This is the PERTAMA MERCHANDISING PTE LTD Personal Data Protection Policy (“Personal Data Protection Policy”) and the purpose of this document is to inform you of PERTAMA MERCHANDISING PTE LTD manages, collects, uses and discloses your Personal Data, which is subject to the Singapore Personal Data Protection Act (2012) (“the Act”). This Privacy Policy outlines COMAPNY’s policy and responsibility in relation to the collection, use and disclosure of Customer Data. By continuing to use PERTAMA MERCHANDISING PTE LTD’s services, you signify that you have read, understood and agree to be bound by this Privacy Policy as amended from time to time in respect of PERTAMA MERCHANDISING PTE LTD’s collection, use and disclosure of your Customer Data. This Privacy Policy is divided into two Parts – A and B:

Part A: General Customer Data Privacy Policy Statement

1. Types of Customer Data

The types of Customer Data that PERTAMA MERCHANDISING PTE LTD collects depend 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 PERTAMA MERCHANDISING PTE LTD collects:

• Personal Data, which includes but is not limited to -
  
• (i) personal information that links back to an individual e.g., name gender, date of birth, NRIC or other personal identification numbers;
  
• (ii) contact information e.g., address, phone number, email address;
  
• (iii) technical information e.g., IP address; and
  
• Statistical Data e.g., number of visitors, to website. This is 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 PERTAMA MERCHANDISING PTE LTD's customer profile and improve PERTAMA MERCHANDISING PTE LTD's service offering.

For purposes of this policy statement, the phrase Customer Data includes Personal Data and Statistical Data. The provision of Customer Data (save for where the request for data ismarked “optional” in the forms used to collect personal data) is obligatory in order for PERTAMA MERCHANDISING PTE LTD to carry out its services to you. The failure to supply such Customer Data may result in (i) PERTAMA MERCHANDISING PTE LTD being unable to provide you with the services and/or products requested; (ii) PERTAMA MERCHANDISING PTE LTD being unable to update you on our latest products and/or launches; and/or (iii) your inability to enter or participate in contests, promotions or redemption activities organised by PERTAMA MERCHANDISING PTE LTD.

2. Purposes for Collection, Use and Disclosure

Generally, PERTAMA MERCHANDISING PTE LTD collects Customer Data, either directly from you or from third parties (e.g. our service provider), or from publicly available sources, through our website, mobile services, and other channels including our retail outlets, in order to fulfil the following purposes, which include but are not limited to:

• Providing services to you such as processing a transaction (e.g., making an order online), providing technical or customer service assistance, assisting you in the transaction through PERTAMA MERCHANDISING PTE LTD’s website;
• Marketing and communicating with you in relation to products and services offered by PERTAMA MERCHANDISING PTE LTD, PERTAMA MERCHANDISING PTE LTD’s service partners, as well as PERTAMA MERCHANDISING PTE LTD’s appointed agents;
• Contacting you for product or customer satisfaction surveys and market research;
• Safety, security and legal compliance.

PERTAMA MERCHANDISING PTE LTD may also use and disclose your Customer Data with and to third parties in order to fulfil the purposes listed above. PERTAMA MERCHANDISING PTE LTD shall use its best endeavours to ensure that its employees, officers, agents, consultants, contractors and such other third parties mentioned above who are involved in the collection, use and disclosure of Customer Data will observe and adhere to the terms of this Privacy Policy. PERTAMA MERCHANDISING PTE LTD may disclose your Customer Data to law enforcement agencies and government for security, customs and immigration purposes.

In addition, PERTAMA MERCHANDISING PTE LTD 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. PERTAMA MERCHANDISING PTE LTD also reserves 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 such as PERTAMA MERCHANDISING PTE LTD. Further, PERTAMA MERCHANDISING PTE LTD may disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.

3. Transfer of Information Overseas

The PERTAMA MERCHANDISING PTE LTD Office is based in Singapore. Customer Data may be transmitted to data storage where PERTAMA MERCHANDISING PTE LTD keeps its central records. Customer Data may be transferred to PERTAMA MERCHANDISING PTE LTD’s offices and appointed agents in Singapore or other countries in connection with PERTAMA MERCHANDISING PTE LTD’s performance of the contract with you.

4. Consent

Generally, in the course of PERTAMA MERCHANDISING PTE LTD performing transactional functions such as making an order online, Customer Data will, by nature of the task or transaction, be provided by our customers to PERTAMA MERCHANDISING PTE LTD. In such instances, consent will necessarily be implied from the Customer that they are agreeable to providing Customer Data in order for PERTAMA MERCHANDISING PTE LTD to provide the requested or necessary service and/or product to them. However, where required by law, PERTAMA MERCHANDISING PTE LTD will adopt an ‘opt-in' policy for obtaining customer consent, in which event, express written consent will be sought from you when collecting your Customer Data e.g., signing a form or checking a box. Where you make reservations on behalf of another person, you undertake and will ensure that the individual whose Customer Data is supplied to PERTAMA MERCHANDISING PTE LTD has authorized the disclosure, is informed of and consents to the terms and conditions of this Privacy Policy. You may submit a request to withdraw your consent at any time by contacting PERTAMA MERCHANDISING PTE LTD (see Section 10). Statistical Data is not linked to a customer record and PERTAMA MERCHANDISING PTE LTD does not need to seek consent for the collection, use or disclosure of Statistical Data. For more information on the collection and usage of Customer Data obtained from PERTAMA MERCHANDISING PTE LTD’s websites facility, please refer to Part B.

5. Access

PERTAMA MERCHANDISING PTE LTD will, upon your written request to our Data Protection Department (see Section 10), allow you to view your stored Personal Data. Where permitted by law, PERTAMA MERCHANDISING PTE LTD reserves the right to charge a reasonable administrative fee for this service. In exceptional circumstances, PERTAMA MERCHANDISING PTE LTD reserves the right to deny you access to your Personal Data and may provide an explanation as required by applicable laws. Exceptional circumstances include where:

• An investigating authority or government institution objects to PERTAMA MERCHANDISING PTE LTD complying with a customer’s request,
• The information may, in the exercise of PERTAMA MERCHANDISING PTE LTD’s reasonable discretion and/or assessment, affect the life or security of an individual, and
• Data is collected in connection with an investigation of a breach of contract, suspicion of fraudulent activities or contravention of law.

To submit a written request to Customer Affairs Department to access your Personal Data, please email us at

HN-DPO@harveynorman.com.sg.

6. Retention

PERTAMA MERCHANDISING PTE LTD will retain Customer Data for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes of PERTAMA MERCHANDISING PTE LTD, or as required by relevant laws. When destroying Customer Data, we will take commercially reasonable and technically possible measures to make the personal information irrecoverable or irreproducible in accordance with the applicable laws.

7. Accuracy

PERTAMA MERCHANDISING PTE LTD needs your assistance to ensure that your Personal Data is current, complete and accurate. As such, please inform PERTAMA MERCHANDISING PTE LTD of changes to your Personal Data by contacting PERTAMA MERCHANDISING PTE LTD and submitting your updated particulars to PERTAMA MERCHANDISING PTE LTD in writing (see Section 10).

PERTAMA MERCHANDISING PTE LTD may also request Personal Data updates from you from time to time. As detailed in Section 2 above under the “Purposes for Collection, Use and Disclosure” sub-section, your delivery address may be disclosed to the appropriate delivery fulfilment companies. As such, it is important to ensure that the Personal Data contained in your order confirmation is current, complete and accurate.

8. Security Safeguards

PERTAMA MERCHANDISING PTE LTD takes the security and protection of your Customer Data very seriously. As such, PERTAMA MERCHANDISING PTE LTD makes reasonable security arrangements to protect your Customer Data against loss or theft as well as unauthorised access and undue disclosure. Examples of technical safeguards include encryption, Network and Web Application Firewalls ,“firewalls” and Secure Socket Layer (SSL). Further details of these technical safeguards for Customer Data collected through PERTAMA MERCHANDISING PTE LTD’s websites facility are set out at Part B below. If, however, a customer does not take reasonable care to ensure the continued confidentiality and accuracy of their Customer Data, PERTAMA MERCHANDISING PTE LTD will not be liable for any consequential misuse and/or fraud. If you have any concerns about security, you should contact PERTAMA MERCHANDISING PTE LTD (see Section 10).

9. Updates to the Privacy Policy

PERTAMA MERCHANDISING PTE LTD will amend this Privacy Policy from time to time and the updated versions will be posted on PERTAMA MERCHANDISING PTE LTD’s website and date stamped so that you are aware of when the Privacy Policy was last updated. Subject to applicable laws, the English version of this Privacy Policy will prevail over any version of this Privacy Policy in another language. In the event of any inconsistency in interpretation between the English version and any translation of the Privacy Policy, this Privacy Policy statement in English will prevail.

10. Contact Us

If you have comments, questions or complaints about or requests relating to this Privacy Policy statement, please contact PERTAMA MERCHANDISING PTE LTD in writing at the address below referencing ‘Privacy Policy':

DATA PROTECTION OFFICER

Poon Chun Onn / Tang Shir Li

Pertama Merchandising Pte Ltd

315 Outram Road #01-01/02

Tan Boon Liat Building

Singapore169074

Or email HN-DPO@harveynorman.com.sg

Referencing: Privacy Policy.

Part B: Privacy Policy Statement for Customer Data collected through PERTAMA MERCHANDISING PTE LTD's websites

1. Security Safeguards

PERTAMA MERCHANDISING PTE LTD takes the protection of your Customer Data collected on PERTAMA MERCHANDISING PTE LTD’s websites very seriously. All Customer Data collected through PERTAMA MERCHANDISING PTE LTD’s websites, e.g., www.harveynorman.com.sg are protected by a secure server. In addition, SSL (Secure Socket Layer) protects the transmission of data from the internet to our systems. To further strengthen the integrity of your internet transactions on our websites, PERTAMA MERCHANDISING PTE LTD also employs relevant software programs to monitor network traffic with a view to identifying unauthorised attempts to upload or change Customer Data, perpetuate fraudulent or illegal activities or otherwise cause damage. If such monitoring reveals evidence of possible abuse or criminal activities, such evidence may be provided to appropriate law enforcement authorities or agencies without notice to you. To give you secure access to our online services, arising from your utilisation of PERTAMA MERCHANDISING PTE LTD’s website, you can register with us. You should not share your User ID or Password and should always ‘log off' once you have finished your session on the websites as well as take the recommended precautions that ensure the safe and secure provision of PERTAMA MERCHANDISING PTE LTD’s website.

2. Cookies

Most websites like ours use cookies to enhance your online experience. Cookies are alphanumeric identifiers that are transferred to your computer's hard drive from your web browser to recognise your preferences and to tailor content to you. The cookies do not contain your Customer Data but only Statistical Data which is entirely anonymous. Please refer to your browsers documentation to check if cookies have been enabled on your computer or to request not to receive cookies. Information and procedures regarding cookie handling are provided by the respective browsers documentation within the browser itself by clicking on ‘help' and performing a search on ‘cookies'.

3. Clickstream Data

In order to improve your online experience, PERTAMA MERCHANDISING PTE LTD may track online behaviour or clickstream data to advance your use of our web pages and track referrals from other websites. Such data will not be stored to your customer record, and will only be aggregated for statistical analysis.

4. Links to Other Websites

PERTAMA MERCHANDISING PTE LTD provides you with links to other websites for your convenience and information. You access these websites at your own risk and PERTAMA MERCHANDISING PTE LTD is not responsible for these websites. Whilst PERTAMA MERCHANDISING PTE LTD will protect your Customer Data on PERTAMA MERCHANDISING PTE LTD websites, PERTAMA MERCHANDISING PTE LTD cannot control or be responsible for the policies of other sites we may link to, or the use of any Customer Data you may share with them. Please note thatthe PERTAMA MERCHANDISING PTE LTD Privacy Policy does not cover these other websites, and PERTAMA MERCHANDISING PTE LTD would recommend that you are apprised of their specific policies.

5. Minors

PERTAMA MERCHANDISING PTE LTD cannot distinguish the age of persons who access and use its websites. If a minor (according to applicable laws) has provided PERTAMA MERCHANDISING PTE LTD with Customer Data without parental or guardian consent, the parent or guardian should contact PERTAMA MERCHANDISING PTE LTD (see Section 10 of Part A) to remove the relevant Customer Data and unsubscribe the minor.

6. Google Analytics

Google Analytics is a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of www.harveynorman.com.sg, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. For more details, please refer to Google’s Privacy Policy.