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Updated on: 28 December 2018
What is personal data?
Personal data refers to any data or information, whether true or not, about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
What personal data do we collect?
Data that we collect may include:
- Date of birth;
- Residential, shipping and billing addresses;
- E-mail address;
- Telephone number;
- Any form of biometric that you may have submitted (such as facial image or voice recording);
- Account information such as your preferred products, services and lifestyle activities and your spending patterns;
- Payment related information such as bank and credit card details;
- Service related information such as your usage of and interaction with our website and the date, time and duration of your phone calls;
- Equipment and network related information, such as device ID, IP address, operating system, browser type, session duration and/or referring website address;
- Employment information;
- Any information relating to you from other organization which we believe you have authorized to provide your personal data to us on your behalf; and
- Any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you.
Collection and use of your personal data
Generally, we collect personal data from you when you:
- Visit our Website or visit us on our social media platform (e.g. Facebook, Instagram, Twitter, YouTube, Flickr etc.);
- Create an account on our website or sign up for our Cathay Photo Rewards Program;
- Make a sales enquiry or make a purchase from us;
- Subscribe to our services and our e-newsletter and sign up for alerts;
- Sign up for events that we organize, such as talks, workshops and product previews;
- Participate in a promotion, survey, lucky draw or contest;
- Register your product with us for warranty purposes;
- Interact with our customer service officers or contact us with any service related questions;
- When you apply for a job position with us; or
- When you submit your personal data to us for any other reason.
If you provide us with any personal data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorised representatives), you represent to us that you have obtained the consent of the third party to you providing us with their personal data for the respective purposes.
You are responsible for ensuring that all personal data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested.
Legal justifications for the processing of your personal data
We generally use the following legal justifications for the processing of your personal data:
- You have given your consent to the processing (Article 6(1)(a) of the GDPR; "Consent Justification"); or
- The processing is necessary for:
- The performance of a contract with you (Article 6(1)(b) of the GDPR; "Contract Justification");
- Compliance with a legal obligation (Article 6(1)(c) of the GDPR; "Legal Obligation Justification"); or
- Realizing a legitimate interest (Article 6(1)(f) of the GDPR; "Legitimate Interest Justification").
- The performance of a contract with you (Article 6(1)(b) of the GDPR; "Contract Justification");
Purposes for the collection, use and disclosure of your personal data
Generally, we may collect, use and disclose your personal data for our legal or regulatory obligations and for our business purposes, which include but are not limited to the following:
- To verify your identity;
- To respond to your queries and requests and respond to complaints
- To manage our business operations and to share the personal data with our affiliates, business partners and vendors for marketing, promotional and warranty purposes;
- To better communicate with you (including but not limited to responding to your enquiries, requests and complaints);
- To store information for performing certain functions on our Website such as completing forms, facilitating website navigation, authentication of user, and enabling marketing and advertising technology;
- To conduct market research and surveys for us to review, develop and improve our products, services and also develop special offers and marketing programs;
- To facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);
- To conduct internal audits;
- To ensure the safety and security of our systems;
- To protect and enforce our contractual and legal rights and obligations or those of others
- To recover debts;
- To prevent or detect actual or potential crime, fraud or illegal activity;
- To ensure compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or
- For any other purpose relating to any of the above or where you have given us your specific and informed consent when you submit your personal data to us.
In addition, we may collect, use and disclose your personal data for the following purposes, depending on the nature of our relationship with you:-
- If you are a user of our Website:
- To manage your registration as a user on our website and improve your user experience with us, online or offline, based on your usage behaviour on our Website;
- To process the orders that you have submitted through our Website;
- To provide you with updates on your order status;
- To process payments in relation to provision of goods and services;
- To pass your personal data to the third-party service provider if you have opted for delivery of the products that you have purchased;
- If you are a member of our Cathay Photo Rewards Program:
- To manage your registration as a member
- To verify your personal particulars and your identity as the rightful owner of your member’s account;
- To maintain your member’s account with us
- To allow you to enjoy the membership privileges such as lucky draws and rebate redemptions (in-store only);
- If you have applied for a job with us:
- To process your job application;
- To conduct pre-recruitment background checks,
- To obtain employee references or other references where relevant; and
- To collect information about your suitability for the position applied for.
In addition, where you have given us your specific and informed consent, we may collect, use and disclose your Personal Data for the following purposes:-
- To send our e-newsletter to you;
- To share promotional benefits which you may qualify for, such as marketing and promotional updates, offers and invitations to events; and
- To provide better after-sales service, such as notifying you of product firmware updates, resolving product issues, etc.
In the event that we decide to sell all or part(s) of our company for the purpose of business development or restructuring, your personal data may be considered an asset of the sale and be transferred as well.
Disclosure of Personal Data
The personal data that we collect from you will only be used for the purpose(s) it was collected for and may be shared with the following trusted parties:
- Our related entities registered under Cathay Photo Store Pte Ltd, such as our flagship store located at 111 North Bridge Road, #01-04 to 08 and #01-11 to 14 Peninsula Plaza, Singapore 179098; our retail store located at 6 Raffles Boulevard, #02-215 to 216 Marina Square, Singapore 039594; our administrative office and service centre located at 315 Outram Road, #05-06 Tan Boon Liat Building, Singapore 169074;
- Our affiliates, business partners and vendors for purposes such as marketing, promotional and warranty;
- Third-party service providers and professional advisors for purposes such as information processing, delivering products to you, facilitating payments, maintaining the Website, market analysis, conducting customer research or satisfaction surveys; and
- Relevant authorities, industry regulators and other government organisations, as required by local laws and regulations
Retention periods for and deletion of your Personal Data
We will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.
If your user account, your Cathay Photo Rewards Program membership account or any other account opened with us is terminated or expired, we will remove your personal data from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it.
How can you access, correct and update, delete and/or withdraw consent to use of your personal data that we have collected?
User Account on Website
If you have a user account on our Website, you can log in to your account and view, edit and/or delete your personal data that you have entered previously.
Rewards Program Membership Account
If you are a member of our Rewards Program, and would like to access your personal data in our records, you may visit our stores and bring along your membership card. Once we are able to verify your identity, we will provide you with access to your personal data.
However, if you would like to correct, update, edit and/or delete your personal data in our membership records, you can:
- Visit any of our stores and request for a copy of our “Update Information Form”. Please complete the form with your new personal data and return it to us; or
- Email us at email@example.com with details of the data that you would like to change.
All Other Records
For your personal data that have been collected in other ways not mentioned above, you may request to access, correct and update, delete and/or withdraw consent to use of your personal data that we have in our records by contacting our Data Protection Officer at firstname.lastname@example.org. We will assist you once we are able to verify your identity.
In certain cases, for example, if the request is unusual or onerous, we may charge you a reasonable fee before providing access to your personal data.
Any and all changes to your personal data will be made after we have verified your identity.
Please note that if you delete and/or withdraw your consent to any or all use of your personal data, depending on the nature of your request, we may not be in a position to continue providing our products or services to you. In the event we are not able to continue with any contractual arrangement with you, this may result in the termination of any such arrangements with us and you may be in breach of your contractual obligations, in which case, our rights and remedies are expressly reserved.
Your statutory rights
You have the following rights under the GDPR:
- Right of access
You have the right to access and obtain a copy of your personal, including the purposes of processing and who the personal data has been disclosed to.
You have the right to obtain a copy of the personal data undergoing processing. For additional copies requested by you, a reasonable fee based on administrative costs may be chargeable.
- Right to rectification
You have the right to rectify inaccurate and incomplete personal data.
- Right to erasure (right to be forgotten)
You have the right to request us to erase your personal data.
- Right to restriction of processing
You have the right to request the restriction of processing your personal data in cases where the accuracy of the personal data is contested or if the processing of personal data is unlawful.
- Right to data portability
You have the right to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit that personal data to another organisation.
- Right to object
You have the right to object to the processing of your personal data at any time. If you exercise this right, your Personal Data will no longer be processed for such purposes by us. In the event exercising this right causes us to terminate any contractual arrangement with you, you may be in breach of your contractual obligations.
- Right not to be subject to automated decision-making (including profiling)
You have the right to not to be subject to automated decision-making (including profiling) where this has legal effect on you or significantly affects you.
The GDPR also gives you the right to lodge a complaint with the competent supervisory authority, in particular in the member state of your habitual residence or alleged infringement of the GDPR.
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