Privacy Policy
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This is the Sunrise Premium Singapore Pte. Ltd. Personal Data Protection Policy (“Personal Data Protection Policy”) and the purpose of this document is to inform you that Sunrise Premium Singapore Pte. Ltd. manages, collects, uses and discloses your Personal Data, which is subject to the Singapore Personal Data Protection Act (2012) (“the Act”). This Privacy Policy outlines Sunrise Premium Singapore Pte. Ltd. ’s policy and responsibility in relation to the collection, use and disclosure of Customer Data.
By continuing to use Sunrise Premium Singapore Pte. Ltd.’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 Sunrise Premium Singapore Pte. Ltd. ’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 Sunrise Premium Singapore Pte. Ltd. ’s website
Part A: General Customer Data Privacy Policy Statement
- Types of Customer Data
The types of Customer Data that Sunrise Premium Singapore Pte. Ltd. collects depend 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 Sunrise Premium Singapore Pte. Ltd. collects:
Personal Data, which includes but is not limited to –
- (i) personal information that links back to an individual e.g., first and last name;
- (ii) contact information e.g. phone number, email address;
- (iii) technical information e.g., IP address; and
Statistical Data e.g., number of visitors, to website. This is stored purely for analytical purposes, and is entirely anonymous. This information will only be aggregated for statistical analysis to improve M&T’s service offering.
For purposes of this policy statement, the phrase Customer Data includes Personal Data and Statistical Data. The provision of Customer Data (save for where the request for data is marked “optional” in the forms used to collect personal data) is obligatory in order for Sunrise Premium Singapore Pte. Ltd. to carry out its services to you. The failure to supply such Customer Data may result in (i) Sunrise Premium Singapore Pte. Ltd. being unable to provide you with the products requested; (ii) Sunrise Premium Singapore Pte. Ltd. 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 Sunrise Premium Singapore Pte. Ltd.
- Purposes for Collection, Use and Disclosure
Generally, Sunrise Premium Singapore Pte. Ltd. collects Customer Data, either directly from you or from third parties (e.g. our service provider), or from publicly available sources, through our website, mobile services, and other channels including our retail outlets, 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 an order online), providing customer service assistance, assisting you in the transaction through Sunrise Premium Singapore Pte. Ltd. ’s website;
- Marketing and communicating with you in relation to products and services offered by Sunrise Premium Singapore Pte. Ltd. , Sunrise Premium Singapore Pte. Ltd. ’s service partners, as well as Sunrise Premium Singapore Pte. Ltd. ’s appointed agents;
- Contacting you for product or customer satisfaction surveys and market research;
- Safety, security and legal compliance.
Sunrise Premium Singapore Pte. Ltd. may also use and disclose your Customer Data with and to third parties in order to fulfil the purposes listed above. Sunrise Premium Singapore Pte. Ltd. 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. Sunrise Premium Singapore Pte. Ltd. may disclose your Customer Data to law enforcement agencies and government for security, customs and immigration purposes to the extent required by the law.
In addition, Sunrise Premium Singapore Pte. Ltd. may disclose Customer Data to its legal advisors for establishing, exercising or defending our legal rights, to its other professional advisors, or as otherwise authorised or required by law. Sunrise Premium Singapore Pte. Ltd. also reserves the right to share Customer Data as is necessary to prevent a threat to the life, health or security of an individual or corporate entity such as Sunrise Premium Singapore Pte. Ltd. Further, Sunrise Premium Singapore Pte. Ltd. may disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.
- Transfer of Information Overseas
The Sunrise Premium Singapore Pte. Ltd. office is based in Singapore. Customer Data may be transmitted to data storage where Sunrise Premium Singapore Pte. Ltd. keeps its central records. Customer Data may be transferred to Sunrise Premium Singapore Pte. Ltd. ’s offices and appointed agents in Singapore or other countries in connection with Sunrise Premium Singapore Pte. Ltd. ’s performance of the contract with you.
- Consent
Generally, in the course of Sunrise Premium Singapore Pte. Ltd. performing transactional functions such as making an order or booking online, signing up for our offers, Customer Data will, by nature of the task or transaction, be provided by our customers to Sunrise Premium Singapore Pte. Ltd. In such instances, consent will necessarily be implied from the Customer that they are agreeable to providing Customer Data in order for Sunrise Premium Singapore Pte. Ltd. to provide the requested or necessary service and/or product to them. However, where required by law, Sunrise Premium Singapore Pte. Ltd. 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 reservations on behalf of another person, you undertake and will ensure that the individual whose Customer Data is supplied to Sunrise Premium Singapore Pte. Ltd. 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 Sunrise Premium Singapore Pte. Ltd. at info@m-and-t-cheese.com. Statistical Data is not linked to a customer record and Sunrise Premium Singapore Pte. Ltd. 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 Sunrise Premium Singapore Pte. Ltd. ’s websites facility, please refer to Part B.
- Access
Sunrise Premium Singapore Pte. Ltd. will, upon your written request to us (see Section 10), allow you to view your stored Personal Data. Where permitted by law, Sunrise Premium Singapore Pte. Ltd. reserves the right to charge a reasonable administrative fee for this service. In exceptional circumstances, Sunrise Premium Singapore Pte. Ltd. reserves the right to deny you access to your Personal Data and may provide an explanation as required by applicable laws. Exceptional circumstances include where:
- An investigating authority or government institution objects to Sunrise Premium Singapore Pte. Ltd. complying with a customer’s request,
- The information may, in the exercise of Sunrise Premium Singapore Pte. Ltd. ’s reasonable discretion and/or assessment, affect the life or security of an individual, and
- Data is collected in connection with an investigation of a breach of contract, suspicion of fraudulent activities or contravention of law.
To submit a written request please email us at info@m-and-t-cheese.com.
- Retention
Sunrise Premium Singapore Pte. Ltd. will retain Customer Data for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes of Sunrise Premium Singapore Pte. Ltd., 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.
- Accuracy
Sunrise Premium Singapore Pte. Ltd. needs your assistance to ensure that your Personal Data is current, complete and accurate. As such, please inform Sunrise Premium Singapore Pte. Ltd. of changes to your Personal Data by contacting Sunrise Premium Singapore Pte. Ltd. and submitting your updated particulars to Sunrise Premium Singapore Pte. Ltd. in writing (see Section 10).
Sunrise Premium Singapore Pte. Ltd. may also request Personal Data updates from you from time to time.
- Security Safeguards
Sunrise Premium Singapore Pte. Ltd. takes the security and protection of your Customer Data very seriously. As such, Sunrise Premium Singapore Pte. Ltd. makes reasonable security arrangements to protect your Customer Data against loss or theft as well as unauthorised access and undue disclosure. Examples of technical safeguards include encryption, Network and Web Application Firewalls, “firewalls” and Secure Socket Layer (SSL). Further details of these technical safeguards for Customer Data collected through Sunrise Premium Singapore Pte. Ltd. ’s website facility are set out at Part B below. If you have any concerns about security, you should contact Sunrise Premium Singapore Pte. Ltd. (see Section 10).
- Updates to the Privacy Policy
Sunrise Premium Singapore Pte. Ltd. will amend this Privacy Policy from time to time and the updated versions will be posted on M&T ’s website and date stamped so that you are aware of when the Privacy Policy was last updated.
- Contact Us
If you have comments, questions or complaints about or requests relating to this Privacy Policy statement, please contact Sunrise Premium Singapore Pte. Ltd. in writing at the address below referencing “Privacy Policy”:
DATA PROTECTION OFFICER (DPO):
Thi Thuy Trang Phan, LL.M.
Luther LLP
4 Battery Road, Bank of China Building #25-01, Singapore 049908
Tel: +65 6408 8021
Email: Trang.Phan@luther-lawfirm.com
If you have comments, questions or complaints about or requests relating to this Privacy Policy statement, please contact Sunrise Premium Singapore Pte. Ltd. at info@m-and-t-cheese.com.
Part B: Privacy Policy Statement for Customer Data collected through Sunrise Premium Singapore Pte. Ltd. ‘s website
- Security Safeguards
Sunrise Premium Singapore Pte. Ltd. takes the protection of your Customer Data collected on Sunrise Premium Singapore Pte. Ltd. ’s website very seriously. SSL (Secure Socket Layer) protects the transmission of data from the internet to our systems. To further strengthen the integrity of your internet transactions on our website, Sunrise Premium Singapore Pte. Ltd. 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.
- Cookies
Most websites like our use cookies to enhance your online experience. Cookies are alphanumeric identifiers that are transferred to your computer’s hard drive from your web browser to recognise your preferences and to tailor content to you. The cookies do not contain your Customer Data but only Statistical Data which is entirely anonymous. Please refer to your browsers documentation to check if cookies have been enabled on your computer or to request not to receive cookies. Information and procedures regarding cookie handling are provided by the respective browsers documentation within the browser itself by clicking on ‘help’ and performing a search on ‘cookies’.
- Clickstream Data
In order to improve your online experience, Sunrise Premium Singapore Pte. Ltd. may track online behaviour or clickstream data to advance your use of our web pages and track referrals from other websites. Such data will only be aggregated for statistical analysis.
- Links to Other Websites
Sunrise Premium Singapore Pte. Ltd. provides you with links to other websites for your convenience and information. You access these websites at your own risk and Sunrise Premium Singapore Pte. Ltd. is not responsible for these websites. Whilst Sunrise Premium Singapore Pte. Ltd. will protect your Customer Data on Sunrise Premium Singapore Pte. Ltd. website, Sunrise Premium Singapore Pte. Ltd. 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 Sunrise Premium Singapore Pte. Ltd. Privacy Policy does not cover these other websites, and Sunrise Premium Singapore Pte. Ltd. would recommend that you are apprised of their specific policies.
- Minors
Sunrise Premium Singapore Pte. Ltd. cannot distinguish the age of persons who access and use its website. If a minor (according to applicable laws) has provided Sunrise Premium Singapore Pte. Ltd. with Customer Data without parental or guardian consent, the parent or guardian should contact Sunrise Premium Singapore Pte. Ltd. (see Section 10 of Part A) to remove the relevant Customer Data and unsubscribe the minor.
- Google Analytics
Google Analytics is a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of www.m-and-t-cheese.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 Google’s Privacy Policy.