Table of Contents
IMPORTANT INFORMATION AND WHO WE ARE
This website is not intended for children and we do not knowingly collect data relating to children.
RESPONSIBILITY FOR YOUR PERSONAL DATA
My Pure Earth Pte Ltd (UEN 201634879)
You have the right to make a complaint at any time to the Personal Data Protection Commission (PDPC), the Singapore supervisory authority for data protection issues (https://www.pdpc.gov.sg/). We would, however, appreciate the chance to deal with your concerns before you approach the PDPC so please contact us in the first instance.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you. We have grouped together examples of different as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing & Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect (but the provider of our payment services plug-in will) financial data that will enable us to directly or indirectly identify you, such as your bank account number and details of your payment card.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will tell you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
WE USE DIFFERENT METHODS TO COLLECT DATA FROM AND ABOUT YOU INCLUDING THROUGH:
- Direct interactions. You may give us your Identity or Contact Data by filling in forms or by corresponding with us through our website, by email or social media. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Third parties or publicly available sources. We will receive personal data about you from various third parties, such as Technical Data from analytics providers such as Google, who may be based outside of Singapore or Contact Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe or DHL, who may be based outside of Singapore.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:
- Where we need to perform the contract we are about to enter into, or have entered into, with you.
- Where it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to Comply with a Legal Obligation
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data, because we rely on other lawful bases. We will, however, get your consent before you enter into a promotion or competition and before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our Legitimate Interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We aim to provide you with choices regarding certain personal data uses, particularly around Marketing & advertising.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent to the use of your personal data in any competitions we run.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us to stop sending you marketing messages at any time by logging into our website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting our DPO at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration (if any) or product experience or other transaction.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is permitted by law or in compliance with a legal obligation.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table in Part 4 above:
- External Third Parties as set out in the Glossary
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some of our External Third Parties are based outside Singapore, so their processing of your personal data will involve a transfer of data outside Singapore.
We will only transfer your personal data to External Third Parties based outside of Singapore where it is necessary for the Performance of a Contract between us and you, necessary to do anything at your request connected to entering into such a contract, or which a reasonable person would consider to be in your interests.
Whenever we transfer your personal data out of Singapore, we will only transfer your personal data to a recipient in a country or territory outside Singapore where we are satisfied that the recipient is bound, either by the law of that country or territory, or by a contract between us and the recipient, to provide to the personal data transferred a standard of protection that is comparable to that under the Personal Data Protection Act 2012.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we are permitted to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to and correct of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interests means “business innovation purposes” where that term is defined by the Personal Data Protection Act 2012 and the interests of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our Legitimate Interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our Legitimate Interests against any potential impact on you in respect of specific activities by contacting us.
Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a Legal Obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
EXTERNAL THIRD PARTIES
- Service providers based in the Philippines and Indonesia who provide bookkeeping, accounts and accounting services to us.
- Service providers based or operating in Singapore and other countries, such as postal services and couriers, to whom we must provide personal data in order to process and deliver products purchased from us.
- Professional advisers including lawyers, bankers, auditors and insurers based in countries where we need their consultancy, banking, legal, insurance and accounting services.
- IRAS, regulators and other authorities based in Singapore or elsewhere who require reporting of our activities in certain circumstances.