Last updated on 15 November 2023
PRIVACY POLICY
This Privacy Policy (“Policy”) sets out the basis on which Secret Potion Pte. Ltd. (“we”, “us”, “our” or “Company”) may collect, use, and disclose personal data of individuals in accordance with the Personal Data Protection Act 2012 (“the PDPA”). In this policy, “personal data” shall have the meaning ascribed to it in the PDPA.
We collect personal data from individuals including users, clients, customers, sales leads, partners, employees, contractors and third parties in our mobile application, website, meetings, email messages, telephone conversations and via other means that may be employed from time to time in the course of our business and operations.
1. Collection, Use and Disclosure of Personal Data
1.1 We collect, use or disclose personal data for our business purposes only if there is consent or deemed consent from individuals and information regarding such purposes has been notified to them. Personal data may also be collected, used or disclosed if it is required or authorised under applicable laws.
1.2 Personal data that we collect may include but not limited to name, photograph, home address, location, date of birth, contact number(s), email addresses, credit card information, and any other information in relation to employment or job application with us, if necessitated.
1.3 Personal data may be collected by us in the following manners:
- When users download and access our mobile application or request us to contact them through our user application or website, telephone, letters, face-to-face meetings or emails
- When personal data are submitted to us for any other reasons including those that are required by laws.
1.4 We collect, use and disclose personal data to fulfil the following purposes:
For administrative management purposes, such as invoicing, account management and day-to-day payments processing activities
For providing solutions to our users and suggesting them relevant and detailed information based on their requirements.
For overall business operations.
All other purposes related to our business or required by applicable laws, regulations or code of practice.
1.5 Personal data may not be provided to third parties except when such disclosure is required by law when we have the consent or deemed consent from individuals or where we have engaged third parties such as data intermediaries or subcontractors specifically to assist with the Company’s activities that necessitate the processing and other business usage of personal data. We will ensure that any third parties engaged in such activities will be bound contractually in ensuring that personal data will be handled according to the PDPA.
1.6 We aim to comply with the Do Not Call (DNC) provisions under the PDPA with regards to us sending promotional and marketing messages to Singapore telephone numbers.
2. Withdrawal of Consent
You may withdraw your consent for the collection, use and disclosure of your personal data for any or all of the purposes listed in clause (1.4) above by submitting your written request via email to our Data Protection Officer (DPO) at the contact details provided in clause (9) of this policy.
Upon receiving your request to withdraw your consent, we will notify you of the likely consequences of the withdrawal of consent and process your request within 7 business days of receiving it.
Thereafter we will cease (and cause your personal data that are in the possession and/or control of third-party organisations engaged by us to cease) collecting, using or disclosing your personal data unless it is required or authorised under applicable laws.
3. Access to and Correction of Personal Data
Upon request, we will provide individuals with access to their personal data or correct an error or omission in their personal data that is in our possession or control in accordance with the requirements of the PDPA. All requests for access to and correction of personal data in writing or via email may be submitted to our Data Protection Officer at the contact details provided in clause (9) in this policy.
4. Accuracy of Personal Data
Best and reasonable efforts will be rendered by us in ensuring the accuracy and completeness of all personal data collected by us. Individuals may inform our Data Protection Officer in writing or via email at the contact details provided in clause (9) below to update us if there are changes to their personal data.
5. Protection of Personal Data
We have implemented appropriate standards of information technology security and control measures to protect the personal data that will be in our possession or control to prevent unauthorised access, misappropriation, destruction and other forms of data risk incidents. We are contractually obliged to keep all personal data confidential and only authorised persons have access to such information.
6. Retention of Personal Data
Retention of personal data will cease as soon as when such retention is no longer necessary for legal or business purposes and it no longer serves the purpose for the collection of such personal data.
7. Transfer of Personal Data outside of Singapore
In the event that it is necessary for personal data to be transferred outside of Singapore in the ordinary course of our business activities, we will first obtain consent from individuals for the transfer to be made. We will use our reasonable endeavours to ensure that the transfer will be carried out according to the requirements of the PDPA such that the protection given to such personal data outside of Singapore is comparable to the standard under the PDPA.
8. Privacy On Our Website
The website of the Company may contain links to third parties’ websites and we are not responsible for the privacy or cookies policies of such websites. Visitors to our websites are encouraged to check the privacy policies on these third parties’ sites before providing any personal information.
This policy also applies to any personal data that may be collected by us via our website through cookies that are used to make our website work more efficiently and improve users’ navigational experience.
If individuals or visitors to our website are concerned about cookies, they can modify their browser settings to disable cookies.
9. Data Protection Officer
If you have any questions on this policy or how we manage and protects your personal data, please contact our Data Protection Officer (Mr. Noel Lee) at contact@dedomena-tech.com.sg
10. Effect of Policy and Modifications
This policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that may apply in relation to the collection, use and disclosure of personal data by us.
We reserve the right to amend this policy at any time and the last revision date will be shown at the beginning of this policy. To keep individuals updated, changes to this policy will be informed through email notifications or other most effective and efficient means of communication that are available for our use.
For any questions or clarifications: developer@secretpotion.co