General

This policy outlines the our basic belief that Two Up Ventures Pte Ltd have with respect to the protection and handling of personal information obtained through business activities.

What is Personal Data

Personal data means 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. Common examples of personal data could include names, identification numbers, contact information, addresses etc.

How Personal Data is collected

Here are examples of situations where your personal data is collected:

(a) when you register for an account on the Website

(c) when you make a purchase on the Website

(d) when you communicate with us directly in relation to our products and services

(f) when you conduct certain types of transactions such as payment and refunds

(g) when you enter, and when you interact with us during promotions, competitions, contests, lucky draws or special events

When Personal Data Collected and what is Collected

We collect personal data through registration, placement of orders, completion of forms, emails, inquiries, requests, and other situations where you have chosen to provide personal data to us.

Examples of the types of personal data which we may collect about you include:

(a) contact information such as names, addresses, telephone numbers, and email addresses;

(c) billing information such as billing address and credit card information;

(f) details of your visits to the Website, such as traffic data, location data, and the resources that you access on the Website; and

(g) your transaction history.

 

Purposes for Collection, Use, Disclosure and Processing of Personal Data

You may, in certain circumstances, provide us with personal data relating to third parties (for example, your next-of-kin or any person who may receive delivery of your purchased item on your behalf). When this happens, you are deemed to have represented and confirmed to us that you have obtained the consent of such third party to provide his/her personal data to us for processing in the manner set out in paragraph 2 above.

We collect personal data if it is necessary for us to conduct our everyday activities or functions.

The personal data which may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process the personal data, including:

(a) to communicate with the customers;

(b) to maintain and improve customer relationship;

(c) to assess, process and provide products, services and/or facilities to you;

(d) to administer and process any payments (including refunds) related to products, services and facilities requested ;

(e) to establish customers’ identity and background;

(f) to respond to enquiries or complaints and resolve any issues and disputes which may arise in connection with any dealings with us;

(g) to provide with services or assistance that are requested;

(h) to provide with information and/or updates on our products, services, upcoming promotions offered and/or events organised by us and selected third parties which may be of interest from time to time;

(i) for direct marketing purposes via SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels

(j) to facilitate any participation in, and our administration of, any events including contests, promotions or campaigns;

(k) to award points in a loyalty or rewards programme;

(l) to maintain and update internal record keeping;

(m) for internal administrative purposes;

(o) to send an invitation to join our events and promotions and product launch events;

(p) to monitor, review and improve our events and promotions, products and/or services;

(q) to process any payments related to customers’ commercial transactions with us;

(r) to process and analyse customers’ personal data either individually or collectively with other individuals;

(s) to conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, planning and statistical and trend analysis in relation to our products and/or services;

(t) to share the collected personal data with the auditor for our internal audit and reporting purposes;

(u) to share customers’ personal data pursuant to any agreement or document which buyers have duly entered for purposes of seeking legal and/or financial advice and/or for purposes of commencing legal action;

(v) for audit, risk management and security purposes;

(w) for detecting, investigating and preventing fraudulent, prohibited or illegal activities;

(x) for enabling us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;

(y) to transfer or assign our rights, interests and obligations under any agreements entered into with us;

(z) for meeting any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to us;

(aa) to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation and regulations; and/or

(ab) for other purposes required to operate, maintain and better manage our business and your relationship with us; which we notify you of at the time of obtaining your consent.

As the purposes for which we may/will collect, use, disclose or process customers’ personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose(s) at the time of obtaining your consent, unless we are permitted by the PDPA or any other applicable law to process your personal data without your consent.

Specific Issues for the Disclosure of Personal Data to Third Parties

To fulfil our obligations to customers, we may also disclose the personal data that have been provided to us to our third party service providers, agents, affiliates or related corporations.

  1. Examples of third parties that disclosures include:

(a) Third party logistics providers
(b) professional advisors, consultants and/or external auditors;
(c) storage and warehousing facility providers;
(e) relevant government regulators or authorities.

 

  1. We respect the confidentiality of the personal data and do not sell personal data to any third party.

Protection and Destruction of Personal Data

Security arrangements have been implemented to ensure that all personal data are adequately protected and secured. Such is to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. We do not however, assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.

We will also put in place measures to ensure that any of your personal data that is in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that:

(a) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and

(b) retention is no longer necessary for any other legal or business purposes.

Complaint Process

If you have any feedback regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us by writing to us aftersales@twoup.com.sg

 

 

 

Updates on Personal Data Protection Policy

 

To ensure the proper management, protection and process all personal data, a review of our policies, procedures and processes will be executed from time to time.

We reserve the right to amend the terms of this Personal Data Protection Policy at our absolute discretion. No individual notice will be sent.

It is deemed that customers have acknowledged and agreed to any amended version of this Personal Data Protection Policy if one continues to use the Website after the changes have taken place. As such, you are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.

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