Privacy First: Our Commitment to Your Information Security
Twiching General Trading Pte. Ltd. Privacy Policy
Twiching General Trading respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1. Important information and who we ar
This privacy policy aims to give you information on how Twiching collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. Controller: Twiching is the controller and responsible for your personal data (collectively referred to as “Twiching”, “we”, “us” or “our” in this privacy policy). Contact details: Full name of legal entity: Twiching Email address: [email protected] Postal address: 1 Tampines North Drive 1, T-Space, Singapore 528559 We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. Contact details: Full name of legal entity: Twiching Email address: [email protected] Postal address: 1 Tampines North Drive 1, T-Space, Singapore 528559 You have the right to make a complaint at any time to the [relevant supervisory authority for data protection issues]. We would, however, appreciate the chance to deal with your concerns before you approach the authority so please contact us in the first instance.2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: – Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender. – Contact Data includes billing address, delivery address, email address and telephone numbers. – Financial Data includes bank account and payment card details. – Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. – Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. – Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. – Usage Data includes information about how you use our website, products and services. – Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.3. How is your personal data collected?
We use different methods to collect data from and about you including through: Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: – apply for our products or services; – create an account on our website; – subscribe to our service or publications; – request marketing to be sent to you; – enter a competition, promotion or survey; or – give us feedback or contact us. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below: – Technical Data from the following parties: – analytics providers such as Google based outside the EU; – advertising networks based inside OR outside the EU; and – search information providers based inside OR outside the EU. – Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside OR outside the EU. – Identity and Contact Data from data brokers or aggregators based inside OR outside the EU. – Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: – Where we need to perform the contract we are about to enter into or have entered into with you. – Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. – Where we need to comply with a legal obligation. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.Purposes for which we will use your personal data:
– To register you as a new customer. – To process and deliver your order including: – Manage payments, fees and charges. – Collect and recover money owed to us. – To manage our relationship with you which will include: – Notifying you about changes to our terms or privacy policy. – Asking you to leave a review or take a survey. – To enable you to partake in a prize draw, competition or complete a survey. – To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). – To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. – To use data analytics to improve our website, products/services, marketing, customer relationships and experiences. – To make suggestions and recommendations to you about goods or services that may be of interest to you. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in paragraph 4 above: – Internal Third Parties such as our employees, IT and system administration. – External Third Parties such as service providers acting as processors based in Singapore who provide IT and system administration services. – Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in Singapore who provide consultancy, banking, legal, insurance and accounting services. – Singaporean Revenue Authorities, regulators and other authorities acting as processors or joint controllers based in Singapore who require reporting of processing activities in certain circumstances. – Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.6. International transfers
We do not transfer your personal data outside Singapore.7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.8. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. In some circumstances you can ask us to delete your data: see your legal rights below for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to: – Request access to your personal data. – Request correction of your personal data. – Request erasure of your personal data. – Object to processing of your personal data. – Request restriction of processing your personal data. – Request transfer of your personal data. – Right to withdraw consent.- If you wish to exercise any of the rights set out above, please contact us.
- You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
- We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
- We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.