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 is highly committed to 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:
1. When you provide Personal Data by filling in forms on any of the Luxasia Group of Companies’ websites and web-based programs, when giving feedback, asking queries, requests and submissions;
2. If and when you contact Luxasia, we may keep a record of that correspondence;
3. Details of your visits to our website including, but not limited to, cookies, location data, weblogs and other communication data, that you access;
4. When you fill up a customer data form or join any of Luxasia’s membership programme at any Luxasia retail outlet, counter or pop-up store;
5. If you enter into any contract with Luxasia or purchase any products from Luxasia;
6. If you participate in any exhibition/event organised by Luxasia or where Luxasia is a participant.
7. When you provide Personal Data by filling in forms for specific services
Luxasia may collect the following kinds of Personal Data through the different channels mentioned above:
2. ID/Passport/Work Permit/TIN numbers and copies;
3. Date of Birth;
4. Mailing and residential addresses;
5. Email addresses;
6. Telephone numbers;
7. Gender; and
8. Photos and CCTV/videos;
9. Medical history and/or skin conditions (for specific services)
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:
1. To perform or carry out Luxasia’s obligations arising from any contracts entered into between you and us (i.e. purchase and delivery of Luxasia’s products and services);
2. To enable Luxasia’s subcontractors, third-party agents and service providers, to fulfil obligations as stipulated in your contract with Luxasia;
3. To handle products and services requests and enquiries (including payments for products and services);
4. To administer and update your records in our databases; monitoring and maintaining a copy of your record of previous transactions;
5. To facilitate the delivery, maintenance and enhancement of Luxasia’s products, services, programmes, activities, and events;
6. To plan, monitor and enhance the provision of new products, services, projects, programmes, activities, and events;
7. To improve Luxasia’s customer service through your feedback and provide recommendations;
8. To process your enquiries and any and all other ancillary administrative purposes;
9. To send regular e-newsletters;
10. To process, formulate, tabulate or evaluate contest information, promotion or other marketing activities;
11. For communications, marketing, and publicity purposes;
12. For government, audit, and other regulatory purposes;
13. For security, surveillance, and monitoring purposes;
14. For internal reporting and/or accounting purposes; and
15. Purposes incidental to each or all of the above.
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 Philippines. 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 Philippines 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.