Data Protection Notice
This Data Protection Notice (“Notice”) sets out the basis which The Verdant Lab (“we”, “us”, or “our”) and theverdantlab.com (the “Site”) 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. It comprises of device information and order information.
- “device information” means data about a customer’s web browser, IP address, time zone, cookies installed on his/her device, individual web pages or products that he/she views, websites or search terms which referred him/her to the Site and how the he/she interacts with the Site.
- “order information” means certain information collected from the customer, including name, billing address, shipping address, payment information (including but not limited to credit card numbers, Paypal data, Shopify pay data, Apple pay data, and Google pay data), email address, and phone number.
2. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
3. When the customer visits the Site, we automatically collect device information using the following technologies:
- “cookies” are data files that are placed on the customer’s device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “log files” track actions occurring on the Site, and collect data including the customer’s IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “web beacons”, “tags”, and “pixels” are electronic files used to record information about how the customer browses the Site.
4. When the customer purchases or attempts to make a purchase, and/or creates an account on the Site, we collect his/her order information.
5. We do not alter our Site’s data collection and use practices when we see a Do Not Track signal from the customer’s browser.
6. The customer’s personal data is used for the following purposes:
- fulfilling any orders placed through the Site (including processing the customer’s order information, arranging for shipping, and providing him/her with invoices, order confirmations and/or any other updates associated to his/her orders.
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from the customer;
- managing the customer’s relationship with us;
- screening our orders for potential risk or fraud;
- when in line with the preferences shared with the Site, providing the customer with targeted information, marketing communications or advertising relating to our products and services which we believe may be of interest. For more information about how targeted advertising works, please visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
The Customer can opt out of targeted advertising by using the links below:
- Facebook: https://www.facebook.com/settings/?tab=ads
- Google: https://www.google.com/settings/ads/anonymous
- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, the customer can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
- any other incidental business purposes related to or in connection with the above.
7. We may disclose the customer’s personal data:
- to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above-mentioned purposes. For example, we use Shopify to power the Site; the customer can read more about how Shopify uses his/her personal data here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site; the customer can read more about how Google uses his/her Personal Information here: https://www.google.com/intl/en/policies/privacy/. The customer can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
- to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
8. The purposes listed in the above clauses may continue to apply even in situations where the customer’s relationship with us has been terminated or altered in any way, for a reasonable period thereafter.
9. The consent that the customer provides for the collection, use and disclosure of his/her personal data will remain valid until such time it is being withdrawn by him/her in writing. He/she may withdraw consent and request us to stop collecting, using and/or disclosing his/her personal data for any or all of the purposes listed above by submitting his/her request in writing or via email to our Data Protection Officer at the contact details provided below.
10. Upon receipt of the customer’s written request to withdraw his/her consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with him/her) for the request to be processed and for us to notify him/her of the consequences of us acceding to the same, including any legal consequences which may affect his/her rights and liabilities to us. In general, we shall seek to process the request within seven (7) business days of receiving it.
11. Whilst we respect the customer’s decision to withdraw his/her consent, please note that depending on the nature and scope of the request, we may not be in a position to continue providing our goods or services and we shall, in such circumstances, notify him/her before completing the processing of the request. Should the customer decide to cancel the withdrawal of consent, he/she is requested to inform us in writing in the manner described in clause 9 above.
12. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
13. If the customer wishes to make (a) an access request for access to a copy of the personal data which we hold about him/her or information about the ways in which we use or disclose his/her personal data, or (b) a correction request to correct or update any of his/her personal data which we hold, he/she may submit the request in writing or via email to our Data Protection Officer at the contact details provided below.
14. Please note that a reasonable fee may be charged for an access request. If so, we will inform the customer of the fee before processing the request.
15. We will respond to the request as soon as reasonably possible. In general, our response will be within seven (7) business days. Should we not be able to respond to the request within thirty (30) days after receiving it, we will inform the customer in writing within thirty (30) days of the time by which we will be able to respond to his/her request. If we are unable to provide the customer with any personal data or to make a correction requested by him/her, we shall generally inform him/her 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
16. To safeguard the customers’ 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 disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
17. Customers 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 the personal data and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
18. We rely on personal data provided by the customer. In order to ensure that the personal data is current, complete and accurate, please update us if there are changes by informing our Data Protection Officer in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
19. We may retain the customer’s 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.
20. We will cease to retain personal data, or remove the means by which the data can be associated with the customer, 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.
DATA PROTECTION OFFICER21. The customer may contact our Data Protection Officer if there are any enquiries or feedback on our personal data protection policies and procedures, or if he/she wishes to make any request, in the following manner:
Name of DPO : Hue Xi Ming
Contact No. : +65 67560473
Email Address : firstname.lastname@example.org
EFFECT OF NOTICE AND CHANGES TO NOTICE
22. 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 the customer’s personal data by us.
23. We may revise this Notice from time to time without any prior notice. The customer may determine if any such revision has taken place by referring to the date on which this Notice was last updated. The customer’s continued use of our services constitutes his/her acknowledgement and acceptance of such changes.
Effective date: 19/09/2019
Last updated: 19/09/2019