This Privacy Policy (“Policy”) sets out the basis which Hot Palette (Asia Pacific) Pte Ltd (“Hot Palette”, “we”, “us” or “our”) may collect, use, disclose or otherwise process your personal data. This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
By sales transactions with Hot Palette, interacting with us, using our website, submitting information to us or otherwise by providing personal data to us, you agree to the collection, use and disclosure of your personal data in the manner set forth in this Policy.
1.1. As used in this Policy:
“personal data” refers to data about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access to, but does not include business contact information.
“PDPA” refers to the Personal Data Protection Act 2012.
2.1. We generally do not collect your personal data unless:
a) it is provided to us by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (collectively referred as “you”) after (i) you have been notified of the purposes for which the data is collected; and (ii) you have provided written consent to the collection and usage of your personal data for those purposes; or
b) such collection and use of personal data without consent is permitted or required under the PDPA or other applicable laws and regulations.
2.2. The type of personal data that we may collect from you will depend on the particular transaction and the dealing. Normally such personal data may include your:
a) Name, title, address;
b) NRIC/FIN/Passport number:
c) Telephone Number;
d) Email address;
e) Records of communications with Hot Palette;
f) Responses to surveys and contests conducted by Hot Palette or on its behalf;
g) Credit card or debit card information;
h) Camera or video footage that identifies individuals (including CCTV footage); and
i) Website usage information.
2.3. Personal data will, generally, only be collected and used for the purposes of:
a) conducting, improving, maintaining and developing a business relationship;
b) processing, servicing or enforcing transactions and sending related communications;
c) identification and verification purposes in connection with any of the services or products that may be supplied to you;
d) responding to, handling and processing your queries, requests, applications, complaints and feedback from you;
e) administering contests or market surveys conducted by Hot Palette or on its behalf;
f) marketing (such as providing you with information about our products and promotional notices and offers); and
g) improving our website;
h) complying with any applicable laws, regulations, codes of practice, guidelines or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
i) any other purposes for which you have provided the information;
j) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
k) any other incidental purposes related to or in connection with the above.
2.4. Hot Palette may disclose your personal data:
a) for the primary purposes for which it was collected;
b) where you have provided prior consent;
c) where such disclosure is required for performing obligations in the course of or in connection with our provision of services requested by you; or
d) to third party service providers, agents and other organization we have engaged to perform any of the functions listed in clause 2.4 above for us.
2.5. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
2.6. We do not sell or license any of your personal data.
3.1. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are any changes to your personal data. We will not be liable for relying upon incomplete and/or inaccurate personal data that you have provided to us.
3.2. If you would like to (i) make a request to obtain a copy of personal data that is in our possession and/or control; (ii) make a request for your personal data to be updated or correct; or (iii) withdraw your consent for us to use or disclose the personal data we hold about you, a written request should be sent by email to the Data Protection Officer at the contact details provided below.
3.3. Hot Palette will cease to collect, use or disclose the personal data upon such withdrawal except where such collection, use and disclosure without consent is permitted or required by PDPA or other applicable laws and regulations. However please note that if you 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 to provide our services to you.
3.4. Please allow us reasonable time to respond and/or effect any updates or correction.
4.1. When you browse our website, you generally do so anonymously and we do not at our website automatically collect personal data, including your email address unless you provide such information. You may however wish to note that Hot Palette may record anonymous information such as IP address (not used to identify a specific individual), time, date, referring URL, pages accessed and documents downloaded, type of browser and operating system.
4.2. Hot Palette’s websites also use “cookies”. A cookie is a small file that stays on your computer until, depending on whether it is a sessional or persistent cookie, you turn your computer off or it expires. Cookies may collect and store your personal data. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use Hot Palette’s websites, but may be limited in the usage of some of its features.
4.3. Our website may contain links to other site and resources that are operated or provided by third parties with different privacy practices. We have no control over and do not take any responsibility for these third party websites and their personal data handling practices, and you are encouraged to review the personal data policies of websites you choose to visit which are linked from our website.
5.1. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service provider’s and agents only on a need-to-know basis.
5.2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
6.1. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
6.2. We will cease to retain personal data or remove the means by which the personal data can be associated with you, as soon as the purpose for which that personal data was collected is no longer served by the retention or retention of the personal data is no longer necessary for legal or business purposes.
7.1. Any personal data provided to Hot Palette may be transferred to, stored by or disclosed to an overseas recipient. For example, Hot Palette may use a server hosted overseas to store data, which may include your personal data. We will take steps to ensure that the overseas recipient provides a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.
8.1. Hot Palette complies with all provisions regarding the DNC Registry under the PDPA.
9.1. This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
9.2. We may revise this Policy from time to time without any prior notice. A current version of this policy will be published on Hot Palette’s website or may be obtained free of charge upon request. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
10.1. You may contact our Data Protection Officer if you have any queries or concerns about Hot Palette’s personal data protection policies and practices, or if you wish to make any request, in the following manner:
Data Protection Officer
1 Coleman Street, #10-08/09 The Adelphi, Singapore 179803
Email: info-sg@hotpalette-apac.com
Updated on 12 December 2022
