PRIVACY POLICY


1. Privacy Policy

1.1. Shiseido Travel Retail Asia Pacific Pte. Ltd. respects your privacy and recognises that your personal data is important to you. The purpose of this Privacy Policy is to inform you of how we manage Personal Data in accordance with the Personal Data Protection Act 2012 (No. 26 of 2016) of Singapore (the “PDPA”). Please read this Privacy Policy carefully so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

1.2. Please note that this Privacy Policy governs only information provided to us via this web application (“Platform”). It does not govern any other information or communications that may reference Shiseido, for example, communications from Shiseido counters located within retail stores.

1.3. We may from time to time update and/or amend this Privacy Policy to ensure that it is consistent with any changes in applicable 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 and/or amended from time to time on this Platform. We encourage you to check this page regularly for updated information on the handling of your Personal Data.

1.4. For the purposes of 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 via this Platform include:

(a) your name, personal identification number (e.g. NRIC or passport number), contact number, mailing address, email address, photograph and any other information relating to you which you have provided us whether in electronic or other forms;

(b) information about your use of this Platform and our services, including cookies, IP address, subscription account details and membership details, but only to the extent that we may identify you from such information;

(c) your age, nationality, employment history, and income level; and

(d) information about your usage of and interaction with this Platform and/or our services.

1.5. By using this Platform, you agree and consent to us, our related entities, affiliates and subsidiaries, as well as their respective representatives and/or agents (collectively referred to herein as "Shiseido", "us", "we" or "our") collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties (as set out in paragraph 3.3) in the manner set forth in this Privacy Policy.

1.6. This Privacy Policy supplements and does not supersede nor replace any other consents you may have previously or separately provided to us. Your consent to this Privacy Policy is in addition to any other rights which we may have at law to collect, use or disclose your Personal Data.

1.7. This Privacy Policy and your use of this Platform shall be governed in all respects by the laws of Singapore.


2. Collection and Use of Personal Data

Collection of Personal Data

2.1. Shiseido collects your Personal Data when you submit your Personal Data or upload your photograph via this Platform for the Shiseido Ultimune #StrongSouls Campaign Site Photo Activity. Generally, Shiseido may also collect your Personal Data in the following ways:

(a) when you contact us with a question or request for assistance;

(b) when you request that we contact you;

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

(d) when you respond to our request for additional Personal Data;

(e) when you ask to be included in an email or other mailing list(s); and

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

Accuracy and completeness of Personal Data

2.2. 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/or services you have requested.

Personal Data of Third Parties

2.3. If you provide us with any Personal Data relating to any individual other than yourself (e.g. information of spouse, children, parents, employees and/or authorised representatives), you represent and warrant to us that:

(a) prior to disclosing such Personal Data to us, you had obtained the consent of these individuals, and that they have permitted you to disclose their Personal Data to us and permitted us to collect, use, disclose and/or process their Personal Data for the Purposes, as set out in paragraph 2.5 below;

(b) any Personal Data of individuals that you disclose to us is complete, accurate, true and correct; and

(c) you are validly acting on behalf of such individuals and have the authority of such individuals to provide their Personal Data to us and for us to collect, use, disclose and process such Personal Data for the Purposes.

Children’s Privacy

2.4. We do not, and do not intend to, transact through this Platform directly with anyone whom we know to be under the age of 18. If you are under the age of 18, you should use this Platform only with the supervision of a parent or guardian and should not submit any Personal Data to us. By providing any Personal Data to us, you declare and confirm that you are over the age of 18.

Use of Personal Data

2.5. Generally, the Personal Data collected by Shiseido from you via this Platform will be used for the following purposes:

(a) the administration, conduct and management of the Shiseido Ultimune #StrongSouls Campaign Site Photo Activity and any programme, event or activity organised in connection therewith;

(b) communicating marketing promotions, advertising and updates in relation to our goods and services;

(c) responding to your queries and feedback;

(d) obtaining feedback on our products and services;

(e) carrying out market research and surveys, and generally to assist us in our marketing efforts;

(f) managing, developing and improving our business and operations;

(g) verifying your identity;

(h) protecting and enforcing our contractual and legal rights and obligations;

(i) preventing, detecting and investigating crime, including fraud and money-laundering, and analysing and managing other commercial risks;

(j) safeguarding the interests of Shiseido in the event of any claim, litigation, suits;

(k) meeting any legal or regulatory requirements relating to our provision of services and to make disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to us or to our affiliates; and

(l) any other purpose relating to any of the foregoing purposes,

(collectively, the “Purposes”).

Collection and use of Anonymised Information

2.6. For the avoidance of doubt, you acknowledge and consent to Shiseido sharing anonymised information (i.e. information which does not identify any particular individual), including but not limited to in the following ways:

(a) we may share anonymised aggregate information about our customers with advertisers and marketing partners; and

(b) a third party may use technology to collect anonymised information about your use of this Platform so that they can provide advertising about products and services tailored to your interest. That advertising may appear either when you are using the Platform, or using the Internet or your mobile device to visit other websites.

Please note that the PDPA does not apply to anonymised data that does not identify an individual and the PDPA does not provide you with a right to object to an organisation handling or processing anonymised data.


3. Disclosure of Personal Data

3.1. Subject to the provisions of any applicable law, we may share your Personal Data with the following third parties, whether they are located in Singapore or overseas:

(a) Shiseido’s subsidiaries, business partners and affiliates that distribute and market Shiseido products or provide related services in connection with our services;

(b) our auditors, consultants, lawyers, accountants or other professional advisers appointed in connection with our services;

(c) our third party service providers, management companies, contractors, agents or other parties as may be deemed necessary by us to facilitate your dealings with us;

(d) any persons, government agencies, statutory authorities and/or industry regulators, for the purpose of complying with any applicable laws or regulations;

(e) anyone to whom we transfer or may transfer our rights and duties, including any actual or proposed assignee or transferee of the business of Shiseido, or a merged entity in the event Shiseido is merged to create such merged entity; and

(f) any other party to whom you authorise us to disclose your Personal Data.

3.2. The third parties to whom we provide your Personal Data in accordance with this Privacy Policy may use your Personal Data in accordance with this Privacy Policy including, if you have so elected, to send you email containing product information or promotions. If you prefer for us not to share your Personal Data with third parties in accordance with this Privacy Policy, please do not provide it to us.

3.3. Third parties who may receive your Personal Data in accordance with this Privacy Policy and the databases in which your Personal Data is stored may be located in Singapore as well as in other jurisdictions which may have varying legal protections applicable to Personal Data. All third parties who receive your Personal Data are required to honour the privacy representations made in this Privacy Policy, regardless of where they are located. In particular, where your Personal Data is to be transferred out of Singapore, we will comply with the PDPA in doing so. This includes taking appropriate steps to ascertain that the overseas recipient of the Personal Data is bound by legally enforceable obligations to provide to the transferred Personal Data a standard of protection that is at least comparable to the protection accorded under the PDPA.


4. Right to Withdraw Consent

4.1. You may at any time withdraw your consent to our continued use and disclosure of, or limit the processing of, your Personal Data currently in our possession or control. Should you wish to withdraw consent to the use and disclosure of your Personal Data or limit the processing of your Personal Data, you may do so by submitting your request via email to corporatecomm@tr.shiseido.com. 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. We will process your request within a reasonable time from such request being made, and will subsequently not collect, use and/or disclose your Personal Data in the manner stated in your request, save to the extent that we are permitted to do so by the PDPA.

4.2. If your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to Shiseido on your behalf.

4.3. If you choose to withdraw your consent to any or all use of your Personal Data, you acknowledge that we may not be able to provide or continue providing certain goods and/or services to you, or administer any contractual relationship in place, and accordingly, we may cease the provision of such goods and/or services without liability. This may also result in the termination of any agreements with Shiseido, and/or result in you being in breach of your contractual obligations or undertakings in respect of such agreements. In such event, Shiseido’s rights and remedies are expressly reserved.


5. Right of Access and Correction

5.1. You may at any time request for access to, or correction of, your Personal Data currently in our possession or control, by submitting your request via email to corporatecomm@tr.shiseido.com.

5.2. For a request to access Personal Data, once we have sufficient information from you to deal with the request, we will endeavour to provide you with the relevant Personal Data as soon as reasonably practicable. Please note that the PDPA exempts certain types of Personal Data from being subject to your request for access.

5.3. For a request to correct Personal Data, once we have sufficient information from you to deal with the request, we will endeavour to correct your Personal Data as soon as reasonably practicable. Please note that the PDPA exempts certain types of Personal Data from being subject to your request for correction. In addition, the PDPA also provides for circumstances where correction need not be made by us despite your request.

5.4. To help us maintain the accuracy of your Personal Data, please inform us whenever there are any changes to your Personal Data which you have provided us by submitting such new information via email to corporatecomm@tr.shiseido.com. While we will take reasonable efforts to ensure that your Personal Data is accurate and complete, we will not be responsible for relying on inaccurate or incomplete Personal Data provided by you or due to your failure to update us of any changes in your Personal Data that you had initially provided us with.


6. Protection, Policies and Procedures

We will endeavour to take all reasonable measures to protect and secure your Personal Data against unauthorised collection, use, disclosure, modification, disposal or destruction. We strive to ensure that our systems are secure and that they meet industry standards. However, we cannot assume responsibility for any unauthorised use of your Personal Data by third parties which are wholly attributable to factors beyond our control. Notwithstanding our security measures for the protection of your Personal Data, please note that no data transmission over the Internet is completely secure, and by providing your Personal Data, you acknowledge that you are transmitting that information at your own risk.


7. Retention of Personal Data

Shiseido will retain your Personal Data for as long as you use our products or services and it is necessarily required or relevant for business or legal purposes. Any Personal Data retained by us shall be destroyed and/or anonymised as soon as it is reasonable to assume that (a) the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data; and (b) retention is no longer necessary for any other business or legal purposes.


8. Cookies

8.1. We use cookies (an alphanumeric identifier that we transfer to your computer’s or mobile device’s hard drive so that we can recognise your web browser or mobile device and track your visits to the Platform) to monitor your use of the Platform. Such information is collected on an aggregate, anonymous basis, which means no Personal Data is associated with this data and gathered through the use of web server logs and cookies. You may disable cookies by changing the settings on your web browser or mobile device, although this may mean that certain features on the Platform will not function properly if you set your web browser or mobile device to not accept cookies.

8.2. By accessing and using this Platform and services, you consent to the storage of cookies, other local storage technologies, beacons and other information on your devices. You also consent to the access of such cookies, local storage technologies, beacons and information by us or our representatives or agents.


9. Third-Party Sites

This Platform may contain links to third-party websites, applications or services that are outside our control. For example, we may enable you to share certain materials on our products and services with others through social networking services such as Facebook. We are not responsible for the privacy practices of the websites, applications or services operated by third parties, or the security or privacy of any information collected by such third party websites, applications or services. Some of these websites or applications may display our logo or trademark, even though they are not operated or maintained by us. We would encourage you to exercise caution, and review the privacy statements applicable to the third-party websites, applications and services you use to determine how they will handle any information they collect from you. To the fullest extent permitted under applicable laws, we cannot be responsible for a third party's acts, omissions, data policies or their use of cookies nor the content or security of any third party websites or applications, even if linked to this Platform. Any such liability is expressly disclaimed and excluded.


10. Contact us

10.1. Should you have any feedback or enquiry relating to your Personal Data or our privacy practices, please contact our Data Protection Officer via email at corporatecomm@tr.shiseido.com.

10.2. For more information about PDPA in general, please visit the Personal Data Protection Commission’s website at http://www.pdpc.gov.sg/.