PRIVACY POLICY

S FOODS PRIVACY POLICY (“PRIVACY POLICY”)

1. Introduction

1.1 We at S FOODS SINGAPORE PTE. LTD. (Singapore Company Registration Number: 201416893W) (“S Foods”) are committed to protecting and respecting your privacy.

1.2 This Privacy Policy sets out the processes and procedures by which the information collected and received by us in, among others, the course of your use of our website (the “Website”) is handled. Such info includes information collected through our Website, direct ordering or purchasing from the Website, direct marketing campaigns and surveys, and through an online form that is available in the Website. By using the Website, you are agreeing to be bound by this Privacy Policy in respect of the information collected about you via the Website.


2. Information We Collect

2.1 We collect your personal data. For the purposes of this Privacy Policy, personal data refers to all and any information related to you and obtained by us, which we can use to identify or contact you, such as your name, email address, company name, home address, telephone number, religion, gender, nationality, race, date of birth, identification number (where required or allowed by law, or necessary), credit card details and any other information necessary which is voluntarily disclosed in the course of dealing with us.

2.2 We may collect information from you in the following instances:

• When an account (“Account”) is registered by you with us.

• When you use our Website.

• When you provide information to place an order.

• When you provide your payment information (including but not limited to bank account, credit card or Paypal information) to perform any transaction through the Website.

• When you enter your details for delivery services.

• When you utilise the features and functions available on our Website, for example but not limited to, making payments, adding products to cart, accessing news and information.

• When you fill up the online form for queries.

• When you contact us to ask a question, to provide feedback or to report a problem.

2.3 At all times, you are not under any obligation to provide any information to us. However, in the event that you choose to withhold certain information or to revoke permission for us to receive information, this may result in us being unable to provide certain aspects of our services to you or result in us being unable to fulfil your requests.

2.4 In the event that you provide us with any information relating to a third party (e.g. information of your spouse, children, parents, and/or employees), you represent and warrant to us that you have sought for and obtained the consent of the relevant third party to provide us with their information for the respective purposes.


3. Third Party Disclosure

3.1 Your personal information will not be disclosed by us to any third party, unless we have your permission or we are under a legal obligation or duty to do so, except for disclosure to the following individuals or entities which you agree to:

(a) other companies within our group of companies;

(b) government authorities or regulators;

(c) our professional advisers, including without limitation our lawyers, accountants and auditors;

(d) our third-party service providers (including those who provide payment, administrative or other services to us in connection with the operation of the Website and/or of our business) or data processors;

(e) any agent acting on our behalf; and

(f) our business alliance partners.


4. How We Use The Information We Collect

4.1 We may use the information collected from you for the following purposes:

• To verify your identity, update our records and generally administer and maintain your Account with us.

• To develop, operate, improve, deliver and maintain our Website.

• To provide our products and customise the content shown to you.

• To fulfil your requests or orders (including process transactions, clarifying, amending, cancelling or fulfilling orders)

• To provide and deliver the products and services, send confirmations and invoices.

• To respond to your questions and resolve complaints.

• To consolidate the information that you provide including publishing surveys, trends and findings for the benefit of our users.

• To provide you with information or updates regarding our products on our Website (e.g. new offers, new feedback, new comments) and/or to send you marketing and/or promotional materials on the latest products of S Foods. Such updates will be sent by email and/or through push notifications and you have the option of choosing to unsubscribe from these updates at any time by utilizing the “Settings” page of your Account. Please also note that these updates may also be communicated to you through text messages and/or voice calls if you have indicated that you wish to receive such updates through these methods.

• To carry out polls, surveys, analysis and research as well as solicit feedback on our products.

• To send you service-related messages (which are not promotional in nature) including, without limitation, a welcome/confirmation email when you register your Account and to enforce our Terms of Use and other policies where required. Such messages will be sent by email and/or through push notifications and you will not be permitted to opt-out of receiving such service-related messages from S Foods, unless you delete your Account.

• To perform such other functions or services as otherwise notified to you at the time of collection.

• To further our business by disclosing some but not all of your personal data (such as name and email) to third parties including government agencies.


5. Who We Disclose Your Information To

5.1 Disclosure of your information may occur in the following ways:

• We may share and/or disclose the information which you upload and/or otherwise make available with our affiliates and with certain third-party service providers who assist us in performing certain aspects of our services on our behalf when you register an Account with us. This would include tasks such as processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services, producing comparative reports, conducting industry comparisons or other tasks. Such service providers will only have access to your personal information to the extent necessary to perform their functions and execute the tasks.

• We may share and/or disclose the information with our potential partners, investors and other parties in the event that we are engaging in discussions and/or negotiations with such parties regarding a potential business partnership, collaboration, joint venture or otherwise in furtherance of our business.

• We may disclose your personal information in the event that we are required to do so by law or if we believe that such action and/or disclosure is necessary to prevent fraud or crime or to protect our Website or the rights, property or personal safety of any person.

• We may disclose your personal information in situations where we are required and/or under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, or if we determine in our sole discretion that such disclosure is reasonably necessary in order to enforce or apply our Terms of Use and other agreements, or to protect the rights, property or safety of S Foods, our users or others.

5.2 You acknowledge, agree and consent to us disclosing certain of your personal information (e.g. name, email address, age, gender, employer, school, industry, college major, geographical location) to third parties in the furtherance of our business, subject to us (where possible) having entered into similar privacy policies with them.

5.3 We also collect non-personal information, being data in a form that does not permit direct association or identification of any specific individual. We may collect, use, transfer and disclose non-personal information for any purpose.

5.4 In particular, we may disclose or provide data and aggregate statistics (including aggregate information derived from your personal information) about users of our Website and sales to prospective partners, advertisers, sponsors and other reputable third parties in order to describe our products, deliver targeted advertisements or for other lawful purposes, but other than as set out above, such data and statistics will not include information which can be used to identify you.


6. Disclosure and Transfer Of Information

6.1 By registering an Account with us and/or using our Website, you authorise us to use and disclose your information in Singapore and other countries where S Foods is operating or will be operating. We will at all times ensure that your information is transferred in accordance with this Privacy Policy and protected in accordance with any applicable laws on personal data protection (including, but not limited to, the Personal Data Protection Act 2012).

6.2 If you are a business user whose company has a business account with us, there may be additional terms and conditions relating to the use and disclosure of data in the agreement between us and your company.


7. Children / Minors

7.1 We are especially concerned with the privacy and safety of children/minors when they use the internet.

7.2 To use the Website, you must be at least 18 years of age. By using the Website, you hereby represent and warrant to us that you are at least 18 years of age or have otherwise obtained parental consent and/or legal guardian consent (as the case may be) to the use by you of our Website.


8. Accessing and Updating Your Information

8.1 You are able to access and update your information within our Website through the use of the “Settings” page of your Account.

8.2 Where you have provided personal information about yourself to us, the responsibility falls on you to provide us with accurate, not misleading, complete and up-to-date information about yourself, and to update this personal information as and when such information becomes inaccurate, misleading, incomplete or out-of-date.

8.3 In certain circumstances, it may be necessary for you to provide to us personal information about someone else. If this is the case, we are relying on you to inform these individuals that you are providing their personal information to us, to obtain their consent to you providing us with their information and to inform them about where they can find and obtain a copy of this Privacy Policy. It is important that they read this Privacy Policy and agree to the terms herein when giving their consent to the provision of their information to us.

8.4 In the event that you wish to:

(a) apply for a copy of the information we possess about you; or

(b) withdraw the consent you previously provided to us to use, collect or disclose the information we hold about you; kindly contact our Personal Data Protection Officer whose contact details are set out in Section 14 below.

8.5 Please grant us a reasonable period of time to respond to any request received and to effect any requested changes. While processing your request, we may contact you to verify your identity and to ask for more information about your request. Where we are legally permitted to do so, we may refuse your request and may give you reasons for doing so.

8.6 Where you have requested for a copy of the information that we possess about you, we may charge you a reasonable administrative fee to cover the costs of responding to your request. If we decide to do so, we will provide you with a written estimate of such fee beforehand and obtain your consent to the fee before proceeding with your request.


9. Data Retention

9.1 We will retain your personal information for as long as your account is active and for as long as is needed after that for compliance with laws on record keeping (for example: we may keep the order data for accounting records purpose). Please note in particular that we generally do not monitor or remove the information which you share and such information may continue to remain available on our Website even after your Account has been deactivated, terminated or is otherwise closed. You are and remain at all times, wholly responsible for the information that you choose to share with other users through the use of our Website.


10. Tracking Technologies

10.1 Tracking technologies are used in our Website. Such tracking technologies enable us to understand how you utilise our Website which, in turn, helps us to modify and improve how we provide our products and services to you. To this end, we have listed out below some examples of the tracking technologies used on our Website:

• Cookies. A cookie is a small data file sent from a website to your browser that is stored on your device. Cookies are used for a number of purposes, including to display the most appropriate content based on your interests and activity on our products and services, estimate and report our Website’s total audience size and traffic, and conduct research to improve our products and services.

• Clear gifs. Clear gifs (a.k.a. web beacons or web bugs) are tiny graphics with a unique identifier similar in function to cookies, and are used to track the online movements of web users that may be included on our Website. They help us better manage content on our Website by informing us what content is effective. In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence.

• Flash cookies. We may use flash cookies (a.k.a local shared objects or LSOs) to store some of your viewing preferences on our Website. These are used to collect and store information, but differ from browser cookies in the amount, type and manner in which data is stored.

You can choose to disable cookies from being stored on your computer by changing your browser settings. Disabling cookies, however, may result in a limited experience of our functionality and services and in some cases may mean that we are unable to provide you with the services, or parts of the services, that you have requested.


11. Security

11.1 The security of your information is of utmost importance to us. In connection with this, we have put in place security measures to protect against the loss, misuse and alteration of information under our control. Additionally, we also adhere to generally accepted industry standards to protect the information transmitted to us over the internet, both during transmission and upon receipt. However, please note that no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we are unable to guarantee its absolute security.

11.2 In particular, please note that we utilise certain third-party software in connection with the provision of the Website and we are unable to bear any responsibility or liability for any loss, misuse and/or alteration of information which may result from the use of any such third-party software. Further, you should be aware that S Foods has no control over the security of other sites on the internet that you may visit when a link to any such third-party site appears on our websites.

11.3 It is of utmost importance that you protect your Account against unauthorised access by choosing your password carefully, and keeping your password and Account secure (e.g. by signing out after using our Website). It is your responsibility to maintain the secrecy of your membership user identity (“User ID”) and password. Each member shall be solely responsible for the management and protection of your User ID and password and may under no circumstance transfer to third party or let others use his/her User ID or password.


12. Third Party Sites and Resources

12.1 Our Website may, from time to time, contain links to external sites or resources which are operated by third parties. Do note that we have no control over the content and privacy practices of such sites or resources. You are strongly advised to review the privacy policies of these sites and resources operated by third parties and understand how your information may be used by those third parties.

12.2 This Privacy Policy is not intended to, nor does it, create any contractual rights whatsoever or any other legal rights, nor does it create any obligations on us in respect of any other party or on behalf of any party. S Foods will not be responsible for the privacy policies and practices of the owners or operators of any third-party services.


13. Changes To This Privacy Policy

13.1 We reserve the right to make changes to this Privacy Policy at any time and all changes that have been made will be published here. Please check back frequently to view any updates or changes that have been made to this Privacy Policy.

13.2 In the event that we believe that the changes that we propose to make are material, we will notify you of such changes by posting a notice on our Website or by way of email.

13.3 Please note that it is your responsibility to review and take note of the changes which we make to this Privacy Policy.

13.4 At all times, your continued use of our Website constitutes your acceptance of the updated Privacy Policy, as the case may be.


14. Contacting Us

14.1 If you have any questions, complaints, concerns or comments on our Privacy Policy, we welcome you to contact us by sending an email to our Personal Data Protection Officer via email sam@sfoods.sg or write to us at sam@sfoods.sg. In this regard, please include an appropriate subject header indicating what is the issue you are contacting us for, as this would assist us in attending to your email speedily by passing it on to the relevant staff in our organisation. For example, you could insert the subject header as "Accessing Personal Data".

Effective on 27 May 2019.