1.1. This is the Personal Data Protection Policy (“Policy”) of Orient Pearl Goods & Services Pte Ltd (“OP Foods”), the owner and operator of the Website. All capitalized terms used herein and not otherwise defined in this Policy will have the meanings set forth in the Terms & Conditions set out at https://coofoods.com/pages/terms-conditions.
1.2. This Policy applies to all personal data you provide to us, or that we may collect about you as we provide you access to the Website. Please do not provide any personal data to us if you do not accept this Policy.
If you notify us that you do not accept this Policy, we may not be able to establish a relationship with you or be able to service your requests.
1.3. If you have any feedback or issues in relation to your personal data, or about this Policy, or wish to make a complaint to us, you may contact us at firstname.lastname@example.org.
1.4. We may amend this Policy from time to time without notice to you, to comply with applicable laws or as we update our data usage and handling processes. The updated Policy will supersede earlier versions and will apply to personal data provided to us previously. The amended Policy will take effect when made available at the Website. Where permissible under Singapore laws, your continued access to the Website, including placing orders, shall constitute your acknowledgment and acceptance of the changes we make to this Policy. You agree that it is your responsibility to check back frequently to see any updates or changes to this Policy.
1.5. This Policy applies in conjunction with other notices, contractual clauses and 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 them unless we state expressly otherwise.
1.6. All of these terms apply to all who access the Website.
2. Personal Data
2.1. Personal data means any information about an individual, whether recorded in a material form or not and whether true or not, who can be identified from that data (whether directly or indirectly), or from that data and other data to which we have or are likely to have access.
2.2. The Personal data we collect depends on the purposes for which we require the personal data and what you have chosen to provide. This may include your name, address, contact information (e.g., telephone number and email address) and any other information that may identify you or is personal to you.
- you browse our website;
- you create an account with us;
- you apply for, subscribe to or otherwise use any of the services we provide;
- you make a transaction regarding the products available on the website;
- you activate or use any payment-related functions available on the website or provided by our third party service providers;
- you use any of the features or functions available on the Website;
- you record any user-generated content which is on the Website;
- you interact with us online, whether via the chat function on the website or such other function;
- you subscribe to our publications or marketing collaterals;
- you enter a competition, promotion or survey;
- you participate in any activity or campaign on the Website;
- you log in to your account on the Website or otherwise interact with us via an external service or application;
- any other user of the website posts any comments on the content you have uploaded on the Website or when you post any comments on other users’ content uploaded to the Website;
- a third-party lodges a complaint against you or the content you have posted on the Website;
- you interact with us offline, whether directly or with our outsourced customer service agents; and
- you submit your personal data to us for any other reason.
- from your family members or friends who provide your personal data to us on your behalf; and
- from agents, vendors, contractors, partners and any others who provide services to us, who collect your personal information and/or perform functions on our behalf, or with whom we collaborate, including but not limited to payment service providers, government sources of data, financial providers, credit bureaus, delivery, marketing and other service partners; and
- from our affiliates.
2.4. We may collect personal data from you, third parties (including but not limited to agents, vendors, contractors, partners and any others who provide services to us, who collect your personal information and/or perform functions on our behalf, or with whom we collaborate, including but not limited to payment service providers, government sources of data, financial providers, credit bureaus, delivery, marketing and other service partners), our affiliates, or such data may be collected automatically when you use the Website, as set out in this section.
2.6. You must ensure that all personal data that you provide is true, accurate and complete and promptly inform us of any changes to the personal data you have provided to us or in the event you believe that the personal data we have about you is inaccurate, incomplete, misleading or out of date. We shall have the right to request for documentation and carry out the necessary checks to verify the personal data provided by you as part of our user verification processes or as required under law. We take steps to share the updates to your personal data with third parties and our affiliates with whom we have shared your personal data if your personal data is still necessary for the purposes stated in this Policy.
2.7. We will only be able to collect certain categories of personal data if you voluntarily provide the personal data to us or as otherwise provided for under this Policy. You have the right to withdraw your consent for us to use your personal data at any time by contacting and submitting a request to us. Your withdrawal will take effect after your request is processed. If you choose not to provide your personal data to us or subsequently withdraw your consent to our use of your personal data, we may not be able to provide you with certain features or functionality of the Website or access to the Website.
3. Use and Disclosure of Your Personal Data
- you have given us consent;
- necessary to comply with our legal or regulatory obligations;
- necessary for our legitimate business interests, provided that this does not override your interests or rights; and/or
- necessary to perform a contract or transaction you have entered into with us, or provide a service that you have requested or require from us.
- processing your Order (in this regard, we may pass your personal information on to third party [e.g., logistics provider and payment service providers]);
- managing your relationship with us and providing services to our users and customers;
- facilitating your use of the Website;
- assisting you with your requests, enquiries and feedback;
- administrative purposes, e.g., accounting, risk management and record keeping, business research, data, planning and statistical analysis, and staff training;
- security and safety purposes, e.g., protecting the Website from unauthorised access or usage and to monitor for security threats;
- carrying out research, data and statistical analysis;
- compliance with laws and regulations, internal policies and procedures, e.g., audit, accounting, risk management and record keeping;
- enforcing legal obligations owed to us, or responding to complaints, litigation or investigations concerning us;
- managing and engaging third parties or data processors that provide services to us, e.g., IT services, data analytics, marketing, and other professional services;
- carrying out our legitimate business interests (listed below); and/or
- protecting our rights and interests and those of our users and customers;
- preventing and investigating possible misuse of our websites, applications and services;
- understanding and responding to inquiries and feedback;
- understanding how our users use our websites, applications and services;
- identifying what our users want and improving our websites, applications, services and offerings;
- sharing data in connection with acquisitions and transfers of our business; and
- any other reasonable purposes related to the aforesaid.
- providing you with information (including events and product launches), promotions and marketing information from us (and/or our affiliates or related entities) we think you may find useful or which you have requested from us (provided you have not opted out to receive such information);
- sending you marketing or promotional information about our or third-party sellers’ products and services on our Website from time to time (provided you have not opted out to receive such information);
- helping us conduct marketing and advertising; and
- analysing and/or profiling your purchases, transactions and/or likes or dislikes so as to be better able to send you relevant or targeted information (including events and product launches), promotion and marketing information from us (and/or our affiliates or related entities); and/or
- Such purposes that may be informed to you when your personal data is collected;
- Any other purpose to which your consent has been obtained; and
- Other purposes, without your knowledge or consent, where this is required or permitted by law.
- Service providers (such as agents, vendors, contractors and partners) in areas such as payment services, logistics and shipping, marketing, data analytics, market or consumer research, survey, social media, customer service, installation services, information technology and website hosting;
- Their service providers and related companies; and
- Regulatory authorities and public agencies.
In disclosing your personal data to them, we endeavour to ensure that the third parties and our affiliates keep your personal data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain your personal data only for as long as your personal data is needed to achieve the above-mentioned purposes.
3.4. When using your personal data to contact you for the above purposes, we may contact you via mail, e-mail, SMS, telephone, pop-up notifications (when you are using the Website), or any other means.
If you do not wish to receive any communication or information from us, or wish to restrict the manner by which we may contact or send you information, you may contact us to do so.
4. Protection of Personal Data
4.1. We will only retain your personal data for as long as we are either required or permitted to by law or as relevant for the purposes for which it was collected.
4.2. We will cease to retain your personal data, or remove the means by which the 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 any legal or business purpose.
4.3. While we take reasonable precautions to safeguard your personal data in our possession or under our control, we cannot be held responsible for unauthorised or unintended access that is beyond our control, including hacking or cybercrimes. We also do not guarantee that the Website is invulnerable to security breaches, or that your use of the Website is safe and protected from viruses, worms, Trojan horses, and other vulnerabilities.
5. Third Party Sites
5.1. Website may contain links to other websites operated by other parties, such as but not limited to our business affiliates, merchants or payment gateways. We are not responsible for the privacy practices of websites operated by these other parties. You are advised to check on the applicable privacy policies of those websites to determine how they will handle any information they collect from you
6. Your Rights
- Withdrawal of consent: you may withdraw consent for our use of your personal data.
- Correction:you may request that any incomplete or inaccurate data that we hold or control be corrected.
6.2 Exercising your rights. If you wish to exercise your rights, you may contact us to do so via email to email@example.com. We may require that you submit certain forms or provide certain information to process your request. Where permitted by law, we may charge you a fee to process your request. We may also be permitted under applicable laws to refuse a request.
6.3 Limitations. We may be permitted under applicable laws to refuse your request to exercise your rights, for example, we may refuse (a) a request for erasure where the personal data is required for in connection with claims; or (b) an objection request and continue processing your personal data based on compelling legitimate grounds for the processing.
Version dated 10 February 2022