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PRIVACY POLICY

This is the ASEAN365 PTE LTD (ASEAN365)’s Privacy Policy. ASEAN365 collects, uses and discloses Customer Data in order to provide you with a safe, smooth, efficient and customised experience with ASEAN365. The collection, use and disclosure of Customer Data enables ASEAN365 to provide services and products that are most likely to meet your needs and requirements. This Privacy Policy outlines ASEAN365’s policy and responsibility in relation to the collection, use and disclosure of Customer Data.

By continuing to use ASEAN365’s services, you signify that you have read, understood and agree to be bound by this Privacy Policy as amended from time to time in respect of ASEAN365’s collection, use and disclosure of your Customer Data.

This Privacy Policy is divided into two Parts – A and B:

  • Part A: General Customer Data privacy policy statement
  • Part B: Privacy policy statement for Customer Data collected through ASEAN365’s websites and ASEAN365’s mobile services facility


PART A: GENERAL CUSTOMER DATA PRIVACY POLICY STATEMENT

1. Types of Customer Data 
 The types of Customer Data that ASEAN365 collects depends on the circumstances of collection and on the nature of the service requested or transaction undertaken.

There are two broad categories of Customer Data that ASEAN365 collects depending on the circumstances:

  • Personal Data, which includes but is not limited to -

(i) personal information that links back to an individual e.g., name, gender, date of birth, passport or other personal identification numbers;

(ii) contact information e.g., address, phone number, email address;

(iii) payment information e.g., credit or debit card information, including the name of cardholder, card number, billing address and expiry date;

(iv) order information e.g., order information, product purchased or other service preferences;

(v) technical information e.g., IP address; and

  • Statistical Data e.g., number of orders, visits to website. This is stored purely for analytical purposes, and is entirely anonymous. This information will not be stored to your customer record, and will only be aggregated for statistical analysis so that we can better understand ASEAN365's customer profile and improve ASEAN365's service offering.

For purposes of this policy statement, the phrase Customer Data includes Personal Data and Statistical Data.

The provision of Customer Data relevant for the transaction or service request at hand, (save for where the request for data is marked “optional” in the forms used to collect personal data) is obligatory in order for ASEAN365 to carry out its services to you.

The failure to supply such Customer Data may result in (i) ASEAN365 being unable to provide you with the services and/or products requested; (ii) ASEAN365 being unable to update you on our latest products and/or launches; and/or (iii) your inability to enter or participate in contests, promotions or redemption activities organised by ASEAN365.


 2. Purposes for Collection, Use and Disclosure 
 Generally, ASEAN365 collects Customer Data, either directly from you or from your authorised representatives (i.e. persons whom you have authorised, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), from third parties (e.g., our service provider), or from publicly available sources, through our website, mobile services, and other channels including our roadshow counters in order to fulfil the following purposes, which include but are not limited to:

  • Providing services to you such as processing a transaction (e.g., making a purchase), providing technical assistance, assisting you in the transaction, providing promotion alert messages through ASEAN365’s mobile services facility, facilitating internet purchases and registering for ASEAN365’s Rewards programme; 
  • Providing in-store services and other services that best meet your preferences and needs (which we may collect during our interactions with you);
  • Marketing and communicating with you in relation to products and services offered by ASEAN365, ASEAN365’s service partners, as well as ASEAN365’s appointed agents;
  • Contacting you for product or customer satisfaction survey and market research; and
  • Safety, security and legal compliance.

ASEAN365 may also use and disclose your Customer Data with and to third parties in order to fulfill the purposes listed above.

In connection with the above, we may disclose your Customer Data to third parties, such as our freight service providers and logistics partners.

ASEAN365 may also use and disclose your Customer Data to persons who have been validly identified as being you or your authorised representative(s) pursuant to our then-current security procedures, for the purpose of the relevant transaction or enquiry.

ASEAN365 shall use its best endeavours to ensure that its employees, officers, agents, consultants, contractors and such other third parties mentioned above who are involved in the collection, use and disclosure of Customer Data will observe and adhere to the terms of this Privacy Policy.
 ASEAN365 may disclose your Customer Data to law enforcement agencies and government for security, customs purposes. For example, in cases where you send a product from ASEAN365 to family and friends overseas.

In addition, ASEAN365 may disclose Customer Data to our legal advisors for establishing, exercising or defending our legal rights, to our other professional advisors, or as otherwise authorised or required by law. ASEAN365 also reserves the right to share Customer Data as is necessary to prevent a threat to the life, health or security of an individual. Further, ASEAN365 may disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.

3. Transfer of information overseas 
 The ASEAN365 Head Office is based in Singapore. Customer Data may be transmitted to data storage facilities where ASEAN365 keeps its central records or for backup purpose. Customer Data may be transferred to ASEAN365’s offices and appointed agents in Singapore or other countries in connection with ASEAN365’s performance of the contract with you.

4. Consent 
 Generally, in the course of making a purchase at ASEAN365 or ASEAN365 performing servicing functions such as processing your order, helping you with membership registration, transmitting promotion alert messages or accepting payment information, Customer Data will, by nature of the task or transaction, be provided by Customer to ASEAN365. In such instances, consent will necessarily be implied from the Customer that they are agreeable to providing Customer Data in order for ASEAN365 to provide the requested or necessary service and/or product to them.  However, where required by law, ASEAN365 will adopt an ‘opt-in' policy for obtaining customer consent, in which event, express written consent will be sought from you when collecting your Customer Data e.g., signing a form or checking a box. Where you make purchases on behalf of another person, you undertake and will ensure that the individual whose Customer Data is supplied to ASEAN365 has authorized the disclosure, is informed of and consents to the terms and conditions of this Privacy Policy.

You may submit a request to withdraw your consent at any time by contacting ASEAN365 (see Section 10) or by logging on to your website account with ASEAN365.

Statistical Data is not linked to a customer record and ASEAN365 does not need to seek consent for the collection, use or disclosure of Statistical Data. For more information on the collection and usage of Customer Data obtained from ASEAN365’s websites and through ASEAN365’s mobile services facility, please refer to Part B.

5. Access 
 ASEAN365 will, upon your written request to our Personal Data Protection Officer (see Section 10), allow you to access your stored Personal Data. Where permitted by law, ASEAN365 reserves the right to charge a reasonable administrative fee for this service. Where permitted by law, ASEAN365 reserves the right to deny you access to your Personal Data and may provide an explanation.

6. Retention 
 ASEAN365 will retain Customer Data for as long as it is necessary to fulfill the purpose for which it was collected, the legal or business purposes of ASEAN365, or as required by relevant laws.
 When destroying Customer Data, we will take commercially reasonable and technically possible measures to make the personal information irrecoverable or irreproducible in accordance with the applicable laws.

7. Accuracy 
 ASEAN365 needs your assistance to ensure that your Personal Data is current, complete and accurate. As such, please inform ASEAN365 of changes to your Personal Data by contacting ASEAN365 and submitting your updated particulars to ASEAN365 in writing (see Section 10). 

ASEAN365 may also request Personal Data updates from you from time to time. As detailed in Section 2 above under the “Use and Disclosure” sub-section, your order information may be disclosed to the appropriate customs and immigration authorities (for overseas purchases) as required by law. As such, it is important to ensure that the Personal Data contained in your order information is current, complete and accurate.

8. Security safeguards 
 ASEAN365 takes the security and protection of your Customer Data very seriously. As such, ASEAN365 makes reasonable security arrangements to protect your Customer Data against loss or theft as well as unauthorised access and undue disclosure.

As an example of a procedural safeguard, ASEAN365 has implemented various authentication procedures internally and with our external service providers that may involve ASEAN365 requesting various personal particulars from you in order to verify your identity (or that of your duly authorised agent) before ASEAN365 processes your request for a particular service, product or transaction.

Examples of technical safeguards include encryption, firewalls and Secure Socket Layer (SSL). Further details of these technical safeguards for Customer Data collected through ASEAN365’s websites and ASEAN365’s mobile services facility are set out at Part B below.

If, however, a customer does not take reasonable care to ensure the continued confidentiality and accuracy of their Customer Data, ASEAN365 will not be liable for any consequential misuse and/or fraud. If you have any concerns about security, you should contact ASEAN365 (see Section 10).

9. Updates to the privacy policy 
 ASEAN365 will amend this Privacy Policy from time to time and the updated versions will be posted on ASEAN365’s website and date stamped so that you are aware of when the Privacy Policy was last updated. Subject to applicable laws, the English version of this Privacy Policy will prevail over any version of this Privacy Policy in another language. In the event of any inconsistency in interpretation between the English version and any translation of the Privacy Policy, this Privacy Policy statement in English will prevail.

10. Contact us / Personal Data Protection Officer Contact Details
 If you have comments, questions or complaints about or requests relating to this Privacy Policy statement or how ASEAN365 handles personal data, please contact ASEAN365 in writing at the address below referencing ‘Privacy Policy':

 Personal Data Protection Officer
 
Asean365 Pte Ltd
 1 International Business Park, #B1-20A
 The Synergy
 Singapore 609917
 Email: 
pdpo@asean365.com 


PART B: PRIVACY POLICY STATEMENT FOR CUSTOMER DATA COLLECTED THROUGH OUR WEBSITES AND OUR MOBILE SERVICES FACILITY

1. Security safeguards 
 ASEAN365 takes the protection of your Customer Data collected on ASEAN365’s websites and through ASEAN365’s mobile services facility very seriously. All Customer Data collected through ASEAN365’s websites, e.g., 
https://www.asean365.com and through ASEAN365’s mobile services facility are protected by a secure server. In addition, SSL (Secure Socket Layer) protects the transmission of data from the internet to our systems.

For example, when you transmit sensitive information such as credit card details through ASEAN365’s websites, such information will be encrypted before being dispatched over the internet.

To further strengthen the integrity of your internet transactions on our websites, ASEAN365 also employs relevant software programs to monitor network traffic with a view to identifying unauthorised attempts to upload or change Customer Data, perpetuate fraudulent or illegal activities or otherwise cause damage. If such monitoring reveals evidence of possible abuse or criminal activities, such evidence may be provided to appropriate law enforcement authorities or agencies without notice to you.

As an additional security feature, ASEAN365 has implemented a time stamp showing the time you have been on ASEAN365’s websites and the last time you logged out. If you detect any anomalies you should inform ASEAN365 immediately.

2. Cookies 
 Most websites like ours use cookies to enhance your online experience. A cookie is a small string of information that the website that you visit transfers to your computer for identification purposes. Cookies can be used to follow your activity on the website and that information helps us to understand your preferences and improve your website experience. Cookies are also used to remember for instance your user name and password.

You can turn off all cookies, in case you prefer not to receive them. You can also have your computer warn you whenever cookies are being used. For both options you have to adjust your browser settings (like internet explorer). There are also software products available that can manage cookies for you. Please be aware though that when you have set your computer to reject cookies, it can limit the functionality of the website you visit and it’s possible then that you do not have access to some of the features on the website. 

3. Clickstream data 
 In order to improve your online experience, ASEAN365 may track online behaviour or clickstream data to advance your use of our web pages and track referrals from other websites. Such data will not be stored to your customer record, and will only be aggregated for statistical analysis.

4. Links to other websites 
 ASEAN365 provides you with links to other websites for your convenience and information. You access these websites at your own risk and ASEAN365 is not responsible for these websites. Whilst ASEAN365 will protect your Customer Data on ASEAN365 websites, ASEAN365 cannot control or be responsible for the policies of other sites we may link to, or the use of any Customer Data you may share with them.  Please note that the ASEAN365 Privacy Policy does not cover these other websites, and ASEAN365 would recommend that you are apprised of their specific policies.

5. Minors 
 ASEAN365 cannot distinguish the age of persons who access and use its websites. If a minor (according to applicable laws) has provided ASEAN365 with Customer Data without parental or guardian consent, the parent or guardian should contact ASEAN365 to remove the relevant Customer Data and unsubscribe the minor.

6. Google Analytics 
 Google Analytics is a web analysis service provided by Google. Google utilizes the data collected to track and examine the use www.asean365.com, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. For more details, please refer to Googe Privacy Policy at https://policies.google.com/privacy?hl=en.