Privacy Policy

Effective Date: 24 February 2021

Last Updated: 24 February 2021

SCOPE

This Privacy Policy (“Policy”) sets out the basis which Livinguard, Inc. (“Livinguard”, “we”, “our”, or “us”) may collect, use, disclose or otherwise process personal data (defined below) of our customers on our websites and other online platforms where this Policy is located (collectively, our “Platform”) in accordance with the Personal Data Protection Act 2012 (Singapore statutes) as may be amended from time to time (“PDPA”). This Policy applies to personal data in our possession or under our control.

As used in this Policy:

customer” or “you” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us (collectively, our “Services”); and

personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

By visiting or using our Platform or Services, you hereby acknowledge and agree that you accept and consent to the practices, rights, obligations, and/or policies outlined in this Policy, and that you consent to us collecting, using, disclosing and/or processing your personal data as stated herein. If you do not consent to us processing your personal data as described in this Policy, please leave the Platform immediately and refrain from using our Services. 

TYPES OF INFORMATION WE COLLECT

We collect information from you and about you. Below are some examples of the information we may collect:

  • Contact Information. For example, we may collect your name, home address, telephone number and email address.
  • Billing Information. For example, this may include your billing address and information about your method of payment.
  • Information You Submit. We may collect information when you send us a message through our Platform. We may also collect other information you submit through an online comment, when you contact our sales or support teams or participate in a promotion.
  • Demographic Information. We may collect demographic information such as your birthdate, age, and zip code.
  • Employment Information. We may collect information about your employer and your professional position. We may also collect your business contact information.
  • Social Media Information. We may collect the information you post on our social media pages.
  • Device Information. For example, we may collect the type of device you use to access our Platform. We may also collect your device identifier, IP address or mobile operating system.
  • Account Information. Certain portions of the Platform allow you to create a user account. In connection with that account, we may collect your user name and password.
  • Commercial Information. We may collect personal data that could identify you and relates to the products or services in which you are interested, or have considered or purchased. We may also collect personal data about your purchasing habits, or consuming history or tendencies.
  • Usage Information. We may collect information regarding how you use the Platform. For example, we may collect information regarding what Platform features are useful or most frequently used.
  • Technical Information. If you use our website, we may collect information about the browser you are using. We may look at what site you came from, or what site you visit when you leave us.

HOW WE COLLECT YOUR INFORMATION

We collect your personal data in different ways. Below are some examples of how we may collect your personal data.

  • Directly From You. For example, when you:
    • Register for an account.
    • Purchase our products and services.
    • Request to receive our marketing communications.
    • Submit an inquiry to us.
    • Complete an online form.
    • Contact our support team.
    • Interact with our social media pages.
    • Otherwise interact with us.
  • Passively. For example, when you visit and navigate our Platform on any device or click on a sponsored link or third-party advertisement. We may also collect information about users over time and across different websites and devices when you use the Platform.
  • From Third-Parties. We may receive information about you from other sources. For example, this may include receiving information from:
    • Our parent, subsidiary, and affiliate entities.
    • Our business partners, including online advertising networks and analytics vendors or companies that co-sponsor one of our promotions.
    • Social media sites, including Facebook, Twitter, YouTube, Pinterest, Snapchat and Instagram.
    • Your contacts who provide your information to us because they think you may be interested in our products and services or they want to share a product or service with you.
    • Companies that provide information to supplement what we already know about you, including data aggregators. Certain third-parties might link your name or email address to other information they have collected. That might include online usage information.
  • By Combining Information. For example, we may:
    • Combine information that we collect offline with information we collect through our Platform.
    • Combine information we collect about you from the different devices you use to access our Platform.
    • Combine information we get from third-parties with information we already have about you.

HOW WE USE YOUR INFORMATION

We process your personal data for the following purposes:

  • To Provide Our Products and Services. This includes fulfilling your requests for our products and Services.
  • To Customize Your Experience With Us. This may include displaying products that may be of interest to you.
  • To Run and Improve Our Platform and Business. We may use your information to make our Platform and business better. We may also use your information to provide you with information about our business.
  • To Provide Customer Support. This includes responding to customer service and support requests.
  • To Respond to Your Requests or Questions. This may include responding to your feedback or notifying you if you win a promotion.
  • To Communicate With You. We may communicate with you about your account or our relationship. We may also contact you about this Policy or our Platform terms and conditions.
  • For Marketing Purposes. We may provide you with information about our company and our business initiatives. This includes using your information to personalize your experience on our Platform and with our products. We may also engage in online behavioral advertising and retargeting. For more information about your choices related to these communications, see the Choices Regarding Your Information section below.
  • For Administrative Purposes. This includes using your information for accounting, record keeping, backup, and administrative purposes.
  • For Security Purposes. This includes ascertaining and verifying your identity in order to protect our company and other customers who use our products and services. This may also include protecting our Platform from any actual or suspected fraud and/or unlawful activity.
  • For Legal Purposes. This includes complying 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.
  • As Otherwise Permitted By Law or Any Other Incidental Business Purposes Related To or In Connection With The Above.

The purposes listed above may continue to apply even in situations where your relationship with us 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 against you).

HOW WE SHARE YOUR INFORMATION

We may share your information in the following ways:

  • Internally. We may share your information with our parent, subsidiary, and affiliate entities.
  • With Our Service Providers. We may share your information with third-parties who perform services on our behalf. For example, this may include companies that send emails on our behalf or help us run our Platform.
  • With Our Business Partners. For example, this may include data aggregators, advertisers, media buying agencies, advertising networks and advertising service providers. We may also share your information with a third party that co-sponsors a contest or promotion.
  • With Third-Parties for Marketing Purposes. This may include third-parties in whose products or services we believe you may be interested. These third-parties may also share your information with others. These third-parties may use your information for their own marketing purposes or the marketing purposes of others. This may include the delivery of interest-based advertising.
  • With Any Successors to All or Part of Our Business. For example, if we merge with, acquires or is acquired, or sells part of its business to another entity. This may include an asset sale, corporate reorganization or other change of control.
  • To Comply With the Law or To Protect Ourselves. For example, this could include responding to a court order or subpoena. It could also include sharing information if a government agency or investigatory body requests. We might share information when we are investigating a potential fraud. This could include fraud we think has occurred during a sweepstakes or promotion. We may also share information if you are the winner of a sweepstakes or other contest with anyone who requests a winner’s list.
  • Where You Have Asked Us to Share Your Information With a Third-Party.
  • For Other Reasons We May Describe to You.

WITHDRAWING YOUR CONSENT

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer (“DPO”) at the contact details provided below.

 

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.In general, we shall seek to process your request within 10 business days of receiving it.

 

Whilst we respect your decision to withdraw your consent, we would highlight that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or Services to you, and we will notify you in such circumstances before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above.

 

We also highlight that withdrawing your consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

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 DPO at the contact details provided below.

 

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 as soon as practicable and in any event within 30 days after receiving your request, we will inform you in writing as soon as practicable and in any event within 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 may generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

CHOICES REGARDING YOUR PERSONAL DATA

You have certain choices about how we use your personal data. Certain choices you make are browser and device specific.

  • Marketing Communications. You can opt out of receiving our marketing communications by using the unsubscribe link within each email. Note that, as long as you maintain an account with us or receive our products or Services, you will continue to receive administrative messages from us regarding your account and our Services.
  •  Cookies & Other Tracking Technologies: For information about our use of cookies and other tracking technologies, and to read our “Do Not Track” policy, please click here.

 

PROTECTION OF PERSONAL DATA

We take appropriate steps to preserve the security of your personal data, including preventing them from being accessed, copied, modified, used or disclosed to unauthorized third parties. We use reasonable means to safeguard personal data under our control and in our possession.

However, the Internet is not 100% secure and no method of transmission over the Internet or method of electronic storage is completely secure. We cannot promise that your use of our Platform will be completely safe. We encourage you to use caution when using the Internet.  A username and a password are needed to access certain areas of our Platform. Consequently, it is your personal responsibility to protect your username and password.

ACCURACY OF PERSONAL DATA

We generally rely on personal data provided by you (or your authorized 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 DPO in writing or via email at the contact details provided below.

STORAGE AND TRANSFER OF INFORMATION

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. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

Information we maintain may be stored in or outside of the United States (“U.S.”). If you live outside of the U.S., you consent, understand and agree that we may transfer your personal data to the U.S. or non-EU countries, in connection with the purposes set out in this Policy. Nevertheless, we will take reasonable steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

DATA PROTECTION OFFICER

You may contact our DPO if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Subject Line: Attn Avril Ng DPO Singapore Webshop

email: avril.ng@livinguard.com

CHILDREN UNDER 21

The Platform where this Policy is located are meant for adults. We do not knowingly collect personally identifiable data from persons under the age of 21, and strive to comply with the provisions of PDPA. If you are a parent or legal guardian and think your child has provided us with information, please contact us immediately at contact.sg@livinguard.com. You may also write to us at the address listed at the end of this Policy. Please mark your inquiries “PDPA Information Request.”

THIRD-PARTY SITES

Our Platform may contain links to other third-party sites that are not governed by this Policy. If you click on a link to a third-party site, you will be taken to a site we do not control.  We are not responsible for the privacy practices used by third-party sites. We recommend that you read the privacy policies of those sites carefully. We are not responsible for these third-party sites.

HOW TO CONTACT US

If you have any questions, comments or concerns with respect to our privacy practices or this Policy, or wish to update your information, please feel free to contact us at contact.sg@livinguard.com.

EFFECT OF NOTICE AND CHANGES IN POLICY

This Policy 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.

From time to time, we may change our Policy. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on our Platform. Please check our Platform periodically for updates. Your continued use of our Platform and Services constitutes your acknowledgement and acceptance of, and agreement to, such changes.