PS SKIN PRIVACY POLICY

1. INTRODUCTION

1.1 This is PS SKIN PTE. LTD.'s privacy policy for all our customers and users of our website, social media platforms, blogs and forums ("Channels"). The Channels operate as an e-commerce website selling certain dermatologically formulated skincare and other products (the "Products").

1.2 Purpose. The purpose of this document (the "Privacy Policy") is to inform you of how we manage Personal Data (as defined below) which is subject to Singapore's Personal Data Protection Act 2012 (No. 26 of 2012) (the "Act"). Please read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

1.3 Your consent. By interacting with us, submitting information to us, or signing up for any Products and/or services offered by us, you agree and consent to us (including our related corporations and business units) (collectively, the "Companies"), as well as their respective representatives and/or agents collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies' authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.

1.4 Amendments. As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to any rights that you may have at law, if you continue to use our website, online services or Products and services, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on our website. Please ensure that you visit our website regularly to obtain updated information on the handling of your Personal Data.

2. PERSONAL DATA

2.1 In this 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 which we have or are likely to have, including data in our records as may be updated from time to time ("Personal Data").

2.2 Personal Data that you may provide to us include (depending on the nature of your interaction with us), amongst others, your name, NRIC, passport or other identification number, telephone number(s), shipping and billing address, email address, credit history, geographical location, network data and any other information relating to any individual which you have provided to us in any form submitted to us, or via other forms of interaction with you.


3. COLLECTION OF PERSONAL DATA

3.1 Generally, we collect Personal Data in the following ways:-

3.1.1 when you submit an application form or other forms relating to any of the Products and services;

3.1.2 when you interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings and emails;

3.1.3 when you use some of our services, for example, websites and apps including establishing any online accounts with us;

3.1.4 when you purchase or obtain third party services through us;

3.1.5 when you request that we contact you, be included in an email or other mailing list;

3.1.6 when you respond to our promotions, initiatives or to any request for additional Personal Data;

3.1.7 when you are contacted by, and respond to, our marketing representatives and customer service officers;

3.1.8 when we receive references from business partners and third parties (e.g. where you have been referred by them);

3.1.9 when we seek information from third parties about you in connection with the Products and services you have applied for; and

3.1.10 when you submit your Personal Data to us for any other reasons.

3.2 Subject to Clause 6 below, your browsing of our website is generally anonymous. We do not automatically collect Personal Data on our websites unless you provide such information or login with your account credentials.

3.3 If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), 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 set out in this Privacy Policy.

3.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Products and services you have requested.

3.5 We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.


4. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA

This Clause describes the purposes for which we collect, use and disclose your Personal Data.

4.1 Generally, we collect, use and disclose your Personal Data for the following purposes:-

4.1.1 to deliver your orders to you;

4.1.2 to send you service updates such as order status by text, email or through other means;

4.1.3 to perform fraud checks to prevent and/or detect fraud against you or our company;

4.1.4 to carry out administrative matters such as your sign-ups/registrations for accounts, payments or refunds;

4.1.5 to maintain your membership account

4.1.6 to communicate with you on your queries;

4.1.7 to find out what you like so we can send you messages that you want to hear about;

4.1.8 to keep you updated on marketing news such as new launches, events, promotions, third-party organisations we are collaborating with etc, by text, email or post;

4.1.9 to show you our ads as you browse the web;

4.1.10 to show you products relevant to you;

4.1.11 to provide customer service and support;

4.1.12 to monitor or record phone calls and customer-facing interactions for quality assurance, employee training, performance evaluation and identity verification purposes;

4.1.13 legal purposes (including but not limited to obtaining legal advice and dispute resolution);

4.1.14 to conduct investigations relating to disputes, billing, suspected illegal activities or fraud;

4.1.15 to meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and

4.1.16 purposes which are reasonably related to any of the above purposes in this Clause 4.1 or for any other purpose which we may notify you at the time of obtaining your consent.

4.2 If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), We may, from time to time, contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our Products and services.

4.3 In relation to particular Products and services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

4.4 You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. To do so, you may contact us using the contact details in Clause 7 below.


5. DISCLOSURE OF PERSONAL DATA

5.1 Shopify Inc. Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our Products and services to you. As such, your Personal Data is disclosed to Shopify and is stored through Shopify's data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall, which can be deleted immediately upon request.

5.2 Payments. If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers. For more insight, you may also want to read Shopify’s Terms of Service or Privacy Statement.

5.3 Additional parties. In addition, in order to provide you with our Products and services, we may disclose your Personal Data to the following parties:-

5.3.1 other external service providers such as delivery companies that provide any services on our behalf;

5.3.2 payment service providers such as PayPal and Stripe; when you choose to use their payment service;

5.3.3 credit reference agencies, law enforcement and fraud prevention agencies; to safeguard you against fraud; and

5.3.4 other professional service providers such as website hosts and marketing agencies who help us run our business.


6. USE OF COOKIES

This Clause describes the use of cookies on our websites.

6.1 We use cookies on our websites for the following purposes:-

6.1.1 to enable certain features and functions on our websites (e.g. remembering your user-id, favourite channel selections, browsing and other service preferences);

6.1.2 to build up a profile of how you and other users use the website;

6.1.3 to improve the efficiency of our website;

6.1.4 to administer services to you and to advertisers; and

6.1.5 to establish usage statistics.

6.2 Most internet browsers provide you with the option of turning off the processing of cookies (please see the "help" section of your browser), but this may result in the loss of functionality, restrict your use of our websites and/or delay or affect the way in which our websites operate.

6.3 Advertisements on our websites may be provided by third party advertisers and their agencies. These may generate cookies to track how many people have seen a particular advertisement (or use the services of third parties to view a particular advertisement), and to track how many people have seen it more than once. We do not control these third parties and their cookie policies and if you have questions about their cookie policies, please contact us and we will endeavour to assist you by providing you with information about these third party advertising agencies.

6.4 We are not responsible for the Personal Data policies (including Personal Data protection and cookies), content or security of any third party websites linked to our websites.


7. WITHDRAWAL OF CONSENT, ACCESS AND CORRECTION OF YOUR PERSONAL DATA

7.1 Withdrawal of Consent

If you would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy, please submit your request to our Data Protection Officer at dpo@passkin.com.

We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your Personal Data in the manner stated in your request.

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 the Products and services to you or administer any contractual relationship that is already in place, which in turn may result in the termination of any agreements that you have with us, resulting in you being in breach of your contractual obligations or undertakings. Our legal rights and remedies in such event are expressly reserved.

7.2 Access to and correction of Personal Data

If you wish to make (a) an access request for access to a copy of the Personal Data which we hold about you or information about the ways in which we use or disclose your Personal Data, or (b) a correction request to correct or update any of your Personal Data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request. 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 the Act).


8. ACCURACY OF PERSONAL DATA

We generally rely on Personal Data provided by you (or your authorised representative). In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data by informing our Data Protection Officer in writing or via email at the contact details provided.

9. TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORE

We generally do not transfer your Personal Data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the Act.


10. GOVERNING LAW

This Privacy Policy and your use of this website is governed by Singapore law.