Privacy Policy
1. About Us
1. This is the Privacy Policy ("Policy" or Privacy Policy”) of SGHINDI PTE.
LTD. ("SGHINDI") and its subsidiaries.
2. You have been directed to this Policy because a company within the
SGHINDI Group is collecting, using or disclosing your personal data.
3. In this Policy, when we use "we", "us" or "our", we refer to the company
(SGHINDI PTE. LTD.) which is collecting your personal data, or which is
operating the website which you are accessing or using.
4. We own and/or operate website(s) such
as and/or any mobile apps that may be
published by us (the said website and mobile apps may be collectively or
individually referred to as the “Website”).
5. SGHINDI is a limited company registered in Singapore (Co. Reg.
202039010D) at 10 JALAN BESAR, #11-02, SIM LIM TOWER,
Singapore 208787.
2. The purpose of this Policy
1. The purpose of this Privacy Policy is to inform you and provide you with
an understanding of how we, our affiliates, related corporations and
associated companies globally, handle, collect, use, disclose and deal
with personal data about you that you give us, that we receive through
third parties or that is in our possession. Please read this Privacy Policy
2. We are committed to safeguarding the privacy and security of your
personal data. We take our responsibilities under Singapore’s Personal
Data Protection Act (the “PDPA”) seriously. We also recognise the
importance of the personal data you have entrusted to us and believe that
it is our responsibility to properly manage, protect and process your
personal data.
3. The contents of this Privacy Policy may change over time so please check
back frequently. Any changes to this Privacy Policy will be posted on and
can be viewed at our Website.
4. This Policy applies to all personal data that you may provide to us and the
personal data we hold about you. By providing us with your personal data
or by accessing, using or viewing the applicable Website or any of its
services, functions or contents (including transmitting, caching or storing
of any such personal data), you shall be deemed to have agreed to each
and all the terms, conditions, and notices in this Policy. If you do not
agree, please cease use of the relevant Website(s) and/or service(s)
and DO NOT provide any personal data to us.
5. The Website is not intended for use by children (below the age of 18)
without parental supervision. We do not and do not intend to, transact
through the Website directly with anyone we know to be under the age of
18, if they do not have parental permission or supervision.
6. By providing any personal data to us, you declare and affirm that you are
at least 18 years of age (or under the supervision and guidance of
parents) and above and agree to the terms set out in this Privacy Policy.
3. Personal data which is collected
1. “Personal data” is defined under the PDPA to mean data, whether true
or not, about an individual who can be identified from that data, or from
that data and other information to which an organisation has or is likely to
have access.
2. When you use our Website, any service we provide or in your interaction
with us, the personal data we may collect include but is not limited to :-
(a) Data collected directly from you. This may be done through our
Website, over the phone, by email, or in person when you meet our staff
or representatives. The personal data collected may include, but is not
limited to:
your contact information, including your (first and last) name, (billing
and/or delivery) address, birthdate and email address and/or your
telephone number. We need your e-mail address and/or telephone
number so that we may contact you if we have questions or
information for you regarding your order or the service that we are
providing or will provide to you;
other information required to be able to process your order or to
provide you with the service, such as information concerning the
products you have ordered or the service we are providing to you,
the billing and/or delivery address, banking and/or credit/debit card
if you have created an online profile or account, the preferences and
interests stored in such profile or account (please see below for
further information concerning the profiles); and/or
if you have contacted customer service, the details of this contact
and the contact history.
(b) Data collected by automated means. Various technologies may be
used on our Website and our mobile and web-based applications in order
to make them more user-friendly, effective and secure. Such technologies
may lead to data being collected automatically by us or by third parties
on behalf of us. This data does not always, but may, contain a user's
personal data or comprise of personal data. Examples of such
technologies include:
Click-stream data. A visit to one of our Websites results in data that
is transmitted from your browser to our server being automatically
collected and stored by us or by third parties on behalf of us. This
data can include, in particular, the following:
the visitor's IP address
the date and time of the visit
the referral URL (the site from which the visitor has come)
the pages visited on our website
information about the browser used (browser type and
version, operating system, etc).
Cookies. A number of places on our Website and our mobile and
web-based applications make use of cookies. These are essentially
small text files that are stored on your computer's hard drive or your
user device by your web browser. We can use cookies to identify the
owner of a user account and to store articles in a shopping basket
during the purchasing process. In other words, cookies help to make
our website or our (mobile and web-based) applications more user-
friendly, more effective and more secure. The cookies usually used
by us are so-called "session cookies", which are automatically
deleted at the end of the visit to the relevant website. By default, web
browsers enable the use of cookies but this function can also be
disabled. However, this will result in some services not being
available. It is also possible to manually delete cookies after their
use via the web browser. More information may be available from
your web browser provider.
Flash cookies. A particular form of cookie is the flash cookie. In
contrast to normal cookies, these cookies are not created and saved
by the web browser but are governed by the Adobe Flash plug-in.
These can contain more information than normal cookies and cannot
be deleted or disabled via the browser; this is only possible if you
follow instructions available from the Adobe Flash Player website.
You can also obtain more information about these cookies on that
Web beacons and tracking links. Web beacons (also known as
pixel tags and clear GIFs) involve graphics that are not apparent to
the user. Tracking links and/or similar technologies consist of a few
lines of programming code and can be embedded in our website or
our (mobile) applications. In conjunction with cookies, these are
primarily used for statistical analysis purposes. This technology can
also be used for tracking traffic patterns on websites, as well as
finding out if an e-mail has been received and opened and to see if
there has been any response.
Web analytics. Web analytics is the term given to a method for
collecting and assessing the behaviour of visitors to websites and
(mobile) applications. This includes the analysis of traffic patterns in
order, for example, to determine the frequency of visits to certain
parts of a website or (mobile) application, or to find out what
information and services our visitors are most interested in. For
these purposes, we primarily make use of click-stream data and the
other techniques listed above. Web analytics are carried out by
Google Analytics and/or other selected parties. You can find out
more information about the processing of web analytics data by
Google Analytics in paragraph 9 below.
3. Hence, depending on the circumstances or the nature of the transaction
with you, the personal data we may collect from you includes :
home address
identification number (such as national ID, passport details
etc.)(collection of this will be in compliance with the PDPA and
depends on the circumstances or transaction at hand)
image and/or photograph
credit/debit card information
location Information of yourself and/or your computer or device
contact Information
transactional information
usage and preferences
bank account number
your purchase and/or your transactions with us
your signature (such as when you sign off on a parcel delivery)
We will collect your personal data in accordance with the PDPA.
4. We may receive information about you from third parties such as if you
use any websites or social media platforms operated by third parties (for
example, Facebook, Instagram, Twitter etc.) and, if such functionality is
available, you have chosen to link your profile on our Website with your
profile on those other websites or social media platforms.
4. The purposes for which we collect, use or disclose your personal data
1. SGHINDI, will/may collect, use, disclose and/or process your personal
data for one or more of the following purposes :
(a) processing and/or dealing with your interest in our products and/or
(b) considering, processing, dealing with and/or managing, your
booking, reservation, request/application for, of or your purchase of,
our products and/or services (the “Transaction”);
(c) facilitating, processing, dealing with, administering and/or
managing Transaction(s) by or with you;
(d) administering, facilitating, managing, processing and/or dealing
with your relationship with us, your transaction(s) with us, your being
our loyalty card member or rewards member, any transactions or
activities carried out by you on the Website or at our
premises/establishments or with us, your requests, including but not
limited to dealing with your adhoc queries, requests or bookings,
dealing with your preferences, dealing with your membership needs,
dealing with your delivery needs, processing orders and payment
transactions, implementing transactions and the supply of products
and/or services to you that you have requested. Without limiting the
generality of the foregoing, should you make a reservation or
transaction that includes third party individual(s) or on behalf of third
party individual(s) or for third party individual(s), you consent to us
disclosing personal data that identifies you, to the said third party
individual(s) (such as but not limited to your name);
(e) administering, facilitating, processing and/or dealing in any
matters relating to your use or access of the Website, including
identifying you for login to the Website, our portals and other online
services provided by or on behalf of us. Without limiting the generality
of the foregoing, if you:
(i) gain access to or sign in to the Website, using your login
credentials of a Social Networking Site, or
(ii) use any features of a Social Networking Site such as its
widgets, plug-ins and browser push notifications, made available
to you on our Website, it may result in information or your personal
data being collected or shared between us and the third party. For
example, if you use Facebook’s “Like” feature, Facebook may
register the fact that you “liked” a product and may post that
information on Facebook. (“Social Networking Site” refers to an
online or digital platform owned or operated by a third party, that
is used by people to build social networks or social relations, or to
interact, with other people, such as but not limited to Facebook,
Instagram, Twitter). By your proceeding pursuant to (i) or (ii)
above, you consent to such collection, use or disclosure of your
personal data;
(f) monitoring, processing and/or tracking your use of the Website in
order to provide you with a seamless experience, facilitating or
administering your use of the Website, and/or to assist us in improving
your experience in using the Website;
(g) administering, facilitating, processing and/or dealing in any
transactions, payments, debt collection, or activities carried out by
you on the Website or at our premises or with us;
(h) providing services to you as our customer, as a member of our
loyalty programme(s)/ card programme(s)/ rewards programme(s) or
when requested by you; dealing with or administering your
participation in contests, gamification, social events organised by us;
(i) registering you as a customer of any of our products or services,
and/or to deal with, process and/or administer the account that you
may open with us, whether a membership account or otherwise,
including to facilitate your transactions or activities at our premises,
the Website, or your transactions or activities with us;
(j) carrying out your instructions or responding to any enquiry or
complaint given by (or purported to be given by) you or on your behalf
including responding to your enquiries and complaints; or responding
to or dealing with your interactions with us or your requests; or
responding to or dealing with your feedback, comments or reviews. If
you have contacted us with any complaints, feedback, comments,
suggestions, we will use and disclose your personal data (including
your contact history) to respond to you and provide you with the best
service possible. If you are the complainant and you do not want us
to disclose your identity to the party you are complaining about, you
must let us know immediately. However, it may not always be possible
to handle your complaint on the basis of anonymity;
(k) contacting you or communicating with you via phone/voice call,
text message and/or fax message, email and/or postal mail for one or
more of the Purposes stated herein. You acknowledge and agree that
such communication by us could be by way of the mailing of
correspondence, documents or notices to you, which could involve
disclosure of certain personal data about you to bring about delivery
of the same as well as on the external cover of envelopes/mail
(l) sharing or disclosing (at our discretion) your suggestions,
comments, feedback or content (including audio, video etc.)
(collectively Feedback”) that you provide through Social Networking
Sites, to the Website or to us (including at our premises), with other
users of the Website or with the public, for publicity and/or promotion
purposes with a view to marketing or showcasing the business,
products or services of SGHINDI, and/or to acquiring customers,
and/or for the purpose of providing the public with your Feedback
which may be useful for the public’s patronage decision or for the
public’s information or otherwise. This includes us disclosing your
name together with your Feedback. Without limiting the generality of
the foregoing, in the above regard, your Feedback and name may/will
be published or shared by us on public media platforms such as the
newspaper, the Internet, in our (including our affiliates’) annual
reports (if any) etc., and/or incorporated as part of SGHINDI’s
marketing collaterals/materials or corporate video to be disclosed to
the public, and you hereby consent to the same. Do not provide us
with Feedback if you do not wish for such Feedback to be disclosed
to the public. If you wish to give us your Feedback without it being
disclosed to the public, please separately contact our Customer
Department at and head the subject of your
feedback content with the word “Confidential”;
(m) understanding and/or managing your interests, concerns and
(n) carrying out due diligence, statutorily required activities or other
screening activities (including background checks, anti-money
laundering checks, know your client checks) in accordance with legal
or regulatory obligations applicable to us (whether Singapore or other
countries), the requirements or guidelines of governmental authorities
which we determine are applicable to us (whether Singapore or other
countries) or any SGHINDI Group company, and/or our risk
management procedures that may be required by law (whether
Singapore or other countries) or that may have been put in place by
us or our affiliates/associated companies;
(o) to prevent or investigate any fraud, unlawful activity or omission or
misconduct, whether or not there is any suspicion of the
aforementioned; dealing with conflict of interests; or dealing with
and/or investigating complaints;
(p) complying with or as required by any applicable law, governmental
or regulatory requirements of any jurisdiction applicable to us or our
affiliates/associated companies, including meeting the requirements
to make disclosure under the requirements of any law binding on us
or our affiliates/associated companies, and/or for the purposes of any
guidelines issued by regulatory or other authorities (whether of
Singapore or other countries), with which we or our
affiliates/associated companies are expected to comply;
(q) complying with or as required by any request or direction of any
governmental authority (whether Singapore or other countries) which
we are expected to comply with; or responding to requests for
information from public agencies, ministries, statutory boards or other
similar authorities. For the avoidance of doubt, this means that we
may/will disclose your personal data to the aforementioned parties
upon their request or direction;
(r) conducting research, (including customer research), surveys,
market surveys, analysis and development activities (including but not
limited to data analytics, and/or profiling), obtaining your feedback to
our products, services or facilities, to :
(i) improve or develop our products, services and/or facilities in
order to enhance any continued interaction between yourself and
us connected or in relation to your relationship with us, the
Website, or your Transaction(s);
(ii) improve any of our products or services or facilities, whether
now or in the future; or
(iii) improve our understanding of your interests, concerns and
Without limiting the generality of the foregoing, we may/will in this
regard send you surveys or request a face to face interview survey or
request your feedback, by way of email or postal mail.
In order for us to market products and services which are of special
interest and relevance to you, we may analyse and rely on your
overall interaction with us (such as but not limited to your shopping
behaviour in e-shops, your use of loyalty programmes, your ratings
and reviews of products, your contact history with our customer
service, your newsletter clicks/ opening results, your surfing
behaviour (web tracking), the newsletter types you are subscribed to,
your participation in promotions or events, your interactions with us
and your use of (mobile) applications);
(s) the conduct of training or training purpose, so as to develop or
improve our products or services and/or our staff’s and agents’
services and/or service quality. Without limiting the generality of the
foregoing, such training may involve collection, use, disclosure or
processing of your personal data including your feedback or
comments or reviews;
(t) to facilitate and/or ensure the safety and security of our premises,
our customers, our staff and/or visitors to our premises; to deal with,
handle and/or conduct disciplinary, security, crime prevention and/or
quality assurance processes, matters and/or arrangements. Without
prejudice to the generality of the aforesaid, we wish to bring to your
attention that there are surveillance cameras installed throughout our
premises and/or our offices, for security, crime prevention, safety and
training reasons and you acknowledge that your personal data will be
collected by such cameras and processed by us consequently;
(u) for marketing purpose and in this regard, SGHINDI would be
providing you with marketing, advertising and promotional
information, materials and/or documents relating to products,
contests, services and/or events (including products, services and/or
events of third party organisations with which SGHINDI may
collaborate with) that we or such third party organisations may be
selling, marketing, offering, organising, involved in or promoting,
whether such products, services and/or events exist now or are
created in the future, :
(i) by way of postal mail, electronic transmission to your email
address(es), push notifications, other forms of in-app notifications
or harnessing other technologies (such as geo-location
technology) for our mobile application(s) on your mobile device(s)
or other technologies on your computers, and/or through other
modes of communication that is not the 3 DNC Modes in
compliance with the PDPA. You may opt out of this or withdraw
from this at any time by sending a request to us. For the avoidance
of doubt, unlike (ii) below, the application of or your acceptance of
or your consent to, this Privacy Policy, constitutes your consent to
this subparagraph (i);
(ii) if you have separately expressly consented to one or more of
the following 3 DNC Modes, by way of the 3 modes of
communications of voice calls, text messages or faxes (the 3 DNC
Modes”) to your Singapore telephone number, in compliance with
the requirements of the PDPA; and/or
(iii) Notwithstanding (ii) above, regardless that you have not
separately provided express consent as aforementioned in (ii)
above, SGHINDI, as the case may be, reserves its right to send a
specified fax message (as defined in Singapore’s Personal Data
Protection (Exemption from Section 43) Order 2013) (the
Exemption Order”) and/or a specified text message (as defined
in the Exemption Order) (i.e. a marketing fax message or
marketing text message) to your Singapore telephone number, if:
(1) there is an ongoing relationship between SGHINDI, and you,
and the purpose of the message is related to the subject of the
ongoing relationship, pursuant to the requirements and
conditions of the Exemption Order; or
(2) the law permits
For the avoidance of doubt, this subparagraph is without prejudice to
subparagraph (r) above for which you have hereby consented to us
contacting you for a survey, which you may subsequently opt out of
by sending our Data Protection Officer notice;
(v) storing, hosting, backing up (whether for disaster recovery or
otherwise) of your personal data, whether within or outside
(w) maintaining and/or developing our IT or business systems and
infrastructure including testing and upgrading of these systems;
(x) creating reports with respect to your Transaction(s) and/or
transactions that we have with our customers;
(y) facilitating, dealing with and/or administering external audit(s) or
internal audit(s) of the business of SGHINDI Transaction(s), and/or
our transactions with our customers;
(z) anonymisation of your personal data. In this regard, you
acknowledge that personal data that has been anonymised is no
longer personal data and the requirements of the PDPA would no
longer apply to such anonymised data;
(aa) dealing with and/or facilitating a business asset transaction or a
potential business asset transaction, where such transaction involves
SGHINDI as a participant or involves only a related corporation or
affiliated company of SGHINDI as a participant or involves SGHINDI
and/or any one or more of SGHINDI’s related corporations or affiliated
companies as participant(s), and there may be other third-party
organisations who are participants in such transaction. business
asset transaction” means the purchase, sale, lease, merger or
amalgamation or any other acquisition, disposal or financing of an
organisation or a portion of an organisation or of any of the business
or assets of an organisation;
(bb) record-keeping purposes and producing statistics and research
for internal and/or statutory reporting and/or record-keeping
requirements, of SGHINDI or of its affiliates/related corporations;
(cc) SGHINDI’s reporting purposes including but not limited to
reporting on SGHINDI’s business performance; and
(dd) to deal with the or as part of a bankruptcy, winding up,
reorganisation, restructuring, insolvency, receivership or an
assignment for the benefit of creditors, of SGHINDI.
(the purposes set out in this paragraph 4.1 above shall be collectively
referred to as the “Purposes”)
2. You may withdraw your consent for us to process your personal data
for marketing purpose mentioned at paragraph 4.1(u) above at any
time via one the following relevant methods:
clicking the Unsubscribe button located at the bottom of our
contacting us or our Data Protection Officer through the contact
details listed at paragraph 13.1
3. We may/will need to disclose your personal data to third parties,
whether located within or outside Singapore, for one or more of the
above Purposes, as such third parties, would be processing your
personal data for one or more of the above Purposes. In this regard,
you hereby acknowledge, agree and consent that we may/are
permitted to disclose your personal data to such third parties (whether
located within or outside Singapore) for one or more of the above
Purposes and for the said third parties to subsequently collect, use,
disclose and/or process your personal data for one or more of the
above Purposes. Without limiting the generality of the foregoing or of
paragraph 4.1, such third parties include:
(a) our associated or affiliated organisations or related corporations,
or any member of the SGHINDI Group;
(b) any of our agents, contractors or third party service providers that
process or will be processing your personal data on our behalf
including but not limited to those which provide administrative or other
services to us such as mailing houses, telecommunication
companies, information technology companies, data centres, hosting
and maintenance service providers, analysis services service
providers, e-mail messaging services service providers, delivery
service provider, handling of payment transactions service providers,
marketing service providers, delivery services, handling of payment
transactions and debt collection, solvency check and address check;
(c) our professional advisers, for example, our auditors and lawyers,
as well as our insurers;
(d) third parties to whom disclosure by us is for one or more of the
Purposes and such third parties would in turn be collecting and
processing your personal data for one or more of the Purposes.
Without limiting the generality of the foregoing, such third parties to
which we may/will disclose your personal data include payment, debt
collection, finance companies or banks including credit card
companies; and
(e) any actual or proposed assignee or transferee of the business of
SGHINDI, or a merged entity in the event SGHINDI is merged to
create the said merged entity.
4. We may share your information with any member of the SGHINDI Group,
which may be based in countries other than Singapore, from time to time
for one or more of the Purposes.
5. Should you provide us with personal data of your child or children, you
confirm, declare and agree that you are the parent and/or legal guardian
of such child/children, and that we may collect, use and/or disclose your
child’s or children’s personal data for the Purposes set out at paragraph
4.1 above and in the manner as set out at paragraphs 4.1 to 4.4 above.
6. You may withdraw your consent for the collection, use and/or disclosure
of your personal data in our possession or under our control by contacting
us at 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, unless an exception under the
law or a provision in the law permits us to. However, your withdrawal of
consent could result in certain legal consequences arising from such
withdrawal, including us being unable to perform the transactions
requested by you or the termination of your relationship with us
(depending on the extent of your withdrawal), as the case may be.
7. We may collect, use, disclose or process your personal data for other
purposes that do not appear above. However, we will notify you of such
other purposes at or before the time of obtaining your consent, unless
processing of your personal data without your consent is permitted by the
PDPA or by law.
8. To the extent permitted by law, we may/will also be collecting from
sources other than yourself, personal data about you, for one or more of
the above Purposes, and thereafter using, disclosing and/or processing
such personal data for one or more of the above Purposes. We may
combine information we receive from other sources with information you
give to us and information we collect about you. We may use this
information and the combined information for the Purposes set out above
(depending on the types of information we receive).
9. Our Website may have the functionalities to allow you to share your
personal data with other third parties such as other users of our website.
You are responsible for your choice(s) and are deemed to have provided
consent for any sharing of your personal data in the manner provided by
the Website.
10. We take reasonable steps to ensure that any personal data we collect,
disclose and use is accurate and complete, if your personal data is likely
to be used by us to make a decision that affects you, or disclosed to
another organisation. However, it is important that you advise us of any
changes to your personal data or if there are any errors in the personal
data we hold about you. We will not be responsible for relying on
inaccurate or incomplete personal data arising from you not updating us
of any changes in your personal data that you had initially provided us
5. Provision of third-party personal data by you
1. Should you provide us with personal data of any individual other than
yourself, you represent, undertake and warrant to us that :
(a) for any personal data of individuals that you disclose to us, you
would have prior to disclosing such personal data to us obtained
consent from the individuals whose personal data are being
disclosed, to :
(i) permit you to disclose the individuals’ personal data to
(ii) permit SGHINDI to collect, use, disclose and/or process the
individuals’ personal data for the Purposes;
(b) at our request, you will use such form(s) or document(s) provided
by us in obtaining such consents from the individuals in question (for
the avoidance of doubt, we are under no obligation to you to create
any such form(s) or document(s));
(c) any personal data of individuals that you disclose to us are
accurate; and
(d) for any personal data of individuals that you disclose to us, that
you are validly acting on behalf of such individuals and that you have
the authority of such individuals to provide their personal data to
SGHINDI and for SGHINDI to collect, use, disclose and process such
personal data for the Purposes.
6. Third Party websites
1. This Policy only applies to our Website and information that we collect
from you. Our Websites may contain links to other websites which are not
owned or maintained by us. When visiting these third-party websites or
disclosing your personal data to third parties (including buyers or sellers
on our website), you should read their privacy policies, or ask relevant
questions before you disclose your personal data. We are not responsible
for the collection, use or disclosure of your personal data by such third
7. Social Networks
1. Our Website and mobile or web-based applications may provide you with
social plug-ins from various social networks (such as Facebook and
Twitter). If you choose to interact with a social network, your activity on
our Website or via our mobile or web-based applications will also be
made available to social networks such as Facebook and Twitter.
2. If you are logged in on one of the social networks during the visit of one
of our Websites or mobile or web-based applications, the social network
might add this information to your profile. If you are interacting with one
of the social plug-ins, this information will be transferred to the social
network. In case you do not wish such a data transfer, please log off on
your social network before you enter one of our Websites or mobile or
web-based applications.
3. We cannot influence this data collection and data transfer via the social
plug-ins. Please read the privacy policies of those social networks for
detailed information about the collection and transfer of personal data,
what rights you have and how you can achieve satisfactory privacy
8. Geo-location Services
1. Our Website and mobile or web-based applications may offer location-
enabled services, such as Google Maps and Bing Maps. If you use those
mobile or web-based applications, they may receive information about
your actual location (such as GPS signals sent by a mobile device) or
information that can be used to approximate a location. You will/may be
asked if the geo-location service can be activated and you can also object
to this geo-location service within the respective mobile or web-based
9. Web analytics by Google Analytics
1. Our Website and mobile or web-based applications may contain web
analytic services provided by Google Analytics. This means that when
you visit our Website or use any mobile or web-based applications, a
cookie will be stored on your computer or mobile device, except when
your browser settings do not allow for such cookies.
2. This further means that when you visit our Website or use any mobile or
web-based applications, the personal data described above in paragraph
3.1 - including the "click-stream data", the data from "web beacons and
tracking links" and information stored in Google Analytics' cookies will be
sent to Google Analytics for analysis for and on behalf of us. Please note
that if you have created an online profile at our Website or mobile or web-
based application and if you are logged on in this profile, a unique number
identifying this profile will also be sent to Google Analytics in order to be
able to match the web analytics data to this profile.
3. Google Analytics acts as our agent, which means that we solely
determine the purposes for which the data is being used. You can find
out more about the relationships between Google Analytics and us in the
Google Analytics' privacy policy.
4. If you do not wish information about your behaviour at our Website or any
mobile or web-based applications being collected and assessed by
Google Analytics, you can install the Google Analytics opt-out browser
add-on. This add-on instructs the Google Analytics JavaScript (ga.js,
analytics.js, and dc.js) to not send your site visit information to Google
Analytics. The browser add-on is available for most modern browsers.
The Google Analytics opt-out browser add-on does not prevent
information from being sent to the website itself or in other ways to web
analytics services.
10. Retargeting Technologies
1. Our Website and mobile or web-based applications may use retargeting
technologies within the internet. This enables us to show our visitors, who
were already interested in our shop and our products, advertisement from
us on partner websites.
2. We also work with other companies who use tracking technologies to
serve advertisements on our behalf across the Internet. These companies
may collect non-personally identifiable information about your visits to our
websites or mobile or web-based applications and your interaction with
our communications, including advertising.
3. Retargeting technologies analyse your cookies and display advertisement
based on your past surfing behaviour. For further information on cookies,
please refer to paragraph 3 of this Policy.
4. We do not store any personal data about you with this technology.
11. Security & how do we store data?
1. Security of your personal data is important to us. We will put in place
reasonable security arrangements to ensure that your personal data is
adequately protected and secured. Appropriate security arrangements
will be taken to prevent any unauthorised access, collection, use,
disclosure, copying, modification, leakage, loss, damage and/or alteration
of your personal data. However, we cannot assume responsibility for any
unauthorised use of your personal data by third parties which are wholly
attributable to factors beyond our control.
2. We will put in place measures such that your personal data in our
possession or under our control is destroyed and/or anonymised as soon
as it is reasonable to assume that (i) the purpose for which that personal
data was collected is no longer being served by the retention of such
personal data; and (ii) retention is no longer necessary for any other legal
or business purposes.
12. Your Rights
1. If you have any questions about the processing of your personal data or
about our Policy, if you do not accept the amended Policy, if you wish to
withdraw any consent you have given us at any time, or if you wish to
update or have access to your personal data, you are welcome to contact
us through the contact details listed at paragraph 13.1.
2. You have the right to access and/or correct any personal data that we
hold about you, subject to exceptions under the law. This right can be
exercised at any time by contacting us through the contact URL at
paragraph 12.1. We will need enough information from you in order to
ascertain your identity as well as the nature of your request, so as to be
able to deal with your request. All requests for correction or for access to
your personal data must be in writing. We will endeavour to respond to
your request within 30 days, and if that is not possible, we will inform you
of the time by which we will respond to you.
3. We may be prevented by law from complying with any request that you
may make. We may also decline any request that you may make if the
law permits us to do so.
4. In many circumstances, we need to use your personal data in order for us
to provide you with products or services which you require or have
requested. If you do not provide us with the required personal data, or if
you do not accept an amended Policy or withdraw your consent to our
use and/or disclosure of your personal data for these purposes, it may
not be possible for us to continue to serve you or provide you with the
products and services that you require or have requested.
5. We may charge you a fee for responding to your request for access to the
personal data which we hold about you, or for information about the ways
in which we have (or may have) used your personal data. If a fee is to be
charged, we will inform you of the amount beforehand and respond to
your request after payment is received.
13. Complaints
1. You may send complaints regarding our handling of personal data in the
following ways:
(a) in writing.
Such complaints must:
be addressed to the SGHINDI PTE. LTD. at:
(ii) Address: 10 JALAN BESAR, #11-02, SIM LIM TOWER,
Singapore 208787
provide the name, contact number and address of the person
submitting the feedback
provide the relevant details required such as the relevant time
period, our employees or who involved, or copies of relevant
(b) by telephone.
Such complaints must:
be made to SGHINDI PTE. LTD at:
Telephone: +65 8801 8900 (This is a recorded line. The caller is
advised that their call will be recorded.)
2. All complaints will be evaluated by SGHINDI in a timely manner. After
SGHINDI has completed its evaluation, the SGHINDI Group Data
Protection Officer (or a duly appointed representative) will respond to the
person who submitted the complaint or feedback, with the results of the
14. Governing Law
1. This Policy is prepared pursuant to the PDPA and governed by the laws
of Singapore.
15. General
1. Your consent that is given pursuant to this Privacy Policy is additional to
and does not supersede any other consent that you had provided to
SGHINDI (and/or any member of the SGHINDI Group) with regard to
processing of your personal data.
2. For the avoidance of doubt, in the event that Singapore personal data
protection law permits an organisation such as us to collect, use or
disclose your personal data without your consent, such permission
granted by the law shall continue to apply.
Effective 16 January 2021