1.           Purpose of this Privacy Policy

1.1         This Privacy Policy (this “Policy”) is issued pursuant to the Personal Data Protection Act 2012 under the laws of Singapore (the “PDPA”) and sets out how Majeton Pte Ltd (the “Company”, “we”, “us”, “our”, “ourselves”) may collect, hold, process, and use the personal data of our customers.  The Company is part of the Essex group of companies which includes the Company and other affiliated or related companies from time to time (“Affiliates”) whose activities may include (from time to time) the Goods and Services.  This Policy applies as between us and you as our customer (“you”, “your”).  In this Policy, the following words and expressions have the following meanings:

“Goods and Services” means goods or services in relation to any of the following (whether through physical or online channels or in any other media now known or available in the future): catering and catering services; food and beverages; restaurants; accounting, auditing, bookkeeping brokerage, mortgage, taxation, and financial services; advertising, public relations, and media production services; agricultural services; architectural, engineering, surveying, and home inspection services; baby products; bags and luggage; banking, lending, investment and financial services; barber and salon services; books and paper products; business information and support services; building maintenance services; casino services; childcare services; cigarettes and cigars; clothing; computer software, games, and gaming services; conference, exhibition management, events, and project management services; consultancy and marketing research services; cosmetics; courier and shipping services; education services; data storage and management services; debt collection agencies; electronics and electrical appliances; equipment rental services; fashion and accessories; florists; fragrances; fuel, oil, and gas services; funeral services; furniture; graphic and interior design services; gym and fitness products and services; health and beauty products and services; home/household products and services; housekeeping services; insurance products and services; hospitality services; hospitals and nursing homes; Internet and telecommunication services; investigative services; janitor services; jewellery; laundry products and services; legal services; locksmiths; mentoring and tutoring; motor vehicles, motor vehicle products and services, motor vehicle towing services, and motor vehicle and general merchandise; pets products and services; pharmaceutical and medical devices/products and services; photography services; plants and accessories, and landscaping and plant maintenance services; plumbing products and services; printing and publishing services; property management services, real estate agencies, investment, leasing, management, and sales services; recreational and spot facilities and services; retail and wholesale solutions and services and supply chain management; reward, loyalty, and privileges programmes; secretarial services; security services; shoes; sports and leisure equipment; stationary; storage and warehousing services; telephones and mobile devices; therapists; toys; airlines, boat, limousine, taxi, truck, and other transportation services; travel agencies and tourism services; utilities services; valuation services; watches; and/or wine and liquor.

“Service Providers” means our authorised third-party accountants, advisers, agents, contractors, dealers, financial or professional advisers, legal advisers, marketing partners, representatives, retailers, service centres, wholesalers, and/or other third-party service providers from time to time which provide the Goods and Services.

2.           What Personal Data do we collect?

2.1         We may collect your Personal Data (or any of them).  In this Policy, “Personal Data” means any data, whether true or not, about you such that you can be identified from that data or from that data and other information to which we have or are likely to have access, including:

(A)         your name, title, gender, date of birth, age, marital/relationship status, family status, image/photograph, and copies/details of your identity documents, and proof of address;

(B)         contact details (including personal email address, personal telephone number, personal facsimile number, personal address, business email address, business telephone number, business facsimile number, business address/work location) and your emergency contact details;

(C)         occupation, position/job title, and company name;

(D)         technical information where you access any of our, our Affiliates’, and/or our Service Providers’ applications, websites, and/or other software platforms (“Platforms”) including internet protocol address, login data, browser (type and version), time zone setting and geo-location information, browser plug-in types and versions, operating system (type and version), equipment identifier (for example, IMEI), device type/manufacturer, network type, wireless carrier/operator, other technology on the device used to access such Platforms, and how the Platforms are used;

(E)         medical reports, results of medical examinations, or other surveys/questionnaires carried out by the Company and/or its Affiliates at your request, and/or the prognosis or any other information related to any medical conditions;

(F)         other personal/profile information (including personal identifiers; social media links; personal and professional interests and preferences; favourite activities; any Goods and Services you may have purchased from us, our Affiliates, and/or our Service providers; your experiences of and how you use our Goods and Services; preferred language; and dietary requirements); and

(G)         any other data or information provided to us when you contact us and/or purchase any of our and/or any of our Affiliates’ Goods and Services.

3.           What are the purposes of collection of your Personal Data?

3.1         We generally do not collect your Personal Data unless:

(A)         it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your Personal Data to us (your “Authorised Representative”) after: (i) you (or your Authorised Representative) have been notified of the purposes for which the Personal Data is collected; and (ii) you (or your Authorised Representative) have provided written consent to the collection and usage of your Personal Data for those purposes;

(B)         collection and use of Personal Data without consent is permitted or required by the PDPA or other laws.

3.2         We may collect your Personal Data for ourselves and for and on behalf of our Affiliates and/or our Service Providers for the Purposes.  In this Policy, “Purpose” means:

(A)         to manage our relationship with you, including the Personal Data we hold about you and notifying you about changes to this Policy;

(B)         assessment of your medical condition;

(C)         storing your Personal Data (whether physically, electronically, or any other means whether now known or available in the future);

(D)         registering you as a user of any Platforms;

(E)         following such registration, accessing and managing your account (including, without limitation, changing your password, updating Personal Data, etc.);

(F)         providing you with support, including investigating and responding to enquiries, complaints, and/or suggestions from you;

(G)         seeking your feedback, including through surveys, in relation to the Platforms and/or our (and our Affiliates’ and/or our Service Providers’) Goods and Services;

(H)         the normal management, operation, and maintenance of the Platforms;

(I)           data analytics, profiling, information management and database administration;

(J)          improving existing Goods and Services or designing new goods and services;

(K)         detection, investigation and/or prevention of activities that may violate, or may be suspected to violate, our policies or may be illegal;

(L)          prevention or detection of crime;

(M)         disclosure/transfer of your Personal Data as set out in this Policy or as required by law or court orders;

(N)         marketing and other business promotion purposes in relation to our, our Affiliates, and/or our Service Providers’ Goods and Services;

(O)         to deliver relevant content to you through the Platforms (and measure and understand the effectiveness of such content), improving the Platforms and our (and our Affiliates’ and/or our Service Providers’) Goods and Services;

(P)         other purposes ancillary or related to the above.

3.3         To enable us to perform the Purposes, it is necessary for you to provide us with your Personal Data that is marked as being “required” or “mandatory”.  It is entirely voluntary for you to provide this other Personal Data which is not marked as “required” or “mandatory” at the time of collection.  However, if you do not provide us with such Personal Data, we may not be able to perform the Purposes or provide Goods and Services to you.  We may also request other Personal Data about you for the Purposes.  We shall seek your consent before collecting any additional Personal Data and before using your Personal Data for a purpose which has not been notified to you (except where permitted or authorised by law).

3.4         This Policy does not apply to aggregated information which summarises statistical information about groups of individuals, and which does not include name, contact information, or any other information that would allow any particular individual to be identified.  We may use your Personal Data for aggregated behavioural analysis, including using anonymised Personal Data for statistical and demographic analysis, data science studies, and data mining.

4.           Disclosure and transfer of Personal Data

4.1         Your Personal Data may be transferred to and/or stored by us in physical locations and/or servers located within or outside Singapore and/or shared with our Affiliates and/or our Service Providers located within or outside Singapore.  We may disclose/transfer (whether in Hong Kong or abroad) your Personal Data:

(A)         to our Affiliates and/or our Service Providers in connection with the Purposes and/or the provision of the Goods and Services, and so that they may provide (among other things) administrative, data processing, development and maintenance, digital storage, distribution, information technology and telecommunications, marketing and research, professional, or other similar services to us including, without limitation, in relation to the Platforms and cloud hosting service providers (which provides us with digital storage services on their servers);

(B)         to employees of the Company and/or its Affiliates (and their employees) in connection with the Purposes including, without limitation, in relation to the Platforms;

(C)         to any of our and/or our Affiliate’s actual or proposed purchasers, assignees, or transferees of our rights with respect to your Personal Data in the event of any actual or proposed transfer of business, transfer of shares, re-structuring, amalgamation, merger, sale, transfer, or purchase of us or our Affiliates (in whole or in part), to collect, hold, process, and/or use such Personal Data for the Purposes;

(D)         to any person to whom the Company, our Affiliates, and/or our Service Providers are under an obligation or otherwise required to make disclosure under the requirement of any applicable law, regulation, or any action of any regulatory authority, court, tribunal, or government agency.

4.2         Where we transfer your Personal Data outside of Singapore, we will take steps to ensure that your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

5.           Withdrawing your consent

5.1         The consent that you provide for the collection, holding, processing, and use of your Personal Data will remain valid until such time it is being withdrawn by you in writing.  You may withdraw consent and request us to stop collecting, using, and/or disclosing your Personal Data for any or all of the Purposes by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

5.2         Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.  In general, we shall seek to process your request within ten (10) business days of receiving it.

5.3         Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our Goods and Services to you and we shall, in such circumstances, notify you before completing the processing of your request.  Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above.

5.4         Please note that withdrawing consent does not affect our right to continue to collect, hold, process, use, and disclose Personal Data where to do so without consent is permitted or required under applicable laws.

6.           Security of your Personal Data

6.1         To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have introduced appropriate administrative, physical, and technical measures.  However, please note 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 your Personal Data and are constantly reviewing and enhancing our information security measures.

7.           Retention of your Personal Data

7.1         We may retain your 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.  We will cease to retain your Personal Data, or remove the means by which the Personal Data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the Purposes for which the Personal Data was collected, and is no longer necessary for legal or business purposes.

8.           Your rights in relation to your Personal Data

8.1         Under and in accordance with the terms of the PDPA, you have the right to:

(A)         ascertain our policies and practices (from time to time) in relation to personal data (as defined in the PDPA) generally, the types of personal data held by us, and the main purposes for which personal data held by us is, or is to be, used;

(B)         ascertain whether we hold any of your personal data;

(C)         request access to your personal data held by us (and be given reasons if such a request is refused and to object to such refusal);

(D)         request us to correct any of your personal data held by us which is inaccurate (and be given reasons if such a request is refused and to object to such refusal).

8.2         We will respond to your request as soon as reasonably possible.  In general, our response will be within thirty (30) business days.  Should we not be able to respond to your request within thirty (30) business days after receiving your request, we will inform you in writing within thirty (30) business days of the time by which we will be able to respond to your request.  If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

8.3         In accordance with the PDPA, we have the right to charge you a reasonable fee for the processing of any personal data access request.  If so, we will inform you of the fee before processing your request.

8.4         If you would like to make a request in relation to the above (or make any general enquiries), please send us your request or enquiry in writing by email addressed to our Data Protection Officer at dpo@essexbio.com.sg.

9.           Miscellaneous

9.1         We may revise this Policy from time to time without any prior notice.  You may determine if any such revision has taken place by referring to the date on which this Policy was last updated.  Your continued use of our Goods and Services constitutes your acknowledgement and acceptance of such changes.

Effective: 15 January 2025