Last Updated: 1 March 2020
EUBIQ is a corporation registered in the Republic of Singapore with registered office at 9 Joo Koon Crescent Singapore, Eubiq Building, Singapore 629025.
For the purposes of the General Data Protection Regulation (“GDPR”) and other applicable data protection laws, we are the data controller. Our data protection officer can be contacted at email@example.com.
The Types of Customer Data we collect
The types of Customer Data that we collect depends on the circumstances of collection and on the nature of the service requested or transaction undertaken.
There are two broad categories of Customer Data that we collect:
- Personal Data.
The data we collect includes but is not limited to:
(i) personal information that can be used to identify an individual, such as name, gender, date of birth, nationality, passport or other personal identification numbers;
(ii) contact information, such as mailing address, phone number, email address;
(iii) payment information, such as credit or debit card information, including the name of cardholder, card number, billing address and expiry date;
(iv) information on your activity and purchases made through EUBIQ our website or mobile applications;
(v) your customer preferences;
(vi) information you choose and/or consent to submit when you use features on our website, mobile applications, or other online facilities, including, but not limited to
– information in the queries you enter into our chatbox, on our global Facebook page, website and mobile application;
– your location information.
(vii) business contact information, such as the contact details of the employees of our vendors and corporate customers, as well as the contact details collected by our divisions including the Cargo Division and Engineering Division.
- Technical Data.
For the purposes of this policy statement, Customer Data means Personal Data and Technical Data.
We also use Customer Data to derive Statistical Data, such as the number of customers, the type of products purchased, the demographics of customers, the timed spent on EUBIQ website. This is processed and stored purely for analytical purposes, and is entirely anonymous. This information will not be stored to your customer record, and will only be aggregated for statistical analysis so that we can better understand our customers’ profile and improve our service offering.
Special categories of information or “sensitive personal data”
Certain categories of Customer Data, such as information about your race, ethnicity, religion or health, are considered special categories of information, or “sensitive personal data” under certain applicable laws, including the GDPR.
Generally, we try to limit the circumstances where we collect your sensitive personal data. However, this can occasionally occur because you have made certain requests in connection with your purchases that reveal or suggest something about you that could be considered “sensitive personal data”, or if you otherwise choose to provide such information to us.
How we collect data from you
We collect Customer Data whenever you use our services, including when you purchase our products, when you use our website or mobile applications, or when you interact with us via email, social media or our hotlines
Is the provision of Customer Data required?
The collection of the following types of Customer Data is mandatory to enable us to fulfil our contract of purchase with you. These types of Customer Data are marked as mandatory on order form. If you do not provide this information, we will not be able to provide you with our services and/or products required.
- Buyer details, e.g title, first/given name, last/family name, date of birth
- Contact details, e.g. email address, mobile phone number, home number or business number.
- Address and shipping details, e.g. home or business address or designated delivery address
- Payment details, e.g. the name on the credit or debit card, the credit or debit card number, expiry date and card verification value on the credit or debit card, and billing address which will be transmitted to our payment processors.
Additional information may be mandatory if you are purchasing from a specific country, e.g. your gender, nationality, passport number, the country of issue of your passport, the name, GST/VAT registration number and address of the business you are buying on behalf of, and your business email address and phone number.
The collection of the following types of Customer Data is mandatory to enable us to administer your account as a Registered Customer: (i) last/family name; (ii) first/given name if you do not have a last/family name; (iii) date of birth and (iv) email address
The failure to supply the following types of Customer Data will result in (i) us being unable to update you on our latest products and/or launches; and/or (ii) your inability to enter or participate in contests, promotions or redemption activities organised by us:
- Contact Information e.g. email address, telephone number; and
- Address of residence.
How we use your Customer Data
If you are an EU or Swiss resident, we are required to disclose the legal basis for processing your data under the GDPR and the Swiss Data Protection Act. We are also required to disclose the purposes for processing your data under certain applicable laws, including the Singapore Personal Data Protection Act. We will use the Customer Data in the following ways:
In accordance with our contract of purchases with you, we will use the Customer Data to:
- process and assist you with any transactions related to your purchases (e.g., colour selection, product selection,.), fulfilling purchases and investigating potential fraudulent transactions);
- notify you about changes to our products;
- provide product recommendation
- in accordance with our contract with you as a Registered Customer, we will use the Customer Data to:
- maintain your account;
- facilitate your transactions and purchases;
iii. enable you to log in using your account on any of the platforms hosted by us; and
- Send you updates and other account related information.
As it is in our legitimate interests to be responsive to you, to provide customised services and marketing, to ensure the success of our business and to ensure the proper functioning of our products, services and organisation, we will use your Customer Data to:
- improve our website and mobile application and to ensure content from the website and mobile application is presented in the most effective manner for you and your device;
- administer the website and mobile application, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- monitor and record calls for quality, training, legal compliance, analysis and other related purposes in order to pursue our legitimate interest of improving service delivery;
- send you surveys by email (including surveys related to our Registered Customer, as detailed below). You can opt-out of receiving these surveys at any time by contacting us;
- send you service emails, such as reminders when you have not checked out your purchases on our website or mobile application. You can opt-out of receiving service emails at any time by contacting us;
- respond to your enquiries, requests or feedback;
- enforce our terms, conditions and policies;
- allow you to participate in interactive features of the website and mobile application, when you choose to do so;
- customise our products and services to you, including by responding to and catering for your customer preferences;
- keep the website and mobile application safe and secure;
- aggregate Customer Data into anonymised statistical data (such as number of passengers flown on a particular journey), which we will use for statistical analysis so that we can better understand our customers’ profile and improve our service offering;
- to customise our marketing e.g. sending you targeted marketing on products you would like to purchases. If you are an EU or Swiss resident, you can object to this profiling and opt-out of receiving such targeting marketing.
- share the Customer Data with selected partners to enable them to better tailor offers, promotions and other direct marketing to you. If you are an EU or Swiss resident, you can object to this profiling and opt-out of receiving such targeting marketing. For more information on this right, click here;
With your consent where required by applicable laws, we will use your Customer Data to:
- send you marketing and promotional materials in relation to products and services offered by us, our distributors and appointed agents.
- serve you with customised advertising from EUBIQ that is relevant to you on social media platforms. We use audience targeting technologies to do this. For example, we may display interest-based advertising to you when you are using Facebook through a tool offered by Facebook called the Custom Audience tool. This tool allows email addresses to be hashed locally on our browser and then sent to Facebook. There, the email addresses are matched against Facebook’s existing list of Facebook users’ hashed IDs and the matches are added to our Custom Audience for advertising. The matched and unmatched hashes are then deleted; and
- register you for the Registered Customer
You have the right to withdraw your consent at any time by contacting us at firstname.lastname@example.org
Disclosure of your Customer Data
We will share your Customer Data with selected third parties in the situations set out below:
- our freight service providers or payment merchants and service providers to fulfill your contract of purchase with us
- advertisers and advertising networks that require the data to select and serve relevant adverts to you or others, as well as other selected partners to enable them to better tailor offers, promotions and other direct marketing to you or others;
- our website or mobile application service providers, so that the services of the interactive features you choose to use may be provided to you;
- analytics and search engine providers that assist us in the improvement and optimisation of the website and mobile application; and
- public agencies and regulatory authorities in Singapore and their subcontractors, for the purposes of participating in industry studies.
- For the purposes of undertaking targeted direct marketing and other forms of marketing or advertisement, including marketing or advertisements for entities within EUBIQ, provided we have the consent of the recipient and/or have provided the opportunity to opt-out, in each case where required by applicable law.
We will disclose your Customer Data to law enforcement agencies, public or regulatory authorities, securities commissions or other organisations for security, health, customs and immigration purposes, if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
- comply with any applicable legal obligation, process or request;
- enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
- detect, prevent or otherwise address security, health, fraud or technical issues; or
- protect the rights, property, health or safety of us, our users, a third party or the public as required or permitted by law (including exchanging Customer Data with other companies and organisations for the purposes of fraud protection and credit risk reduction).
We will also disclose your Customer Data to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your data to the prospective seller or buyer of such business or assets;
- if we or substantially all of our assets are acquired by a third party, in which case Customer Data held by us about our customers will be one of the transferred assets; or
- to comply with any applicable legal obligations, processes or requests (such as disclosing Customer Data to executors in response to court orders).
In addition, we may disclose Customer Data to our legal advisors for establishing, exercising or defending our legal rights, to our other professional advisors, or as otherwise authorised or required by law. We also reserve the right to share Customer Data as is necessary to prevent a threat to the life, health or security of an individual or corporate entity. Further, we will disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.
Transfer of information overseas
Our Head Office us based in Singapore. Customer Data will be kept in our central records. Customer Data will be transferred overseas will be done on the basis that it is necessary for the performance of our contract of purchase with you.
We will retain Customer Data for as long as it is necessary to fulfil the purpose for which it was collected, our legal or business purposes, or as required by relevant laws. We will usually keep your Customer Data for up to 7 years to ensure that any contractual disputes can be addressed.
If you opt-out or withdraw your consent to marketing, we will remove you from our marketing database.
Eubiq Holdings Pte Ltd
9 Joo Koon Crescent