Luxasia Pte Ltd, its Subsidiaries and Affiliated Companies (“Luxasia”)
Updated as at 27 Apr 2018
Overview and Scope
Your personal data privacy is important to us and Luxasia are highly committed in respecting and managing your Personal Data collected in line with this Policy.
When and what kind of Personal Data do we collect?
Luxasia may collect, use and disclose the following data about you:
Luxasia may collect the following kinds of Personal Data through the different channels mentioned above:
What purposes does Luxasia Collect, Use and Disclose Personal Data?
Luxasia may use the information we collect from you for any of the following purposes:
We may also contact you by any means of communication for which you have given us contact details, including but not limited to via email, telephone numbers, and post, for the purpose of getting your feedback or for providing you with information which we believe could be of interest to you or your organisation.
By your submission of your Personal Data to us, you consent to the onward disclosure of your Personal Data to these agents or service providers and the processing of your Personal data by these agents or service providers. These agents and service providers include:
1. Affiliated companies within Luxasia for marketing and administrative purposes (i.e. verification and IT purposes); and
2. Marketing partners and third-party service providers (such as subcontractors, agents or network operators providing IT, website, customer relationship management and marketing support) who perform functions such as marketing. The entities to whom we disclose your Personal Data may be located in a range of countries.
The countries in which these third parties are located will depend on the circumstances. In the ordinary course of business we commonly disclose Personal Data to parties located in Singapore. Luxasia may also disclose or transfer out of the country personal data as permitted or required by law. In the event any cross-border transfer or disclosure is required, we will take steps to ensure that the recipient organisation will take reasonable measures in the protection of your personal data.
Consent for the collection and use of my Personal Data
In this regard, please note that it is on your part to ensure that all personal data submitted to us is complete, accurate, true and correct at the time of submission. Failure on your part to do so may result in our inability to provide you with products and services you have requested.
Please note that if you do not consent to any of the above business purposes, Luxasia may also be unable to meet the purposes for which the information was collected.
Luxasia shall not be liable for any damage, claim and/or harm suffered by you as a result of your failure to update us of any change of your Personal Data.
Does Luxasia disclose Personal Data to third parties?
Luxasia may disclose your Personal Data to any member of our group, which means our subsidiaries, affiliates, our ultimate holding company and its affiliates or subsidiaries, as defined in the Companies Act (Cap. 50).
On occasion, Luxasia may use third party agents and service providers to assist us in the use of your Personal Data as outlined under "What purposes does Luxasia Collect, Use and Disclose Personal Data?" You consent to such use of your Personal Data by continuing to browse on Luxasia’s website.
Luxasia will not transfer Personal Data within or outside Singapore unless it is ensured that the Personal Data will be accorded a level of protection which is comparable to the protection under the PDPA.
For how long does Luxasia retain my Personal Data?
Luxasia will cease to retain Personal Data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.
How does Luxasia protect your Personal Data?
The Personal Data that we hold about you will be stored on our servers. Luxasia implements a variety of security measures to maintain the safety of your submitted information. All electronic storage and transmission of personal data is secured and stored on managed servers with controlled access and appropriate security technologies.
Although every reasonable effort has been made to ensure that all personal data will be so protected, Luxasia cannot be responsible for any unauthorised use or misuse of such information and from risks which are inherent in all internet communications.
Your Personal Data will only be disclosed for the express purpose of delivering the product or service requested and shall not be sold or disclosed to any other company for any other reason whatsoever without your consent.
Links to third party websites from Luxasia’s website
Access and Correction of Personal Data
Please contact us via email@example.com should you wish to have access to or seek to update, correct or withdraw the consent to collect and use your Personal Data. Your email should identify yourself and state which Personal Data and information about its use and/or disclosure is requested.
Luxasia reserves the right to change this Policy with or without notice from time to time.
Luxasia Pte Ltd, its Subsidiaries and Affiliated Companies (“Luxasia”)
Updated 19 July 2018
1. Collection and Use of Personal Data
1.1 This policy regulates the way in which Luxasia obtains, uses, holds, transfers and otherwise processes your personal data. It is also intended to ensure that personnel understand the rules on the protection of personal data and the individual’s rights in relation to their personal data processed by Luxasia. In addition, the policy regulates the circumstances in which one Company entity processes personal data on behalf of another Company entity.
1.2 Luxasia processes personal data about individuals such as its personnel (past and present), job applicants, client contacts and contacts/personal data provided by clients and business partners, supplier contacts, website users, and shareholders. Luxasia processes such personal data for a number of business purposes, including:
(a) Scheduling/Rostering for staffing retail outlets, counters and stores and work related projects and activities;
(b) Recruitment, including evaluation of an individual for suitability of employment;
(c) Assessment of security clearance and access controls at Luxasia;
(d) Employee performance management and professional development;
(e) Payroll, claims reimbursements and accounting;
(f) Assessing insurance coverage and provision of medical services;
(g) Knowledge management and training;
(h) Government and other regulatory reporting;
(i) Business and market development;
(j) Publicity, internal and external marketing purposes;
(k) For security, surveillance and employee monitoring purposes;
(l) For travel arrangements and determining Per Diems and application of corporate purchasing credit cards;
(m) For internal reporting and/or accounting purposes; and
(n) Other purposes required by law or regulation;
1.3 Please note that if you do not consent to any of the above business purposes, it may affect Luxasia’s ability to continue an employer/employee relationship with you.
2. Luxasia's Duties
2.1 Luxasia will process your personal data in accordance with the Personal Data Protection Act 2012 (the “PDPA”). In particular, Luxasia will not process personal data unless one of the following conditions is met:
(a) the individual concerned has consented to such processing;
(b) Luxasia needs to carry out such processing (i) to perform, or take steps with view to enter into, a contract with the individual concerned, (ii) to comply with legal obligation of Luxasia or (iii) to protect the vital interests of the individual concerned in a `life or death' situation; or
(c) Luxasia needs to carry out such processing to pursue Luxasia's legitimate interests, and those interests are not overridden because the processing prejudices the interests or fundamental rights and freedoms of the individual concerned.
2.2 When an individual gives Luxasia his/her personal data, Luxasia will observe compliance with the PDPA.
2.3 Luxasia will make sure that information to individuals is also provided in all instances where existing personal data are going to be used in a new way, or for different purposes.
2.4 Luxasia will not collect Personal Data unless: (a) you consent to such collection, or (b) Luxasia needs to do so to meet its obligations or exercise its rights under employment law, or (c) in exceptional circumstances such as where the processing is necessary to protect the vital interests of the individual concerned, or (d) in circumstances permitted by the PDPA.
2.5 Luxasia may in exceptional circumstances, rely on consent given on behalf of the individual, for example, by a company employee on behalf of a family member.
2.6 Luxasia shall:
(a) not collect excessive personal data;
(b) the personal data collected are adequate and relevant for the intended purposes, accurate and up to date;
(c) process personal data only for the purposes specified in this policy or in information provided to the individual concerned; and
(d) one of the conditions in section 2.1 is met if it processes personal data for new or different purposes.
2.7 Luxasia will maintain retention policies and procedures so that personal data is deleted after a reasonable time, given the purposes for which the personal data are held, except where, given those purposes, another law requires the data to be kept for a certain time. When Luxasia no longer needs to keep personal data for the purposes for which they are held, it will destroy them as soon as practicable.
2.8 Luxasia will maintain organizational, physical and technical security arrangements in relation to all of the personal data it holds.
2.9 Luxasia will not transfer personal data to entities outside Luxasia in other countries for further processing unless such entities agree to abide by a data privacy standard at least as high as this policy, or enter into a contractual arrangement. The only exceptions are where:
(a) the transfer is necessary to (i) protect the vital interests of the individual concerned in a `life or death' situation, or (ii) enter into or perform a contract with (or for the benefit of) that individual; or
(b) the individual has consented to the transfer.
2.10 Luxasia has procedures to deal with any suspected breach of data security arrangements, unauthorized access or disclosure, or loss of personal data.
3. An Individual's Rights
3.1 Right of Access and Correction
3.1.1 Your Right of Access and Correction shall be as set out in the PDPA.
4. Company Compliance with this Policy
4.1 Luxasia will maintain internal arrangements to:
(a) facilitate compliance with this policy;
(b) allow effective exercise of individuals' rights guaranteed in the policy; and
(c) consider and respond to complaints from individuals that Luxasia may not have complied with this policy.
All individuals may rely upon these procedures and/or exercise their rights provided for in the policy by contacting the Data Privacy Officer (“the DPO). The email address of the DPO is firstname.lastname@example.org.
4.2 This Policy may be routinely updated. Please check this page to ensure that you are familiar with the most updated version of the Policy.