Privacy Policy

1. Scope of this Privacy Policy

1.1. This Privacy Notice (this “Notice”) sets out the manner in which we MMA Brand Services Pte. Ltd. (“we”, “us”, or “our”) and our related corporations and affiliates (each, a “Related Party”, and, collectively, the “Related Parties”) may collect, use, disclose, transfer, and otherwise process your Personal Data (as defined below) in connection with the websites, goods, and services that link to this Notice. In this Notice, “Personal Data” means any data that is capable of identifying an individual whether on its own or in conjunction with other data accessible by us.

1.2. Importantly, some laws distinguish between a “controller” and a “processor” (or similar terms). We note that we are a “controller” where we make decisions on how Personal Data is used in connection with our goods or services (for instance in relation to Personal Data from visitors to our websites; from our job applicants; and about our customers and vendors to help us manage our business relationships with them), and we are a “processor” where we only use Personal Data in accordance with the instructions given by third parties providing such Personal Data

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2. Collection of Information

2.1. Types of Personal Data that we collect

The type of Personal Data we collect depends on how you are specifically interacting with us. Generally, we collect, among other, the following categories of Personal Data:

2.1.1. “Identity Data”, which includes, but is not limited to, your first name, maiden name, last name, or similar identifier, marital status, title, date of birth and gender, and similar information;

2.1.2. “Contact Data”, which includes, but is not limited to, your billing address, delivery address, email address and telephone numbers, and similar information;

2.1.3. “Financial Data”, which includes, but is not limited to, your bank account and payment details, and similar information;

2.1.4. “User Data”, which includes, but is not limited to, content within communications, suggestions, questions, comments, feedback, and other information you send to us, that you provide to us when you contact us, or that you post on our website, and similar information;

2.1.5. “Transaction Data”, which includes, but is not limited to, details about payments to and from you and other details of products and services you have purchased from us, and similar information;

2.1.6. “Location Data”, which includes, but is not limited to, the location of your device, your household, and similar information;

2.1.7. “Account Data”, which includes, but is not limited to, security-related information (including user names and passwords, authentication methods, and roles), purchases or orders made by you, your interests, preferences, and similar information;

2.1.8. “Usage Data and Browsing History”, which includes, but is not limited to, usage metrics (including usage rates, occurrences of technical errors, diagnostic reports, settings preferences, backup information, API calls, and other logs), content interactions (including searches, views, downloads, prints, shares, streams, and display or playback details), and user journey history (including clickstreams and page navigation, URLs, timestamps, content viewed or searched for, page response times, page interaction information (such as scrolling, clicks, and mouse-overs), and download errors), advertising interactions (including when and how you interact with marketing and advertising materials, click rates, purchases or next steps you may make after seeing an advertisement, and marketing preferences), and similar information;

2.1.9. “Social Media and Online Content”, which includes, but is not limited to, information in social media and online profiles, online posts, and similar information;

2.1.10. “Marketing and Communications Data”, which includes, but is not limited to, your preferences in receiving marketing from us, our Related Parties, and our third parties and your communication preferences, and similar information; and

2.1.11. “Technical Data”, which includes, but is not limited to, your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website, and similar information.

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2.2. How we collect your Personal Data

We use different methods to collect Personal Data from and about you including, without limitation, through:

2.2.1. Direct interactions. You may give us your Personal Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes Personal Data you provide when you:

(a) apply for our products or services;

(b) create an account on our website;

(d) request marketing to be sent to you;

(e) enter a competition, promotion or survey; or

(f) give us feedback or contact us.

2.2.2. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies.

2.2.3. From your authorised representatives. We may collect your Personal Data from your authorised representatives. These include, without limitation, persons whom you have authorised and persons who have been validly identified as acting on your behalf pursuant to our security procedures.

2.2.4. Third parties or publicly available sources. We may receive your Personal Data from third parties that are located in various countries. These include, without limitation:

(a) Technical Data from analytics providers such as Google, advertising networks and social media platforms such as LinkedIn, Twitter and Facebook; and

(b) Contact and Transaction Data from providers of technical, payment and delivery services.

3. Use of Information

3.1. General

3.1.1. We may collect, use, disclose, transfer, and otherwise process your Personal Data for any or all of the following purposes:

(a) to register you as a new customer;

(b) to perform obligations in the course of or in connection with our provision of the goods and/or services requested by you, including, without limitation, to process and deliver your order(s) and to process your returns or refunds in accordance with our terms and conditions (if applicable);

(c) to manage your account and our relationship with you, including, without limitation, managing payments, fees and charges and collecting and recovering money owed to us;

(d) to administer, operate, provide, maintain and protect our business and our website (including, without limitation, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, as well as ensuring that unauthorised users do not access the information on our website);

(e) to deliver relevant content, advertisements, and marketing materials to you (including, without limitation, to provide personalised advertising to you) and measure or understand the effectiveness of the advertising we serve you;

(f) to make suggestions and recommendations to you about products or services (including, without limitation, the products or services of our Related Parties) that may be of interest to you;

(g) for internal research and development for new content, products, and/or services, to monitor the performance of our current products and/or services and to improve, test, and enhance the features and functions of our current products and/or services;

(h) to send you relevant information about our events, news announcements or promotions;

(i) to enable you to complete a survey or participate in a promotion, survey, event or other marketing campaign organised by us;

(j) to detect, prevent, identify, investigate, and deter fraudulent, harmful, unauthorised, unethical, or illegal activity to ensure the security and protection of all customers and others, as well as to identify and authenticate your access to our products and/or services or to identify and authenticate you before we provide you with certain information;

(k) to comply 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;

(l) for any other purposes for which you have provided the information;

(m) to facilitate and effect an investment in or a sale, merger, acquisition, or other disposition of our business or the business of any Related Party (including, without limitation, in connection with any bankruptcy or similar proceedings);

(n) to exercise our rights and to protect our and others’ rights and/or property, including, without limitation, to take action against those that seek to violate or abuse our websites, goods, and/or services;

(o) to audit our internal processes for compliance with legal and contractual requirements or our internal policies;

(p) for transmitting to our Related Parties and any third parties, including, without limitation, our third party service providers and agents, and relevant governmental and/or regulatory authorities, for the aforementioned purposes; and

(q) for any other incidental business purposes related to or in connection with the above.

3.1.2. 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 a contract with you).

3.2. Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us via email at the contact details provided below. If we need to use your Personal Data for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules of this Notice, where this is required or permitted by law.

3.3. Lawful Basis

Some laws require us to explain the lawful basis upon which we process your Personal Data. With respect to these laws, we process Personal Data about you for one or more of the following basis:

3.3.1. To Perform a Contract. Where the processing is necessary for the performance of contract;

3.3.2. Legitimate Interests. Where the processing is necessary for legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of Personal Data;

3.3.3. Your Consent. Where you have given us consent to process your Personal Data for specified purposes, such as to provide our products, services and other items requested by you; and

3.3.4. Comply with the Law. Where the processing is necessary for compliance with a legal obligation.

3.4. Cookies

3.4.1. We use cookies to provide visitors with a personalised experience on our website. Cookies are pieces of information that a website transfers to the memory or hard drive of a visitor’s computer for record-keeping purposes. We use cookies to make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection), to make improvements, and to better tailor our website to our visitors’ needs. We also use this information to verify that visitors meet the criteria required to process their requests.

3.4.2. Most browsers used by visitors have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. Nevertheless, if you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

4. Disclosure of Information

4.1. We may disclose your Personal Data in the circumstances set out below:

4.1.1. We may share your Personal Data with our Related Parties, third party service providers, agents, and other organisations, whether located in your home jurisdiction or elsewhere, in order to carry out the purposes set out above.

4.1.2. We may share your Personal Data with third parties to comply with a legal obligation, when we believe in good faith that an applicable law requires it, at the request of governmental authorities conducting an investigation, to verify or enforce our contractual rights or other applicable policies, to detect and protect against fraud or any technical or security vulnerabilities, to respond to an emergency, or otherwise to protect the rights, property, safety or security of third parties and visitors to our website or the public.

4.1.3. To a buyer or other successor in the event of merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the Personal Data we hold.

4.2. We do not disclose your Personal Data to third parties for their independent use and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.‍

5. Retention of Information

5.1. We only retain your Personal Data for as long as is reasonably necessary for us to use your Personal Data as described above. Nevertheless, please be advised that we may retain some of your Personal Data after you cease to use our services, for instance, if the data is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.

5.2. In some circumstances we may anonymise or aggregate your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.‍

6. International Transfers of Information

6.1. We, our Related Parties, and our third party service providers operate around the world (including, without limitation, in Singapore, Australia, Malaysia, India, China, and Indonesia). Accordingly, your Personal Data may be transferred to, and processed in, countries other than the country in which you are resident (with different privacy laws that may or may not be as comprehensive as your own). In doing so, we will comply with the applicable data protection and privacy laws.

6.2. By submitting your Personal Data or engaging with our website, you consent to this transfer, storing, or processing

7. Data Security

7.1. The security of your Personal Data is important to us. Taking into account the nature, scope, context, and purposes of processing Personal Data, as well as the risks to individuals of varying likelihood and severity, we have implemented technical and organizational measures designed to protect the security of Personal Data.

7.2. Nevertheless, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable measures designed to protect Personal Data, we cannot guarantee its absolute security.

8. Personal Data Choices

8.1. We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

8.2. We have established the following Personal Data control mechanisms:

8.2.1. Promotional Offers and Marketing Materials. We may use your Personal Data to recommend you products or services (including, without limitation, the products or services of our Related Parties), including, without limitation, special offers, promotions, contests or entitlements that may be of interest to you or for which you may be eligible. Such marketing messages may be sent to you in various modes including, without limitation, via electronic mail, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services. You may, at any time, make a request for us (via email at the contact details provided below) to stop sending you such marketing messages. You may also choose not to receive future marketing or advertising emails from us by clicking the unsubscribe link at the bottom of each marketing or advertising email that you receive from us.

8.2.2. Cookies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Nevertheless, if you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.‍‍

9. Personal Data Rights

9.1. Rights

9.1.1. In certain circumstances, local data protection laws may give you rights with respect to Personal Data if you are located in or are a resident of that country, state, or territory. We are only required to honour rights to the extent that these rights have been granted to you and apply to you under applicable data protection laws. Please consult your local data protection laws to determine what rights may be available to you and when access to these rights are limited.

9.1.2. These rights differ based upon local data protection laws in your country, state, or territory, but these rights may include one or more of the following:

(a) Access to Personal Data. You may have the right to obtain confirmation from us that we process your Personal Data and, if so, you may have the right to request access to your Personal Data. Please note that, to the extent permitted by law, we may charge a reasonable fee based on administrative costs for the first or further copies of your Personal Data requested by you.

(b) Correction. You may have the right to request that we correct or rectify inaccurate Personal Data concerning you and, depending on the purposes of the processing, you may have the right to have incomplete Personal Data completed.

(d) Restriction of Processing. You may have the right to require us to restrict the further processing your Personal Data. If so, the respective information will be marked as restricted, and may only be processed by us for certain purposes.

(e) Object. You may have the right to object, on grounds relating to your particular situation, to the processing of your Personal Data by us, and we may be required to no longer process some or all of your Personal Data.

(f) Data Portability. You may have the right to receive a copy of your Personal Data that you have provided to us, in a structured, commonly used, and machine-readable format, and you may have the right to transmit that Personal Data to another entity without hindrance from us.

(g) Withdrawal of Consent. You may have the right to withdraw consent you have previously provided to us where we rely solely on your consent to process your Personal Data. Please note, however, that we may still be entitled to process your information if we have another legitimate reason or legal basis (other than consent).

(h) Right to Complain. You may have the right to lodge a complaint to an applicable supervisory authority or other regulator if you are not satisfied with our responses to your requests or how we manage your Personal Data. For example, if you are located in Singapore, a personal data protection complaint may be made to the Personal Data Protection Commission at https://www.pdpc.gov.sg/complaints-and-reviews/report-a-personal-data-protection-concern/personal-data-protection-complaint; if you are located in Malaysia, a personal data protection complaint may be made to the Department of Personal Data Protection at https://daftar.pdp.gov.my/p_aduan; and if you are located in Australia, you must raise the issue with us, and if not satisfied with our response or if you do not receive a response within 30 days, you can lodge a complaint with the Office of the Australian information Commissioner at https://www.oaic.gov.au/privacy/privacy-complaints/lodge-a-privacy-complaint-with-us. We encourage you to first or also reach out to us (via email at the contact details provided below), so we have an opportunity to address your concerns directly.

9.1.3. Pertinently, the foregoing rights are not absolutely guaranteed and there are several exceptions where we may not have an obligation to fulfil your request. Please consult your local data protection laws to determine what rights may be available to you and which exceptions may apply.

9.2. Submitting a Request

9.2.1. To make a request or exercise your Personal Data rights, kindly contact us (via email at the contact details provided below) with the following information:

(a) The Right You Are Exercising. Please let us know which right you want to exercise and the Personal Data to which your request relates (if not to you). If you are acting on behalf of another individual, kindly indicate this fact clearly and provide evidence of your authority to act on such person’s behalf.

(b) Your Relationship with Us. Please let us know how you are associated with us, such as that you use certain services of ours, purchased goods of ours.

(c) Help Us Verify Your Identity. Given our personal information security measures, we generally require proof of identity before we disclose Personal Data to you or before we process your requests. Help us by providing us with enough information to verify your identify. If we cannot initially verify your identity, we may request additional information to complete the verification process (such information may include your picture, a copy of your driver’s license or other government-issued ID and/or a recent utility or credit card bill). Please note that if we cannot verify your identity, we may not be able to fulfil your request. Any Personal Data you disclose to us for purposes of verifying your identity may be shared with our third party service providers and/or third parties or government agencies for the purpose of verification.

9.2.2. Please allow up to 30 calendar days (or such other maximum period as prescribed by applicable law, if shorter) to respond to your request.

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10. Minors

Our website is not directed at minors (as defined by local legal requirements) and we do not knowingly collect data relating to such minors. If you are a minor, please do not provide Personal Data of any kind whatsoever, unless you have parental or guardian consent. If we learn we have mistakenly or unintentionally collected or received Personal Data from a minor without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a minor, please contact us via email at the contact details provided below.

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11. Other Websites

This Notice only applies to our website. Our website may contain links to other websites which are not maintained by us. When visiting these third party websites, you should read their privacy policies which will apply to your use of such websites

12. Conflicts

In the event of any conflict between the English version of this Notice and a version translated in another language, the English version shall prevail.

13. Effect of this Notice and Changes to this Notice

13.1. This Notice 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.

13.2. As our organisation changes over time, this Notice is expected to change as well. We may revise this Notice 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 Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

14. Contact Us

If you have any comments, questions, or complaints about this Notice, please contact us at data.privacy@una-brands.com