Monthly Box Privacy Policy for Singapore
Effective: 01 June 2020
At Monthly Box, we recognize that privacy is a fundamental human right and further recognizes the importance of privacy, security and data protection to our customers and partners. This Privacy Policy (“Privacy Policy” or “Policy”) informs you of our privacy practices and of the choices you can make and rights you can exercise in relation to your personal data (“Personal Data”), including information that may be collected from your online activity, use of devices, and interactions you have with us, such as when you engage with our customer support representatives.
This Privacy Policy is governed by Singapore law and applies to personal data we obtain through websites, including www.monthlybox.sg (the “Website”), services, applications, subscriptions and products by Monthly Box PTE LTD (individually, “Monthly Box”), and those of our subsidiaries and affiliates (collectively, “we”, “us” or “our”), such as but not limited to:
- when you enroll in our Monthly Box Loyalty programs.
- when you register and/or use an account for our websites, services, applications, subscriptions, and products.
- when you submit any form, including, but not limited to, application forms or other forms relating to any of our websites, services, applications, subscriptions, and products, whether online or by way of a physical form.
- when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails, including when you interact with our customer service agents.
- when you use our electronic services or interact with us via our application or use services on our websites. This includes, without limitation, through cookies which we may deploy when you interact with our applications or website.
- when you provide us with feedback or complaints;
- when you register for events, such as, but not limited to, giveaways, contests;
- when you submit your personal data to us for any reason;
- through third-party sources, including business partners, advertising and social media companies, and vendors;
- through other data collection points that reference this Privacy Policy (collectively, the “Channels”); and
- through other offline interactions (collectively, “Offline Channels”), such as but not limited to, events and trade shows.
This Policy applies in conjunction with other notices, contractual clauses, consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override those notices or clauses unless we state expressly otherwise.
To the fullest extent permissible under applicable law, your continued use of the Website and/or Channels, including placing of any orders, shall constitute your acknowledgment and acceptance of the changes made to this Privacy Policy. If you do not consent to the processing of your personal data as described in this privacy policy, please do not use our services, access our websites and/or the Channels that reference this Privacy Policy.
Personal Data we collect
We collect personal data about you in different ways and from various sources, such as our website and events. Depending on the Channels you use and the nature of your interactions with us, you may provide us with certain types of personal data, including but not limited to:
- Contact information such as name, email address, postal address, fax number, and telephone number;
- Demographic information such as age, nationality, date of birth, education, profession, marital status, race, color, religion, sex, gender, medical condition, disability, citizenship status, and military and veteran status;
- Billing and financial information such as your payment card number, expiration date, security code, delivery address, and billing address;
- Government-issued ID information such as your passport, driver’s license, national registration identity card or other government-issued ID, which you may provide, for example, when participating in contests;
- User account information such as username and password when you sign up for our Monthly Box loyalty program;
- Content such as photos, comments, feedback, and other content you provide;
- Signature, which you may provide, for example, when confirming receipt of delivery;
- Any other personal data you provide through the Channels.
Personal Data Obtained from Other Sources
In addition to the personal data, you provide to us directly, we may obtain from other sources additional personal data about you, including:
- Friends and family-provided information such as information that your friends or family provide to us about you in connection with their reservations;
- Publicly available information such as name, contact information, content and online activity that we obtain from publicly available sources (such as public databases) and social media platforms you interact with;
- Device information such as geolocation data and other location information derived from your IP address, country, and zip code;
- Data collected by cookies and similar technologies such as information about your online activities, devices, browsing actions, and usage patterns across the Website and third-party websites that we obtain through the use of cookies, web beacons, and similar technologies;
- Video, audio and other sensory information such as images, video, audio, thermal, and olfactory data that may be collected or processed through our security cameras, closed-circuit television, recorded phone lines, voice recorders, and other technologies, where permitted by law;
- Location data;
- Sensory information such as audio, electronic, visual, thermal, olfactory, and similar information;
- Data from third-party sources such as personal data we obtain from our third-party service providers (including background check providers, data aggregators and data cleansing companies), business and marketing partners;
- Marketing and communications data, such as your preferences in receiving marketing from us and third parties, your communication preferences and history of communications with us, our service providers, and other third parties;
- Usage and transaction data, including details about your searches, orders, the advertising and content you interact with on the Website and/or Channels, and other products and services related to you;
- Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes;
- any other information about you when you sign up to use the Website or the Channels, and when you use the Website or the Channels, as well as information related to how you use the Website or the Channels; and
- aggregate data on content you engage with.
Collection of Other Data
As with most websites and mobile applications, your device sends information which may include data about you that gets logged by a web server when you browse our Website and/or Channels. This includes, but not limited to:
- Device and network information, including your device’s Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web site (if any), the pages you visit on our website and mobile applications and the times of visit, and sometimes a “cookie” (which can be disabled using your browser preferences) to help the site remember your last visit. If you are logged in, this information is associated with your personal account. The information is also included in anonymous statistics to allow us to understand how visitors use our site; and
- Advertising and other software information, such as when you watch content and advertising on our Website and/or the Channels, most of the same information may be sent to us (including, without limitation, IP Address, operating system, etc.); but, instead of page views, your device may send us information on the content, advertisement viewed and time.
How we use Personal Data
We may collect, use, disclose and/or process the personal information we obtain for various purposes, including:
- Processing and managing your orders, to process payment for your purchase of products and services, your application/transaction with us, your transactions or communications with third parties via the Channels;
- Managing our communications with you, to contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to the Website and Channels. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages, to
- Responding to you and providing support, to address your inquiries and feedback, requests, and other communications you send us, and provide you with respective information;
- Managing your account, to create, manage, and administer your loyalty account, and to provide you with certain offers and services (such as special events, promotional offers, etc.);
- Advertising and marketing, to present or send you messages, news, and other types of information about offers, promotions, and events that may be of interest to you, . We may use your contact information to send newsletters or marketing materials from us and from our related companies;
- Data Analytics, for know your customer purposes and to maintain, improve our products and services, to produce statistics and research for internal and statutory reporting and/or record-keeping requirements, to analyze behavioral patterns;
- Prevention and Protection, to enforce our Terms of Service or any applicable end user license agreements, to protect personal safety and the rights, property or safety of others, for identification, verification or due diligence;
- Operating, evaluating, and improving our business, to perform accounting, auditing, record keeping, credit risk management, and other internal functions (such as ensuring the functioning, safety, and security of our Channels, premises, infrastructure, and networks), developing new products and services, analyzing and improving our existing products and services, and personalizing the Website and/or the Channels experience for you and others; and
- Legal and Compliance, to comply with and enforce, without limitation, to applicable laws and regulations, industry standards, and contractual obligations, as well as our policies and terms and conditions or where we have a good faith belief that such disclosure is necessary, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on Monthly Box or on its related corporations or affiliates (including, where applicable, the display of your name, contact details and company details); and
- any other purposes which we notify you of at the time of obtaining your consent.
We may combine data collected from you with other sources to help us improve our products, services, marketing, and communications, as well as to help expand and tailor our interactions with you. This includes combining personal information we obtain through our Website with information we obtain through the Channels and/or Offline Channels, as well as other sources for the purposes described above. We may anonymize, de-identify, or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we specify at the time of collection.
As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purposes at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.
Cookies and Similar Technologies
We or our authorized service providers and advertising partners may use “cookies” or other similar technologies on our Website to allow us or third parties to collect or share certain information about you by automated means.
“Cookies” are identifiers that are stored on your computer or mobile device that record data about computer or device, how and when the Website and/or Channels are used or visited, by how many people and other activity within our Website. We may link cookie information to personal data. Cookies also link to information regarding what items you have selected for purchase and web pages you have viewed. This information is used to keep track of your shopping cart, to deliver content specific to your interests, to enable our third party advertising partners to serve advertisements on sites across the internet, and to conduct data analysis and to monitor usage of the Services.
We use these automated technologies to collect information about your devices, browsing actions, and usage patterns. The information we collect are used to improve the Website and service experiences we offer, including new services and features, and/or enable us and our advertising partners to serve more relevant content to you, including through remarketing.
Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. You may refuse the use of cookies by selecting the appropriate settings on your browser or device. However, please note that if you do this you may not be able to use the full functionality of our Website and services.
Retainment of your personal data
We will retain personal data in accordance with the Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data when we have reasonably determined that
- the purpose for which that personal data was collected is no longer being served by the retention of such personal data;
- retention is no longer necessary for any legal or business purposes; and
- no other legitimate interests warrant further retention of such personal data. If you cease using the Website, or your permission to use the Website is terminated or withdrawn, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.
How your Personal Information is shared
We may share your personal information with certain third parties, including as indicated below.
- Our Affiliates and Subsidiaries. We may share your personal information with our affiliates and subsidiaries for the purposes set out in this Privacy Policy.
- Service Providers, Suppliers, Agents, and Other Business Partners. We use service providers, suppliers, and agents to help us provide our products and services and to perform services on our behalf (such as maintenance, IT services and support, analysis and analytics, audit, payments, marketing, development, reservations, ticketing operations, security, ID verification, and background and credit checks). We do not authorize these entities to use or disclose such information except as necessary to perform services on our behalf or comply with legal requirements. We also may share personal information with business and advertising partners for the purposes described in this Privacy Policy.
- Marketing Partners. We may run promotions and marketing efforts, such as contests, sweepstakes, and giveaways, with certain third parties. If you choose to participate in any such promotions, the personal information you provide may be shared with those third parties and would be subject to their Privacy Policies unless otherwise indicated.
We also may disclose personal information about you:
- if we are required or permitted to do so by applicable law, regulation, or legal process (such as a court order or subpoena);
- to law enforcement authorities and other government officials to comply with a legitimate legal request;
- when we believe disclosure is necessary to prevent physical harm or financial loss to Monthly Box, our customers, employees, or the public as required or permitted by law;
- to establish, exercise, or defend our legal rights; and
- in connection with an investigation of suspected or actual fraud, illegal activity, security, or technical issues.
In addition, we reserve the right to transfer to relevant third parties the personal information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation), or other business transaction.
We also may share the information in other ways for which we provide specific notice at the time of collection and obtain your consent to the extent required by applicable law.
Regarding Children’s Personal Data
Our services, the Website and Channels are not intended for children under the age of 13. We do not knowingly collect or maintain any personal data or non-personally- identifiable information from anyone under the age of 13 nor is any part of the Website and Channels directed to children under the age of 13.
As a parent or legal guardian, please do not allow such children under your care to submit personal data to Monthly Box. In the event that personal data of a child under the age of 13 in your care is disclosed to Monthly Box, you hereby consent to the processing of the child’s personal data and accept and agree to be bound by this Policy on behalf of such child.
We will close any accounts used exclusively by such children and will remove and/or delete any personal data we believe was submitted without parental consent by any child under the age of 13.
Data Transfers
We may transfer, store and/or process your personal data and/or information outside of your country. In most cases, your personal data will be processed in Singapore. Monthly Box will only transfer your personal data and/or information overseas as described in this Privacy Policy and in accordance with applicable law.
Links to Third party Websites
Our Website may contain links to other sites on the Internet that are owned and operated by third parties. The information practices of those websites linked to our Website are not covered by this Privacy Policy. We are not responsible for the Privacy Policies of websites to which our website links. If you provide any information to such third parties, different rules regarding the collection and use of your personal information may apply. We strongly suggest you review such third parties’ Privacy Policies before providing any data to them.
Updates to this Privacy Policy
This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information practices. We may post a notice on our Website to notify you of significant changes to this Privacy Policy and indicate at the top of the notice when it was most recently updated. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.
QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US
For questions or comments regarding this Privacy Notice, or to update your preferences, please contact us by email at [email protected]
The Data Protection Officer,
Monthly Box Private Limited,
Henderson Industrial Park,
203 Henderson Road #02-06,
Singapore 159546.
Email: [email protected]