may choose to refer the dispute on an exclusive basis for mediation in the Singapore Mediation Centre or for final resolution by arbitration in Singapore in accordance with the Arbitration Rules of the Singapore International Arbitration Centre for the time being in force which rules are deemed to be incorporated by reference into this provision.

Last updated: 6 August 2020