General Data Protection Policy

PRIVACY NOTICE (GDPR)

 

We, LAC Global Group (Singapore Co. Reg. No. 200106977R), are part of the V3 Group which includes V3 Group Limited (Cayman Islands Co. Reg. No. 320464), V3 Group (Singapore) Pte. Ltd. (Singapore Co. Reg. No. 201736255H) and OSIM International Pte. Ltd. (Singapore Co. Reg. No. 198304191N) (collectively with our subsidiaries and other related companies, the “V3 Group” ).

 

 

We, together with Xndo Pte. Ltd. , collect information to understand your needs better. This helps us to improve our services and the way we communicate with you. We know that privacy is important to you and we strive to be as open and transparent as possible in how we serve you.

 

 

This Privacy Notice will explain how our organization uses the personal data we collect from you when you use our products andservices, our website, our online store or otherwise interact with us, for example, by filling up forms at our stores, responding to our surveys and questionnaires or attending our events.

 

 

This Privacy Notice applies to personal data held by ONI Global Pte. Ltd. as data controller, as described below.

 

 

Whenever we have used “we” , “us” , or “our” in this Privacy Notice, this means LAC Global Group. Our registered address is 65 Ubi Avenue 1, OSIM Headquarters, Singapore 408939.

 

 

I. WHEN THIS PRIVACY NOTICE APPLIES

 

 

If your personal data is covered by the General Data Protection Regulation (EU) 2016/679 ( “GDPR” ), e.g. because you are a resident of the European Economic Area, this Privacy Notice will apply to you.

 

 

If your personal data is not covered by the GDPR, this Privacy Notice does not apply to you. Please refer instead to our Personal Data Protection Policy which can be found Here

 

 

There may be other different or separate privacy policies/privacy notices that apply to specific products and services provided by us. This Privacy Notice supplements the other policies or notices and is not intended to override them.

 

 

II. WHAT DATA WE COLLECT

 

 

Examples of the personal data you may provide to us include:

(a) Personal details, e.g. your name, gender, date of birth;
(b) Contact details, e.g. your telephone numbers, mailing address, or email address;
(c) Information about your identity, e.g. your national identity card numbers or passport information;
(d) Billing information, e.g. your bank and credit card details;
(e) your network data, server logs, device ID and IP address;
(f) information about your usage of our products and services;
(g) your preferences on how you would like to be contacted by us, your preferred products and services, lifestyle activities, and similar data.

 

 

If you provide us with any personal data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of t he third party to provide us with their personal data for the respective purposes.

 

 

You should ensure 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 the services you have requested.

 

 

III. HOW WE COLLECT YOUR DATA

 

Generally, we collect your personal data either directly from you or from your authorised representatives (i.e. persons whom you have authorised, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), from third parties, or from publicly available sources or through our products and services.

We collect your personal data in the following ways:

 

(a)    Usage and Preference Information:

We collect information about how you interact with our online services, such as preferences expressed, and settings chosen. In some cases we do this through the use of cookies and similar technologies that create and maintain unique identifiers. To learn more about these technologies, please see section XI below (Additional Information About Our Websites);

 

 

(b)     Log Information:

When you interact with our online services or our websites, we collect server logs, which may include information like access dates and times, pages viewed, site crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with our online service or website ;

 

 

(c)    Submission of Forms

when you submit your personal data to us via forms in our stores, our websites, our surveys or questionnaires, or when you submit a form for registering an account with us or any other forms relating to any of our services;

 

 

(d)    Customer Service Interactions

when you interact with our customer service team or our marketing representatives, for example, via telephone calls, letters, face-to-face meetings and emails;

 

 

(e)    Using Our Services

when you use some of our services, for example, our website, including establishing any online accounts with us. For example, we collect information about you when you register for an account, create or modify your profile set preferences, sign-up for or make purchases through our online store.

 

 

(f)    Third Parties

- when we receive references from business partners and third parties, for example, where you have been referred by them;

- when we receive contact data, financial data and transaction data from providers of technical, payment and delivery services;

- when you integrate or link a third-party service with our online platforms, e.g. if you create an account or log into the online platforms using your Facebook credentials, we receive your personal data as permitted by your Facebook profile settings in order to authenticate you ;
 

 

 

(g)    Our Global Network

We may receive your personal data from the other companies in the V3 Group or other companies related to Xndo. For example, when you have purchased products or services from a member of Our Global Network, we may receive your personal data from that member of Our Global Network for the purpose of resolving complaints and handling requests and enquiries from you about the products or services

 

 

(h)    Request for Us to Contact You, Subscription to Mailing List

when you request that we contact you, or that you be included in an email or other mailing list;

 

 

(i)    Promotions and Requests for Additional personal data

when you respond to our promotions, lucky draws, initiatives or to any request for additional personal data;

 

 

(j)     Feedback, Surveys and Market Research

When you provide feedback to us, respond to our surveys, or participate in market research.

 

 

IV. LEGAL BASIS FOR DATA PROCESSING

We will generally process your personal data based on the following legal justifications:
(a) you have given your consent to the processing ( "Consent Basis" );

(b) the processing is necessary for the performance of a contract with you, or processing is necessary to carry out pre-contractual steps that are taken at your request ( " Contractual Basis ");

(c) the processing is necessary to comply with a legal obligation (" Legal Obligation Basis "); or

(d) the processing is (i) necessary for us to realize our legitimate interest in being responsive to you, to provide customised services and marketing and to ensure the proper functioning of our products, services and organisation; or (ii) necessary for companies in Our Global Network to provide services and products to you (" Legitimate Interest Basis ").

 

 

 

V. HOW WE’LL USE YOUR INFORMATION

We may collect, and use your personal data for the following purposes and based on one or more legal justifications, as set out below:

 

 

 

 

Purpose	Justifications
(a)     Provide and Maintain Services : To allow us to provide services to you such as processing a transaction (e.g. making a purchase), providing technical assistance and assisting you in the transaction. We may also send you information about the products and services that you have purchased from us. For example, we may send you product usage information;	Contractual Basis and/or Legitimate Interests Basis
(b)     Internal Policies, Administration and Business Operations managing our administrative and business operations and complying with internal policies and procedures;	Legitimate Interests Basis
(c)     Business Asset Transactions Facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving us;	Legitimate Interests Basis
(d)     Crime Prevention and Managing of Commercial Risks preventing, detecting and investigating crime and analysing and managing commercial risks and conducting investigations relating to disputes, billing or fraud;	Legitimate Interests Basis and/or Legal Obligation Basis
(e)     Complaint Resolution, Requests and Enquiries For resolving complaints and handling requests and enquiries;	Legitimate Interests Basis
(f)     Legal Purposes for legal purposes, including but not limited to obtaining legal advice and dispute resolution, and meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us (including responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); (For example, we may disclose information to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of our services or the physical safety of any person);	Legitimate Interests Basis and/or Legal Obligation Basis
(g)     Data Matching Matching any personal data held by us which relates to you with any other personal data that we hold for any of the purposes that are listed in this table. (For example, we may combine your personal data collected from your account on our website with personal data collected via your interactions with us at our other customer touchpoints, e.g. information provided to us during roadshows or your interactions with our customer service team, for the purposes of providing you with a uniform experience across all our customer touchpoints);	Legitimate Interests Basis
(h)     Media Announcements and Responses providing media announcements and responses; (For example, we may: list of examples of how personal data is used for this purpose])	Legitimate Interests Basis
(i)    Promotional Events, Contests, Marketing Campaigns organising promotional events, administering contests, competitions and marketing campaigns (For example, if you have indicated that you wish to receive marketing sales, marketing or promotional materials from us, we may use your personal data to contact you to inform you about our promotions, contests, competitions, and provide you with product or service recommendations);	Legitimate Interests Basis
(j)     Market Research conducting market research to enable us to understand and determine customer preferences and demographics to develop special offers and marketing programmes in relation to our products and services, and to improve our service delivery and personalise our customers’ experience at our touchpoints;	Legitimate Interests Basis
(k)     Special Promotions, Loyalty and Reward Programmes ,br/> providing additional products and services and benefits to you, including promotions, loyalty and reward programmes from us. For example, when you sign up for our newsletter or for an account with us, we may use your contact details to provide you with information about exclusive promotions, loyalty and reward programmes. We may use your personal data to determine if you are eligible to receive special promotions, for example, birthday treats or other rewards and promotions specifically offered to the category of customers that you fall within;	Legitimate Interests Basis
(l)     Customise Your Customer Experience to customize our marketing, e.g. by providing you with product recommendations based on your past purchases or based on your responses to optional questions on our customer surveys;	Legitimate Interests Basis
(m)     Direct Marketing (If You Opt-In) if you have indicated that you wish to receive direct marketing messages from us, we will use your personal data to send you advertisements involving details of our products and services, special offers and rewards, which may either be sent to our customers generally, or which we have identified may be of interest to you (including but not limited to upselling, cross selling and online marketing).	Consent Basis

 

 

 

 

VI. WHO WE MIGHT SHARE YOUR INFORMATION WITH

Your personal data may be disclosed, for the purposes listed below and based on one or more legal justifications, as set out below:

 

 

 

 

Disclosure of personal data made to:	Justification
(a) V3 Group companies Companies within the V3 Group and their employees to provide content and services to you , address your questions and requests in relation to your customer accounts, subscription and billing or order arrangements with us as well as our services, to activate, deactivate, install, maintain and operate our systems and/or services;	Legitimate Interests Basis and/or Contractual Basis
(b)     External Service Providers companies providing services relating to insurance and consultancy to us; agents, contractors or third party service providers who provide operational services to us; (For example, your personal data may be disclosed to our external vendors providing us with services such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, or security services, etc.) Some of our operations, such as our electronic commerce, may be managed by service providers who are unaffiliated companies. These companies may share personal data with their affiliates and with service providers whom they engage to perform services related to our website or the operation of our business. Examples of these services include payment processing and authorization, fraud protection and credit risk reduction, product customization, order fulfilment and shipping, marketing and promotional material distribution, web site evaluation, data analysis and, where applicable, data cleansing. These companies may have access to your personal data on a confidential basis only to the extent necessary to perform their functions. In no event will we authorize these companies to use your personal data for any reason other than to provide you with those specific services.	Legitimate Interests Basis
(c)     Business Partners, Investors any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving us;	Legitimate Interests Basis
(d)    Professional Advisors our professional advisers such as auditors and lawyers;	Legitimate Interests Basis
(e)     Regulatory Authorities, Law Enforcement relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority;	Legal Obligation Basis
(f)     Parties Authorised By You any party to whom you authorise us to disclose your personal data to.	Consent Basis

 

 

 

 

VII. HOW LONG WE WILL KEEP YOUR INFORMATION

 

 

 

We will retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required by relevant laws.

If you have de-registered any account you have with us, we will delete the personal data associated with that account as soon as reasonably possible unless there is a valid legal or business purpose for the continued retention of such data whereupon the personal data shall be retained only for the duration of such valid legal or business purpose. For example, after termination of your membership with us, we will retain your personal data for such length of time that may be required for the purposes of determining applicability for referral programs or benefits.

When we no longer need to use your personal data, we will remove it from our systems and records and/or take steps to anonymise it so that you can no longer be identified from it.

 

 

VIII. TRANSFERRING YOUR INFORMATION OVERSEAS

 

 

Your personal data may be transferred to and processed in all countries where we have established a legal presence by our affiliates and our service providers.

You can view a list of all the countries where your personal data may be transferred below:

 

 

List of Countries where your personal data may be transferred to and processed in: (a) Singapore (b) Malaysia (c) Taiwan (d) Philippines

 

 

We will take all steps that are reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice as well as applicable data protection laws, including, where relevant, by entering into EU standard contractual clauses (or equivalent measures) with the party outside the European Economic Area (available here:)

 

 

IX. CHILDREN

 

 

We do not knowingly collect personal data from children under 13, or equivalent minimum age depending on jurisdiction. If you become aware that a child has provided us with personal data without parental consent, please contact us at dpo.sg@xndo.com

 

 

If we learn that we have collected the personal data of a child under 13, or equivalent minimum age depending on jurisdiction, without parental consent, we will take steps to delete the information as soon as possible.

 

 

X. YOUR RIGHTS

If you are a resident in the European Economic Area, you have the following rights in relation to your personal data:

(a)     The right of access

You have the right to obtain the following from us: confirmation that we are processing your personal data, a copy of your personal data that we are processing, and information about how we process it.

(b)     The right to rectification

You have the right to have inaccurate or incomplete personal data about you rectified.

(c)     The right to erasure

You have the right to request that we delete personal data that we process about you, except we are not obliged to do so if we are entitled or required to retain your personal data, for example, where we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.

(d)     The right to restrict processing

You have the right to restrict our processing of your personal data in the following circumstances:
 

1. when you are contesting the accuracy of your personal data and we are verifying the accuracy of the data;
2. when our processing is unlawful and you want us to restrict processing of your personal data instead of erasing your personal data;
3. when we no longer need to process such data for a particular purpose but you need us to keep it in order to establish, exercise or defend a legal claim;
4. when you have objected to us processing personal data we hold on the basis of our legitimate interest and you wish us to stop processing your personal data whilst we determine whether there is an overriding interest in us retaining such personal data;

(e)     The right to data portability

You have a right to obtain personal data we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal information which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you.

 

(f)     The right to object
 

1. Right to Object to Direct Marketing. You have the right to object to us processing your personal data for direct marketing at any time. This includes any profiling of data that is related to direct marketing.
2. Right to Object to Processing Based on Legitimate Interest Justification. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.

 

(g)    Withdrawing Consent

If you have consented to our processing of your personal data, you have the right to withdraw your consent at any time, free of charge. However, please note that we may be unable to provide you with access to certain services as a result of your withdrawal of consent. If you wish to withdraw your consent to our processing of your personal data, please contact our Data Protection Officer at dpo.sg@xndo.com

(h)    Access and Correction

You can make a request to exercise any of these rights in relation to your personal data by sending the request:

 

1. by mail to LAC Global Group at 65 Ubi Avenue 1, OSIM Headquarters, Singapore 408939, attention: Xndo Data Protection Officer; or
2. by email to dpo.sg@xndo.com

If you believe that we have not complied with applicable data protection laws, you also have the right to lodge a complaint with the local data protection authority of the European Economic Area country where you live or work or where the alleged infringement of the GDPR occurred.

 

 

XI. ADDITIONAL INFORMATION ABOUT OUR WEBSITES

(a)     Visiting Our Sites

In general, you can visit our websites without telling us who you are or providing us with any information. However, we collect the IP (Internet protocol) addresses of all visitors to our websites and other related information such as page requests, browser type, operating system and average time spent on our websites. We use this information to monitor and improve our websites.

(b)     Cookies

Our websites use a technology called "cookies". A cookie is a tiny element of data that our websites can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. All pages on our websites where you are prompted to log in or that are customizable require that you accept cookies. If you have registered with our websites, these cookies (1) may let us know who you are, (2) are necessary to access your account information (stored on our computers) in order to deliver products and personalized services, and (3) will provide us and our service providers with information that we will use to personalize our websites in accordance with your preferences. Cookies are also required to optimize your shopping experience in that they allow you to add multiple items to your shopping basket before checking out. You may set your web browser to notify you when you receive a cookie. However, should you decide not to accept cookies from our websites, you will limit the functionality we can provide when you visit our websites.

(c)     Security of Personal Data

We maintain administrative, technical and physical safeguards to protect against unauthorized access, use, modification and disclosure of Personal Data in our custody and control. We also are committed to employing reasonable technology in order to protect the security of our websites. We will take reasonable measures which we believe are appropriate to protect your Personal Data from loss, misuse, alteration or destruction, and, where possible, will ask that any third parties to whom we may transfer such information to take comparable steps to protect that security.

(d)     Secure Shopping

When you place orders on our websites, all of your order information, including your card number and delivery address, is transmitted through the Internet using Secure Sockets Layer (SSL) technology. SSL technology causes your browser to encrypt your order information before transmitting it to our secure server. SSL technology, an industry standard, is designed to prevent someone other than operators of our websites from capturing and viewing your Personal Data. Since any order information you provide to us on our websites will be transmitted using a secure connection, if your web browser cannot support this level of security, you will not be able to order products through our websites.

(e)    Passwords

To provide you with an increased level of security, online access to your Personal Data is protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (including unsolicited correspondence such as letters, phone calls or e-mail messages).

XII.    UPDATES TO PRIVACY NOTICE

We reserve the right to change our Privacy Notice from time to time. If we decide to change our Privacy Notice, we will post the updated Privacy Notice on our website. If we make any material changes to this Privacy Notice, we will provide adequate notice to you .
Subject to applicable laws, the English version of this Privacy Notice will prevail over any version of this Privacy Notice in another language.