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MT COSMETICS SINGAPORE PTE. LTD.
PERSONAL DATA PROTECTION ACT (“PDPA”) COMPLIANCE POLICY

Introduction
1. The Personal Data Protection Act (“PDPA”) governs the collection, storage, use and disclosure of personal data in Singapore. We take our responsibilities with respect to personal data protection seriously and have thus formulated a policy on the use of personal data for your protection. The provision of your personal data is voluntary but if you choose not to provide us with any requested data, such failure may inhibit our ability to provide services to you or affect the quality of the services we provide to you.
Data Collection
2. Data will be collected from you in the following manner:-
(a) When you apply to be a Privilege Pass customer of our Company or where an order is placed for our products or services whether through physical or electronic means, access to our online services or to our website or use of our mobile application services;
(b) When documents or application forms are submitted to us for the Privilege Pass application or for the purchase of our products or services at our physical stores or through online, including after sales service;
(c) When you submit your enquiries for personal consultations, on our products, services or events, or issue instructions or make any requests or updates to your account with us or requests for any marketing materials (e.g. brochures) or for changes to any products or services purchased;
(d) When you seek personal consultation, interact or communicate with our personnel, our agents, or customer service officers whether by telephone, email, face to face meeting, text messages, fax, by letter or otherwise;
(e) When we receive referrals and collect or share personal data from within our group of related or affiliated businesses and/or companies and third party providers of services to us or to other members of our group of related or affiliated businesses and/or companies;
(f) When we seek information from third parties who hold personal data concerning your good self, including your legal, banking, accounting professionals;
(g) When you submit personal data to us during the course of your participation in any marketing promotional or advertising event organized or hosted by us or our related or affiliated businesses and/or companies; and
(h) When you respond to our approaches or promotions.
Use of Personal Data
3. Personal Data information directly obtained from you is used for the following purposes:
(a) To evaluate and provide advice or recommendations to you to fulfil your requirements for our goods or services, and so that we may arrange for the shipping and delivery of our goods or services according to your needs;
(b) To fulfil any applicable rules and regulations whether of a local governmental nature or of foreign authorities and generally for legal compliance requirements;
(c) To respond to your requests and enquiries, to receive feedback and complaints from you to improve the quality of our goods or services to you and in this regard, to verify your identity or the identity of your representative(s) who contact us;
(d) To communicate with you to obtain your instructions or regarding any changes or updates to our products or services or to introduce any products or services that may be relevant to you, to update you on policies and rules and regulations or compliance requirements of any governmental agencies that are relevant to you;
(e) To recover any and all amounts owed to us;
(f) To create, administer, maintain, and to manage your account with us or the products and services offered to you or purchased by you including processing your instructions, preparing documentation and instruments relating to the products and services you have purchased, and the issuing and printing of statements of accounts to you on a regular basis;
(g) For statistical, trend analysis and planning purposes including data processing, statistical or market analysis;
(h) To store and safe keep or to archive documents and records in both electronic and physical format as part of the administrative and operational requirements of our business;
(i) To comply with any contractual or other obligations, and arrangements for data sharing and information within our Company, our affiliates and related business companies and partners who provide administrative, professional advisory or other support services to us;
(j) To prevent, detect and investigate any crime, including fraud and any form of financial crime, analyzing and managing any financial risks;
(k) For marketing or promotional purposes relating to our Company, our related or affiliated businesses and/or companies;
(l) To conduct our internal checks, to carry out financial reporting and analysis related to our business operations; and
(m) For any other purposes directly relating to the above purposes.
4. If you have provided your Singapore contact number(s) and addressee(s) and have indicated that you consent to receiving marketing or promotional material, then our affiliates and related business companies and partners who provide administrative, professional advisory or other support services to us may contact you using such contacts to inform you or to recommend to you relevant products and services that we feel may be of interest to you.
Online Collection of Data
5. In addition to the information we collect directly from you, we also use “cookies” to monitor and track usage of our Website, viewing and traffic patterns, customer behavior and other similar information.
6. We compile this information into a statistical aggregate and use this information as well as all of your personal or business information for our internal business and administrative purposes which includes improving our website, our product and service offerings, our operations, and our customer service.
7. Our Company including our related or affiliated businesses and/or companies also might use your personal or business information from time to time to send you notices about special offers, new products, new services, promotions, and other similar information if you have Indic when you use our online services or access our website.
8. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser but you may not then be able to enter certain part(s) of our website.
9. Our website may contain links to other sites but our Company is not responsible for the privacy practices or the content of these other Websites.
10. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable data protection policy of the third party to determine how they will handle any information they collect from you.
Disclosure of Personal Data
11. Your personal data will be protected subject to disclosure to our Company’s agents, our personnel, or customer service officers who are servicing you on a “need to know” basis as a necessary part of our business and operational requirements:
Limited Disclosure to Third Parties
12. Personal Data is only otherwise disclosed to the following third parties:-
(a) Our Company’s holding company or subsidiary or a subsidiary of our Company’sholding company;
(b) A company or business entity in which any of our Directors or shareholders hold an equity or business interest of not less than 10%;
(c) Operators of payment systems such as Network for Electronic Transfers (Singapore) Pte Ltd, banks, financial institutions, credit card companies and their respective service providers;
(d) Our financial or legal advisers or other professional advisers for the purposes of obtaining financial, or accounting, legal or other professional advice and services in relation to our business operations;
(e) Governmental agencies or regulatory agencies or authorities for legal compliance purposes;
(f) Any liquidator, receiver, official assignee / trustee, judicial manager under or pursuant to any applicable law or court order in connection with the bankruptcy, liquidation, winding up, judicial management or any other like process; and
(g) Any third party company or business with whom we have a business relationship and who provide us with administrative or other support services such as telecommunications, call centre, mailing, information technology, payment, payroll, data processing training, marketing research, storage and archival services or who are our sub-contractors, advisers, assistants or agents [whether on paid or voluntary basis] tasked with performing all or part of the services we have contracted to provide to you.
13. Save for Governmental agencies or regulatory agencies or authorities, your personal data is disclosed only to such of the above mentioned third parties as have entered into an express or implied Confidentiality Agreement with us to preserve the confidentiality of your personal data and on a “need to know” basis and for the purposes we have set out in Clause 3 above.
No Trading In Personal Data
14. Save as provided herein, we do not disclose any customer information to any other third party unless we are required by law or by an Order of Court. In addition, we only permit authorized employees, who are trained in the proper handling of customer information to have access to such information and on a “need to know” basis.
15. We do not trade or sell your personal data or such information to anyone under any circumstances.
Withdrawal Of Consent
16. You may withdraw your consent for the collection, use or disclosure or your personal data in our possession by contacting us at:shop-admin@metatron-cosme.sg
17. Please note that if you withdraw your consent to any or all use or disclosure of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our products or services to you or administer any contractual relationship in place and such withdrawal may also result in the termination of any agreement we may have with you.
18. You may withdraw my consent for the receipt of marketing information at any time by clicking on the “Unsubscribe” link in the email(s) containing such marketing information that we send to you or contacting us at:shop-admin@metatron-cosme.sg but if you do so, you will not be able to be informed of, and you will not be able to continue to avail yourself to the full range of the products or services or customer experiences offered by our Company, our affiliates, business partners and related companies in particular, for any new or improved product lines.
Updates On PDPA Compliance Policy
19. As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
20. We reserve the right to amend the terms of this PDPA Compliance Policy at our absolute discretion. Any amended PDPA Compliance Policy will be posted on our website at:https://www.metatron-cosme.jp/en/sgPDPA and you are encouraged to visit our said website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection. Your continued retention of your Privilege Pass, placement of orders with us for our goods and services, or access to and/or use of our website or online services will be taken to be your agreement to, and acceptance of, all changes made in each updated version.
Contacting Us
21. If you have any questions about our PDPA Compliance Policy or the privacy practices of our website, please contact us at:shop-admin@metatron-cosme.sg
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