This is the Sureclean/Steriluxe  Personal Data Protection Policy (“Personal Data Protection Policy”) and the purpose of this document is to inform you of how Sureclean/Steriluxe manages, collects, uses and discloses your Personal Data, which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”).

When you submit information to us, or sign up as a customer on our website to purchase, view or otherwise surf any of the products or services offered by us (the “Products and Services”), you agree and consent to Sureclean/Steriluxe (including its related corporations and business units) (collectively, the “Companies”), as well as their respective representatives and/or agents collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies’ authorised service providers and relevant third parties in the manner set forth in this Personal Data Protection Policy.

This Personal Data Protection Policy supplements but does not supersede nor replace any other consent you may have previously provided to Sureclean/Steriluxe in respect of your Personal Data.

Sureclean/Steriluxe may update this Personal Data Protection Policy to ensure that it is consistent with industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Personal Data Protection Policy as updated from time to time on our website www.sureclean.com.sg and www.steriluxe.com.

• PERSONAL DATA
• COLLECTION OF PERSONAL DATA
• PURPOSES FOR THE COLLECTION, USE & DISCLOSURE OF PERSONAL DATA
• DISCLOSURE OF PERSONAL DATA
• USE OF COOKIES
• GOOGLE ANALYTICS
• CONTACTING US
• GOVERNING LAW
• WHY & WHAT DO WE COLLECT
• SECURITY
• CONTROLLING YOUR PERSONAL INFORMATION
• LIST OF COOKIES WE COLLECT

PERSONAL DATA

In this Personal Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual 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, including data in our records as they may be updated from time to time. Examples of such Personal Data you may provide to us include your name, NRIC, passport or other identification numbers, telephone numbers, mailing address, email address, network data and any other information relating to any individuals which you have provided in any forms you may have submitted to us, or via other forms of interaction with you.

COLLECTION OF PERSONAL DATA

Generally, Sureclean/Steriluxe collects Personal Data, either directly from you or from your authorised representatives (i.e. persons whom you have authorised, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), from third parties, or from publicly available sources or through our website in the following ways:

• when you submit a form for registering as a customer on our website or any other forms relating to any of our Products and Services
• when you interact with our customer service team, for example, via telephone calls, letters, face-to-face meetings and emails
• when you use some of our services, for example, websites and apps including establishing any online accounts with us
• when you request that we contact you to be included in an email or other mailing list
• when you respond to our promotions, initiatives or to any request for additional Personal Data
• when you are contacted by, and respond to, our marketing representatives and customer service team
• when we receive references from business partners and third parties, for example, where you have been referred by them
• when you submit your Personal Data to us for any other reasons.

When you browse our website, you generally do so anonymously but please see paragraph below on cookies.

If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Products and Services you have requested.

PURPOSES FOR THE COLLECTION, USE & DISCLOSURE OF PERSONAL DATA

Sureclean/Steriluxe collects, may use and disclose your Personal Data for the following purposes :

• responding to your queries and requests;
• managing the administrative and business operations of Sureclean/Steriluxe in compliance with internal policies and procedures;
• facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
• matching any Personal Data held which is related to you for any of the purposes listed herein;
• resolving complaints as well as handling requests and enquiries;
• preventing, detecting and investigating crime as well as analyzing and managing commercial risks;
• providing media announcements and responses;
• monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training, performance evaluation and identity verification purposes;
• organising promotional events;
• legal purposes (including but not limited to obtaining legal advice and dispute resolution);
• conducting investigations relating to disputes, billing or fraud;
• meeting or complying with any applicable rules, laws, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Sureclean/Steriluxe; and
• purposes which are reasonably related to the aforesaid.

Where permitted under the Act, Sureclean/Steriluxe may also collect, use and disclose your Personal Data for the following “Additional Purposes” :

• analytics and tracking;
• conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics;
• to develop special offers and marketing programmes in relation to Sureclean/Steriluxe ‘s products and services as well as improve our service delivery and customer experience;
• providing additional Products and Services as well as benefits to you, including promotions, loyalty and reward programmes from Sureclean/Steriluxe;
• matching Personal Data with other data collected for other purposes and from other sources in connection with the provision, marketing or offering of products and services by Sureclean/Steriluxe;
• leads generation and management for marketing Sureclean/Steriluxe’s Products and Services;
• administering contests, competitions and marketing campaigns, and personalising your experience at Sureclean/Steriluxe;
• communicating to you through advertisements involving details of our Products and Services, special offers and rewards;
• organising promotional events and corporate social responsibility projects; and
• purposes which are reasonably related to the aforesaid.
• In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for Sureclean/Steriluxe Additional Purposes, to the vendors or other third party service providers in connection with promotions and services offered by Sureclean/Steriluxe.
• Sureclean/Steriluxe may also collect, use and disclose your Personal Data for the following “Preferred Partners Additional Purposes”:
• conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics;
• to develop special offers and marketing programmes with our preferred partners;
• matching Personal Data with other data collected for other purposes and sources in connection with the provision, marketing or offering of products and services by our preferred partners;
• leads generation and management for marketing the products and services offered by our preferred partners;
• administering contests, competitions and marketing campaigns in connection with the products and services offered by our preferred partners;
• communicating to you through advertisements involving details of our Products and Services, special offers and rewards offered by our preferred partners;
• purposes which are reasonably related to the aforesaid.

In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for Preferred Partners’ Additional Purposes, to the vendors or other third party service providers in connection with promotions and services offered by Sureclean/Steriluxe’s preferred partners. If you have provided your Singapore telephone numbers, Sureclean/Steriluxe may contact you using such Singapore telephone numbers (including channels like voice calls, sms, fax or other means) with information about our Products and Services or those products and services offered by our preferred partners (including discounts, flash sales and special offers).

In relation to particular Products and Services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

When you shop on Sureclean/Steriluxe’s website, we may send you promotional/marketing material via mail along with your order package.

Should you wish to withdraw your consent for us to send you sales, marketing or promotional information via a specific mode, please inform us as follows:

• to withdraw consent from receiving SMS promotions: please unsubscribe by following the steps provided in the promotional SMS;
• to withdraw consent from promotional emails: please click on the Unsubscribe link in the promotional emails;
• to withdraw consent from receiving promotional material with your order package: please email customer service, with the words “PERSONAL DATA” in the subject line.

Please be aware upon receiving confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to thirty (30) days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials through a specific mode, we may still contact you for other purposes in relation to the Products and Services that you hold or have subscribed to with Sureclean/Steriluxe.

DISCLOSURE OF PERSONAL DATA

Sureclean/Steriluxe will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:

• Sureclean/Steriluxe’s related corporations and employees to provide content, Products and Services to you, address your questions and requests in relation to your customer accounts, subscription and billing or order arrangements with us as well as our Products and Services, to activate, deactivate, install, maintain and operate our systems and/or services;
• companies providing services relating to insurance and consultancy to Sureclean/Steriluxe;
• agents, contractors or third party service providers who provide operational services to Sureclean/Steriluxe, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services to Sureclean/Steriluxe;
• vendors or third party service providers in connection with marketing promotions and services offered by Sureclean/Steriluxe or its preferred partners;
• commercial shops and retailers in relation to providing rewards and benefits;
• any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;
• our professional advisers such as auditors and lawyers;
• relevant government regulators, statutory boards, authorities or law enforcement agencies to comply with any laws, rules, guidelines, regulations or schemes imposed by any governmental authority; and
• any other party to whom you authorise us to disclose your Personal Data to

USE OF COOKIES

A cookie is a small piece of information that is placed on your computer when you visit certain websites. Most websites like ours use cookies to enhance your online experience. Sureclean/Steriluxe uses cookies on its websites for the following purposes :

• enabling certain features and functions on our websites, eg. remembering your user-id, browsing and other service preferences
• building up a profile of how you and other users use the website;
• improving the efficiency of our website;
• administering services to you and to advertisers; and
• establishing usage statistics

Advertisements on the Sureclean/Steriluxe website may be provided by third party advertisers and their agencies. These may generate cookies to track how many people have seen a particular advertisement (or use the services of third parties to do this), and to track how many people have seen it more than once. Sureclean/Steriluxe does not control these third parties and their cookie policies and should you have any enquiries about their cookie policies, please contact Sureclean/Steriluxe and we will try our best to assist by providing information on these third party advertising agencies.

Sureclean/Steriluxe is not responsible for the Personal Data policies (including Personal Data protection and cookies), content or security of any third party websites linked to the Sureclean/Steriluxe website.

GOOGLE ANALYTICS

Sureclean/Steriluxe uses features of Google Analytics, please see this link

http://www.google.com/policies/privacy/partners/ for how your data is collected.

https://tools.google.com/dlpage/gaoptout for how to opt-out of any Google Analytics tracking.

As part of the above, Sureclean/Steriluxe may use Google Analytics features based on Display Advertising, including but not restricted to the following : Remarketing, Google Display Network Impression Reporting, DoubleClick Campaign Manager Integration, Google Analytics Demographics and Interest Reporting. Using the Google Ads Settings (https://www.google.com/settings/ads), you can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads.

Sureclean/Steriluxe also uses Remarketing with Google Analytics to advertise online; third-party vendors, including Google, may show VIIMART ads on sites across the Internet. Sureclean/Steriluxe and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on visitors’ past visits to Sureclean/Steriluxe, as well as report how ad impressions, other uses of ad services, and interactions with these ad impressions as well as ad services that are related to visits to Sureclean/Steriluxe.

When you log on to Sureclean/Steriluxe, with the help of Google Analytics, we may use your browsing behaviour to connect it with any other data that has previously been provided by you, in accordance with this Personal Data Protection Policy.

CONTACTING US

For any enquiries relating to your Personal Data or about our Privacy Policy, you may contact our Data Privacy Officer at +65 6899 8643 or email us at sales@Steriluxe.com

GOVERNING LAW

This Personal Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.

WHY & WHAT WE COLLECT

We may collect the following information :

• name
• contact information including email address
• demographic information such as postcode, preferences and interests
• other information relevant to customer surveys and/or offers

For the exhaustive list of cookies we collect see below “List of cookies we collect”

We require this information to understand your needs and provide you with better service, and in particular for the following reasons:

• Internal record keeping.
• We may use the information to improve our products and services.
• We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
• From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.

SECURITY

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

CONTROLLING YOUR PERSONAL INFORMATION

You may choose to restrict the collection or use of your personal information in the following ways :

• whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
• if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to us at sales@Steriluxe.com.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional materials about third parties which we think you are interested in upon receiving your personal preferences.

Should any information we hold on you is incorrect or incomplete, please write to us at the above email address as soon as possible. We will promptly correct any inaccurate information.