Your privacy is important to us. The purpose of this Privacy Policy is to inform you of how Sincere Luxor Private Limited manages personal data in accordance with the Personal Data Protection Act 2012 (“the Act”). Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.  

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to SINCERE LUXOR nor does it affect any rights which SINCERE LUXOR may have at law in connection with the collection, use or disclosure of your Personal Data. SINCERE LUXOR may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with our future developments, 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 Privacy Policy as updated from time to time on our websites. Please check regularly for updated information on the handling of your Personal Data.

For avoidance of doubt, this Privacy Policy forms a part of the Website terms and conditions (‘Website Conditions’). In the event of any conflict, inconsistency or conflict between this Privacy Policy and the Website Conditions, the Privacy Policy shall prevail. All defined terms contained in the Website Conditions shall apply to this Privacy Policy unless otherwise specifically stated.

1.

Your Personal Data

1.1

In this Privacy Policy, “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide to us include (depending on the nature of your interaction 

with us:

1.2

your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;

1.3

your payment related information, such as your bank account or credit card information, and your credit history; and

1.4

information about your usage of and interaction with our website and/or services 

2

Collection of Personal Data

2.1

Generally
, 
SINCERE LUXOR
collects your Personal Data in the following ways:

(a)

when you submit forms relating to any of our products or services;

(b)

when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us, or use services on such websites; 

(c)

when you interact with our customer service officers;

(e)

when you establish any online accounts with us;

(f)

when you request that we contact you;

(g)

when you are contacted by, and respond to, our marketing representatives and agents;

(h)

when you respond to our request for additional Personal Data

(i)

when you ask to be included in an email or other mailing list;

(j)

when you respond to our promotions and other initiatives;

(m)

when we receive references from business partners and third parties, for example, where you have been referred by them;

(n)

when you submit your Personal Data to us for any other reason.

2.4

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 products and services you have requested.

3

Purposes for the Collection, Use and Disclosure of Your Personal Data

3.1

Generally, SINCERE LUXOR collects, uses and discloses your Personal Data for the following purposes:

(a)

responding to your queries and requests and responding to complaints;

(e)

verifying your identity;

(g)

protecting and enforcing our contractual and legal rights and obligations;

(h)

conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;

(j)

compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or

(k)

any other purpose relating to any of the above.

3.2

In addition, 
SINCERE LUXOR may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

(a)

If you have a subscription or membership account with us
:

(i)

to process your application for Online Services and/or membership,

(ii)

to maintain your account with us;

(iii)

to verify and process your personal particulars and payments in relation to provision of Online Service and/or Membership to you;

(vi)

resolving complaints and handling requests and enquiries;

(vii)

conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and

(viii)

the processing of your Personal Data in relation to any of the purposes stated above.

(b)

If you use download or use any of our Apps
:

(i)

where the App includes App Subscription Services, to process your application for these services;

(ii)

to maintain your account with us and to ensure your access of the App is within the scope of your membership

(iii)

to verify and process your personal particulars and payments in relation to provision of goods and services connected to the App;

(v)

communicating with you to inform you of changes and development to SINCERE LUXOR policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;

(vi)

resolving complaints and handling requests and enquiries;

(vii)

conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and

(viii)

the processing of your Personal Data in relation to any of the purposes stated above.

3.3

In addition, where permitted under the Act, SINCERE LUXOR may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data):

(a)

providing services, products and benefits to you, including promotions, loyalty and reward programmes;

(d)

sending you details of products, services, special offers and rewards, either to our customers generally, or of particular products and services which may be of interest to you; and

(e)

conducting market research, understanding and determining customer location, preferences and demographics for us to review, develop and improve our products, services and also develop special offers and marketing programmes.

3.4

4

Disclosure of Personal Data

4.1 

SINCERE LUXOR
will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in   Singapore:

8

Governing Law

8.1

This Privacy Policy shall be governed in all respects by the laws of Singapore.