This Privacy Notice (“Notice”) sets out the basis which Leben Wasser (S) Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
1. As used in this Notice:
“customer” 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; 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.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include:
(a) contact information such as name, partial NRIC number (last 4 characters, e.g. xxxxx893C) address, telephone number and email address;
(b) payment information such as billing address, shipping address, debit card or credit card or bank information;
(c) unique information such as photograph, contact preferences, date of birth, audio-visual information;
(d) employment information such as NRIC number, passport number, nationality, gender, marital status, work eligibility status and employment history;
(e) details of your visits to https://www.leben.sg and https://wode.sg/ (“Websites”), such as traffic data, location data, and the resources that you access on the Websites; and
(f) your transaction history.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION OF PERSONAL DATA
4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
5. When do we collect your Personal Data?
(a) When you register for an account on the Websites or apps;
(b) When you complete purchase orders, requests or applications for our products or services (by telephone, in person, snail mail or electronically);
(c) When you make a purchase on the Websites;
(d) When you communicate with us directly in relation to our products and service (in person via our r oad shows, by email, telephone or any other means);
(e) When you use services that are made available on the Websites such as home delivery, assembly/installation service, etc.;
(f) When you conduct certain types of transactions such as refunds;
(g) When you enter, and when you interact with us during promotions, competitions, contests, lucky draws or special events;
(h) When you apply for employment with us;
(i) When you participate in surveys and other types of research.
USE OF PERSONAL DATA
6. We may use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) managing your relationship with us;
(e) processing payment or credit transactions;
(f) sending your marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership, rewards and other promotions;
(g) 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;
(h) managing career opportunities and other human resource purposes;
(i) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(j) any other incidental business purposes related to or in connection with the above, which we notify you of at the time of obtaining your consent.
DISCLOSURE OF PERSONAL DATA
7. We may disclose your personal data:
(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or
(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 6 above for us.
8. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) 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 under any contract with you).
9. We will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third party Websites from which you may have linked or been directed to our Websites.
THIRD PARTY SERVICES
10. In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide us.
11. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
12. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers. In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
13. Once you leave our Websites or are redirected to a third-party website or application, you are no longer governed by this Privacy Notice or our websites’ Terms of Service.
14. Our e-shop is hosted on the following platforms. They provide us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through the platforms’ data storage, databases and general application on a secure server:
Please refer to the Privacy Policies/Notices of the above platforms to understand the manner in which your personal information will be handled by them.
15. Our Websites let you share content with your friends and followers on the following Social Media platforms:
Please refer to the Privacy Policies/Notices of the above Social Media platforms to understand the manner in which your personal information will be handled by them.
WITHDRAWING YOUR CONSENT
16. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being 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 at the contact details provided below. Please click here for the Consent Withdrawal Form.
17. 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 fourteen (14) business days from the day we issue you an email acknowledging the receipt of your written request.
18. Whilst we respect your decision to withdraw your consent, please note 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 shall, in such circumstances, notify you 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 in clause 16 above.
19. Please note that withdrawing 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 AND CORRECTION OF PERSONAL DATE
20. If you wish to make a correction or update any of your personal data which we hold about you, or to request for information about the ways in which we use or disclose your personal data, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below. Please click here for the Access Request Form.
21. Please note that a reasonable fee will be charged for an access request. We will inform you of the fee in the Access Request Form.
22. We will respond to your request as soon as reasonably possible. At the same time, we may ask you to provide certain details about yourself so that we can be sure you are the person to whom the data refers. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (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 shall 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).
PROTECTION OF PERSONAL DATA
23. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
24. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
25. We generally rely on personal data provided by you (or your authorised 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 Data Protection Officer in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
26. 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.
27. 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.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
28. If there is a need for us to transfer personal data about you to a country or territory outside Singapore, we will take 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.
29. When you visit the Websites, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Websites, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Websites, and information about how you interact with the Websites. We refer to this automatically-collected information as “Device Information”.
30. We collect Device Information using the following technologies:
(a) “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier.
(b) “Log files” track actions occurring on the Websites, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
(c) “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Websites.
31. You can set your browser to accept or refuse all cookies automatically, or notify you when a cookie is being requested. Taking this action should not cause a problem with the continued use of our Websites. Consult the Help section of your browser for guidance on how to refuse all cookies or to notify you when a cookie is requested.
32. If you choose to refuse Leben Wasser (S) Pte Ltd Websites’ cookies, you may not be able to fully experience the interactive features of the Websites.
33. We also use Google Analytics to help us understand how our customers use the Websites. You can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
CHILDREN’S PRIVACY PROTECTION
34. The Websites are directed to adults. They are not directed to children under the age of 18. We operate our sites in compliance with current regulations. Anyone under the age of 18 must provide parental consent to use these Websites. We do not knowingly collect or use personally identifiable information from anyone under 18 years of age.
DATA PROTECTION OFFICER
35. You may contact our Data Protection Officer 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:
Address : Leben Wasser (S) Pte Ltd
81, Ubi Avenue 4, #05-20
Office Phone : +65 3109 1970
Email : email@example.com
EFFECT OF NOTICE AND CHANGES TO NOTICE
36. This Notice 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.
37. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Effective date : 30 April 2019
Last updated : 1 November 2019