Privacy Policy

This is Sebastian Liew Centre Pte Ltd (SLC) Privacy Policy.

SLC collects, uses and discloses Customer Data in order to provide you with a safe, smooth, efficient and customised experience with SLC.

The collection, use and disclosure of Customer Data enables SLC to provide services and products that are most likely to meet your needs and requirements. This Privacy Policy outlines SLC’s policy and responsibility in relation to the collection, use and disclosure of Customer Data.

By continuing to use SLC’s services, you signify that you have read, understood and agree to be bound by this Privacy Policy as amended from time to time in respect of SLC’s collection, use and disclosure of your Customer Data.

 

This Privacy Policy is divided into two Parts – A and B:

  • Part A: General Customer Data privacy policy statement

  • Part B: Privacy policy statement for Customer Data collected through SLC’s website and SLC’s mobile services facility

PART A: GENERAL CUSTOMER DATA PRIVACY POLICY STATEMENT

1. Types of Customer Data 
The types of Customer Data that SLC collects depends on the circumstances of collection and on the nature of the service requested or transaction undertaken.

There are two broad categories of Customer Data that SLC collects depending on the circumstances:

  • Personal Data, which includes but is not limited to –

    • personal information that links back to an individual e.g., name, gender, date of birth, passport or other personal identification numbers;

    • contact information e.g., address, phone number, email address;

    • payment information e.g., credit or debit card information, including the name of cardholder, card number, billing address and expiry date;

    • order information e.g., order information, product purchased or other service preferences;

    • technical information e.g., IP address; and

  • Statistical Data e.g., number of orders, visits to website. This is stored purely for analytical purposes, and is entirely anonymous. This information will not be stored to your customer record, and will only be aggregated for statistical analysis so that we can better understand SLC’s customer profile and improve SLC’s service offering.

For purposes of this policy statement, the phrase Customer Data includes Personal Data and Statistical Data.

The provision of Customer Data relevant for the transaction or service request at hand, (save for where the request for data is marked “optional” in the forms used to collect personal data) is obligatory in order for SLC to carry out its services to you.

The failure to supply such Customer Data may result in (i) SLC being unable to provide you with the services and/or products requested; (ii) SLC being unable to update you on our latest products and/or launches; and/or (iii) your inability to enter or participate in contests, promotions or redemption activities organised by SLC.


2. Purposes for Collection, Use and Disclosure 
Generally, SLC collects Customer Data, either directly from you or from your authorised representatives (i.e. persons whom you have authorised, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), from third parties (e.g., our service provider), or from publicly available sources, through our website, mobile services, and other channels including our roadshow counters in order to fulfil the following purposes, which include but are not limited to:

  • Providing in-store services and other services that best meet your preferences and needs (which we may collect during our interactions with you);

  • Marketing and communicating with you in relation to products and services offered by SLC, SLC’s service partners, as well as SLC’s appointed agents;

  • Contacting you for product or customer satisfaction surveys and market research; and

  • Safety, security and legal compliance.

SLC may also use and disclose your Customer Data with and to third parties in order to fulfill the purposes listed above.

In connection with the above, we may disclose your Customer Data to third parties, such as our freight service providers and logistics partners.

SLC may also use and disclose your Customer Data to persons who have been validly identified as being you or your authorised representative(s) pursuant to our then-current security procedures, for the purpose of the relevant transaction or enquiry.

SLC shall use its best endeavours to ensure that its employees, officers, agents, consultants, contractors and such other third parties mentioned above who are involved in the collection, use and disclosure of Customer Data will observe and adhere to the terms of this Privacy Policy.

SLC may disclose your Customer Data to law enforcement agencies and government for security, customs purposes. For example, in cases where you send a product from SLC to family and friends overseas.

In addition, SLC may disclose Customer Data to our legal advisors for establishing, exercising or defending our legal rights, to our other professional advisors, or as otherwise authorised or required by law. SLC also reserves the right to share Customer Data as is necessary to prevent a threat to the life, health or security of an individual. Further, SLC may disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.

3. Transfer of information overseas 
Data may be transferred to the SLC’s office and appointed agents in Singapore or other countries in connection with SLC’s performance of the contract with you.

4. Consent 
Generally, in the course of making a purchase at SLC or SLC performing servicing functions such as processing your order, helping you with membership registration, transmitting promotion alert messages or accepting payment information, Customer Data will, by nature of the task or transaction, be provided by Customer to SLC. In such instances, consent will necessarily be implied from the Customer that they are agreeable to providing Customer Data in order for SLC to provide the requested or necessary service and/or product to them. However, where required by law, SLC will adopt an ‘opt-in’ policy for obtaining customer consent, in which event, express written consent will be sought from you when collecting your Customer Data e.g., signing a form or checking a box. Where you make purchases on behalf of another person, you undertake and will ensure that the individual whose Customer Data is supplied to SLC has authorised the disclosure, is informed of and consents to the terms and conditions of this Privacy Policy.

Statistical Data is not linked to a customer record and SLC does not need to seek consent for the collection, use or disclosure of Statistical Data. For more information on the collection and usage of Customer Data obtained from SLC’s websites and through SLC’s mobile services facility, please refer to Part B.

5. Access 
SLC will, upon your written request to our Personal Data Protection Officer (see Section 10), allow you to access your stored Personal Data. Where permitted by law, SLC reserves the right to charge a reasonable administrative fee for this service. Where permitted by law, SLC reserves the right to deny you access to your Personal Data and may provide an explanation.

6. Retention 
SLC will retain Customer Data for as long as it is necessary to fulfill the purpose for which it was collected, the legal or business purposes of SLC, or as required by relevant laws.
When destroying Customer Data, we will take commercially reasonable and technically possible measures to make the personal information irrecoverable or irreproducible in accordance with the applicable laws.

7. Accuracy 
SLC needs your assistance to ensure that your Personal Data is current, complete and accurate. As such, please inform SLC of changes to your Personal Data by contacting SLC and submitting your updated particulars to SLC in writing (see Section 10). SLC may also request Personal Data updates from you from time to time. As detailed in Section 2 above under the “Use and Disclosure” sub-section, your order information may be disclosed to the appropriate customs and immigration authorities (for overseas purchases) as required by law. As such, it is important to ensure that the Personal Data contained in your order information is current, complete and accurate.

8. Security safeguards 
SLC takes the security and protection of your Customer Data very seriously. As such, SLC makes reasonable security arrangements to protect your Customer Data against loss or theft as well as unauthorised access and undue disclosure.

As an example of a procedural safeguard, SLC has implemented various authentication procedures internally and with our external service providers that may involve SLC requesting various personal particulars from you in order to verify your identity (or that of your duly authorised agent) before SLC processes your request for a particular service, product or transaction.

Examples of technical safeguards include encryption, and Secure Socket Layer (SSL). Further details of these technical safeguards for Customer Data collected through SLC’s website and SLC’s mobile services facility are set out at Part B below. If, however, a customer does not take reasonable care to ensure the continued confidentiality and accuracy of their Customer Data, SLC will not be liable for any consequential misuse and/or fraud. If you have any concerns about security, you should contact SLC (see Section 10).

9. Updates to the privacy policy 
SLC will amend this Privacy Policy from time to time and the updated versions will be posted on SLC’s website and date stamped so that you are aware of when the Privacy Policy was last updated. Subject to applicable laws, the English version of this Privacy Policy will prevail over any version of this Privacy Policy in another language. In the event of any inconsistency in interpretation between the English version and any translation of the Privacy Policy, this Privacy Policy statement in English will prevail.

10. Contact us / Personal Data Protection Officer Contact Details
If you have comments, questions or complaints about or requests relating to this Privacy Policy statement or how SLC handles personal data, please contact SLC in writing at the address below referencing ‘Privacy Policy’:

Personal Data Protection Officer

Sebastian Liew Centre Pte Ltd
320 Serangoon Rd
#11-10
Singapore 218108
电子邮件:customerservice@leaftolife.com.sg

referencing: Privacy Policy.

PART B: PRIVACY POLICY STATEMENT FOR CUSTOMER DATA COLLECTED THROUGH OUR WEBSITES AND OUR MOBILE SERVICES FACILITY

1. Security safeguards 
SLC takes the protection of your Customer Data collected on SLC’s websites and through SLC’s mobile services facility very seriously. All Customer Data collected through SLC’s websites, e.g., https://leaftolife.com.sg and through SLC’s mobile services facility are protected by a secure server. In addition, SSL (Secure Socket Layer) protects the transmission of data from the internet to our systems.

For example, when you transmit sensitive information such as credit card details through SLC’s websites, such information will be encrypted before being dispatched over the internet.

To further strengthen the integrity of your internet transactions on our websites, SLC also employs relevant software programs to mitigate unauthorised attempts to upload or change Customer Data, perpetuate fraudulent or illegal activities or otherwise cause damage. If such monitoring reveals evidence of possible abuse or criminal activities, such evidence may be provided to appropriate law enforcement authorities or agencies without notice to you.

2. Cookies 
Most websites use cookies to enhance your online experience. A cookie is a small string of information that the website that you visit transfers to your computer for identification purposes. Cookies can be used to follow your activity on the website and that information helps us to understand your preferences and improve your website experience. Cookies are also used to remember for instance your user name and password.

You can turn off all cookies, in case you prefer not to receive them. You can also have your computer warn you whenever cookies are being used. For both options you have to adjust your browser settings (like internet explorer). There are also software products available that can manage cookies for you. Please be aware though that when you have set your computer to reject cookies, it can limit the functionality of the website you visit and it’s possible then that you do not have access to some of the features on the website. 

3. Clickstream data 
In order to improve your online experience, SLC may track online behaviour or clickstream data to advance your use of our web pages and track referrals from other websites. Such data will not be stored to your customer record, and will only be aggregated for statistical analysis.

4. Links to other websites 
SLC provides you with links to other websites for your convenience and information. You access these websites at your own risk and SLC is not responsible for these websites. Whilst SLC will protect your Customer Data on SLC website, SLC cannot control or be responsible for the policies of other sites we may link to, or the use of any Customer Data you may share with them. Please note that the SLC Privacy Policy does not cover these other websites, and SLC would recommend that you are apprised of their specific policies.

5. Minors 
SLC cannot distinguish the age of persons who access and use its websites. If a minor (according to applicable laws) has provided SLC with Customer Data without parental or guardian consent, the parent or guardian should contact SLC to remove the relevant Customer Data and unsubscribe the minor.

6. Google Analytics 
Google Analytics is a web analysis service provided by Google. Google utilises the data collected to track and examine the use of leaftolife.com.sg, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. For more details, please refer to Google’s Privacy Policy.

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