This Personal Data Protection Policy (“Policy”) sets out the ways in which Brand Brew Pte Ltd (“Brand Brew”) collects, uses, discloses and retains personal information in order to carry out our activities and operations on behalf of ourselves or our clients; and the measures we take to protect your personal information. The Policy is designed to meet the requirements of Singapore’s personal data protection laws.
We generally do not collect your personal data unless:
(i) when you order, purchase, or use products or services from us or our clients;
(ii) when you request that we or our clients contact you, include you in an email or other mailing list;
(iii) when you respond to our promotions, campaigns or other initiatives, or attend our events;
(iv) when you visit our or our clients’ websites;
(v) when you take part in any contest, survey or promotion conducted by us and/or our clients;
(vi) when we receive information about you from third party social networking services when you choose to connect with those services;
(vii) when you submit your Personal Data to us for any other reasons; and/or
(viii) when we collect your Personal Data by other lawful means.
Unless permitted by applicable laws, we will not collect, use or disclose your Personal Data (including your NRIC number or, where applicable, a copy of your NRIC) without your consent. We will limit our collection, use and disclosure of your Personal Data to what is adequate and relevant to the purposes for which they are needed and to which you have consented.
You warrant and represent to us that (a) Personal Data which you disclose to us is accurate and complete; and (b) where you volunteer Personal Data of another person to us, that you are authorized by such other person to disclose such Personal Data to us, and that such Personal Data is accurate and complete.
You shall consult your parent or guardian before giving us your Personal Data if you are under the age of eighteen.
Your Personal Data may be collected, used and/or disclosed for the following purposes:
(i) to verify and process your personal particulars and payments;
(ii) to provide goods and services to you;
(iii) to respond and deal with enquiries, complaints and other customer-care matters or otherwise communicate with you;
(iv) to send you information, promotions, updates, and marketing and advertising materials in relation to our’s and our clients’ goods and services;
(v) to carry out marketing promotions and campaigns, contests and lucky draws and personalising your experience at our customer touchpoints;
(vi) to carry out market research and customer surveys;
(vii) to conduct investigations or audits or carry out crime and fraud prevention and risk management activities;
(viii) to comply with legal and regulatory requirements;
(ix) to enforce our legal rights and obligations;
(x) for other purposes for which we have obtained your consent; and
(xi) for any other purposes reasonably necessary, ancillary or related to the above specified purposes.
Save for relevant government regulators and authorities or law enforcement agencies, we will ensure that such parties receiving your Personal Data (i) are under a duty of confidentiality to us with respect to the use, holding, processing, retention and/or transfer of your Personal Data; and (ii) have the need to know or handle such Personal Data.
If you have provided us with your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, we may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services.
Likewise, we will only collect, use and/or disclose your Personal Data for marketing purposes where you have consented to us doing so after being informed of such purposes and the consequences of providing consent.
Your Personal Data may be transferred, stored and/or processed in a country or territory outside Singapore and you consent to any such transfer, storage and/or processing of your Personal Data outside Singapore. We will however ensure that any party to whom we transfer your Personal Data outside Singapore provides to such Personal Data a standard of protection at least comparable to the protection under the Act. This includes without limitation ensuring that any party coming into contact with the Personal Data outside Singapore:
(i) complies with the Act and accompanying guidelines issued by the relevant regulatory authorities, all applicable laws and regulations and this Privacy Policy (“Data Standards”) and shall not do or permit anything to be done which might cause such party or us to breach the Data Standards;
(ii) takes all appropriate measures to ensure such compliance by implementing such Data Handling Principles as notified by us to them from time to time and appropriate technical and organisational measures and providing a standard of protection for the Personal Data that is comparable to the protection under the Act; and
(iii) protects the Personal Data by making reasonable security arrangements to prevent unauthorised access, use, disclosure or modification.
You may withdraw your consent to our continued use and disclosure of your Personal Data or seek access to your Personal Data (to a reasonable extent and as permitted by the Act) at any time by writing to us. You may also withdraw your consent for specific forms of communication and on specific communications via the unsubscribe options as stated on our email or other marketing messages.
In withdrawing your consent, you acknowledge that we may not be able to provide or continue providing certain goods and/or services to you and that we may cease such provision accordingly without any liability. Please note that it may take up to 30 days for any request for consent withdrawal to be reflected in our systems.
We will, at your request, within 30 days, endeavour to provide you with an account of your Personal Data in our possession or control or inform you of the deadline by which we will respond. Such account shall be in respect of how your Personal Data has been or may have been generally used or disclosed within the year before the date of your request. We reserve the right to charge a reasonable administrative fee for carrying out your request, where permitted under applicable laws.
We may seek and obtain consent from you to the disclosure of your PII through means other than this Policy.
Choices. If you no longer wish to receive promotional emails from us on a going-forward basis, you may opt-out of receiving such emails by following the “unsubscribe” directions on the e-mails or by changing your preference settings on any page on the Site where you requested to receive such communications. We will endeavor to comply with your request as soon as reasonably practicable. Please note that if you opt out as described above, we may not be able to remove PII about you from the databases of those third parties with which we have already shared PII about you as of the date that we implement your opt-out request. If you wish to cease receiving promotional emails from such third parties, please contact them directly or utilize any opt-out mechanisms set forth in their respective privacy policies or email communications.
We reserve the right to modify or update this Privacy Policy from time to time. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time. The date stated at the bottom of this Privacy Policy indicates the last time this document was revised. We encourage you to check back regularly for the latest version of this Privacy Policy.
Last updated: 23 June 2023
